Submission 425
Submission 425
Our Commitment to First Nations Wellbeing,
Culture, and Self-Determination
We stand in strong support of First Nations Australians, affirming their inherent right to self determination, cultural preservation, and sovereignty over their land and traditions. We acknowledge that for First Nations peoples, mental health is inseparable from cultural, emotional, physical, and spiritual wellbeing - a holistic understanding maintained through thousands of years of continuous culture.
The Gayaa Dhuwi (Proud Spirit) Declaration Framework and Implementation Plan, launched
in Meanjin (Brisbane) on the lands of the Turrbal and Yuggera peoples where our office stands, provides a crucial 10-year roadmap. QAMH fully endorses this community-led approach to integrating First Nations leadership, cultural knowledge systems, and healing practices into Australia’s mental health frameworks.
QAMH is committed to supporting truth-telling as a process of acknowledging the histories, lived experiences, and ongoing strengths of First Nations peoples, particularly in the context of mental health. By confronting the impacts of colonisation, intergenerational trauma, and ongoing systemic injustices, we can better address the historical and contemporary factors affecting the mental wellbeing of First Nations individuals and communities.
In this submission, we emphasise the importance of holistic and healing approaches to mental health that incorporate the cultural knowledges, connection to Country, and spiritual practices of First Nations peoples. We are dedicated to ensuring that the principles of self determination, cultural safety, truth-telling, and holistic health are central to the mental health initiatives and recommendations we propose. Our goal is to help build a future where mental health systems respect and respond to the unique needs and strengths of First Nations Australians.
QAMH acknowledges and pays deep respect
to Aboriginal and Torres Strait Islander
peoples as the Traditional Custodians of the lands and waters across Australia. We honour their Elders past and present, whose knowledge, leadership, and cultural practices have sustained these lands for millennia.
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Who is QAMH?
The Queensland Alliance for Mental Health (QAMH) is the peak body for community-based mental health and wellbeing services delivered by non-government organisations (NGOs) in Queensland. We represent more than 146 members and stakeholders, involved in the delivery of these services.
Our purpose is to strengthen, promote, and advocate for community-based mental health and wellbeing service delivery for all Queenslanders, through direct engagement with our members, collaboration with government and statutory bodies, and active participation in policy reform at state and national levels.
QAMH maintains a formal collaboration with Community Mental Health Australia and contributes to the work of Mental Health Australia. We also work with both the National and Queensland Mental Health Commissions.
Our membership gives us direct insight into the experience of people living with mental health challenges, their families, carers, and kin, and the organisations that support them.
Recognition of Lived and Living Experience and
Expertise
QAMH honours and affirms the lived and living experience of those who have experienced mental health and wellbeing challenges, suicide, and Alcohol and Other Drug use, and the essential contributions they make to the community mental health sector. We equally recognise the lived and living experience of family, carers, and kin, acknowledging their unique perspectives and contributions. We acknowledge the courage and strength of those who bring their Lived and Living Expertise into professional spaces and affirm that expertise as an essential foundation for a responsive, effective, and human-centred sector. Throughout this submission, we use the term “lived and living experience” to reflect that mental health challenges are often ongoing rather than historical, and “Lived and Living Expertise” where we refer to the knowledge, skills and insights that people develop through that experience. Both terms recognise that experiential knowledge is a genuine and valuable form of expertise, not simply a personal characteristic.
QAMH Contact Details
For any further information please contact:
Chloe Jesson
Deputy Chief Executive Officer
109 Logan Road, Woolloongabba QLD 4102
| Web: www.qamh.org.au3
Submission 425
Summary of Recommendations
Recommendation 1: Changes that restrict or reduce access to the NDIS should not commence until Foundational Supports are operational, accessible, adequately resourced, and capable of meeting expected demand. Any rules arising from the Bill should be co designed with people with lived and living experience, carers, Aboriginal and Torres Strait Islander peoples, and the community mental health sector. Recommendation 2: The Bill should include explicit legislative protections recognising that ongoing treatment engagement does not preclude permanence of psychosocial disability. Related NDIS rules should be co-designed with people with lived and living experience, with clear guidance on how “appropriate treatment” will be defined. Recommendation 3: Assessment tools, thresholds, and methods should be co-designed with people with lived and living experience and the community mental health sector and must appropriately account for the episodic nature of psychosocial disability and the role of support environments and social context in shaping functioning. Recommendation 4: The existence of a service in another system should not, on its own, be sufficient grounds to deny NDIS access. The NDIA should be required to demonstrate that alternative supports are genuinely available, accessible, and capable of meeting a person’s needs in practice, including consideration of wait times, workforce capacity, geographic access, cultural safety, and continuity of support.
