Submission to the Senate Community Affairs Legislation Committee

Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Submitted by: Tasmania

I make this submission as both the parent of a child with significant disability and as a professional working within the disability sector supporting participants and families to navigate the National Disability Insurance Scheme every day.

I support the objective of ensuring the long-term sustainability of the NDIS. Families like mine have a greater interest than most Australians in ensuring the Scheme remains viable because our family members, who are participants will rely upon the NDIS for the entirety of their lives.

However, sustainability must not become synonymous with cost reduction. The NDIS was established to improve participation, inclusion, independence, choice and control for Australians with disability. These principles should remain central to all reform efforts.Whilst I acknowledge the Governments’ objective of clarifying eligibility, strengthening integrity measures and improving

long-term sustainability, I remain concerned that several aspects of the Bill may create unintended consequences for participants and families. My primary concerns relate to:

Schedule 4 and the significant reliance on future Rules and implementation decisions that have not yet been released.
Schedule 1 Part 8 and the potential for increased medicalisation of disability through the revised approach to permanence.
The risk that participants with access to private healthcare may be able to satisfy permanence requirements more easily than participants reliant on public healthcare systems.
Schedule 1 Part 9 and the interaction between the NDIS and other service systems.
The potential impact of uncertainty on participants, families and providers attempting to plan for the future. I urge the Committee to ensure that reforms remain focused on participant outcomes and preserve the principles upon which the NDIS was established. The NDIS has transformed the lives of many Australians with disability and their families. For my family, the Scheme has provided opportunities that previous generations of Australians with disability often did

have access to.

It has supported access to therapies, assistive technology, communication supports, support workers and opportunities for community participation. The NDIS is not an abstract policy discussion for us. It influences every aspect of daily life. It affects opportunities for communication, learning, participation, independence and inclusion. Professionally, I also support participants and families to navigate the Scheme every day. This provides a unique perspective on how legislative changes and policy decisions affect people in practice. I see families attempting to understand increasingly complex systems. I see participants struggling to access supports. I see carers experiencing significant pressure. I see providers attempting to navigate evolving compliance obligations and operational requirements. I also see the positive impact that occurs when supports are delivered effectively. The NDIS is one of the most significant social reforms in Australia’s history. It has contributed to greater visibility of disability within Australian society and has supported many people with disability to participate more fully within their communities. Whilst reform is necessary, reforms

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should strengthen these outcomes rather than underline them.

Schedule 4 - New Framework Planning and Legislative Uncertainty. One of my most significant concerns relates to Schedule 4 of the Bill and the proposed transition to New Framework Planning.

Whist the legislation establishes the architecture for future planning arrangements, many of the practical details that will ultimately determine participant experiences remain unknown. Participants, families and providers are being asked to assess substantial legislative reform without access to the information that will ultimately determine how those reforms operate in practice. Key questions remain regarding:

support needs assessments;
budget determination methodologies;
support categories;
foundational supports;
planning processes;
review mechanisms;
transition arrangements; and
future Rules.

Throughout consultation processes, participants

have frequently been reassured that many concerns will be addressed through future Rules and implementation decisions. However, for many participants this reassurance creates additional uncertainty rather than confidence. The practical reality is that participants are being asked to support legislative reform before they have sufficient information to understand how those reforms will affect their lives. This is particularly concerning because planning decisions directly influence a participant’s ability to access supports necessary for daily living, communication, education, employment and community participation. The issue is not opposition to reform. The issue is transparency. Participants should be able to understand the practical implications of reforms before they are implemented. For many families, uncertainty itself has become one of the most significant consequences of the reform process. The disability community is repeatedly being asked to trust that future Rules will address current concerns. However, people with disability, families and providers should not be expected to assess reforms based solely on assurances

Schedule 1 Part 8 - Permanency and the Medicalisation of Disability

I am deeply concerned about the proposed changes relating to permanence. The explanatory materials indicate that a participant must demonstrate that appropriate treatment pathways have been explored and that no further treatment is likely to substantially improve the impairment before it can be considered permanent.

