Submission Regarding Proposed NDIS
Reforms
“Freyr” (De-identified): A Homeless Wuthathi Woman with Lifelong Complex Disability Support Needs — A Case Study Demonstrating the Failure of Current and
Proposed NDIS Systems to Protect Vulnerable First
Nations Participants
Submitted by:
Danielle (Dee) Maree Hill
Director — Deaf Plus Australia Pty Ltd
Owner / Primary Support — Slow Down Rose
June 2026
Introduction
I write this submission as a disability advocate, support provider, Auslan user, and Director of Deaf Plus Australia Pty Ltd, an organisation supporting Deaf, neurodivergent, psychosocial, trauma-affected, and high-support-needs participants across Australia.
This submission is made in response to the proposed NDIS reforms and the increasing concerns being experienced across the disability sector regarding:
- reduction in practical participant supports,
- erosion of Support Coordination,
- increased administrative gatekeeping,
- failures within Home and Living pathways,
- culturally unsafe planning practices,
- and increasing reliance on guardianship systems where disability systems fail. The following de-identified case study demonstrates the real-world consequences already occurring under the current system for vulnerable participants with lifelong complex disability support needs.
It raises serious concerns regarding how proposed reforms may further disadvantage First Nations participants living with permanent disability, homelessness, communication vulnerability, trauma histories, and cultural disconnection.
Case Study: “Freyr” (De-identified)
A Proud Wuthathi Woman Living with Lifelong Complex
Disability
“Freyr” is a young Aboriginal woman of the Wuthathi People of Cape York living with a lifelong genetic disability resulting in permanent and complex high support needs across:
- daily functioning,
- emotional regulation,
- independence,
- communication,
- social participation,
- decision-making,
- and community living. Freyr’s disability is lifelong.
It is not a condition from which she will recover.
Her support needs are permanent, substantial, and require ongoing disability-specific supports and safeguarding systems to safely sustain her within the community.
At the time of writing, Freyr is homeless.
She is currently being cared for solely by her mother within temporary accommodation arrangements after the collapse of formal disability support pathways and the failure of systems to provide operational supports repeatedly identified as necessary within professional reports and Occupational Therapy recommendations.
Transparency of Disability Need Without
Equivalent Support Delivery
Freyr’s support needs have been extensively documented across:
-
Functional Capacity Reports,
-
Occupational Therapy assessments,
-
safeguarding discussions,
-
Support Coordination records,
-
and Home and Living recommendations. Professional recommendations consistently identified the need for:
-
disability-specific accommodation,
-
structured supported living pathways,
-
gradual transition supports,
-
relationship-based support models,
-
increased daily living assistance,
-
emotional regulation support,
-
culturally safe service provision,
- familiar and consistent support workers,
- and carefully managed transition planning. Importantly, these recommendations acknowledged Freyr’s disability as lifelong and permanent.
The supports identified were not temporary therapeutic interventions aimed at “recovery.”
They were essential disability supports required to sustain:
- safety,
- emotional stability,
- participation,
- communication,
- cultural connection,
- and quality of life. Despite this transparency of disability need, the funding and practical implementation of supports failed to align with the recommendations repeatedly identified by qualified professionals.
This represents a growing systemic issue across the disability sector: participants undergo extensive assessment processes, reports clearly identify support requirements, Occupational Therapists outline necessary supports — yet the resulting funding does not operationalise those recommendations into practical service delivery.
In Freyr’s case, this resulted in:
- no disability-specific accommodation,
- no funded transition pathway,
- no culturally safe housing solution,
- no funded educational “buddy shifts,”
- and no stable support infrastructure despite repeated evidence of need. Homelessness and Failure of Disability
Housing Pathways
Freyr currently remains homeless despite extensive professional evidence demonstrating her inability to safely transition into unsupported or inappropriate accommodation environments.
No funded or operational pathway has been established to provide:
- stable supported accommodation,
- culturally safe disability housing,
- transition staffing,
- or gradual relational support models required to safely introduce new support workers and environments.
Instead, Freyr and her mother have effectively been left managing homelessness within temporary accommodation arrangements while systems continue to review, assess, and administratively respond without implementing practical supports.
This reflects a broader systemic failure within disability housing pathways for participants whose needs are:
- culturally complex,
- trauma-informed,
- communication-sensitive,
- and heavily reliant upon trusted relationships.
Guardianship Intervention Following
Support System Failure
Historically, Freyr’s mother acted as her:
- primary safeguard,
- advocate,
- support person,
- and relational anchor. As formal systems became increasingly inadequate and Support Coordination funding exhausted, rather than strengthening family-led safeguarding arrangements with practical funded supports, an application was made to the Office of the Public Guardian Queensland seeking intervention into the mother’s decision-making role.
This occurred while:
- Freyr remained homeless,
- disability accommodation remained unavailable,
- no equivalent safeguarding structure existed,
- and no culturally safe alternatives had been implemented. The practical effect is that the family most actively sustaining Freyr’s safety became subject to scrutiny and statutory intervention while the underlying disability support failures remained unresolved.
This raises serious concerns regarding the increasing use of guardianship systems where disability service systems fail to provide practical operational support.