Recommendation 5: Social, Civic and Community Participation and Capacity Building Daily
Activity supports should be recognised as core supports for people with psychosocial disability. The direct causal link requirement must reflect the interaction between psychosocial disability and co-occurring conditions, and impacts on Aboriginal and Torres Strait Islander participants, and carers should be assessed before implementation. Recommendation 6: Support coordinators should retain the ability to initiate reassessment requests for participants with psychosocial disability. Reassessment criteria should explicitly recognise the episodic and fluctuating nature of psychosocial disability, permit reassessment where there is evidence of significant deterioration regardless of whether change is considered ongoing, and the response period should remain at 21 days. Recommendation 7: Automated decision-making should be restricted to routine administrative functions. Decisions affecting eligibility, access, reassessment, or funded supports must involve human oversight, transparent reasoning, and review rights. Recommendation 8: Participants should not have their plans suspended or status revoked solely because they are temporarily uncontactable due to disability-related circumstances. The NDIA should be required to consider evidence from providers, carers, and trusted supports before acting. Recommendation 9: The Government should assess the cumulative impact of the Bill on the viability of community-based psychosocial support providers before implementation, including the interaction between proposed funding changes, provider sustainability, and the Foundational Supports rollout.
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Psychosocial supports are non-clinical, trauma-informed, recovery-oriented services that support people experiencing mental health challenges to live independently and safely in the community. They enable people to stay well, avoid crisis and participate in community life. By strengthening wellbeing and social participation, they also reduce pressure on hospitals and emergency services, making them a cornerstone of a sustainable mental health system. Community-Based Mental Health Services delivered by the NGO sector This sector occupies a unique and critical position within the broader mental health system. These services address the complex realities of distress shaped by trauma, poverty, isolation and other social determinants, providing practical support with housing, relationships, employment and social inclusion. These services are critical for:
- People who are eligible for the NDIS and those who are not
- Individuals facing barriers to accessing mainstream mental health services
- People whose needs are significant but not primarily clinical.
Introduction
QAMH welcomes the opportunity to provide feedback on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. The long-term sustainability and integrity of the NDIS are important objectives, as is including measures to improve consistency, reduce fraud, to ensure the Scheme remains available for people with significant disability into the future. The Government’s commitment to developing Foundational Supports alongside these reforms is also acknowledged. However, significant concerns remain regarding the sequencing of the proposed reforms and the absence of safeguards ensuring that appropriate alternative supports will be accessible, adequately resourced, and operational before access changes commence.
This submission focuses on the aspects of the Bill most relevant to people living with psychosocial disability and the organisations that support them. It emphasises the need for reforms to reflect the non-linear and episodic nature of psychosocial disability and avoid unintended barriers to support. It also highlights the critical role community-based psychosocial services play in keeping people well, reducing crisis escalation and avoidable hospital use, and relieving pressure across the broader service system.
This submission is informed by consultation with community-based mental health organisations delivering psychosocial supports. QAMH received detailed written feedback and operational examples relating to the likely impacts of the Bill on people with psychosocial disability, including impacts on access, continuity of support, community participation, reassessment processes, and crisis prevention. The positions outlined in this submission reflect consistent themes raised across service provider feedback.
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Sequencing of Reforms
A central structural problem with this Bill is its order of operations. The 2023 NDIS Review was explicit: eligibility changes should occur only once alternative supports outside the Scheme are available and operational.i The Bill defers commencement of major access changes until January 2028 but does not make that commencement conditional on alternatives being in place. Deferred implementation is not the same as conditional implementation. For people living with psychosocial disability, this distinction will determine whether reforms preserve continuity of support or increase service gaps and crisis escalation. Access to the NDIS for people with psychosocial disability has already been constrained in recent years. NDIA quarterly data shows that access approval rates for applicants with primary psychosocial disability have fallen from 56 per cent in 2021-22 to 31 per cent in Quarter 2, 2025-26.ii Independent sector analysis puts the picture more starkly: the Australian Psychosocial Alliance’s Access Denied report documents a 62 per cent drop in NDIS approval rates for people with psychosocial disability over five years, with only 25 per cent of applications now succeeding.iii The Bill proposes to tighten access to a scheme that is already turning away significant numbers of applicants with psychosocial disability. Every measure in it must be read in that context.
The Alternative System Does Not Yet Exist
The sequencing argument depends on what people are being redirected to. For most people with psychosocial disability, the answer is a community-based support system that remains significantly under-resourced relative to the clinical system it is intended to complement. In Queensland, just 4.6 per cent of mental health funding is directed to the community-based mental health NGO sector.iv Foundational Supports are not yet operational across jurisdictions, and existing community based mental health services delivered by NGOs are not currently funded or staffed to absorb significant additional demand from people who may no longer qualify for the NDIS. National analysis from 2022-23 data estimates that approximately 493,600 Australians aged 12-64 with severe or moderate mental health challenges who fall outside the NDIS already have unmet psychosocial support needs.v These are people the current system is already not reaching. The Bill does not create capacity to reach them; it creates conditions that will increase their number.