Whilst I understand the objective of improving consistency in access decisions, I am concerned that this approach risks increasing the medicalisation of disability. Many disabilities cannot be cured. Treatments may improve comfort, mobility, communication, independence or quality of life. However, they do not necessarily eliminate disability. The NDIS was established because people continue to experience functional impairment and participation barriers even after

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treatment has occurred. Disability support and healthcare serve different purposes. Healthcare seeks to diagnose, treat and improve health outcomes. Disability support exists because people continue to require assistance regardless of medical intervention. The distinction is important. I am concerned that increasing emphasis on treatment pathways may unintentionally shift focus away from functional impairment and participation. Families should never feel pressured to pursue invasive, expensive or high-risk interventions simply to establish permanence. Medical opinion is frequently not clear-cut. Different specialists often provide different recommendations. Many interventions involve significant uncertainty regarding outcomes. Some involve substantial risks. Others may provide only marginal benefits. Families should be able to make decisions based on clinical advice, quality of life considerations and individual circumstances. They should not feel compelled to pursue treatment pathways because of concerns regarding access to disability supports. The Committee should ensure that clarification of permanence does not inadvertently create incentives for participants to pursue

Treatment Pathways

treatment pathways solely to satisfy eligibility requirements.

The Risk of a Two-Tier Disability Scheme A further concern arising from Schedule 1 Part 8 is the potential for inequitable outcomes based on access to healthcare. Participants with private health insurance, financial resources and access to specialists are often able to progress through treatment pathways significantly faster than participants who rely on public healthcare systems. Across Australia, many families face lengthy waiting periods for:

specialist appointments;
diagnostic assessments;
surgical consultations;
therapeutic interventions; and
multidisciplinary reviews.

In regional and rural areas these challenges are often amplified. If demonstrating that treatment pathways have been explored becomes an important component of establishing permanence, participants with greater financial resources may be able to satisfy these requirements more quickly and more easily than participants relying on public systems. This creates a serious equity concern.

Schedule 1 Part 9 - Access and Other Service Systems

The NDIS was designed as a disability support scheme. It was not designed as a scheme where access to disability supports is influenced by wealth. Yet the practical consequence of these provisions may be that participants with financial means can establish permanence more easily than participants without those resources. This risks creating a two-tier disability support system. One pathway for participants who can access private healthcare. Another pathway for participants who remain on public waiting lists through no fault of their own. Disability does not discriminate based on socioeconomic status. Access to disability supports should not do so either. The Committee should ensure that participants are not disadvantaged due to financial circumstances, geographic location or inability to access timely healthcare.

Schedule 1 Part 9 – Access and Other Service Systems

I am also concerned about amendments relating to participants who may have access to supports through other service systems. Whilst it is important to clarify responsibilities between systems, many families already experience

Community Participation, Inclusion and the Visibility of Disability

There are significant challenges navigating the boundaries between disability, health, education and compensation systems. The practical reality is that participants frequently become trapped between systems. One system may identify another as responsible. The participant is then left attempting to navigate complex jurisdictional arrangements whilst essential supports remain unavailable. Families often spend months attempting to resolve questions regarding responsibility. This creates stress, delays and uncertainty. The risk is not merely administrative complexity. The risk is reduced access to support.

The Committee should ensure that interactions between the NDIS and other service systems do not create additional barriers for participants and families. Participants should not be disadvantaged because different systems disagree regarding responsibility. Any reforms in this area should be accompanied by strong safeguards to ensure continuity of support and timely resolution of disputes.

One of my greatest concerns regarding the

broader reform agenda is the potential impact on community participation and inclusion. The Government has indicated that participant budgets relating to social, and community participation and capacity building supports will be reset as part of efforts to slow expenditure growth. Whilst these supports are often portrayed as discretionary or non-essential & nice to have, this characterisation fails to recognise the significant role they play in promoting inclusion and participation. For much of Australia’s history, persons with disability were largely absent from public life. Many attended segregated schools. Many lived in institutional settings. Many had limited opportunities to participate in employment, recreation, sport and community activities. Disability was often hidden. The introduction of the NDIS contributed to a profound shift in this reality. Today, Australians with disability are increasingly visible within their communities. Children with disability participate in sporting clubs. Young people with disability attend social activities. Adults with disability participate in employment, recreation and community events.

Families Are Able To Engage More Fully With Their Communities

These outcomes did not occur by accident. They occurred because people received the supports necessary to participate.

Community participation supports are not simply about recreation. They are often the mechanism through which people develop friendships, build confidence, improve communication skills, develop independence and establish connections that contribute to long-term wellbeing.

The benefits extend beyond the individual participant. When people with disability are visible within communities, society becomes more inclusive. Schools become more welcoming. Sporting clubs become more accessible. Employers become more willing to employ people with disability. Communities become more accustomed to diversity.

