Submission 4243 — Name Withheld — NDIS Future Generations Bill

Submission to the Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026: Ignorance Has a Certain Dignity and I am Indignant

Submitted by —version 3, submitted 5:55pm on 01/06/2026

Table of Contents

Summary 2 Background 3

Inside the National Contact Centre 4

Specific Concerns 7

1. Lack of time to consider the changes 7 Recommendations 8

2. Functional Capacity—proposed new section 9B 8 Recommendation 10

3. Appropriate treatment—proposed new subsection 25A(1) 10 Recommendations 11

4. Alternative Supports—proposed section 25B 12 Recommendations 13

5. Repealing section 31 13 Recommendations 14

6. Effective and Beneficial—proposed new subsections 34(1E) and 34(1F) 14 Recommendation 14

7. NDIA and NCC Staff Support 15 Recommendations 15 Conclusion 18

Note: this is an updated version of the earlier two versions of this Submission I have uploaded. Please consider this the final document.

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Summary

“Knowledge only means complicity in guilt; ignorance has a certain dignity”

—Sir Humphrey Appleby; Yes, Minister

I am making this submission to ensure there can be no dignity of ignorance: the NDIA’s implementation of previous NDIS amendments is already harming participants, their families and carers, as well as workers within the NDIA and National Contact Centre. The

National Disability Insurance Scheme Amendment (Securing the NDIS for Future

Generations) Bill 2026 (The Bill) will only make this worse.

I am writing this submission in a number of capacities:

as a person with multiple overlapping disabilities and chronic illnesses who does not ● have adequate support;

as an informal support person for another person with disabilities ●

as a former worker within the NDIA’s National Contact Centre (NCC) ● In addition to the concerns I have raised regarding the culture of the NCC and my suspicions about the culture of the NDIA, I have specific concerns about the Bill, including:

1. the inadequate consultation on the proposed changes
2. the new definition of functional capacity—proposed new section 9B
3. appropriate treatment—proposed new subsection 25A(1)
4. alternative supports—proposed new section 25B
5. repealing section 31
6. the changes to effective and beneficial—proposed new subsections 34(1E) and 34(1F)

While this Submission may appear to be written in bureaucratese and with an air of professional detachment, please note that this is only due to my own Autistic hyperlexia, which I am least able to moderate when I am dysregulated. I cannot state my objections to this Bill in simple terms because my disability will not allow me to. I instead implore you to read with great care the story of each person who has taken the time to make a submission to this Inquiry. Remember that, for each person who made a submission, there are scores of people who did not—not because they didn’t care, but because they did not believe it would make a difference. Please do not prove them right.

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Background

I have diagnosed ADHD and Polyendocrine Metabolic Ovarian Syndrome (PMOS, until recently known as PCOS) as well as suspected Autism, Postural Orthostatic Tachycardia

Syndrome (POTS), Hypermobile Ehlers-Danlos Syndrome (h-EDS) and Mast Cell

Activation Syndrome (MCAS). I live with a partner who is diagnosed with Autism and ADHD as well as other undiagnosed chronic health conditions.

The only support we receive for our disabilities is ADHD medication and the informal supports we provide to each other. We can’t afford anything beyond that, but we do not qualify for any form of assistance without needing to spend thousands of dollars that we don’t have.

I am also a former worker in the NCC, operated mostly by Serco. I believe the changes proposed by the Bill are a risk to the health and wellbeing of NDIS participants, as well as the staff within the NDIA and NCC, who are forced to be the face of a system that is already harming participants.

My experience in the NCC was terrible and I left around three months after I started. It is easily the worst job have ever had, including my first job where I cleaned service station toilets. I ended most of my NCC shifts in a state of emotional dysregulation and spent much of my free time in a dissociative state. I experienced increased stress headaches and migraines, and was often so mentally and physically unwell that I could not complete a full five day work week. I had been lucky in my 35 years of life not to experience suicidal ideation, until I worked in the NCC. A friend has characterised it rather aptly as a “vicarious trauma factory”.

Following my resignation I posted on social media about my experience and was blown away by the responses I received from the NDIS community. I also heard from several current and previous workers in the NDIA and NCC. One NDIA staff member told me anonymously of their worries that we are “going to have a Robo debt fiasco including planners doing things that they can’t take back to themselves”. That same person mentioned hearing a coworker saying they wanted to commit suicide on a statewide Teams meeting.