Cost Transfer, not Cost Saving
When people with psychosocial disability lose access to community-based support, the costs do not disappear from the system. They transfer to more expensive acute services. QAMH members who contributed to this submission provide direct evidence of what community based psychosocial support achieves, and by implication, what its absence produces. This evidence is examined in the Support Determinations and Reasonable and Necessary section of this submission (page 10). An independent evaluation of the NSW Community Living Supports and Housing and Accommodation Support Initiative programs found a 74 per cent reduction in hospitalisations and estimated cost offsets of $108,470 per participant over five years.vi Reductions to the support categories most at risk under this Bill risk shifting costs to more expensive acute services rather than reducing them.vii
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The Sequencing Risk is Not Uniform
The risk of falling through a gap between systems is not equally distributed. It is most acute where alternatives are least available. In regional, rural and remote Queensland, community mental health services already operate with workforce shortages, limited capacity, and significant wait times.viii For a participant in regional Queensland who loses NDIS access or experiences a significant reduction to their plan, the “other service system” the Bill assumes they will transition to is often not accessible. For people from refugee and asylum seeker backgrounds living with psychosocial disability, the gap is compounded further. This group may experience psychosocial disability shaped by experiences of torture, war trauma, displacement, family separation, racism, housing instability, and profound distrust of institutions. The alternative service system assumed by the Bill is often not accessible to this cohort regardless of geography, due to language barriers, absence of culturally safe services, and restricted eligibility under short-term funding models. For these communities, there is no adequate alternative in place, and no realistic prospect of one before 2028.
Provisions with Immediate Effect
QAMH also notes that the January 2028 commencement date does not apply to all relevant provisions. While the Bill delays major eligibility changes until January 2028, several measures affecting existing participants and providers commence much earlier. The commencement table in the Explanatory Memorandum shows that provisions relating to support determinations, reasonable and necessary supports, direct causal link requirements, plan suspension and revocation, and provider payment arrangements begin progressively from 2026 and 2027, before Foundational Supports are expected to be operational.ix These changes will affect existing participants and place additional pressure on community-based NGO providers before alternative supports are established and capable of meeting demand. The sequencing problem is not confined to the 2028 eligibility provisions. Recommendation 1 Changes that restrict access to the NDIS or reduce participant supports should not commence until Foundational Supports are operational, accessible, adequately resourced, and capable of meeting expected demand. Any subordinate rules arising from the Bill should be co-designed with people with lived and living experience, carers, Aboriginal and Torres Strait Islander peoples, and the community mental health sector.
‘All Appropriate Treatment’ and Permanence (Sch. 1, Part 8)
The proposed changes to permanence introduce a requirement that a person must have undertaken “all appropriate treatment” before an impairment can be considered permanent for the purposes of NDIS access. While the Explanatory Memorandum acknowledges psychosocial disability as a distinct context, the relevant protections are not reflected in the Bill itself and are instead left to subordinate NDIS rules. This creates significant uncertainty regarding how the provisions will be interpreted and applied in practice for people living with psychosocial disability.
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For many people living with psychosocial disability, ongoing treatment does not necessarily reduce the permanence or severity of functional impact. Many people continue to experience substantial psychosocial disability despite long-term engagement with clinical treatment, medication, psychosocial supports, and recovery-oriented care. Requiring evidence that “all appropriate treatment” has been exhausted risks creating a higher and less certain access threshold for psychosocial disability than for other disability types. The Bill does not provide clarity regarding:
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what constitutes “appropriate treatment” for psychosocial disability
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who determines whether appropriate treatment has occurred
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how treatment availability, affordability, cultural safety, geography, and informed choice will be considered
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the interaction between treatment access and workforce shortages, particularly in regional, rural and remote communities
These concerns are particularly significant in the context of uneven access to mental health treatment and psychosocial supports across Australia, and the absence of a single accepted treatment pathway for many psychosocial conditions. QAMH supports greater consistency in NDIS access processes. However, the Bill should explicitly recognise that ongoing treatment engagement does not preclude permanence of psychosocial disability. Recommendation 2 The Bill should include explicit legislative protections recognising that ongoing treatment engagement does not preclude permanence of psychosocial disability. Related NDIS rules should be co-designed with people with lived and living experience, with clear guidance on how “appropriate treatment” will be defined and applied for psychosocial disability.
Functional Capacity Thresholds (Sch. 1, Part 1)
The Bill introduces a legislative definition of functional capacity and enables the future introduction of thresholds for NDIS access. Functional capacity is defined as a person’s ability to undertake activities “without assistance from other people, assistive technology or modifications” and, as far as possible, excluding the impact of environmental and personal circumstances.