Participation creates inclusion. Inclusion creates belonging. I am concerned that reducing access to these supports may have consequences that are not adequately captured through financial modelling. The risk is not simply reduced activity. The risk is increased isolation. The risk is reduced visibility. The risk is a gradual reversal of many of the social gains achieved through the NDIS.

This concern is particularly relevant for

participants with intellectual disability, autism, psychosocial disability and significant communication barriers, who may rely heavily upon structured supports to participate safely and meaningfully within their communities.

For many of these participants, community participation is not a luxury. It is an essential component of social inclusion. The Committee should carefully consider the broader social and economic value of participation supports when assessing sustainability measures. The Hidden Cost of Reduced Participation The long-term consequences of reduced participation are often difficult to measure. However, they are real. Social isolation is associated with poorer mental health outcomes, reduced employment participation, increased reliance on crisis services and reduced quality of life. Families experiencing isolation often require additional support. Carers experience increased pressure. Participants may lose opportunities to develop independence and community connections.

The costs associated with social exclusion rarely appear within NDIS budgets. Instead, they emerge elsewhere. They emerge in health systems. They emerge in mental health systems. They emerge in welfare systems. They emerge in reduced workforce participation.

A sustainability discussion that focuses only on immediate NDIS expenditure risks overlooking these broader impacts.

Consideration for Savings Achieved Through Reductions In Participation Supports

The Committee should consider whether apparent savings achieved through reductions in participation supports may ultimately result in increased costs elsewhere.

Cost Shifting Is Not Genuine Reform

A central objective of the Bill and broader reform agenda is improving the sustainability of the NDIS. However, sustainability should not be assessed solely through reductions in NDIS expenditure. Reducing expenditure within one system does not necessarily reduce overall costs. Frequently, costs simply move. When disability supports are reduced, pressure often shifts elsewhere.

It shifts to public hospitals.
It shifts to Medicare.
It shifts to mental health services.
It shifts to education systems.
It shifts to welfare systems.

Most significantly, it shifts to families and carers.

This is an important distinction.

Reducing NDIS expenditure does not automatically represent a reduction in societal costs. In some cases, it may simply represent a transfer of costs from government to families.

A support worker who assists a participant to attend appointments, participate in the community or develop daily living skills may represent a cost within the NDIS. If that support is removed, the participant’s needs do not disappear. Someone else must meet them. In many cases, that person is a family member.

The support has not been removed. It has been transferred. This distinction is critical.

The success of reform should not be measured solely by how much money is removed from NDIS budgets. It should also be measured by whether costs are genuinely reduced or merely shifted elsewhere. The Committee should carefully consider the whole-of-government impacts of

reforms rather than focusing exclusively on NDS

The Contribution of Carers

Any discussion regarding sustainability must acknowledge the extraordinary contribution made by unpaid carers. Without carers, the disability support system would be unsustainable.

Carers provide practical, emotional and advocacy support every day. They coordinate appointments. They organise therapies. They manage medications. They attend meetings. They navigate multiple service systems. They respond to crises. They provide support during evenings, weekends and overnight. Many do so whilst balancing employment and caring for other family members. The economic contribution made by carers is enormous.Various studies have estimated that unpaid carers contribute upwards of 80 billion of dollars of support each year.Yet carers are often largely absent from sustainability discussions.The reality is that carers already subsidise the disability support system on a massive scale.

When formal supports are reduced, carers absorb

much of the impact. When services become harder to access, carers absorb much of the impact. When participants require additional support, carers absorb much of the impact. This contribution should be recognised and valued. Policy decisions that increase pressure on carers may create consequences that extend far beyond disability policy. Carer burnout contributes to workforce withdrawal, reduced household income, mental health pressures and family breakdown. These outcomes carry significant social and economic costs. The Committee should ensure that the contribution of carers is considered as part of any assessment of sustainability.

Women, Care and the Disability Workforce

The reforms may also have significant gendered impacts. Women make up the majority of unpaid carers in Australia. Women also make up a substantial proportion of the disability workforce. This means women are uniquely exposed to the consequences of disability reform. When supports are reduced, women are often the people who

increase their caring responsibilities. When disability sector expenditure contracts, women are often the people whose employment opportunities are affected. This creates a dual impact. Women may experience increased unpaid care obligations whilst simultaneously facing reduced workforce opportunities. These impacts are rarely discussed within reform debates. However, they represent an important consideration. The disability sector has become a significant source of employment for women across Australia. At the same time, women continue to undertake the majority of caring responsibilities within families. Any assessment of sustainability should therefore include consideration of gender equality, workforce participation and economic security. Failure to do so risks overlooking substantial unintended consequences.

