Ensuring Reform is Ready, Accountable and Safe (DRO advocacy)

Submission 429

AUSTRALIAN

Autism Alliance

Australian Autism Alliance

Submission to the Senate Community Affairs

Legislation Committee

Inquiry into the National Disability Insurance

Scheme Amendment (Securing the NDIS for

Future Generations) Bill 2026

Systems That Work:

Ensuring Reform is Ready, Accountable and Safe

Submitted by: Australian Autism Alliance

Contact: Jenny Karavolos, Chair, Australian Autism Alliance

www.australianautismalliance.org.au Date: 01/06/2026

Generations) Bill 2026

Submission 429

AUSTRALIAN

Autism Alliance

Acknowledgements

We acknowledge the First Nations and Traditional Owners of the land, sea and waterways and pay respects to Elders past, and present and recognise those whose ongoing effort to protect and promote Aboriginal and Torres Strait Islander cultures will leave a lasting legacy for future Elders and leaders. We recognise the enduring connection that First Nations peoples have to land, waters, culture, and community. This land was, is, and always will be Aboriginal land.

We acknowledge the Individual and collective expertise of those with a living or lived experience of disability, as well as the lived experience of people who have been carers. We recognise their vital contribution at all levels and value the courage of those who share their unique perspective for the purpose of learning and growing together to achieve better outcomes for all.

Generations) Bill 2026

Submission 429

AUSTRALIAN

Autism Alliance

Acknowledgements ………………………………………………………………………………………………………………………. 2 About the Australian Autism Alliance …………………………………………………………………………………………….. 4 1 Executive Summary ………………………………………………………………………………………………………. 5 2 Summary of Recommendations and Assessment of the Bill ………………………………………………… 8 3 The Alliance Supports Reform BUT ……………………………………………………………………………….. 11

4 The Alliance’s Position Which Has Remained Consistent (2024 Inquiry) …………………………….. 12

5 Potential Impacts for Autistic People and their Families ……………………………………………………. 15 6 Systems That Work: The Foundation for Reform ……………………………………………………………… 17 7 Cumulative Impact Lens ………………………………………………………………………………………………. 17

Lessons from Previous Reforms …………………………………………………………………………………… 19 9 Sustainability Must Include Outcomes ……………………………………………………………………………. 23 10 Reform Must Remain Anchored in Principles ………………………………………………………………….. 25 11 Consistency with the Independent NDIS Review ……………………………………………………………… 26 12 Conclusion …………………………………………………………………………………………………………………. 27 Attachment A – Detailed Legislative Analysis and Autism-Specific Safeguards ………………………….. 30 Attachment B – Systems That Work Readiness Index ……………………………………………………………. 41 Attachment C – Systems That Work Accountability Index ……………………………………………………….. 42 Attachment D – Comparative Lessons from the Disability Royal Commission, NDIS Review and Veterans Affairs Reform …………………………………………………………………………………………………….. 43

Generations) Bill 2026

Submission 429

AUS TR AL I A N

Autism Alliance

About the Australian Autism Alliance

www.australianautismalliance.org.au

The Australian Autism Alliance (the Alliance) is a funded national peak body Disability Representative Organisation (ORO) providing a Strong Unifying Voice for Autism, and authoritative policy expertise on autism working with Australian government at all levels to strengthen policy and service systems affecting Autistic Australians. Established in 2016, the Alliance works to improve the life chances of Autistic people and strengthen collaboration across the Australian autism community.

The Alliance contributes futures-focused adviser expertise to a range of national advisory and reform processes, including DHDA Disability Representative Organisation program, the NOIA

Autism Advisory Group, the NOIA DRCO Co-Design Advisory and Reform groups, NDIS

Commission Disability Sector Consultative group, the National Autism Strategy Oversight

Council, and National Health and Mental Health Roadmap for Autistic people. The Alliance is focused on system design solutions that enable disability systems to respond effectively to the diversity of Autistic support needs - “Change the System, Not the Person”.

