PWDA Template: Submission to the

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

Attention: Committee Secretary, Senate Standing Committee on Community Affairs

Submitted by email: community.affairs.sen@aph.gov.au

Date: 9th July, 2026

I/we welcome the opportunity to make a submission to the Senate Standing Committee on Community Affairs about the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

I am writing this submission as a person with disability, a social worker and the Practice Manager of Quality Care Network, a lived experience-led registered NDIS provider delivering Support Coordination and Psychosocial Recovery Coaching.

My perspective is informed by both lived experience and professional practice. I completed a Bachelor of Psychology at Macquarie University before undertaking a Master of Social Work at the University of Melbourne, with a focus on disability policy. Through my role at Quality Care Network, I work alongside people with

• psychosocial disability, intellectual disability, autism and other complex disabilities,

• supporting them to navigate not only the NDIS but also broader health, mental health, housing and community systems.

This submission reflects both my lived experience as a person with disability and my frontline experience supporting participants through complex service systems. It is informed by the experiences of the participants, families and carers we work with every day, as well as my commitment as a social worker to evidence-informed, human rights-based and recovery-oriented practice.

While I recognise the importance of ensuring the long-term sustainability of the NDIS, I am concerned that several of the proposed reforms may unintentionally reduce participant safeguards, create gaps between government systems and undermine Australia’s commitments under the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD) and the Australian Disability Strategy 2021–2031.

I want to outline the harm this Amendment Bill will cause if it passes Parliament. This Bill is too far-reaching to pass as it stands. I believe the Bill requires further scrutiny and amendment before it proceeds.

Parliamentary Scrutiny and Transparency

The consultation period for the Amendment Bill is two weeks, which is insufficient to allow for appropriate consultation, considering accessibility and communication needs. The Australian Government Guide to Policy Impact Analysis says consultation should occur for a minimum of 30 days where possible.

The short timeline impacts me by:

As a small lived experience-led provider, we believe two weeks is not enough time for participants, families and small organisations to understand and respond to complex legislative changes. Many of the people we support require accessible

• information, additional time or support to participate in consultation. A longer consultation period would better enable meaningful engagement from the disability community. Furthermore, a longer timeframe will allow for broader voices, presumably those of the most vulnerable, from the disability community to be heard.

Recommendation: Amend the consultation period for a best practice minimum of 30 days.

Key decisions left to ministerial instruments, not law

The issue: The Bill allows Ministers to change who gets NDIS support (Schedule 1 Parts 8 and 9) and how much funding people receive (Schedule 1 Part 4; Schedule 3) by signing an instrument, without going back to Parliament. The rules that will determine critical eligibility thresholds (Schedule 1 Parts 1, 8 and 9) have not yet been written.

How this affects participants:

We are concerned that significant decisions affecting participant eligibility, funding and access to essential disability supports could be made through ministerial instruments without the same level of parliamentary scrutiny, transparency or public consultation as primary legislation. This creates uncertainty for participants, families and providers and makes long-term planning and continuity of supports more difficult.

For many people with disability, NDIS supports underpin their housing, health, employment, education and community participation. Changes to eligibility criteria or funding arrangements can therefore have profound impacts on a person’s independence, wellbeing and safety. Decisions of this significance should be subject to transparent parliamentary oversight and meaningful consultation with people with disability before they are implemented.

• We are also concerned that broad ministerial powers may reduce opportunities for

• people with disability, their families, lived experience organisations and frontline

• providers to contribute to policy development. This appears inconsistent with the

• principles of co-design and meaningful participation that underpin Australia’s

• disability policy framework.

• These proposed changes raise important considerations regarding Australia’s

• obligations under the United Nations Convention on the Rights of Persons with

• Disabilities (UNCRPD), particularly Article 4(3), which requires States Parties to

• closely consult with and actively involve persons with disability, through their

• representative organisations, in the development and implementation of legislation

• and policies affecting them. They also raise important considerations regarding the

• Australian Disability Strategy 2021–2031, which promotes a rights-based, person-

• centred and collaborative approach to disability policy and reform.

Recommendation: Require that all decisions affecting NDIS eligibility and funding levels be made through primary legislation subject to full parliamentary scrutiny, with mandatory advance notice to affected participants before any changes take effect.

