Submission 422
Committee Secretary
Senate Standing Committees on Community Affairs
PO Box 6100
Parliament House
Canberra ACT 2600
community.affairs.sen@aph.gov.au
Submission to the Senate Community Affairs Legislation Committee
Supporting Reform and Sustainability
The Autism Association of Australia welcomes the opportunity to provide a submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.
The Autism Association of Australia (AAA) supports the objective of securing the long-term sustainability of the National Disability Insurance Scheme. The NDIS remains one of Australia’s most significant social policy reforms and has transformed the lives of hundreds of thousands of Australians with disability and their families. At its best, it provides dignity, agency, participation and security to people who were historically excluded from many aspects of community life.
AAA recognises that reform is necessary. The Scheme cannot continue indefinitely without careful stewardship, strong governance, effective safeguards and public confidence. Measures aimed at reducing fraud, strengthening oversight, improving consistency and ensuring public funds are directed towards effective supports are both reasonable and necessary.
However, sustainable reform cannot be achieved through haste, ambiguity or poorly designed implementation. The NDIS faces genuine challenges, but many of the issues now cited as justification for reform, including fraud, inconsistent decision-making, escalating costs and declining public confidence, are not failures of participants. They are failures of stewardship.
Successive governments and the National Disability Insurance Agency have not always demonstrated the discipline, oversight and long-term planning required to manage a reform of this scale. As Parliament considers significant changes to the Scheme through this Bill, it is reasonable to expect that the same standards of accountability now being imposed on participants, nominees and providers should also apply to the institutions responsible for administering the NDIS.
Submission 422
Evidence-Based Eligibility and Assessment
AAA supports evidence-based reform. Public funds should be invested in supports that are effective, proportionate and capable of improving outcomes for participants. We support robust assessment processes, clear eligibility criteria and funding decisions informed by research and demonstrated efficacy. The NDIS should not fund supports simply because they are preferred, familiar or historically accepted. It should fund supports because they are connected to disability-related need and have a reasonable evidence base for improving function, independence, participation or quality of life.
At the same time, assessment frameworks must accurately reflect the realities of autism and developmental disability. Autism is a lifelong neurodevelopmental disability that presents differently across individuals and across the lifespan. Functional capacity is often influenced by context, environment, communication demands, sensory factors, anxiety, transitions and the availability of skilled support. Assessment methodologies that fail to account for these factors risk producing inaccurate outcomes and unintended exclusion.
AAA is particularly concerned that eligibility and assessment reforms not rely on unpublished, unvalidated or poorly explained tools. If Government intends to introduce tighter eligibility settings or new assessment frameworks, it must provide clarity about how decisions will be made, who will make them, what evidence will be relied upon and whether assessment tools have been validated for autistic children, autistic adults, people with co-occurring intellectual disability and people with complex communication needs.
Thriving Kids, Foundational Supports and System Transitions
AAA also supports the principle that not every child with developmental concerns requires access to the NDIS. Foundational supports, including the proposed Thriving Kids program, may play an important role in providing earlier and more accessible support to children and families, where this is clinically appropriate and supported by evidence.
However, no child should be moved out of the NDIS, or denied access to it, unless the alternative support system is operational, adequately funded, evidence-based and demonstrably capable of meeting their needs. Government should not assume that a system exists simply because it has been announced. Before children are diverted from the NDIS to foundational supports, families must have confidence that those supports are available in practice, not just in policy.
There must also be clear, nationally consistent pathways between foundational supports and the NDIS. Families need to know what happens when a child does not progress, when a child’s disability or support needs are more significant than initially understood, or when foundational supports are not sufficient. The Government should define who makes those decisions, what evidence will be required, how quickly escalation will occur and how consistency will be maintained across jurisdictions.
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Submission 422
Accountability Must Apply to the NDIA
AAA is also concerned that the Bill imposes significant new obligations, compliance requirements, and penalties on participants, nominees, and providers without introducing equivalent accountability measures for the NDIA itself. Families continue to experience inconsistent planning decisions, unexplained funding reductions, poor communication, long delays and a review environment that is often needlessly adversarial.
