SUBMISSION:

NDIS Amendment Bill Inquiry

10 July 2026

About Phoenix Lifestyle Support Association Inc

Phoenix Lifestyle Support Association Inc. started because of a vision of a parent who wanted a better life for her children and other people living in institutional care. Services commenced in 1999 for two people and we have been supporting the independence of a small group of adults with intellectual and/or physical disabilities in the Redlands City Council (QLD) since that time.

We are a registered service provider with the National Disability Insurance Scheme providing supported independent living (SIL); assistance with self-care activities within a person’s own home; assistance in accessing the community; development of life skills and assistance in meeting NDS goals. We also run a community hub where people with disabilities are welcome to come and connect with others through our BYO support worker programs (e.g. art, music, cooking, swimming). We value the contribution of our participants, staff and community. We are proud to remain a small boutique service provider serving the Redlands Community.

Phoenix is committed to a principle of small and sustainable (among several others). This principle has meant we have no current intention of extending service provision beyond the current 7 SIL & In home supports for supporting 16 adults and another 7 people supported in our community program. We are a viable, registered, not-for-profit incorporated association committed to quality service provision for our current participants. Our committee gives their time voluntarily to the organisation. Although, it is agreed there is the need for some NDIS reform, this bill has aspects that we believe put participants at risk and responsibility to manage the outcome of those risks back onto providers, particularly in the context of new SIL registration requirements.

Areas of concern and likely impacts regarding the proposed amendments

There are many aspects of the proposed amendments that significantly disadvantage people with a disability. For example, suspending plans and revoking participant status if not responded to, this would not be possible any of the people we support and would have a profound impact. Their aging parents as nominees may not understand the consequences of not being in contact with the NDIA or not be able to respond in a timely

• manner. Of main concern for our organisation is the proposed Ministerial powers in the amendment.

Ministerial powers to reduce funding for a type of support across all participant plans and against a cohort (all without an appeal mechanism) is a gross breach of power and goes completely against the intent of the scheme. This type of power in the ‘wrong’ hands could be catastrophic on individual lives. The lack of ability to appeal is alarming and distressing for participants and their families and we can expect to see the significant gaps being gpicked up by unpaid labour like aging parents and mothers who may have to give up work to provide the necessary support.

Applying these powers to a specific cohort without alternative services in place and in conjunction with the other parts of the amendment to link funding to eligible impairments completely fails to understand the impacts of a diagnosis, complex social and economic environments of individuals and effects like trauma on that particular diagnosis. It is alarming, short sighted and puts the burden of proving the need for support, as well as providing that support, back on people and their families. This will likely see increases in homelessness, relinquishing care, impacts on family systems (financial and care burden) and service practices that will ultimately result in abuse, neglect and death of people with disability. For example, people with intellectual disability are more likely than the rest of the population to experience trauma related to violence, abuse and neglect (see references below). In another example, people with autism are more vulnerable to the effects of traumatic experience than others in the population and are more likely to experience trauma in the first place (see references below). How can you separate out the mental health experiences of a person and the disabling impacts of trauma on their other diagnosis – autism, intellectual disability, epilepsy etc.

The revelation that the current minister intends to reduce funding by 50% for Community participation and 10% for capacity building daily activities is cause for extreme concern for the participants we serve and the future of our small organisation. If we take this as a case study of what can happen under this power in relation to the people we support, these are the likely consequences:

• Participants living at home with family will likely experience any of these outcomes when a reduction in community participation occurs:
• Care burden significantly increased to pick up this unpaid gap in supports, including loss of employment for the primary care giver. Reduction in superannuation and other systemic impacts that will mostly impact women who take up the caring gap.
• Families deciding they can no longer support all the needs of their family member and seek additional funding to move out of the family home and into group care or they relinquish care onto an overburdened state system.
• Carer burnout will rise significantly increasing the risk of violence, abuse and neglect of those with disabilities.
• Participants we support in SIL settings (either ours or other providers) will be significantly impacted by a reduction of community participation:

• We support people with complex behaviours including a number of people under restrictive practice orders. Reduction in this support will see a move to group and congregate care which will increase behaviours through reduced supervision. There is likely to be an increase in behaviours of concern (including harm to others) between people who share in a SIL house, resulting in injury to both the cotenants and the staff that support them. There is likely to be an increase in the use of restrictive practices. Ultimately this will result in additional reporting to the commission and increase likelihood of harm to vulnerable people. o Participants with additional needs like severe dysphagia, even where not funded as high intensity (as this is no measure of need) will be at greater risk of choking, aspiration and death due to supervision limitations at mealtime. This will then be blamed on the providers who already have additional regulations due to the new SIL registration group requirements.
• Not for profit, providers not being viable to provide support that aligns with the new SIL registration requirement whilst simultaneously experiencing a reduction in funding. We support the new registration process and its intent and at the same time you cannot reduce key funding that makes those situations viable for the participant and the service provider.

This reduction in community funding will result in group support, escalation in behaviours, languishing lives and a significant increase in personal vulnerabilities to people with disability.

References

• McNally, P., Taggart, L., & Shevlin, M. (2021). Trauma experiences of people with an intellectual disability and their implications: A scoping review. Journal of Applied Research in Intellectual Disabilities. [onlinelibr….wiley.com]
• Starke, M., Larsson, A., & Punzi, E. (2024). People with intellectual disability and their risk of exposure to violence: Identification and prevention – a literature review. Journal of Intellectual Disabilities. [journals.sagepub.com]
• Maclean, M. et al. (2017). Abuse and neglect in children with disabilities: Risk varies by type of disability. International Journal of Population Data Science. [pmc.ncbi.nlm.nih.gov]
• Khoury, S. M. et al. (2025). Neglect of Children with Disabilities: A Scoping Review. Children. [mdpi.com], [telhai.ac.il]
• Hartley, G., Sirois, F., Purrington, J., & Rabey, Y. (2023). Adverse Childhood Experiences and Autism: A Meta-Analysis. Trauma, Violence, & Abuse. [researchgate.net]
• Quinton, A. M. G., et al. (2024). The Assessment and Treatment of Post-Traumatic Stress Disorder in Autistic People: A Systematic Review. [kclpure.kcl.ac.uk], [link.springer.com]
• Rumball, F. (2022). Post-traumatic stress disorder in autistic people. National Autistic Society. [autism.org.uk]
• Dufour, M.-M., et al. (2026). Trauma and Autism: A Scoping Review of the Literature.