Existing participants face narrower criteria and fewer rights to challenge decisions

The issue: The Bill changes the rules for existing NDIS participants and makes it harder to challenge some decisions about supports and funding. It also restricts when you can request a reassessment, removes review rights for automatic plan renewals, and makes funding reductions unreviewable (Schedule 1 Parts 1 and 8). Combined with restrictions on reassessment requests (Part 2), automatic plan renewals without review rights (Part 5), and unreviewable funding reductions (Part 4), existing participants face narrower criteria with significantly fewer avenues to challenge decisions about their supports.

How this affects participants

This does not protect participants already on the

NDIS, who could be reassessed under stricter rules. If someone’s funding is reduced

or their plan renewed automatically, they may have limited or no ability to challenge

that decision. This could make it harder for people to get extra support when their

circumstances or disability change.

Many of the participants we support experience changing, fluctuating or episodic

disabilities, particularly those living with psychosocial disability. Restricting review

rights and reassessment opportunities may prevent participants from accessing

additional supports when their circumstances deteriorate, increasing the likelihood of

crisis and greater reliance on emergency departments, public mental health services, /homelessness services, police and other crisis response systems.

We are also concerned that reducing opportunities for direct engagement between

participants and the NDIA removes an important safeguarding mechanism.

Historically, plan reassessments and planning meetings provided an opportunity for

participants to discuss changing circumstances directly with an NDIA representative /or Local Area Coordinator (LAC). These interactions were not solely administrative /processes - they also provided an opportunity to identify emerging risks, changes in /functional capacity, safeguarding concerns and unmet support needs. Replacing /these interactions with automatic plan renewals or brief administrative contact may /reduce opportunities to identify participants who are at increased risk of harm, social /isolation or disengagement from essential services.

This concern is further compounded by the significant reduction in Support Coordination funding experienced across the Scheme. As access to Support Coordination becomes increasingly limited, many of the participants who would previously have received proactive assistance to navigate the NDIS and broader service system may instead go without regular oversight or advocacy. Those who are the most vulnerable, particularly people with complex needs, fluctuating mental

health conditions or limited informal supports, are at the greatest risk of being left

behind.

From our frontline experience as a lived experience-led provider, NDIS-funded supports frequently address gaps where mainstream health, mental health, housing and community services are unavailable, inaccessible or unable to respond. These supports are often preventative rather than reactive, helping participants maintain housing, remain engaged with treatment, strengthen informal supports and seek assistance before situations escalate into crisis. Removing or restricting access to these supports before equivalent alternatives are available risks transferring demand to already overstretched health, mental health, housing and justice systems rather than reducing overall government expenditure.

We are concerned that these proposed changes raise important considerations regarding Australia’s obligations under the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD). In particular, they may reduce participants’ practical ability to exercise choice and control, access appropriate supports, participate fully in their communities and seek review of decisions affecting their rights. These principles are reflected in Articles 12 (Equal recognition before the law), 13 (Access to justice), 19 (Living independently and being included in the community), 25 (Health), 26 (Habilitation and rehabilitation) and 28 (Adequate standard of living and social protection) of the UNCRPD.

We recommend that existing participants retain meaningful opportunities to request reassessment, access independent review of decisions affecting their supports and engage directly with the NDIA throughout their NDIS journey to ensure participant safety, uphold procedural fairness and maintain Australia’s commitment to a human rights-based approach to disability support.

Recommendation: Require a “no harm” safeguard ensuring no current participant loses access to supports unless equivalent supports are in place, with independent review rights before any exit decision and access to unscheduled reassessments

preserved. We recommend that participants retain the right to independent review

where funding reductions significantly affect their supports and that any changes to

funding arrangements are implemented only after transparent consultation and

appropriate safeguards are in place. Participants should continue to have reasonable

flexibility to manage funding across their plan period where this supports the

achievement of their goals and long-term independence.

Unreviewable ministerial power to cut funding across all support categories

The Minister can reduce funding for any support or group of supports by a specified

percentage through an instrument that cannot be challenged (Schedule 1 Part 4).

This applies across all budget categories. Unspent funds will no longer carry over at

plan renewal (Schedule 1 Part 5).

How this affects participants: A participant’s community participation, capacity building or assistive technology funding could be cut without warning and without any right to appeal. Participants who save unspent funds across plan periods for high- cost items will lose that ability entirely.

We regularly support participants who carefully manage their funding across multiple plan periods to prepare for changing circumstances, major life transitions or higher- cost disability-related supports. Many participants intentionally use funding conservatively so they can respond to unexpected changes in their disability, maintain housing, purchase assistive technology or invest in supports that will improve their long-term independence.

