Submission to the Senate Community Affairs Legislation Committee Inquiry

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

Submitted by:

Business: Paediatric Speech Pathologist (sole trader) servicing children and families Location: Mid North Coast, NSW Date: 1st June 2026

I am a speech pathologist working within a rural community, supporting children and families accessing the National Disability Insurance Scheme (NDIS). I have over 10 years experience across both health and disability sector settings. I stand with the disability community in supporting a sustainable NDIS. However, this Bill instead creates powers for large scale reductions to participant supports before adequate consultation, co-design, safe-guards and impact assessment. I am writing to express serious concerns regarding the proposed amendments contained within the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

While I acknowledge the importance of ensuring the long-term sustainability of the NDIS, I do not believe these proposed changes will achieve this in a safe, equitable or evidence-based way. Instead, I am deeply concerned they will significantly reduce access to essential supports, disproportionately impact vulnerable families, and further disadvantage rural communities already experiencing workforce shortages and barriers to healthcare access.

Many of the concerns outlined below align closely with those raised within the Occupational Therapy Society for Hidden and Invisible Disability (OTSi) discussion paper regarding the proposed legislation, particularly in relation to safeguarding, functional capacity assessment, automation, participant rights, and the erosion of individualised planning and support processes.

Rural and Regional Impact

The realities of rural healthcare appear largely absent from the proposed reforms. Families in rural communities already face:

• limited access to allied health providers,
• extensive waitlists,

• significant travel requirements,

• workforce shortages,

• reduced access to specialist services,

• financial strain associated with travel and accommodation, and

• limited alternative or foundational supports.

Reducing participant funding, tightening eligibility requirements, and increasing administrative burden will have a disproportionately severe impact on rural participants and providers.

Many families in my community are already struggling to access consistent supports despite being eligible for the NDIS. Reducing funding or narrowing eligibility criteria without first establishing robust foundational supports risks leaving families with no meaningful access to intervention, therapy or support services at all.

Arbitrary Funding Reductions

I am particularly concerned about proposed powers allowing broad percentage-based reductions to participant funding for reasons of “financial sustainability.”

• increased carer burnout,

• regression in communication and functional skills,

• increased behavioural distress,

• reduced school participation,

• higher rates of hospital presentations, and

• increased long-term costs to health and education systems.

These impacts are likely to be amplified in rural communities where service access is already fragile.

Concerns Regarding Ministerial Powers and Lack of Safeguards

I am deeply concerned about the expansion of Ministerial powers with limited oversight or accountability mechanisms.

The proposed amendments appear to allow significant changes to participant funding, definitions of disability, and support eligibility without adequate independent review, transparency or procedural safeguards.

Decisions that profoundly affect the lives, safety and participation of disabled Australians should not be able to occur without strong checks and balances.

I strongly support recommendations that any major changes to:

• funding reduction powers,

• definitions of functional capacity,

• permanence criteria, or

• support determination rules

should require greater parliamentary scrutiny and agreement from states and territories.

Disability Evidence and Impact on Low SES Communities

The proposed tightening of permanence and treatment requirements raises serious concerns for low socioeconomic status (SES) communities and individuals with low health literacy.

Many families I work with experience barriers including:

• inability to afford private assessments,

• long public waitlists,

• transport limitations,
• unstable housing,
• trauma,
• difficulty navigating complex systems,
• limited literacy,
• difficulty obtaining historical documentation, and
• limited understanding of administrative requirements.

The expectation that participants provide extensive evidence of past treatment or intervention fails to acknowledge the realities many families face.

I am concerned these changes will disproportionately exclude vulnerable participants not because they lack disability-related needs, but because they lack the resources, knowledge or capacity to navigate increasingly complex administrative processes.

This is not equitable access.

Plan Reassessment and Contact Requirements

I am extremely concerned by proposals allowing participant plans to be suspended where the NDIA is unable to contact a participant within short timeframes.

The reported possibility of funding suspension after a 24-hour response period is particularly alarming.

Families of disabled children are often managing:

• medical appointments,
• school challenges,
• behavioural crises,
• caring responsibilities,
• mental health concerns,
• housing instability,
• family violence,
• financial stress, and
• periods of burnout.

Expecting all families to reliably respond within a single 24-hour period fails to reflect the realities of disability and caregiving.

Additionally, many participants experience communication barriers, executive functioning difficulties, psychosocial disability, trauma, or unstable living circumstances that may affect responsiveness to administrative communication.

No participant should lose access to essential supports because they were temporarily unable to answer a phone call, email or message.

The consequences of suspended funding can be severe and immediate, including:

- loss of therapy,

- loss of support workers,

- breakdown of routines,

- increased risk to child safety,

- family crisis,

- mental health deterioration, and

- hospitalisation.

Automation and Reduction of Clinical Judgement

I am deeply concerned about the proposed expansion of automated decision-making within the NDIS.