Our membership represents a cohesive national network of key organisations with a diverse focus on autism - that is led by Autistic people, advocacy groups, peak bodies, service providers, and researchers. Together, this network provides a platform for the diversity of Autistic perspectives and lived experience across Australia. Through our members and communication channels, the Alliance reaches more than half a million people and supports Autistic people and their families across the lifespan. Most importantly, our work is informed by Autistic people and the Australian autism community.

Submission 429

AU STRA LIAN

Autism Alliance

1 Executive Summary

The Australian Autism Alliance (the Alliance) welcomes the opportunity to provide this submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

The Alliance supports reform of the National Disability Insurance Scheme. We support long-term sustainability, stronger mainstream systems, effective foundational supports, action against fraud and exploitation, and reforms that improve outcomes for people with disability.

However, the Alliance does not support progression of the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 in its current form or proposed implementation timeframe.

Our concern is not whether reform should occur.

Our concern is whether Parliament can be confident that the systems required for reform are ready, accountable and capable of delivering better outcomes.

The Alliance has consistently advocated for systems that work.

Systems that work are not built after people are expected to rely on them. They are built first.

The Bill proposes significant legislative change while many of the systems upon which those reforms depend remain under development, untested, unavailable or subject to future negotiation. Foundational supports are not yet operational, mainstream responsibilities remain unresolved, assessment methodologies have not been finalised or independently validated, and the oversight, accountability and harm-monitoring mechanisms needed to identify and respond to emerging problems have not been clearly established.

The Alliance’s position is informed by the Disability Royal Commission, the Independent NDIS Review, the National Autism Strategy, previous NDIS reform processes and lessons arising from the Government’s response to the Royal Commission into Defence and Veteran Suicide. These reviews and inquiries identified remarkably similar systemic risks including fragmentation, poor coordination, inadequate accountability, delayed responses to harm and people falling through gaps between systems.

The Alliance is concerned that equivalent implementation architecture has not been clearly established for disability reform despite reforms of similar scale and complexity now being proposed through this Bill. This raises a fundamental question:

Why are disability reforms proceeding without people with disability being afforded equivalent implementation and accountability architecture that Government itself considered necessary for Veterans Affairs reform, particularly when the Disability Royal Commission identified many of the same systemic risks? 5 © 2026 Australian Autism Alliance: Submission to Inquiry to National Disability Insurance Scheme Amendment (Securing the NDIS

Submission 429

AUSTRALIAN

Autism Alliance

The Alliance notes that Government recognised these risks in Veterans Affairs reform and responded by establishing implementation oversight, monitoring arrangements, escalation pathways and accountability mechanisms.

The Alliance’s position is simple:

Oversight should precede reliance.

Government should not ask people with disability to depend upon reformed systems before accountability arrangements, escalation pathways, harm monitoring, public reporting and independent oversight are in place.

The Alliance is also concerned that discussion of sustainability has become heavily focused on expenditure without equivalent consideration of outcomes.

A sustainable system is not simply one that spends less.

The Alliance believes sustainability and good outcomes are not competing objectives. A sustainable system is one that prevents future costs, increases participation, strengthens families and communities, and enables people to contribute.

The question is not only what support costs today.

It is also what Australia pays tomorrow if support is withdrawn too early.

For Autistic people, delayed access to support can reduce educational participation, employment opportunities, independence, mental health and long-term life outcomes. Early support should be viewed as an investment in future participation and contribution, not a cost to be deferred.

Sustainable reform should therefore focus not only on controlling expenditure, but also on reducing avoidable future costs arising from crisis intervention, hospitalisation, homelessness, family breakdown, workforce exclusion and unmet need.

Sustainability matters for people with disability, for families and carers, and for the economy.

So, the Alliance believes this Bill is about more than legislative reform.

It is about what kind of country Australia wants to be.