Reducing funding across support categories through an unreviewable ministerial instrument, together with removing the ability to carry forward unspent funds, may significantly impact participants’ ability to plan for the future, exercise choice and control, and achieve the goals identified in their NDIS plans. Importantly, these 7

• decisions would occur without participants having access to independent review,

• limiting procedural fairness for decisions that may substantially affect their lives.

From our frontline experience, capacity building and community participation supports are often viewed as discretionary; however, they are frequently the supports that enable participants to maintain independence, build relationships, participate in education and employment, develop daily living skills and remain connected to their communities. These supports are preventative investments that reduce social isolation and help participants avoid more intensive and costly interventions later.

We are concerned that these proposed changes raise important considerations regarding Australia’s obligations under the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD). In particular, reducing access to supports that promote independence, community participation and social inclusion may impact the practical realisation of Articles 19 (Living independently and being included in the community), 27 (Work and employment), 28 (Adequate standard of living and social protection) and 30 (Participation in cultural life, recreation, leisure and sport).

Recommendation: Require that unspent funds carry over at plan renewal for participants saving for high-cost items and require independent review rights before any funding reduction takes effect.

Requirement to exhaust treatment options before eligibility The issue: A person with disability will need to exhaust treatment options before they can be eligible for the Scheme (Schedule 1 Part 8). There will also be a removal of whole-of-person assessment, replaced by single eligible impairment consideration (Schedule 1 Part 3). The note that previously acknowledged environmental factors and other ineligible impairments could affect support needs will be removed (Schedule 1 Part 3).

How this affects participants

People with disability will need to prove their impairment cannot be treated before they access the NDIS. Once in the scheme, their supports will only be assessed against a single eligible impairment rather than their whole experience. A person’s individual circumstances will not be considered, including ability to pay for treatment, where they live or whether treatment is actually available to them.

Many participants already experience lengthy waiting lists, limited access to specialist services and significant financial or geographical barriers to treatment. Access to healthcare is not equitable across Australia, particularly for people living in regional and rural areas or those requiring specialist mental health, neurological or allied health services.

Requiring people to exhaust treatment options before accessing the NDIS risks delaying essential disability supports while participants wait months or years for services that may be unavailable, unaffordable or clinically inappropriate. This may disproportionately disadvantage people living with psychosocial disability, complex or multiple disabilities, and those experiencing significant socioeconomic disadvantage.

We are also concerned that the proposed removal of a whole-of-person assessment fails to recognise that disability is rarely experienced in isolation. In practice, participants often have multiple interacting impairments, environmental barriers, social circumstances and cultural factors that collectively influence their functional capacity and support needs. Assessing support needs against a single eligible impairment risk overlooking the cumulative impact of disability on a person’s daily life, independence and participation.

Importantly, access to treatment is not only influenced by availability, but also by whether treatment is culturally safe, trauma-informed and appropriate for the individual. Aboriginal and Torres Strait Islander peoples, people from culturally and linguistically diverse communities, refugees, people living in rural and remote communities, and those requiring specialist services often face additional barriers to

• accessing appropriate care. A requirement to exhaust treatment options may

therefore create inequitable outcomes for people whose access to culturally

responsive healthcare is already limited.

From our frontline experience, disability supports should be based on the functional

impact of a person’s disability, recognising that healthcare and disability support are

complementary systems with different purposes. Many conditions are lifelong,

fluctuating or only partially responsive to treatment. Disability supports should

complement healthcare, not be delayed until treatment pathways have been

exhausted.

We are further concerned that the proposed requirement does not adequately

consider participant safety. Individuals may be expected to undertake treatments

associated with significant side effects, uncertain outcomes or considerable personal

burden without sufficient recognition of informed consent, clinical judgement or

individual choice. The proposal also appears to provide limited consideration of a

participant’s financial capacity to access treatment, the geographic availability of

services, the availability of culturally safe care, or whether treatment is reasonably

accessible within an appropriate timeframe.

These proposed changes raise important considerations regarding Australia’s

obligations under the United Nations Convention on the Rights of Persons with

Disabilities (UNCRPD). In particular, Articles 5 (Equality and non-discrimination), 19

(Living independently and being included in the community), 25 (Health), 26

(Habilitation and rehabilitation) and 30 (Participation in cultural life, including

recognition of cultural and linguistic identity) recognise the importance of equitable,

accessible and person-centred supports. Delaying disability supports until treatment

pathways have been exhausted may unintentionally disadvantage participants who

face systemic barriers to healthcare, undermine culturally safe practice and reduce

opportunities for early intervention, recovery and community participation.