A Sustainable NDIS Must Remain True to Its Purpose Families understand the need for sustainability better than anyone. Those of us caring for people with lifelong disability know that the Scheme must remain viable not only today but decades into the future.

Schedule 2 Part 6 – Plan Management and Participant Choice

However, sustainability should not be measured solely through expenditure reduction. A sustainable NDIS is one that:

supports participation;
promotes inclusion;
supports carers;
strengthens communities;
improves long-term outcomes;
supports workforce participation; and
reduces downstream social and economic costs.

If reforms achieve budget savings whilst increasing isolation, carer burnout, workforce withdrawal and cost shifting, then the Scheme may become financially smaller without becoming genuinely more sustainable. The Committee should ensure that sustainability remains connected to participant outcomes rather than being measured solely through expenditure targets.

I remain concerned regarding public narratives

that increasingly portray Plan Management as a significant source of fraud, waste or misuse within the NDIS. As someone working within the disability sector, this narrative does not reflect the reality of the role Plan Managers perform every day.

Plan Managers are already one of the most heavily regulated provider groups operating within the NDIS. Registered Plan Managers operate under audit requirements, compliance obligations, registration requirements and direct NDIA oversight. At the same time, Plan Managers increasingly perform functions that extend well beyond invoice processing.

every day plan managers:

identify duplicate invoices;
identify pricing breaches;
identify billing errors;
identify potential non-compliant claims;
identify provider issues;
identify emerging safeguarding concerns;
monitor budget utilisation; and
educate participants regarding legislative and policy changes.

these activities provide significant protection to both participants and the scheme.

Much of this work occurs behind the scenes and
there therefore receives little public attention.
However, it represents an important integrity
function within the NDSI.
Schedule 2 Part 6 includes reforms relating to
registration requirements and commissioned Plan
Management arrangements.
Whilst I understand the Governments objective of
improving consistency and oversight, I am
concerned that reform may unintentionally
contribute to market consolidation and reduce
participant choice. One of the strength of the
current system is diversity. Participant can
choose provides that understands their
circumstances, communicates in way that suits
their need and builds trust relationship over
time. Small community based plan manager often identifies concern early because they maintain closed relationship with participant and family. these provide frequent identified safeguard issue, provide concern and emerging risk long before they became visible through administration system. The committee should ensured that reform preserved participant choice and recognize the important role that

The Role of Independent Plan Managers

Independent Plan Managers play in supporting both participants and Scheme integrity.

Support Coordination as a Safeguarding Support

Support Coordination is frequently misunderstood within broader discussions regarding NDIS expenditure. It is often characterised as an administrative support or a service that can be reduced without significant consequences.

This perspective fails to recognise the critical role Support Coordinators play in helping participants navigate increasingly complex systems.

Support Coordinators assist participants to:

connect with services;
implement plans;
coordinate multiple providers;
navigate mainstream systems;
manage crises;
address service breakdowns; and
build long-term capacity.

For participants with complex support needs, Support Coordination frequently prevents escalation into more restrictive and expensive interventions. Without effective coordination, many participants struggle to understand their plans, engage providers and access appropriate supports.

This issue becomes even more significant as

legislative and operational complexity increases. Participants are increasingly required to navigate:

changing legislation;
changing pricing arrangements;
changing support categories;
replacement support provisions;
foundational supports;
new planning frameworks; and
interactions between multiple service systems. At the same time, Support Coordination funding is often being reduced. This creates a contradiction. Participants are expected to navigate increasingly complex systems whilst receiving less support to do so. The Committee should recognise Support Coordination as a safeguarding support that contributes to participant outcomes, crisis prevention and effective plan implementation.