The NDIS was established because Australians believed that people with disability should not be excluded from opportunity, participation and community life simply because they require support.

The Alliance supports sustainable reform. However, reform should proceed only when Parliament can be satisfied that systems are ready, safeguards are in place, accountability is clear and people with disability will not bear the consequences if assumptions underpinning reform prove incorrect.

Submission 429

AUSTRALIAN

Autism Alliance

If systems are not ready, reform is not ready.

Success should not be measured by how many people leave the NDIS.

Success should be measured by whether people experience better lives afterwards.

Detailed autism-specific legislative analysis, identified risks, proposed safeguards and recommended amendments are contained in Attachment A.

Submission 429

AU ST RA L IA N

Autism Alliance

2 Summary of Recommendations and Assessment of the Bill The Australian Autism Alliance supports reform, sustainability, stronger mainstream systems and the establishment of foundational supports.

However, the Alliance does not support progression of the Bill in its current form and timeframe.

The recommendations below are intended to ensure reforms are implemented in a manner that is safe, accountable, evidence-based and capable of delivering better outcomes for people with disability, their families and carers.

21S       fR        d  f

Rec  Recommendation   Summary                            Section in

No   Topic                                                Submission

Major reforms should not proceed until Section 4; Attachment B Government can demonstrate that replacement (Readiness Index) systems, foundational supports, workforce

capability, No-Gap Transition Guarantee and        Readiness Before R1                               implementation arrangements are operational         Reliance                                and capable of meeting need. Government

should also publicly identify the criteria by which reform readiness, success and participant outcomes will be measured.

Parliament should not approve broad enabling     Section 5; Attachment A         Parliament Should Not                                powers where the operational detail, safeguards, R2    Approve Undefined                                   implementation arrangements and accountability         Future Powers                              mechanisms have not yet been demonstrated.

Ensure reforms reflect contemporary autism Section 6; Attachment A

evidence, recognise the diversity of Autistic         Autism-Informed Design R3                              experience and support timely access to        and Implementation                                            disability supports that improve long-term

outcomes Autistic people, families and autism Section 6

Autism Co-Design and      representative organisations should be actively R4        Shared Accountability       involved in the design, implementation,

monitorina and evaluation of reforms. Government should demonstrate that reforms Sections 4 & 8;

Demonstrate Readiness    meet the Alliance's Systems That Work           Attachments B & C RS        and Accountability         Readiness and Accountability Tests before

implementation proceeds. Major disability reforms should be assessed Section 7; Attachment A

cumulatively rather than in isolation, including     Table A        Cumulative Impact R6                              impacts across health, education, housing,        Assessment                                employment, community supports and family

caoacitv. The Committee should have regard to the Section 7; Attachment A

legislative concerns including autism-specific,          Legislative Safeguards R7                                      risks, safeguards and proposed amendments        and Amendments                                   contained in Attachment A and recommend

Submission 429

AU ST RA L IA N

Autism Alliance

Rec  Recommendation   Summary                            Section in

No   Topic                                                Submission

provisions accordingly. This includes Broad Ministerial powers relating to support determinations and caps be removed or sianificantlv amended. No functional capacity assessment framework Section 7; Attachment A should be implemented until methodology,

Functional Capacity        safeguards, validation, workforce capability and RS        Framework Safeguards     autism-specific impacts have been

independently assessed and publicly scrutinised. Government should establish an independent Section 8; Attachment C disability reform implementation and oversight &D architecture, including public reporting, harm

Oversight Before R9                                  monitoring, escalation pathways, independent         Reliance                                     oversight and accountability for outcomes before

major reforms commence.

Government should publicly release the Section 9; Attachment A evidence, modelling, assumptions and impact Table D analysis underpinning projected savings and

reform outcomes. Reforms should be evaluated          Sustainability Must R10                               not only against expenditure reductions but also         Include Outcomes

against participant outcomes, workforce participation, wellbeing, cost avoidance and long-term social and economic impacts.