For people living with psychosocial disability, functioning is often shaped by social and environmental factors such as housing stability, trauma, poverty, cultural safety, social connection, and access to support. It may also fluctuate significantly over time, particularly during periods of stress, crisis, isolation, or changes in support. Assessment approaches that minimise these factors risk failing to accurately reflect psychosocial disability in practice. As one provider noted “a member who presents well in the structured, supportive environment of the Clubhouse may function very differently in unstructured settings or during a period of stress or symptom exacerbation.”
The assessment tools, thresholds, and rules underpinning this framework have not yet been developed. The Explanatory Memorandum states that further work is required to determine the methods and criteria that will be used to assess functional capacity. At present, it
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remains unclear how a threshold-based framework designed to support more standardised decision-making will adequately capture psychosocial disability, particularly where functional capacity may vary significantly over time and across support environments. Recommendation 3 Functional capacity assessment tools, thresholds, and methods should be co designed with people with lived and living experience and the community mental health sector and must appropriately account for the episodic nature of psychosocial disability and the role of support environments and social context in shaping functioning.
Eligibility and the Interface With Other Service
Systems (Sch. 1, Part 9)
The Bill requires the NDIA to consider whether a person’s support needs can reasonably be met by another service system before granting access to the NDIS. While intended to reduce cost-shifting between systems, the provision may redirect people with psychosocial disability into services that are not designed, funded, or consistently available to provide ongoing psychosocial support. Community-based mental health services, Primary Health Network (PHN)-funded supports, and state-funded psychosocial programs are all potentially within scope as “other service systems”. Many of these services operate with limited capacity, workforce shortages, geographic gaps, restrictive eligibility criteria, and short-term funding arrangements.
Providers consistently explained that the existence of a service does not necessarily mean it is genuinely accessible or capable of meeting ongoing psychosocial support needs in practice. One provider noted that “availability must mean current availability, not theoretical capacity”. For many people living with psychosocial disability, continuity, flexibility, intensity of support, and long-term relationship-based care are central to maintaining stability and preventing crisis escalation. This issue is particularly significant for psychosocial disability, where support needs frequently intersect across mental health, housing, alcohol and other drug services, primary care, and social supports. It may also be particularly significant in regional, rural and remote communities and for culturally and linguistically diverse populations, where service availability and cultural safety may already be limited. Recommendation 4 The existence of a service in another system should not, on its own, be sufficient grounds to deny NDIS access. The NDIA should be required to demonstrate that alternative supports are genuinely available, accessible, and capable of meeting a person’s needs in practice, including consideration of wait times, workforce capacity, geographic access, cultural safety, and continuity of support.
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Support Determinations and ‘Reasonable and Necessary’ (Sch. 1, Parts 4 and 6)
The Bill tightens the definition of reasonable and necessary supports and introduces a mechanism allowing the Minister to reduce funding for specified support categories across the entire Scheme. Government data shows that people with psychosocial disability have a higher proportion of their plans allocated to Social, Civic and Community Participation (SCCP) supports than most other NDIS participant groups.x The Bill creates a mechanism that could allow scheme-wide reductions of up to 50 per cent to these supports, and reductions of up to 10 per cent to Capacity Building Daily Activity supports.
For people living with psychosocial disability, these are not supplementary or lifestyle-based supports. They are central to psychosocial recovery, community connection, daily functioning, and early intervention before crisis escalation. Member feedback from Queensland community-based mental health NGOs was consistent and unambiguous on this point. These supports fund structured activities that build social connection, reduce isolation, develop daily living skills, support community participation, and enable recovery oriented psychosocial rehabilitation. For many participants, they provide the foundation for maintaining stability and wellbeing over time. Standardised scheme-wide reductions will therefore disproportionately affect participants whose supports are less clinically oriented and more focused on long-term psychosocial rehabilitation and daily functioning, precisely the cohort for whom these categories are most essential.
Evidence from Queensland Providers
Consultation feedback highlighted the role both Social, Civic and Community Participation and Capacity Building supports play in helping people remain connected to their communities and engaged in recovery. A peer-reviewed evaluation of Stepping Stone’s Clubhouse model found that established members had a mental health-related hospitalisation rate of 16 per cent compared with 41 per cent among new members. Established members also reported higher quality of life, stronger social connectedness, and better outcomes across multiple domains of psychosocial recovery.xi
Other Queensland provider feedback reinforced the importance of sustained community based psychosocial support. One provider reported no unplanned psychiatric hospital admissions among participants receiving intensive daily community-based support over a six-year period. While provider-reported and not independently evaluated, the example was presented as evidence of the role ongoing psychosocial support can play in helping people maintain stability and avoid crisis. Providers also expressed concern that significant reductions to these support categories may increase reliance on more intensive service responses, including hospital, crisis, homelessness, and justice services.