Schedule 2 Parts 2–5 — Compliance, Records

and Administrative Burden The Bill introduces a range of measures relating to claims, record keeping, information gathering powers and civil penalties. I support reasonable measures that improve Scheme integrity and

Schedule 3 – Pricing and Market Stewardship

address deliberate fraud. However, it is important that compliance measures remain proportionate and do not create unnecessary administrative burden for participants and providers acting in good faith. Most participants, families and providers are attempting to comply with increasingly complex legislative requirements. The challenge is often not unwillingness to comply. The challenge is understanding what compliance requires. The NDIS has become significantly more complex over time. Participants, providers and support coordinators are now expected to understand a growing range of legislative provisions, pricing rules, support restrictions and administrative requirements. Additional compliance obligations may improve integrity outcomes. However, they may also increase administrative burden and divert resources away from participant support. The Committee should ensure that integrity measures are proportionate, practical and accompanied by clear guidance and education. The objective should be improving compliance, not simply increasing penalties.

The Bill

includes reforms relating to pricing and market stewardship, including changes to pricing decision-making responsibilities.

Pricing decisions have significant implications for participants, providers and workforce sustainability. The disability sector relies upon a workforce that is already experiencing significant challenges relating to recruitment, retention and workforce shortages. Pricing decisions influence:

workforce attraction;
workforce retention;
provider viability;
service availability; and
participant access.

These impacts are particularly significant in regional and rural areas where provider markets are often already fragile. If pricing decisions do not adequately reflect the costs of delivering supports, provider viability may be affected. When providers exit markets, participant choice and access are reduced. This is particularly concerning in areas where service availability is already limited.

The Committee should ensure that pricing reforms consider workforce sustainability, regional service delivery and participant access alongside broader financial objectives.

An issue that receives relatively little attention is

the growing level of reform fatigue being

generated throughout the disability community.

Over recent years participants, families and

providers have experienced:

legislative reform;
pricing changes;
support category changes;
replacement support reforms;
foundational support discussions;
changes to planning arrangements;
and increasing compliance obligations.

Many participants and families report feeling

overwhelmed. Providers are also attempting to

adapt to ongoing change whilst continuing to

deliver services. This fatigue should not be

underestimated. Successful reform requires

confidence, trust and engagement. Excessive

uncertainty can undermine all three. The

Committee should carefully consider the

cumulative impact of reform activity on

participants, families and providers.

Nothing About Us, Without Us

The NDIS was built upon decades of advocacy by

people with disability, families and carers.

It reflects a fundamental shift away from systems

that made decisions about people with disability

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and towards systems that empower people with disability to exercise choice and control. One of the most enduring principles of the disability rights movement is: “Nothing About Us, Without Us.”\n\nThis principle recognises that people with disability should not merely be consulted after decisions have been made. They should be active participants in designing, implementing and evaluating policies that affect their lives.

This principle is particularly relevant to the current reforms. Many of the practical details associated with the reforms will ultimately be determined through future Rules, operational guidance and implementation decisions. Meaningful co-design will therefore remain essential long after the passage of this Bill. The success of the reforms will depend not only upon legislative changes but also upon how those changes are implemented in practice. People with disability, families and carers must remain central to that process.

Recommendations I respectfully recommend that the Committee: Ensure participants, families and providers have access to future Rules and implementation guidance before transition to New Framework Planning.

Ensure permanence provisions do not create pressure for participants to pursue treatment pathways solely to establish eligibility.
Ensure participants are not disadvantaged due to financial circumstances, geographic location or inability to access private healthcare.
Monitor the interaction between the NDIS and other service systems to prevent gaps and delays in support.
Carefully assess the impact of reforms on community participation, inclusion and social connection.
Evaluate sustainability using a whole-of-government approach rather than focusing solely on NDIS expenditure.
Recognise the substantial economic contribution made by unpaid carers.
Consider the gendered impacts of reforms on both unpaid carers and the disability workforce.
Preserve participant choice and diversity within Plan Management arrangements.
Recognise Support Coordination as a safeguarding support that contributes to participant outcomes and crisis prevention.
Ensure compliance measures remain proportionate and practical.
Maintain meaningful co-design with people with disability, families and carers throughout implementation.

Conclusion

I support the objective of ensuring the NDIS remains sustainable for future generations. However, sustainability must not be measured solely through expenditure reduction. The NDIS was established to improve participation, inclusion, independence, dignity, choice and control. These principles remain as important today as they were when the Scheme was first conceived. The success of the NDIS should ultimately be measured by whether Australians with disability are able to live meaningful, connected and inclusive lives. The future of the NDIS should continue to be guided by the voices of people with disability, families and carers, consistent with the principle that has underpinned disability advocacy for generations: “Nothing About Us, Without Us.”