Failure to Recognise Connection to
Country and Cultural Safety
Freyr is a proud First Nations woman of the Wuthathi People of Cape York.
Despite this, there has been minimal meaningful recognition throughout planning and safeguarding processes that:
- connection to Country,
- kinship systems,
- trusted family relationships,
- cultural continuity,
- and Aboriginal self-determination are critical protective factors for Aboriginal participants living with disability.
Current systems continue to assess support needs through predominantly administrative and clinical frameworks while failing to adequately integrate cultural safety into:
- housing decisions,
- safeguarding responses,
- guardianship processes,
- and Home and Living pathways. For participants like Freyr, cultural disconnection is not simply emotional harm.
It directly affects:
- emotional regulation,
- communication safety,
- identity,
- behavioural stability,
- trust in services,
- and long-term wellbeing. The removal or destabilisation of trusted relationships without equivalent culturally safe supports can itself become a safeguarding risk.
Failure of Transitional Support Models
A significant issue in Freyr’s circumstances has been the lack of provider willingness to facilitate gradual educational “buddy shifts” to support safe transition into future supported living arrangements.
These supports would allow Freyr to:
-
gradually build trust with support workers,
-
develop routine familiarity,
-
strengthen communication consistency,
-
reduce emotional distress,
-
and safely adapt to new environments. For participants living with lifelong complex disability support needs, abrupt placement transitions can significantly increase risks of:
-
retraumatisation,
-
emotional dysregulation,
-
behavioural escalation,
-
service refusal,
- placement breakdown,
- restrictive practice escalation,
- and institutional trauma. Despite these risks being clinically well understood, flexible transition funding and provider willingness to implement these models remains extremely limited.
Concerns Regarding Proposed NDIS
Reforms
Freyr’s case raises serious concerns regarding whether current and proposed NDIS reforms are capable of adequately protecting highly vulnerable First Nations participants living with lifelong complex disability support needs.
The current issue facing participants like Freyr is not over-servicing.
It is under-implementation of clearly identified disability supports.
The repeated commissioning of reports, assessments, safeguarding meetings, and Functional Capacity Reports becomes meaningless if participants cannot access the practical supports those reports recommend.
There is growing concern across the disability sector that proposed reforms may further disadvantage participants already struggling to access essential supports by:
-
reducing flexibility,
-
narrowing access pathways,
-
diminishing Support Coordination,
-
increasing administrative gatekeeping,
-
centralising decision-making,
-
restricting participant autonomy,
-
and increasing reliance on statutory intervention where disability supports fail. For First Nations participants, these failures risk replicating broader historical patterns involving:
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removal of decision-making,
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erosion of family authority,
-
cultural disconnection,
-
and institutional control over vulnerable Aboriginal people.
Recommendations
Freyr’s case highlights the urgent need for:
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Funding models that accurately reflect lifelong complex disability support needs.
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Practical implementation of Occupational Therapy and Functional Capacity recommendations.
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Culturally safe Home and Living pathways for Aboriginal and Torres Strait Islander participants.
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Recognition of connection to Country within NDIS planning and safeguarding processes.
-
Flexible transition funding for educational “buddy shifts” and relationship-based transition supports.
-
Strengthened independent advocacy and Support Coordination protections.
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Preservation of trusted informal safeguarding relationships wherever safe and appropriate.
-
Trauma-informed and culturally informed guardianship responses.
-
National review of disability homelessness pathways for participants with complex support needs.
-
Direct consultation with First Nations participants and Aboriginal disability organisations regarding all future NDIS reforms.
Conclusion
Freyr’s story is not an isolated case.
It reflects a growing national failure to adequately protect vulnerable First Nations participants living with lifelong disability under systems increasingly driven by administrative containment rather than human need.
At present, a proud Wuthathi woman with lifelong complex disability support needs remains homeless, without disability-specific accommodation, without practical implementation of professional recommendations, and reliant entirely upon her mother within temporary accommodation arrangements to maintain her safety and survival.
This should not be occurring within Australia’s disability support system.
Without substantial reform toward culturally safe, participant-led, relationally informed support systems, participants like Freyr will continue to fall through the gaps between:
- disability systems,
- housing systems,
- guardianship systems,
- and safeguarding systems. The proposed NDIS reforms risk widening those gaps further.
Submitted respectfully,
Please contact me directly for more information and if in fact there are any avenues for support, representation, long term NDIS Planning or Escalation options.
Dee
Dee Hill - Director DeafPlus Australia
Owner/Primary - Slow Down Rose
All Ability Support
Auslan FaceTime & WhatsApp
Phone:
ABN: 2851813988
Slow Down Rose acknowledges and pays respect to the Bunurong People Traditional Custodians of the Australian lands on which we work and live Slow Down Rose acknowledges and respects the members of the Deaf Community in Australia, who preserve their rich heritage, culture and our language; Auslan (Australian Sign Language) Sign Language People (SLP) We also acknowledge our custodians of Auslan, promoting awareness, equality and access through our sign language - Through Auslan, we inspire future leaders in our deaf community to continue our legacy and heritage