QAMH also notes that the Government is simultaneously pursuing significant reforms to provider regulation, including the phased implementation of mandatory registration for NDIS providers alongside broader workforce capability and safeguarding reforms. Implementing major reductions to psychosocial support categories before these reforms have taken effect and been evaluated risks reducing access to effective supports before quality improvement measures have been fully realised.
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Human Rights Obligations
The human rights implications of these provisions require explicit consideration. The Convention on the Rights of Persons with Disabilities (CRPD) affirms the right of people with disability to be included in the community and to access the support services necessary for full community participation. It also requires an adequate standard of living. A ministerial mechanism that reduces community participation supports for the cohort most dependent on them, without prior independent equity assessment, engages both obligations directly. The Bill’s Statement of Compatibility with Human Rights does not adequately address the disproportionate impact of these provisions on people with psychosocial disability. QAMH asks that this gap be specifically addressed before the Bill proceeds.
Disproportionate Impact on Aboriginal and Torres Strait Islander
Participants
The Government’s own analysis confirms that First Nations participants have higher average Social, Civic and Community Participation budgets than the Scheme average ($17,600 compared to $17,500), a higher rate of plan inflation from unscheduled reassessments at 25 per cent compared to the Scheme average of 21 per cent, and will experience a higher dollar value reduction on average from the proposed budget reset.xii Proposed reductions to these support categories will therefore have a disproportionate financial impact on a group already experiencing significant systemic disadvantage.
For Aboriginal and Torres Strait Islander people with mental health challenges, participation in community, culture, and Country is fundamental to social and emotional wellbeing and recovery. As recognised by Gayaa Dhuwi (Proud Spirit) Australia, culture, kinship, and community are central determinants of healing and wellbeing. Reductions to Social, Civic and Community Participation supports will disproportionately affect recovery pathways that are culturally grounded and community led. Any equity assessment of these provisions must be undertaken in genuine partnership with Aboriginal and Torres Strait Islander peoples and Aboriginal Community Controlled Organisations and completed before any reduction mechanism is activated. The assessment must be independent, publicly available, and tabled before Parliament.
The Direct Causal Link Requirement
The Bill reverses a Federal Court decision by requiring that all funded supports have a direct causal link to the impairment that qualified a person for the NDIS. For participants living with psychosocial disability, this requirement does not reflect the nature of the condition.
People living with psychosocial disability frequently experience co-occurring mental health, physical health, substance use, cognitive, and social challenges that interact to shape functional support needs.xiii These needs cannot be neatly separated into discrete causal categories. For participants from refugee and asylum seeker backgrounds, support needs may arise from the intersection of torture, trauma, displacement, family separation, housing instability, and psychosocial disability in ways that no single causal attribution can adequately capture. A narrow interpretation of direct causation will reduce access to supports that are central to maintaining psychosocial stability and functioning, not because those supports are unnecessary, but because the interaction between conditions is not visible within a narrow causal framework.
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Family and Carer Availability
The Bill also strengthens expectations that family, carers, kin, and informal supports will fill gaps in funded supports. Feedback from providers highlighted that this assumption may not reflect the realities of psychosocial disability. Some participants are estranged from family, while others have relationships that have been strained by the long-term impacts of serious mental health challenges. In many cases, family members are already providing substantial support and have limited capacity to take on additional caring responsibilities. Providers also noted that, for some participants, community-based services represent their primary source of social connection, stability, and practical support. Mental health carers already experience high levels of psychological distress, social isolation, and reduced workforce participation.xiv,xv Any shift in support responsibilities from funded services to unpaid care networks should therefore be carefully assessed. Recommendation 5a
Social, Civic and Community Participation and Capacity Building Daily Activity
supports should be recognised as core supports for people with psychosocial disability and should not be subject to scheme-wide reduction without prior independent equity assessment. Recommendation 5b The direct causal link requirement must reflect the interaction between psychosocial disability and co-occurring conditions. Impacts on families, carers, kin, and young carers should be assessed before any implementation of reductions that may shift support responsibilities onto unpaid care networks.
Reassessment Requests and Support Coordination
Who can request reassessment The Bill removes the ability for support coordinators and plan managers to request reassessment of a participant’s plan or circumstances. QAMH supports removing plan managers from the list of people able to initiate reassessment requests, as this represents a genuine conflict of interest. Support coordinators are not service providers. They do not deliver direct supports to participants and do not benefit financially from a plan increase. Their function is coordination, navigation, and advocacy. Removing them from the reassessment process is not a conflict-of-interest reform. It removes the professional most likely to identify deterioration at the precise moment a participant is least able to advocate for themselves.