I already knew that the culture within the NCC is appalling, but it’s clear to me that the problem extends into the fabric of the NDIA. NDIA staff and NCC staff alike are terrified of speaking up, which gives the government plausible deniability of the human cost of the previous NDIS cuts, and the cost of the proposed amendments. As it is, I suspect the human cost already exceeds that of roboDebt.

In my opinion, the changes proposed by the Bill represent, at best, a reckless disregard for the wellbeing of the more than 240,000 participants proposed to be removed from the

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NDIS,1 their family, friends and loved ones, as well as workers across the NDIS ecosystem—and for all participants who risk having their funding arbitrarily cut in the name of “financial sustainability”. At worst the changes represent a willingness to sacrifice the lives and wellbeing of hundreds of thousands of Australians for the sake of political and fiscal expediency. If this Bill passes, it will be a mark of shame for generations to come.

Inside the National Contact Centre

Every person I have encountered in the NCC has multiple traumatic stories about what is already happening to participants. NCC Customer Contact Officers employed by Serco do not have a direct interface with NDIA staff, nor many opportunities to engage with other Serco staff beyond their small teams. As a result, there are few, if any, people who understand the full scope of the harms that the system is already perpetrating—which I believe is by design. This means that there is, from the perspective of politicians and senior public servants, plausible deniability about the scale of harm the system already perpetuates against participants, families and workers.2

I have either directly experienced or heard from workers who have directly experienced the following:

threatening or attempting suicide or self harm while on the call ●Participants of participants or their carers attempting suicide or self harm following an ●Hearing adverse decision (every single worker I know has experienced this).

being unable to access funded supports because the hours they are ●Participants funded for are below legal minimum shift lengths for workers

being instructed to use their Core Flexible funding before an escalation ●Participants can be made on their behalf if their funding runs out.

disabilities deteriorating as a direct result of inadequate funding or ●Participants’ supports, or as a result of delays in plan review processes.

to participants as a direct result result of inadequate funding. ●Injuries example, inadequate assistance in daily living leading to a participant ●For falling and fracturing a bone.

1 Parliament of Australia (May 2026). ‘Response to orders of 14 May 2026 (503, 504, 505, 506, 507 and

508. relating to the National Disability Insurance Scheme—Treasury modelling’. p2. https://www.aph.gov.au/Parliamentary_Business/Tabled_Documents/16585

2 Hannah, A., & Botterill, L. C. (2025). Ignoring harm, saving face: non-knowledge, senior public servants and the Robodebt scheme. Australian Journal of Political Science, 60(2), 149–162. https://doi.org/10.1080/10361146.2025.2486108

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having to check themselves into hospital as a result of shortfalls in ●Participants funding.

Many of these scenarios interact with and compound on each other. I clearly recall one participant whose Functional Capacity Assessment stated a need for 24/7 care for daily activities as they used a wheelchair and required assistance toileting. They were funded for an amount that averaged to one hour per day. While they tried to ration their funding, they still quickly ran out of funding and were unable to get workers in, resulting in an injury and subsequent hospitalisation.

Current systemic issues that are well-known amongst NCC staff and that I have seen/directly experienced within the NCC include:

materials and processes being inadequate. The training that is provided ●Training contains a huge amount of dense material to absorb.

only had one day where we observed live calls before we started Consolidation, ●We and were expected to take calls alone (without coach observation) within a couple of days of starting Consolidation.

processes and scripts change with little notice or explanation. As a ●Requirements, result of increased scrutiny of the NCC employment arrangements, we went from being able to use a greeting that suited us, to being required to follow a script verbatim: Welcome to the NDIS. This is [name], how can I help you today?

deviation will be marked down on quality assessments for not following ●Any the Knowledge Article guidance.

PACE system regularly failing to recognise documents as attachments, ●The resulting in missed evidence in ongoing processes.

is sometimes possible to track these documents down, but only if you’re ●It given good advice by a coach during email training.

plan change processes not being commenced following a request from ●Requested a participant or an authorised person.

to participants’ recognised disabilities, including their primary disability, not ●Changes initiated by the participant, without any communication to the participant.

or their representatives being given incorrect information by staff as a ●Participants result of poor training or lack of transparency.

to escalate issues according to the risk matrix not being processed ●Attempts appropriately or at all.

recording attempts to contact the participant or their representative where ●Officers no reasonable attempt was actually made (e.g.insufficient time was given for the participant to answer their phone).