Recommendation: Do not proceed with a requirement to exhaust “appropriate

treatment“ options – there are no safeguarding measures around participant harm

due to side effects or complications, a participant’s financial ability to pay, or their

geographic capacity to access treatments.

Unvalidated functional capacity assessment tool risks misidentifying need

The issue: The Bill shifts assessment from whole-of-person consideration to a single eligible impairment (Schedule 1 Part 3). Read together with the eligibility thresholds in Parts 8 and 9, the tool used to conduct functional capacity assessments must be capable of sufficiently identifying whether a person meets the threshold for that single impairment.

The named assessment tool is the Instrument for Classification and Assessment of Support Needs (I-CAN). I-CAN requires validation to ensure it will sufficiently identify the needs of all people with disability, including those whose needs may be fluctuating or episodic and may not be captured through a point-in-time assessment, and to ensure it is culturally appropriate for First Peoples with disability.

How this affects participants: If the assessment tool does not accurately capture the full extent of a person’s disability, including needs that fluctuate or vary over time, a participant may be found ineligible or have their supports undercounted, with no guarantee the result reflects their actual experience.

Many of the participants we support experience complex, multiple or fluctuating disabilities that cannot always be accurately captured during a single assessment.

Functional capacity is rarely determined by impairment alone. It is influenced by the interaction between a person’s disability, their environment, available supports, health, culture, trauma history and social circumstances.

We are concerned that replacing a whole-of-person assessment with consideration of a single eligible impairment risks oversimplifying the lived experience of disability.

In Practice

In practice, many participants experience multiple impairments that interact to create significant functional limitations. Assessing only one impairment may underestimate the cumulative impact of disability on a person’s daily life, independence and participation.

For participants living with psychosocial disability or other episodic conditions, functional capacity may fluctuate significantly over time. A point-in-time assessment may not accurately reflect how a person’s disability affects them across different stages of illness or periods of recovery, increasing the risk that support needs are underestimated.

We are also concerned that any functional assessment tool should be independently validated across the broad range of disability cohorts represented within the NDIS, including people with psychosocial disability, intellectual disability, autism, neurological conditions, acquired brain injury and people with multiple co-occurring disabilities. Validation should demonstrate that the tool accurately measures functional need across these diverse populations.

Equally important is ensuring that assessment processes are culturally safe and equitable. Functional assessments should be validated for Aboriginal and Torres Strait Islander peoples and culturally and linguistically diverse communities to ensure they accurately reflect cultural context, communication differences, family structures and the impact of systemic barriers. Disability should not be assessed in a way that unintentionally disadvantages people because the assessment framework does not adequately reflect their lived experience or cultural context.

From our frontline experience, effective disability assessment requires consideration of the whole person, including the interaction between impairment, environmental barriers, informal supports, trauma, culture and community participation. This approach is consistent with contemporary biopsychosocial models of disability and person-centred practice.

Proposed Changes Regarding Australia’s Obligations Under the United Nations Convention on the Rights of Persons with Disabilities

These proposed changes raise important considerations regarding Australia’s obligations under the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD). Articles 5 (Equality and non-discrimination), 19 (Living independently and being included in the community), 25 (Health), 26 (Habilitation and rehabilitation) and 30 (Recognition of cultural and linguistic identity) support equitable, person-centred and culturally responsive assessment processes.

Assessment tools used to determine eligibility for essential disability supports should be demonstrably valid, reliable and culturally appropriate before being relied upon for decisions that may significantly affect a person’s rights and access to support.

Recommendation: Do not proceed with I-CAN as the functional capacity assessment tool unless it has been demonstrably validated to identify the needs of all people with disability, including those with episodic or fluctuating disability, and demonstrated to be culturally appropriate for First Peoples with disability.

Supports cut before replacement system is ready

The issue:

The government has announced funding for social, civic and community participation supports will be cut by 50 per cent and capacity building daily activities by 10 per cent for all participants, reductions that will be implemented through the ministerial instrument power in Schedule 1 Part 4. The Foundational Supports system intended to fill that gap has no confirmed implementation date and is not yet operational.

How this affects participants:

We are concerned that participants may lose existing disability supports before equivalent replacement supports are available. While Foundational Supports are intended to fill this gap, they are not yet operational, creating a significant risk that participants will experience reduced support without access to appropriate alternatives.