Member feedback from across the Queensland community-based mental health sector was consistent on this point. Support coordinators are frequently among the first to identify when a participant is becoming unwell, disengaging from supports, experiencing housing instability, or losing capacity to manage daily life. For many participants living with psychosocial disability, the support coordinator is the only person in the system with both the real-time knowledge of their circumstances and the professional capacity to act on it. As one provider stated, “they are often the professional with the most complete, real-time picture of
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a participant’s changing circumstances and they are frequently the only person in the system with both the knowledge and the capacity to act when a participant is deteriorating.” One large service provider provided direct examples of support workers and coordinators identifying significant deterioration before participants were able to articulate or initiate any formal response themselves.
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Example 1: A worker identified a housing crisis following a move that preceded a significant decline in functioning. The participant was unable to initiate the reassessment process themselves. The involvement of a trusted provider was critical to identifying the change in circumstances and responding appropriately.
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Example 2: A participant was briefly hospitalised and required immediate reassessment upon discharge to restore supports reduced during the admission. The participant could not initiate the process themselves. The involvement of a trusted provider was not supplementary. It was what made the response possible.
These examples illustrate a consistent theme raised during consultation. Participants experiencing deterioration are not always able to recognise, articulate, or act on changing support needs. Blocking this capacity does not strengthen participant autonomy. For people living with episodic psychosocial disability, it removes a safeguard at exactly the moment it is most needed.
The impact of reassessment restrictions will not be uniform across Queensland. Member organisations reported that, in many regional, rural and remote communities, support coordinators play a critical role in maintaining continuity across multiple service systems and helping participants navigate a limited-service landscape. Where provider options are scarce, a support coordinator may be the only person with an overview of a participant’s circumstances and the ability to identify when support needs have changed. Removing their ability to initiate reassessment does not simply transfer that responsibility to another person. The ‘Significant and Ongoing’ Test Beyond the question of who can request a reassessment, the Bill introduces a threshold test under new section 48A that is structurally misapplied to psychosocial disability. Any unscheduled reassessment will only be permitted where there has been a change that is ‘significant and ongoing’ and linked to a substantial reduction in functional capacity or a qualifying change in personal circumstances. Neither ‘significant’ nor ‘ongoing’ is defined in the legislation. For people living with psychosocial disability, this test fails in two distinct directions simultaneously.
Where deterioration is acute and episodic, a participant’s support needs may escalate rapidly in response to a trauma trigger, a housing crisis, a relationship breakdown, or the onset of a mental health episode. The change can be profound and immediate. It is not yet demonstrably ‘ongoing’ at the point when early intervention matters most. By the time the change clearly satisfies the threshold, the window for prevention and early intervention has closed. The participant has either managed the crisis with inadequate supports, or they have escalated to emergency department presentation, hospitalisation, or homelessness. Neither outcome represents what the NDIS is designed to produce.
Where deterioration is gradual and cumulative, a participant whose functioning is slowly eroding over months may well satisfy an ‘ongoing’ test eventually. But this is precisely the kind of quiet, undocumented decline that falls through the cracks of a system that responds
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to crisis rather than preventing it. These participants are unlikely to be able to articulate ‘significant change’ in a form the system will recognise when they need support adjusted, without the support coordinator who can no longer make the request on their behalf.
In both cases the system is pointing people toward crisis rather than away from it. The absence of clear definitions for “significant” and “ongoing” creates uncertainty regarding how the provisions will be applied in practice. For people living with psychosocial disability, this may result in inconsistent decision-making and barriers to timely reassessment when support needs change.
The 90-Day Response Period
The Bill extends the NDIA’s response period for reassessment requests from 21 days to 90 days. Provider feedback consistently indicated that this timeframe is poorly aligned with the episodic and rapidly changing nature of psychosocial disability. Providers described circumstances where participants experienced rapid deterioration following housing instability, hospital discharge, relationship breakdown, or acute mental health episodes. In these situations, timely reassessment is often critical to maintaining stability and preventing escalation.
Reassessment delays also undermine continuity of support for people with complex psychosocial disability. Effective psychosocial support often depends on stable relationships, consistent staffing, and support arrangements that are appropriately matched to a participant’s needs and risk profile. One provider described a participant whose support needs changed over time, eventually culminating in a serious incident requiring emergency intervention. Reflecting on the situation, the provider observed: “A reassessment that recognised the changing risk profile of this participant’s support needs, initiated promptly by a support coordinator with visibility over the situation, might have enabled an earlier and less disruptive response. A 90-day window would have made that response structurally impossible.” Recommendation 6 Support coordinators should retain the ability to initiate reassessment requests for participants with psychosocial disability. Reassessment criteria should explicitly recognise the episodic and fluctuating nature of psychosocial disability, permit reassessment where there is evidence of significant deterioration regardless of whether change is considered ongoing, and the response period should remain at 21 days.