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stated communication preferences being ignored because of the ●Participants’ requirement to follow Knowledge Article processes dogmatically.

being marked down on their quality scores due to procedures that are unclear, ●Staff contradictory to the training we received or would have resulted in poorer outcomes for the participant.

being instructed (expressly or implicitly) not to offer information that would help ●Staff participants navigate the system better.

required to summarise the call at the end, and being marked down for not ●Being doing so even if it was clear the caller did not require a summary or was eager to get off the phone.

incentive to only offer the post-call survey to callers who are likely to give ●An favourable answers.

Meanwhile, NCC workers are expected to adhere to KPIs including a maximum Call Handling Time of around 15 minutes (excluding After Call Work). They are instructed to utilise hold times to make their notes instead of using After Call Work time (2.5-3 mins). They are simultaneously expected to find the correct Knowledge Article each time, find the correct procedure within that Knowledge Article, make detailed and accurate notes, say the exact script given for particular queries, and not make the caller feel hurried or dismissed.

In order to receive live advice on how to handle a particular call, NCC workers need to call the Serco escalations line, which may result in a longer hold time. Quality and accuracy of the advice depends entirely on the person who answers your call.

NCC workers must also adhere to strictly scheduled break times: 10 minute morning break; 10 minute afternoon break; and 30 minute lunch breaks. While I understand the need to ensure schedules are conformed to, and to ensure calls are as efficient as possible, it can be impossible to meet these requirements while also handling the often complex calls with empathy and care. For NCC workers there is a choice between adhering to your KPIs and exercising the care and diligence that the public should expect of people representing a public agency.

NCC workers are expected to handle these calls with no training in counselling, which arguably should be an inherent requirement of the role. They self-manage psychosocial hazards by using the Employee Assistance Program and taking a longer personal break as required (thus not meeting their Adherence KPI for the day). In addition, the Serco NCC employees are paid just over $28 per hour, amounting to around an annual full time salary of $55,000 per year. This was not enough for myself and my partner to live on, even temporarily, especially due to the number of days I took off work due to my deteriorating mental health. It’s particularly galling that during onboarding, we were instructed to complete a Conflict of Interest Declaration field that listed our APS Equivalent level as APS4, which attracts a salary starting at $76,737 (when I first joined; now $79,346).

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It is no wonder that of the 15 people I started training with, there are approximately five (or fewer) left still working with Serco. From what I understand, this is routine, but neither Serco nor the NDIA appear to be concerned by this. In fact, I believe it to be quite convenient to ensure workers feel as isolated as possible.

The above information represents the knowledge I accumulated between mid January and early May 2026, plus some other anecdotal experiences I heard from colleagues during my tenure. I believe it to be the tip of the iceberg when it comes to NCC and Agency culture, which I believe has already and will led to the deaths of participants, carers and workers. These deaths will only increase if this Bill passes.

Specific Concerns

1. Lack of time to consider the changes The Bill is more than 100 pages long, and its explanatory memorandum is nearly 300 pages long. The Bill contains complex amendments that will, according to the Government’s own modelling, result in more than 240,000 participants being kicked off the NDIS by 30 June 2031.3 It is an understatement to say that the changes introduced in the bill are significant.

The Office of Impact Analysis Best Practice Consultation Guidance Note recommends the

following timeframes for consultation on a change to policy:

Depending on the significance of the proposal, between 30 to 60 days is usually appropriate for effective consultation, with 30 days considered the minimum. Longer consultation periods may be necessary when they fall around holiday periods.4

Given the significance of the changes introduced in this Bill, many of which do not arise from previous consultation processes, and the vulnerability of the communities impacted by the changes, the Government knows that the time it has afforded for this Inquiry is manifestly inadequate.

I hold a law degree and have considerable experience working in public policy, including Cabinet and Parliamentary processes. I know how to interpret legislation and legal principles. I am certain that I have not had enough time to fully absorb and understand the provisions of the Bill and the practical effects of the changes proposed therein.