The existence of review rights is important, but those rights have limited practical value when families must navigate complex, lengthy and intimidating proceedings through the Administrative Review Tribunal. While the ART provides an important avenue for independent review, many participants and families experience the process as highly adversarial, resource-intensive and difficult to navigate.
Accountability must operate in both directions. Participants should be expected to meet reasonable obligations. The NDIA should also be expected to meet clear standards of performance, transparency and fairness. This should include enforceable decision-making timeframes, mandatory written reasons for significant funding reductions, accessible review pathways, transparent reporting of planning outcomes and independent oversight of planning quality and consistency.
AAA advocates for the whole autism community. However, the impact of these reforms should ultimately be judged by their effect on those with the highest and most complex support needs.
This includes autistic people with co-occurring intellectual disability, severe communication impairments, complex behavioural support needs, complex health conditions and high levels of daily support requirements.
These participants are most likely to be affected by service gaps, funding restrictions, workforce shortages, poor assessment design and delays in reassessment or review. If reforms do not work for people with high and complex support needs, they cannot be considered safe or effective reforms.
Sustainability is not the same as short-term cost reduction. A sustainable NDIS is financially viable, publicly trusted, administratively competent and capable of delivering effective outcomes over time. Reducing expenditure in the short term while shifting costs to families, health systems, education systems, or crisis services is not genuine reform. It is a cost transfer.
The objective should not simply be to make the NDIS smaller. The objective should be to make it better governed, more consistent, more accountable and more focused on effective supports that improve the lives of Australians with disability.
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Submission 422
Recommendations
AAA recommends that the Committee:
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Require the Government to publish and independently validate all eligibility assessment methodologies, tools and decision-making frameworks before implementation, including evidence of their suitability for autistic children, autistic adults, people with co-occurring intellectual disability and people with complex communication needs. The assessment framework should include specific, validated protocols for people with profound autism and other cohorts with high and complex support needs. The Technical Advisory Group responsible for advising on assessment design should include genuine representation from clinicians, researchers and families with direct experience supporting people with profound autism and complex developmental disability.
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Ensure functional capacity assessments are evidence-based and capable of accurately capturing the impact of disability across real-world settings, support arrangements and environments. Assessment processes should be undertaken by appropriately qualified and experienced professionals and supported by clear standards, training and quality assurance mechanisms to promote consistency and reliability of decision-making.
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Establish clear, nationally consistent and transparent pathways between foundational supports, including Thriving Kids, and the NDIS, with defined escalation processes when support needs exceed the capacity of foundational systems.
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Guarantee that no participant loses access to NDIS-funded supports until alternative supports are demonstrably available, operational, adequately funded and capable of meeting their needs.
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Introduce reciprocal accountability measures for the NDIA, including enforceable decision- making standards, mandatory written reasons for significant funding reductions, transparent reporting of planning outcomes and accessible review processes.
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Review the operation of the Administrative Review Tribunal in relation to NDIS matters to ensure that review processes are timely, accessible and non-adversarial for participants and families.
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Require all major reforms arising from this legislation to be independently evaluated and publicly reported, including their impact on autistic people and participants with high and complex support needs.
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Maintain a strong commitment to evidence-based supports and ensure funding decisions are informed by contemporary research, demonstrated effectiveness and long-term participant outcomes.
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Submission 422
Conclusion
The Autism Association of Australia supports the objective of securing the NDIS for future generations. Reform is necessary. Stronger governance, clearer eligibility criteria, better oversight, and a stronger focus on evidence are all required.
However, reform must be done properly. Australians with disability and their families and their families need an NDIS that is sustainable, trusted and future-focused. That requires long-term thinking, evidence, transparency, accountability and careful implementation.
The decisions made through this legislation will shape the future of disability support in Australia. Parliament should therefore be guided by a simple principle: measure twice, cut once.
The Autism Association of Australia would welcome the opportunity to appear before the Committee to give evidence on this submission. Nicole Rogerson, CEO and Founder, is available to attend a hearing in person or by video. We are happy to provide any additional information the Committee requires.
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