These supports are not simply discretionary community activities. They are often the mechanisms through which people exercise their rights under the UNCRPD, including the right to live independently and be included in the community (Article

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19), participate in cultural, recreation and community life (Article 30), access

ehabilitation and rehabilitation (Article 26), and enjoy the highest attainable standard

of health (Article 25). Removing these supports before equivalent alternatives are

available risks limiting the practical exercise of these rights.

As a lived experience-led provider delivering Support Coordination and Psychosocial

Recovery Coaching, we regularly support participants whose lives intersect with

multiple government systems, including public mental health services, primary

healthcare, housing and homelessness services, community services and informal

family supports.

From our frontline experience, participants’ disability-related support needs do not

disappear when appropriate supports are unavailable or insufficient.

When participants are unable to access the level or type of disability support, they

require, we frequently observe increased reliance on other government systems.

This may include more frequent presentations to emergency departments, increased

contact with crisis mental health services, police involvement during periods of acute

distress, housing instability, and greater pressure on families and informal carers. We

also observe increasing levels of carer stress and burnout, which can ultimately

result in additional demand for disability, health and social services.

In our experience, many NDIS-funded supports are preventative rather than reactive.

Effective Support Coordination and Psychosocial Recovery Coaching help

participants remain engaged with treatment, maintain stable housing, strengthen

natural supports, identify deterioration early and seek assistance before situations

escalate into crises. These preventative supports not only improve participant

outcomes but also reduce demand on more intensive and costly crisis responses

across other government systems.

We support the development of Foundational Supports as part of broader disability

reform. However, reductions to existing NDIS supports should only occur once

replacement supports are fully operational, adequately funded and demonstrably

• capable of meeting participants’ needs. Participants’ disability-related support needs
• do not disappear simply because responsibility shifts between government systems.

We are concerned that reducing supports before equivalent alternatives are

• available risks creating gaps in service delivery that are inconsistent with the
• objectives of the Australian Disability Strategy 2021–2031, which promotes a
• coordinated, whole-of-government approach to improving outcomes for people with
• disability. These proposed changes also raise important considerations regarding
• Australia’s obligations under the United Nations Convention on the Rights of Persons
• with Disabilities (UNCRPD), including Articles 19 (Living independently and being
• included in the community), 25 (Health), 26 (Habilitation and rehabilitation), and 28
• (Adequate standard of living and social protection).

We encourage Government to evaluate the sustainability of these reforms across the

• entire human services system rather than the NDIS budget alone. A reduction in
• NDIS expenditure should not be regarded as a successful outcome if it results in
• increased demand on health, mental health, housing, homelessness, policing or
• justice systems while participant outcomes deteriorate. Sustainable reform should be
• measured by both participant outcomes and the overall effectiveness and efficiency
• of government investment across all service systems.

Recommendation: Require that no reductions to community participation or

• capacity building supports take effect until Foundational Supports are fully
• operational, adequately funded and demonstrably able to meet the needs of those
• who will lose NDIS supports.

Quality Care Network supports reforms that improve the long-term sustainability of

• the NDIS. However, we encourage Government to consider sustainability across the
• entire human services system rather than the NDIS budget in isolation.

Participants do not experience disability within government portfolios. A single

• participant may interact with the NDIS, hospitals, GPs, psychiatrists, housing
• services, Centrelink, community mental health teams, police and informal carers at

Support Coordination

Support Coordinators and Psychosocial Recovery Coaches are often the only professionals working across these systems to ensure they function together.

Support Coordination is frequently misunderstood as simply making referrals. In practice, it is an early intervention and risk management function. Coordinators often identify deteriorating mental health, housing instability, disengagement from treatment or increasing risks before they become crises, allowing intervention before emergency responses are required.

This is particularly important for people living with psychosocial disability. Recovery is rarely linear. Many participants appear stable because they are receiving appropriate supports. Removing supports because someone appears well risks misunderstanding the episodic nature of psychosocial disability. Stability is often the result of ongoing intervention, not evidence that support is no longer required.

We encourage Government to evaluate reforms using a whole-of-government approach. A reduction in NDIS expenditure should not be considered a successful outcome if it results in increased demand on emergency departments, public mental health services, homelessness services, policing or the justice system while participant outcomes deteriorate.

Quality Care Network supports reform that strengthens both participant outcomes and the long-term sustainability of the Scheme. We believe this is best achieved by ensuring that equivalent, accessible and adequately funded alternative supports are in place before reducing existing NDIS-funded supports.