If a person such as myself, with a legal education and public policy experience, has not had sufficient time to understand the Bill in its entirety, people who do not those have

3 Above n1

4 The Office of Impact Analysis (May 2023). Best Practice Consultation guidance note. p.7 https://oia.pmc.gov.au/resources/guidance-oia-procedures/best-practice-consultation

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same privileges are far less likely to be in a position to adequately understand and respond to the Bill. The submission process itself has been largely inaccessible, and but for the tireless work of advocacy organisations, individual advocates and allies, many members of our community would have no way to have their say in this process.

I would also be surprised if the Office for Parliamentary Counsel (OPC) has had sufficient time to develop the legislation according to its own standards. For example, the recommended timeframe for the development of a large or complex Bill is 6 to 24 months.

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According to the OPC Timeframes for the development of Bills:

The following are some of the risks that come with developing a Bill in a compressed timeframe:

likelihood of unintended consequences or ineffective provisions ●increased likelihood of amendments being needed during the Parliamentary ●increased process and/or in the future

likelihood of adverse comments from the Senate Standing Committee for ●increased the Scrutiny of Bills, other Parliamentary Committees, stakeholders and others5

From my own initial reading of the Bill, all three of these risks are likely to manifest, particularly the likelihood of unintended consequences or ineffective provisions.

The Explanatory Memorandum for the Bill notes that two significant changes have not undergone specific consultation: the “reset” of Social, Civic and Community Participation (SCCP) and Capacity Building Daily Activity (CBDA) budgets; and the changes to “reasonable and necessary” supports.

The issues I, and others, have identified with the Bill are merely the ones that have come to light within the last 14 days. No person or organisation, no matter how skilled, educated or organised, could be expected to make a fully-informed submission through this farcical process.

Recommendations

1.1 that the bill, in its entirety, should be withdrawn, and the Government should engage in a genuine co-design process consistent with its own policy and with the rights of disabled people.

1.2 failing in the above, that the reporting date, time for submissions to be made, and time for community hearings for the Community Affairs Legislation Committee Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 be extended to provide sufficient time for the community to understand, absorb, and respond to the changes proposed in the Bill.

1.3 that additional support be provided to the Community Affairs Legislation Committee Secretariat to ensure that the process for making a submission is accessible to all people who may wish to make one.

5 Office for Parliamentary Council. Timeframes for the development of Bills. https://www.opc.gov.au/drafting-resources/bills-resources

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2. Functional Capacity—proposed new section 9B Proposed section 9B(1) defines functional capacity as follows:

A person’s functional capacity, in relation to an activity, is the person’s ability to undertake the activity:

(a) without assistance from other people, assistive technology or modifications; and

(b) in a context that excludes, as far as possible, the impact of the person’s environmental and personal circumstances.

My particular concern is with 9B(1)(a). According to the Explanatory Memorandum:

The requirement to assess functional capacity excluding the environmental and personal circumstances, as much as possible, intends to confine the assessment to the person’s intrinsic ability to undertake an activity.6

This appears to ignore the reality that a person’s intrinsic ability to undertake an activity is often dependent on, or heavily influenced by, their environmental and personal

circumstances. The World Health Organisation’s International Classification of

Functioning, Disability and Health (ICF) recognises disability and functioning:

…as outcomes of interactions between health conditions (diseases, disorders and injuries) and contextual factors. Among contextual factors are external environmental factors (for example, social attitudes, architectural characteristics, legal and social structures, as well as climate, terrain and so forth); and internal personal factors, which include gender, age, coping styles, social background, education, profession, past and current experience, overall behaviour pattern, character and other factors that influence how disability is experienced by the individual.7

The proposed definition of functional capacity directly contradicts the ICF and other commonly accepted understandings of disability. Planning decisions made under the proposed definition of functional capacity are likely to result in inadequate levels of support. One cannot expect to measure someone’s capacity to undertake an activity without reference to their environmental and personal circumstances, and then use that measure to create a budget that is adequate to support that same person within the context of their environmental and personal circumstances.

6 Explanatory Memorandum to the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 (“Explanatory Memorandum”) at p15

7 ICF Beginner’s Guide: Towards a Common Language for Functioning, Disability and Health (World

Health Organisation) https://www.who.int/publications/m/item/icf-beginner-s-guide-towards-a-common-

language-for-functioning-disability-and-health

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Someone’s personal circumstances could include the fluctuating nature of their disability, and compounding or co-occurring impairments.