Automated Decision-Making
The Bill enables automated decision-making across a range of administrative functions, including decisions that may affect eligibility, access, reassessment, payments, and funded supports. QAMH supports the appropriate use of automation for routine administrative functions where it improves efficiency and reduces unnecessary administrative burden. However, providers consistently raised concerns about the application of automated decision-making to psychosocial disability. Complex psychosocial presentations do not reduce neatly to algorithmic criteria. Decisions affecting eligibility, access, reassessment, or
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funded supports require human judgement informed by specialist expertise and should not be determined solely through automated processes.
Human Oversight and Review Rights
For participants with psychosocial disability who may already find the NDIS difficult to navigate, automated decisions with limited human review create a significant risk that important decisions will not properly reflect individual circumstances and will be difficult to challenge when they are wrong. Participants must be able to understand how a decision was made, on what basis, and how to effectively challenge it. The participants least likely to successfully challenge an automated decision are often those whose circumstances are most complex and whose needs are most likely to be misunderstood by a standardised system. Automated decision-making in this context also engages Australia’s obligations under the CRPD, including the right to equal recognition before the law and access to fair decision-making processes.
Impacts on Priority Populations
The risks associated with automated decision-making are unlikely to be evenly distributed across the Scheme. They are likely to be amplified for population groups whose circumstances are less visible within standardised assessment processes, including Aboriginal and Torres Strait Islander participants, people from refugee and asylum seeker backgrounds, and people living in regional, rural and remote communities. As Queensland Program of Assistance to Survivors of Torture and Trauma (QPASTT) noted: “Automated systems may not understand trauma, cultural context, interpreter issues, inconsistent documentation or complex psychosocial presentations.” Recommendation 7 Automated decision-making should be restricted to routine administrative functions. Decisions affecting eligibility, access, reassessment, or funded supports must involve human oversight, transparent reasoning, and meaningful review rights, with participants able to access timely human review of any decision affecting their eligibility or supports.
Plan Suspension and Revocation for
Uncontactable Participants
The Bill allows the NDIA to suspend a participant’s plan where reasonable attempts to contact them have been unsuccessful and revoke their participant status after 90 days of no contact. For people living with psychosocial disability, temporary loss of contact is often a manifestation of disability, crisis, trauma, hospitalisation, homelessness, or other forms of vulnerability. The Bill risks treating these circumstances as grounds for suspension or revocation when they are often the clearest indicators that support remains necessary.
Providers described numerous situations where participants became temporarily uncontactable during periods of acute mental ill health. Richmond Fellowship Queensland provided examples of participants experiencing extended hospital stays after losing their phone, car, and housing during a mental health crisis. They also described participants
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experiencing paranoia who refused phones and electronic communication altogether, becoming uncontactable and, in some cases, experienced homelessness for extended periods before receiving treatment. These are not examples of participants no longer requiring support; they are examples of participants whose disability has significantly affected their capacity to maintain contact with services.
This was reinforced by Stepping Stone Clubhouse Incorporated (SSCI). Its peer reviewed evaluation found outreach initiated through calls, texts, and messages was the most frequently accessed service by both new and established members.xi SSCI noted: “the people who become temporarily uncontactable to the NDIA are often the people SSCI is actively trying to maintain contact with, those who are acutely unwell, hospitalised, or withdrawing from all services.” This reflects a fundamental difference between administrative systems and recovery-oriented psychosocial support. Where administrative systems may interpret non-response as disengagement, psychosocial services often view it as a signal that additional outreach and support may be required.
As one large service provider observed, “disability itself should never become grounds for losing access to disability support”. This principle is particularly important in the context of psychosocial disability, where periods of disengagement may be temporary, episodic, and directly related to a person’s disability or circumstances. QPASTT highlighted additional risks for people from refugee and asylum seeker backgrounds, noting that language barriers, trauma, family violence, homelessness, settlement pressures, and immigration-related crises can all contribute to periods where participants become temporarily uncontactable despite continuing to require support. Across provider feedback, the common theme was clear: the circumstances that make someone difficult to contact are often the same circumstances that make support essential. Recommendation 8 Participants should not have their plans suspended or status revoked solely because they are temporarily uncontactable due to disability-related circumstances. The NDIA should be required to consider evidence from providers, carers, and trusted supports before acting, and a formal mechanism should be established for providers to notify the NDIA when a participant is unreachable due to disability-related circumstances.
Impact on Community-Based Providers
The Bill does not consider the cumulative impact of multiple reforms on the viability of community-based organisations delivering psychosocial supports. Many providers already operate in a challenging environment. Independent analysis found that a significant proportion of disability providers are operating at a loss and that current pricing arrangements do not always reflect the true cost of service delivery.xvi,xvii The Bill creates a mechanism that could substantially reduce funding for support categories heavily utilised by people with psychosocial disability, particularly Social, Civic and Community Participation supports. Community-based organisations delivering psychosocial supports today are likely to form a critical part of the future support system. If provider capacity is lost before alternative supports are operational, rebuilding that workforce, infrastructure, and community trust will be difficult and costly.
