Concerns Regarding the Proposed NDIS Amendment Bill

I am an Occupational Therapist with almost 25 years of experience working with people with disability across community, rehabilitation, aged care, and the National Disability Insurance Scheme (NDIS). I currently work extensively with NDIS participants and their families and have direct experience supporting individuals with intellectual disability, autism, acquired brain injury, neurological conditions, dementia, psychosocial disability, and complex support needs.

I am writing to express my serious concerns regarding the proposed NDIS Amendment Bill and its potential impact on people with disability, their families, and the clinicians who support them.

My position is that I do not support this Bill in its current form and urge the Government to withdraw it and undertake further consultation with people with disability, families, advoates, and frontline clinicians.

The NDIS was established to provide individualised, person-centred support to Australians with signiﬁcant disability. While I acknowledge the need for the Scheme to be financially sustainable and to address fraud and misuse, I am deeply concerned that the proposed amendments move the Scheme further away from its original intent and risk causing signiﬁcant harm to some of the most vulnerable members of our community.

My primary concerns are outlined below.

Increased Administrative Burden

The proposed changes appear to place greater administrative obligations on participants and their representatives.

Many of the individuals I support already struggle to navigate the complexity of the NDIS. They often require assistance from family members, support coordinators, advoates, and allied health professionals simply to understand correspondence, attempt meetings, and respond to requests.

Many participants have intellectual disabilities, cognitive impairments, acquired brain injuries, autism, psychosocial disabilities, communication impairments, or literacy challenges. Expecting these individuals to comply with increasingly complex administrative requirements creates additional barriers to accessing support.

For example, I currently support a participant with an acquired brain injury who experiences significant difficulties with memory, organisation, planning, problem- solving, and managing complex information. Despite requiring substantial support, he struggles to follow through with appointments, complete paperwork, respond to correspondence, and coordinate services independently. He has previously

underutilised funded supports, not because the supports were unnecessary, but

because his cognitive impairments made it difficult to organise and access them. He requires ongoing assistance from clinicians, support workers, and coordinators to manage tasks that many people take for granted.

Additional administrative requirements, tighter response timeframes, and more complex review processes would create further barriers for participants with similar cognitive disabilities.

In practice, I am concerned that people will lose access to essential supports not because they are ineligible, but because they are unable to navigate the system.

The very impairments that qualify them for disability support may place them at greater risk of losing that support.

2. "Not Contactable" Provisions

This is one of my most signiﬁcant concerns.

Many people with disability experience periods where they are unable to engage with services or respond to communication.

Examples I regularly encounter include:

Hospital admissions
Mental health crises
Burnout
Communication impairments
Cognitive decline
Homelessness or housing instability
Family crises
Domestic violence situations
Limited access to technology
Lack of informal supports

The proposed provisions risk penalising people precisely when they are most vulnerable.

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The participants I support are not disengaged because they do not care about their supports. They are often disengaged because their disability or circumstances temporarily prevent them from responding.

For example, I currently support a participant with dementia who experiences significant memory impairment, reduced insight, poor information retention, and difficulty managing daily tasks independently. She relies heavily on her husband to manage appointments, correspondence, decision-making, and engagement with services. If correspondence from the NDIA was sent directly to her, she would be unlikely to remember receiving it, understand what was being requested, or respond within required timeframes. This would not be due to a lack of willingness to engage, but rather the direct impact of her disability. Participants such as this could be disproportionately affected by provisions that place greater emphasis on participant responsiveness or contactability.

A system designed to support vulnerable people should not create additional barriers during periods of crisis.

3. Reduced Flexibility During Changing Circumstances

Disability is not static.

Many of my participants experience significant fluctuations in their functional capacity, health status, support needs, and living circumstances.

As an Occupational Therapist, I regularly assist participants whose needs have changed due to:

Progressive neurological conditions
Mental health deterioration
Falls and injuries
Hospital admissions
Carer burnout
Loss of informal supports
Changes in accommodation
Behavioural escalation
Increasing care needs

The NDIS must retain flexibility to respond quickly to changing circumstances.

Increased Reliance on Administrative and Automated Decision-Making

I am concerned about any move toward greater reliance on standardised or automated decision-making processes.

The people I support are individuals, not categories.

No automated system can adequately capture the complexity of disability, particularly where multiple diagnoses, communication barriers, behavioural support needs, trauma histories, cultural factors, or fluctuating conditions are involved.

Clinical decision-making requires professional judgement, context, observation, and an understanding of how disability affects a person’s daily life.

I fear that increasing reliance on standardised systems will result in decisions that fail to reflect participants’ actual needs.

Lack of Genuine Co-Design and Consultation

The disability community has repeatedly emphasised the importance of genuine consultation and co-design.

Changes of this magnitude should not proceed without meaningful engagement with people with disability, families, advocates, and frontline clinicians.

Those most affected by these reforms should be central to the decision-making process.

Professional Experience

Throughout my career, I have seen firsthand how appropriate disability supports can transform lives.

I have also seen the consequences when supports are delayed, reduced, or denied.

Without adequate supports, people experience:

Increased social isolation
Reduced independence
Greater reliance on family carers
Higher rates of hospitalisation
Increased risk of institutionalisation
Reduced community participation
Deteriorating physical and mental health

The NDIS was created to address these issues and to enable Australians with disability to live ordinary lives within their communities.

I am concerned that aspects of this Bill move us away from those principles.

What Needs to Change

I urge the Government and Senate Committee to:

Withdraw the Bill in its current form.

Undertake genuine consultation with people with disability, families, advocates, and frontline clinicians.
Ensure that participants are not disadvantaged because of disability-related communication barriers or periods of crisis.
Preserve ﬂexibility within the Scheme to respond to changing circumstances.
Limit reliance on automated decision-making processes.
Ensure all reforms remain consistent with the principles of person-centred, individualised support.