Recommendation

2.1 that any proposed definition of functional capacity should acknowledge the person’s environmental and personal circumstances, fluctuating disability, co occurring and compounding impairments, and other personal and environmental factors acknowledged by the ICF.

3. Appropriate treatment—proposed new subsection 25A(1) According to the Explanatory Memorandum for the proposed s25A(1):

Proposed new subsection 25A(1) provides that appropriate treatment for a person’s impairment or impairments is treatment that is evidence based, is regularly undertaken in Australia and can reliably be expected to improve, reverse or alleviate the impact of the impairment or impairments.

…

Treatment may be appropriate treatment for a person’s impairment or impairments regardless of whether the person’s individual circumstances restrict the person from accessing the treatment. A person’s personal and environmental circumstances, including financial and geographical circumstances, are not relevant in considering whether a person has undertaken all appropriate treatment. This is because ensuring people with disability have access to mainstream services, regardless of their circumstances, is the responsibility of all mainstream support systems.8

The new proposed subsection 25A(1) functions as a reverse means test: people who can afford to undertake all appropriate treatment will be given access to NDIS supports, whereas people with the same disabilities who cannot afford treatment will not be given access, or have to wait longer to be given access.

Data from the Australian Institute of Health and Welfare show that the median waiting time for admissions from public elective surgery waiting lists in public hospitals differ significantly depending on a patient’s socioeconomic status, geographical location, and whether or not they are First Nations:9

8 Explanatory Memorandum, above n5 at p63.

9 Australian Institute of Health and Welfare . Waiting times by patient characteristics, 2024–25. https://www.aihw.gov.au/hospitals/topics/elective-surgery/waiting-times-by-patient-characteristics

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The median waiting time across all intended procedures was 51 days for people in ● the most disadvantaged socioeconomic areas and 38 days in the least disadvantaged socioeconomic areas.

The median wait time for First Nations people (61 days) is much lower than for all ● other Australians (45 days).

The median wait time for people living in Major Cities (44 days) is better than in ● most other areas:

Inner regional is 48 days ●

Outer regional is 51 days ●

Remote is 42 days ●

Very remote is 50 days. ●

It is illogical to the point of absurdity that the people with the least access to resources should be made to wait longer for NDIS support, or worse, to be denied NDIS support entirely, due to their lack of access to resources.

According to the ABC, in parts of South Australia, some people are waiting more than six years to see a neurologist; and people on public waiting lists are suffering “irreversible complications” and risking death while waiting.10

In addition, an appropriate treatment being one that is “regularly undertaken in Australia” is so broad that it could mean that a procedure that is only available in one private hospital in Australia is “regularly undertaken in Australia”. It does not matter how long the waiting list for the treatment is. “Regularly” could be interpreted quite broadly by the CEO, such that a treatment could be considered “regularly undertaken” if it is approved by the relevant authorities and performed only once per year in one hospital in the entire country.

If applicants are expected to exhaust all treatment options, this could result in more people extracting money from their Superannuation account in order to pay for these treatments under the private system.

10 Stephanie Dalzell and Celina Edmonds. ‘Australians suffering ‘irreversible complications’ waiting years to see medical specialists’. ABC News. 13 November 2025. https://www.abc.net.au/news/2025-11 13/australians-waiting-years-to-see-specialists/105991158

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Recommendations

3.1 At the very least, this provision should be amended to remain consistent with the criteria applied to the Disability Support Pension, i.e. that the impairment must be reasonably treated.

3.2 An appropriate treatment should be taken to mean one that is actually available to the participant, taking into account their geographical location and personal circumstances including whether they can access affordable treatment within a reasonable timeframe through the public system; and whether private treatment is affordable for them.

3.3 consideration must be given to circumstances where a treatment may be available, but nonetheless unsuitable for a person due to cultural or religious beliefs; and other factors including potential complications and personal considerations. There should be a presumption that where a person has not consented to undertake a treatment, that the refusal is reasonable.