As a speech pathologist, I know that disability support needs cannot be accurately determined through simplistic or standardised processes alone.

Functional capacity and participation are influenced by:

- communication,

- sensory needs,

- cognition,

- executive functioning,

- environmental demands,

- cultural context,

- trauma,

- co-occurring conditions, and

- the availability of supports.

These complexities require nuanced clinical judgement and individualised assessment.

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I am concerned that automated or classification-based systems will:

• oversimplify participant needs,
• fail to capture fluctuating or less visible disabilities,
• reduce the weight given to treating therapist recommendations,
• produce inequitable funding outcomes, and
• prioritise cost containment over participant wellbeing.

Therapist recommendations should not be overridden by automated systems or rigid funding classifications. Participants are individuals, not categories.

AAC Assessment and Assistive Technology Requests

I am also deeply concerned about the implications these reforms may have for Assistive Technology (AT) applications, particularly Augmentative and Alternative Communication (AAC) devices.

AAC assessment and funding processes are highly specialised and require significant clinical expertise, time, collaboration and individualised assessment. Comprehensive AAC trials often involve:

• extensive assessment across multiple environments,
• collaboration with families, schools and support teams,
• trialling multiple communication systems and devices,
• analysis of language access and communication function,
• detailed reporting,
• consideration of access methods and motor needs, and
• evaluation of long-term participation outcomes.

These assessments are not simple equipment requests. AAC systems are often a person’s primary means of communication and are essential for:

• expressing wants and needs,
• participation in education,
• social connection,
• autonomy,
• emotional regulation,
• safety

• healthcare access, and
• protection from abuse and exploitation.

I have supported families through lengthy AAC trial processes requiring substantial clinician, school and family collaboration, only for recommendations to be questioned or delayed by decision-makers without specialist communication or disability knowledge.

In my experience, families are frequently placed in situations where they are required to respond to detailed questions about highly specialised AAC recommendations despite not being the clinician who completed the assessment or report. Families often report feeling interrogated or placed under significant pressure to justify recommendations they do not have the technical knowledge to explain.

Rather than communicating directly with the treating therapist who conducted the assessment, trial process and report writing, questions are often filtered through families, creating unnecessary stress, delays and risk of miscommunication.

This process is particularly concerning given the significant time, expertise and collaboration involved in comprehensive AAC assessments. Treating therapists are best placed to clarify clinical reasoning, explain trial outcomes, and discuss the functional communication and participation impacts underlying recommendations.

Communication disability is complex and cannot be adequately understood through administrative processes alone. AAC recommendations should be reviewed by appropriately qualified professionals with expertise in disability, communication, aidive technology and participation-based assessment, with meaningful opportunity for direct clinician consultation where clarification is required.

I am concerned that increasingly standardised or automated decision-making processes may fail to appropriately recognise the complexity and significance of AAC recommendations.

Failure to adequately fund or approve AAC supports can have profound consequences for communication access, mental health, education participation, family functioning and community inclusion.

Reduction in Choice and Control

The proposed reforms appear inconsistent with the core NDIS principles of choice and control.

Increasing standardisation, restricting supports to narrow definitions, and reducing the influence of participant and therapist evidence risks creating a system where participants receive predetermined funding allocations rather than genuinely individualised supports.

For rural participants especially, reduced flexibility can mean there are effectively no usable services available within funding constraints.

Choice and control only exist when participants can realistically access and use supports that meet their needs.

Recommendations

I urge the Committee to:

• Delay implementation of the proposed reforms pending meaningful consultation and comprehensive impact assessment.

• Remove or substantially limit powers allowing broad funding reductions across participant groups.

• Ensure therapist and participant evidence remains central to planning and funding decisions.

• Prohibit fully automated eligibility and funding decisions.

• Strengthen safeguards regarding plan reassessment and participant contact requirements.

• Ensure participants cannot lose funding due to short-term communication barriers or periods of crisis.

• Consider the disproportionate impact of these reforms on rural, remote and low SES communities.

• Ensure foundational and community supports are fully established before restricting access to NDIS supports.

• Preserve the principles of individualisation, choice and control within the Scheme.

• Ensure Assistive Technology and AAC funding requests are reviewed by appropriately qualified professionals with expertise in communication disability and participation-based assessment, with direct avenues for consultation with treating clinicians where clarification is required.

Conclusion

The NDIS was created to support disabled Australians to participate meaningfully in their communities and access supports based on individual need.

I am deeply concerned that the proposed amendments risk shifting the Scheme away from these principles and toward increasingly standardised, restrictive and fiscally driven processes that fail to reflect the realities of disability.

As a clinician working directly with families in a rural community, I can see the likely consequences of these changes: reduced access to therapy, increased family stress, worsening inequity, greater pressure on already stretched rural services, and poorer long-term outcomes for disabled Australians.

I urge the Committee to carefully consider the real-world impacts these reforms will have on participants, families, clinicians and communities before proceeding with the Bill in its current form.