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Recommendation 9 The Government should assess the cumulative impact of the Bill on the viability of community-based psychosocial support providers before implementation, including the interaction between proposed funding changes, provider sustainability, and the Foundational Supports rollout.
Concluding Statement
QAMH supports the Government’s objective of strengthening the long-term sustainability and integrity of the NDIS. However, reforms intended to improve consistency, sustainability, and value must also reflect the realities of psychosocial disability and the systems that support people living with it.
Across the provisions examined in this submission, a consistent theme emerges. Many of the proposed changes assume the existence of alternative supports, stable support networks, and service system capacity that do not currently exist in many communities. For people living with psychosocial disability, the risk is not simply that individual provisions may create barriers. It is that the combined effect of these reforms may reduce access to support before appropriate alternatives are available. Community-based supports are often the factors that keep people connected to their communities and out of more intensive and costly service systems.
QAMH urges the Government to ensure that implementation of the Bill is accompanied by appropriate safeguards, genuine co-design with people with lived and living experience, and careful consideration of the practical impacts on people with psychosocial disability, their families and carers, and the community-based organisations that support them. The success of these reforms will depend not only on the legislative changes themselves, but on whether the broader support system is ready to support those affected by them.
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i Department of the Prime Minister and Cabinet. (2023). Working together to deliver the NDIS: Independent Review into the National Disability Insurance Scheme final report. Australian Government. https://www.ndisreview.gov.au/resources/reports/working-together-deliver-ndis ii National Disability Insurance Agency. (2025). Quarterly report Q2 2025–26. Australian Government. https://www.ndis.gov.au/about-us/publications/quarterly-reports iii Access Denied Inc. (2025). APA report access denied 2024–25 iv Australian Institute of Health and Welfare. Mental Health serves in Australia Expenditure Series, Table EXP.6 (constant prices). AIHW v Health Policy Analysis. (2024). Analysis of unmet need for psychosocial supports outside of the
National Disability Insurance Scheme. Department of Health and Aged Care
vi Purcal, C., O’Shea, P., Giuntoli, G., Zmudzki, F., & Fisher, K. R. (2022). Evaluation of NSW community-based mental health programs: Community Living Supports and Housing and
Accommodation Support Initiative (CLS-HASI) evaluation report. Social Policy Research Centre,
UNSW Sydney. vii Flatau, P., Kaleveld, L., Callis, Z., & Kuppers, D. (2026). Capturing the economic value of psychosocial support: A discussion paper. Summary of findings. Centre for Social Impact, University of Western Australia. viii Queensland Alliance for Mental Health. (2025). Distance apart, community at heart: 2025 regional, rural and remote roadshow report. Queensland Alliance for Mental Health. ix Australian Government. (2026). National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026: Explanatory memorandum. Parliament of Australia. x Australian Government. (2026). National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026: Explanatory memorandum. Parliament of Australia. xi Fjeldsoe, B. S., Vitangcol, K., Lamerton, T., Sennett, M., Helton, D., Hardy, F., Wyder, M., Cunningham, Z., McGrath, M. O., Roseby, M., McLean, A., Brown, S., & Lawler, S. (2025). The Stepping Stone Clubhouse evaluation: Exploring members’ experiences, service engagement, and perceived impact of the Clubhouse International model. Community Mental Health Journal, 61, 382
xii Australian Government Department of Health, Disability and Ageing. (2026). National Disability
Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026: Explanatory
memorandum. Parliament of Australia. xiii Momen, N. C., Plana-Ripoll, O., Agerbo, E., Christensen, M. K., Iburg, K. M., Laursen, T. M., Mortensen, P. B., Pedersen, C. B., Prior, A., Weye, N., & McGrath, J. J. (2022). Mortality associated with mental disorders and comorbid general medical conditions. JAMA Psychiatry, 79(5), 444–453. https://doi.org/10.1001/jamapsychiatry.2022.0347 xiv Arafmi Ltd. (2024). At what cost? The experiences of unpaid mental health carers in Queensland 2023–2024. Arafmi Ltd. https://arafmi.com.au/ xv Warren, D., & Edwards, B. (2025). Young carers: Impacts of caring on children’s learning and wellbeing. Australian Institute of Family Studies. https://aifs.gov.au/ xvi Ability Roundtable. (2024). IHACPA consultation: NDIS pricing reform opportunities. Ability Roundtable. xvii Independent Health and Aged Care Pricing Authority. (2025). A fresh approach to NDIS pricing: Exploring opportunities for pricing reform. A snapshot of what we’ve heard. IHACPA.
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