4. Alternative Supports—proposed section 25B According to the Explanatory Memorandum:

This Part introduces amendments which tighten eligibility to the NDIS where alternative supports are available through other service systems which can reasonably meet the needs of a person.11

I only recently became aware of the Home and Community Care Program for Younger People (HACC PYP). I currently fall under the “medium fee” income range under the current Schedule of Fees, and might be able to access some support for my disabilities under this program. However, the Committee should note that the website for the Victorian HACC PYP states:

The HACC PYP schedule of fees will be updated from 1 July 2026. Income ranges will not apply after 1 July 2026. Concession card status will replace income levels as the basis for determining the applicable fee group.12

This introduces a great deal of uncertainty for me. I do not hold a concession card, but I do not earn nearly enough to be able to afford the full cost of the services covered under the HACC PYP. The proposed section 25B would render people like me ineligible for NDIS

11 Explanatory Memorandum. Above n4 at p66.

12 Department of Health (Victoria). Home and Community Care Program for Younger People – Schedule of fees. https://www.health.vic.gov.au/home-and-community-care/hacc-pyp-fees-policy-and-schedule-of fees

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support by virtue of the fact that the HACC PYP exists, regardless of whether or not I am actually able to access it.

Friends who have attempted to access the HACC PYP in their area have been told that while they meet the requirements, there is not enough capacity within the program to provide the support their needs.

This will result in people being thrown off the NDIS, or being unable to access the NDIS, because of programs that may theoretically be available to them; but that are inaccessible to them in reality.

Recommendations

4.1 the definition of ‘alternative supports’ should include supports that are demonstrably available and appropriate to a particular applicant and equivalent to support they would otherwise receive from the NDIS.

4.2 there should be a presumption in favour of a person being eligible for the NDIS unless and until they are confirmed to be eligible for an alternative support as defined above.

5. Repealing section 31 According to the Explanatory Memorandum:

Item 66 repeals Division 1 of Part 2 of Chapter 3 (which consists only of section 31). This reflects consolidation of principles dealing with planning decisions incorporated into one Part of the Act. The purpose of this item is to remove the principles under section 31 as the relevant principles from this section will be included in amendments made to section 4 and new section 17B.13

Several other submissions have noted their objection to the proposal to repeal section 31. I echo those concerns, with an addition of my own: it is unclear which amendments are being made to section 4, as claimed in the Explanatory Memorandum. Neither the Bill nor the Explanatory Memorandum appear to contain any proposed changes to section 4. This raises a concern that the Explanatory Memorandum was drafted at a time where there were other proposed changes that have since been removed; and that not all of the “relevant” principles from section 31 are included in the Bill.

Furthermore, all of the principles from section 31 are relevant, particularly when it comes to planning a budget that reflects the lived expertise of the participant, their informal supports, and their treating professionals. The existence of similar principles in other parts

13 Explanatory Memorandum. Above n4 at p49.

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of the Act should serve to reinforce the those contained within section 31. It is therefore unnecessary to remove it.

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Recommendations

5.1 section 31 should remain in its entirety.

5.2 failing in this, the Government should explain in detail why any provisions from section 31 not contained within the Bill are not “relevant” principles.

5.3 the Government should clarify which amendments, if any, are being made to section 4, and if none, why the Explanatory Memorandum refers to such amendments.

6. Effective and Beneficial—proposed new subsections 34(1E) and 34(1F)

Proposed subsections 34(1E) and 34(1F) give the CEO (or their Delegates) the power decide that they are not satisfied a support will be, or is likely to be, effective and beneficial for a participant even if there is evidence that it is effective having regard to the participant’s circumstances; and even if there is evidence that the support has already been effective and beneficial for the participant if they used it in their previous plan.

In practical terms, a participant who has previously been given a support in their NDIS Plan, can be denied the same support in a new plan under the new laws, even if there is direct evidence that the support is actually effective and beneficial for the participant. This flies so far in the face of logic that it makes a mockery of it.

For example, a particular support helped a participant to find and maintain a job in her previous plan. However, there is not much published and peer-reviewed research on the effectiveness of that support. Under the new laws, the Delegate can decide that, in spite of the direct evidence of the support being beneficial for the participant, they are not satisfied the support will be, or is likely to be, effective and beneficial for the participant.

This is particularly alarming when one considers the systemic lack of research in conditions that predominately or disproportionately affect women and people who were assigned female at birth; people with intersex variations; First Nations people; and people from other marginalised ethnic groups.

Recommendation

6.1 there should be a presumption in favour of a support being effective and beneficial if there is evidence that it is effective having regard to the participant’s circumstances; or evidence that the support has already been effective and beneficial for the participant if they used it in their previous plan.

7. NDIA and NCC Staff Support The following is based on a contribution made by a former NDIA planner who wishes to remain anonymous. I have made some additions to support their points. I will also add my own recommendations based on my own experiences within the NCC.

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One of the biggest opportunities to improve the planning role at the NDIA is to focus on both planner wellbeing and participant outcomes.

Planners are currently managing increasingly complex work while also being measured heavily on volume. A more balanced performance model that recognises case complexity rather than simply the number of approvals completed would support better decision making and reduce pressure on staff. Complex plans involving SIL, SDA, behavioural supports, nursing supports or significant risk factors often require substantially more time than standard plans and should be recognised accordingly.

Reducing administrative duplication would also make a significant difference. Planners spend a large amount of time completing repetitive documentation, navigating multiple systems and rewriting similar information. Streamlining processes, improving system functionality and providing better templates would allow planners to spend more time engaging with participants and making quality decisions.

There is also value in strengthening technical support and training. New planners are often expected to develop expertise quickly across a wide range of complex policy and legislative areas. Improved mentoring, longer onboarding periods and easier access to specialist advice would improve confidence, consistency and decision quality.

From a participant perspective, greater consistency and transparency in decision-making would improve trust in the Scheme. Participants often become frustrated when similar circumstances appear to result in different outcomes. Clearer explanations, plain English communication and nationally consistent approaches would help participants better understand decisions and evidence requirements.

Faster processing of plan changes and reassessments would also improve participant experience, particularly where support needs have changed significantly or urgent circumstances exist.

Finally, stronger collaboration between the NDIA and mainstream systems such as health, mental health, education and housing would reduce confusion and minimise situations where participants are caught between systems trying to determine responsibility.

Recommendations

7.1 improve planner support by reducing administrative burden, recognising complexity and enhancing transparency in communication with participants. This would benefit both NDIA staff and the people the Scheme is designed to support.

Below is a table that summarises the issues within the planning process and recommendations that would improve the experience for Planners and participants.

Issue for Planners Possible solutions

KPIs: A blanket planner KPI of 4 approvals Remove approval KPIs entirely or weight

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per week does not take into account the plans accordingly to reflect the additional complexity of different participants. time required to produce high quality decisions.

Administrative Duplication: A lot of Better templates and forms that are planner time is wasted on re-entering integrated into planning systems, including information into multiple systems, the ability to auto-populate information that completing repetitive tasks, and re-writing commonly appears throughout plans. similar information for multiple tasks

Access to technical expertise A dedicated “technical advice hotline” or Planners often need quick advice on the real-time specialist support could reduce delineation between health and NDIS delays. systems, complex Assistive Technology, home modifications, behaviour support and nursing supports.

Training for planners Increased support for new planners would New planners feel expected to perform at support their development of expertise over the level of someone with years of time. This could include reduced case experience. loads during their first 6-12 months, more mentoring and shadowing with experienced planners, practical case-study learning, and in-depth education on particular disabilities, supports and systems.

Poor psychological safety Opportunities to debrief following Planners are regularly expected to manage distressing events, increased wellbeing distressed participants, high workloads, support, realistic workload expectations, challenging behaviour and other risk and stronger support form leaders factors without much support. Create an avenue for anonymous whistleblowing within the agency before issues escalate to crisis point.

Three jobs in one Separating parts of this role would allow The planner role often involves planners to focus more on understanding assessment, budget determination and goals, building relationships and helping system navigation support for participants. participants navigate the scheme, allowing more specialisation within the system.

Issue for Participants Possible solutions

Inconsistency in decision-making: Improve operational guidance, improve similar cases can receive vastly different decision support tools, and conduct regular outcomes, leaving participants confused consistency checks across similar cases

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and frustrated and decisions.

Faster plan changes and reassessments Introduce dedicated plan change teams, Participants are facing large delays when introduce better triaging of plan change requesting plan changes. requests, and provide more staffing resources during peak demand periods.

Better communication Simple, plain- or easy English guidance Participants often say they don’t and explanations of decisions would understand why funding was approved, why funding was declined, and what evidence is needed.

Supports are not being provided soon Introduce a better early intervention system enough to ensure participants can access supports Delays in providing supports are leading to in a timely manner. more hospital admissions, carer burnout, acute crises and the deterioration of conditions that may necessitate more expensive support needs if not addressed early.

“NDIS is the only lifeboat”. Stronger partnerships between the NDIA, Many participant frustrations arise because state health departments, housing responsibility sits between systems, and providers and education systems could the NDIS does not provide sufficient reduce participants falling between support to find and access the appropriate systems. system.

7.2 improve the working conditions for all NCC staff, making all staff direct NDIA employees and allowing greater integration between the NCC and other parts of the NDIA.

Issue for NCC staff Possible solutions

KPIS: The focus on call handling time and Remove call handling time KPIs. Instead, strict adherence to schedules compromise strengthen quality requirements and set the quality of service provided. There is an clear expectations. Automate the post-call incentive to only offer the post-call survey survey (e.g. send it as a text after the call). to callers who are likely to give favourable answers.

Unclear expectations: Callers often do Provide clear guidance about what to not know why they are being asked to expect when you call the NCC, including provide personal information before being social scripts for people with

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able to proceed with their inquiry. They communication difficulties. Set clear don’t necessarily understand the role of the expectations about what NCC staff can and NCC in supporting the NDIS. can’t do on a call.

Inadequate training and support: training Overhaul training materials and materials and processes are inadequate. assessments. Focus more on practical The training that is provided contains a case studies and “shadowing” Planners huge amount of dense material to absorb. and other NDIA staff to understand how and why decisions are made.

Increase call observation opportunities and time before being expected to handle calls.

Inconsistent escalation decisions: Allow NCC staff to request escalations Escalation decisions are inconsistent, directly without TL approval. Provide clear require Team Leader approval, and can guidance on how to do this. take a lot of time to approve while on call.

Unclear or inconsistent procedures: Weight the quality assessment in favour of Staff are marked down on their quality participant outcomes. Allow staff to deviate scores due to procedures that are unclear, from Knowledge Articles if it would result in contradictory to the training received or a better outcome for a participant, and would have resulted in poorer outcomes for where the participant.

Poor psychological safety Provision for stress leave following adverse incidents.Training in mental health first aid and/or counselling. Create an avenue for anonymous whistleblowing within the agency before issues escalate to crisis point. Do not enact changes that are likely to result in adverse incidents.

Inadequate pay and conditions, and Employ all NCC officers as direct NDIA isolated working environment. staff. Pay all NCC officers APS rates commensurate with their level of responsibility.

Conclusion

Through my experience working within the NCC, I have interacted with well over a thousand callers, including participants, family members, carers and loved ones. Many of those calls shouldn’t have needed to happen in the first place. Participants and their loved ones spend countless unpaid hours trying to navigate the NDIS, fight its decisions and advocate for the level of support they are, and should be, entitled to.

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These people are going to be most impacted by the changes proposed in this Bill, and will represent the largest human cost should the Government proceed to cut more than 240,000 people off from supports that they have demonstrated that they need.

There will also be be a cost to the workers within the NDIS ecosystem. This includes job losses as a result of funding cuts, support workers being subjected to environments they are neither trained nor paid enough to be in, and industrial-scale wage theft by the large companies who will profit most from these changes.

There is also a real cost as a result of moral injury. As I said previously, my experience in the NCC had me experiencing suicidal ideation for the first time in my life. It’s only due to the support of friends, family and loved ones, and the good fortune of finding better employment, that I did not experience a complete mental breakdown.

I can only imagine that others have not been so fortunate. We do not know, because we have conveniently not counted, how many workers have died because of the stress of being part of a machine that grinds vulnerable people into a fine paste. Similarly, we have not counted how many Participants, family members, loved ones and supporters who have died due to a system that reaches beyond passive neglect and into the horrific realm described by Hannah Arendt as the “banality of evil”.

It is that same kind of evil that describes the NDIS as “unsustainable” and points to fraud with one hand, while cutting support for living, breathing people with the other, knowing that death is an inevitable result, and still actively choosing to plunge the knife into the hearts of our communities.

Please do not allow yourself to become complicit in that evil.

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