Reforms should preserve and strengthen Section 10

person-centred approaches, trauma-informed        Preserve Disability Rights R11                                   practice, supported decision-making,          Principles                                          participation, inclusion, dignity of risk, choice

and control. Government should not selectively implement Section 11 ; Attachment elements of the NDIS Review while omitting the D safeguards, navigation functions, transition Implement the NDIS protections, accountability mechanisms and

R12   Review as a Complete      supporting infrastructure that accompanied

Reform Package those reforms.

Table 1: Recommendation Summary Table

The Alliance’s recommendations are informed by lessons arising from the Disability Royal

Commission, the Independent NDIS Review, the National Autism Strategy, previous NDIS reform

processes and the Government’s response to the Royal Commission into Defence and Veteran Suicide.

Submission 429

AUS T RAL IA N

Autism Alliance

Taken together, these recommendations reflect a simple principle:

Readiness should precede reliance. Oversight should precede reliance. Reform should improve outcomes before it reduces supports.

Supporting Analysis:

Attachment A: Detailed autism-specific legislative analysis.
Attachment B: The Systems That Work Readiness Index.
Attachment C: The Systems That Work Accountability Index.
Attachment D: Comparative lessons from the Disability Royal Commission, Independent NDIS Review, National Autism Strategy and Veterans Reform.

2.2 Summary of the Alliance’s Assessment of the Bill The Alliance has assessed the Bill against the principles outlined throughout this submission, including the Systems That Work Readiness Index (Attachment C), the Systems That Work Accountability Index (Attachment D), lessons arising from the Disability Royal Commission, the Independent NDIS Review, the National Autism Strategy and the Government’s response to the Royal Commission into Defence and Veteran Suicide.

The Alliance’s assessment is summarised below.

No   Alliance Assessment                          Conclusion

1    Reform required                             Yes

2     Sustainability required                        Yes

3    Stronger mainstream systems required           Yes

4    Foundational supports required                 Yes

5      Bill appropriate in current form                 No

6    Systems demonstrably ready                     Not demonstrated

7    Accountability demonstrated                      Not demonstrated

8    Oversight architecture established                 Not demonstrated

9    No-gap protections demonstrated                  Not demonstrated

10   Functional assessment framework validated         Not demonstrated

11   Autism-specific safeguards established             Not demonstrated

12   Family capacity impacts assessed                 Not demonstrated

13   Cumulative impacts assessed                     Not demonstrated

The Alliance’s position is therefore not whether reform should occur.

The question is whether Parliament can be confident that the systems, safeguards, accountability arrangements and implementation architecture required for reform are in place.

The Alliance’s assessment is that this has not yet been demonstrated.

Submission 429

AUSTRALIAN

Autism Alliance

3 The Alliance Supports Reform BUT

The Alliance supports reform.

We support:

long-term sustainability of the NDIS;
strengthened scheme integrity;
stronger mainstream systems;
establishment of foundational supports;
improved participant experiences and outcomes;
greater transparency and consistency; and
addressing through action against fraud, exploitation and poor-quality practice. The Alliance has consistently supported reforms that are:
evidence-based;
appropriately safeguarded;
independently evaluated;
guarantees no participant loses supports, transition protections or funding before replacement systems are operational, accessible, accountable and capable of meeting need; and
implemented within systems capable of delivering their intended outcomes. We have equally and consistently opposed reforms that remove supports based upon assumptions that replacement systems will exist or function effectively at some future point or transfer risk to people with disability, families and carers before replacement systems, safeguards and accountability mechanisms are demonstrably in place.

The issue before Parliament is therefore not whether reform should occur.

The issue is whether the systems required for reform are demonstrably ready.

The Alliance is simply asking Parliament to apply the same principles of readiness, oversight, accountability and harm monitoring that Government has recognised as necessary in other major reform programs.

Reform should improve outcomes.

Reform should not rely on assumptions that systems will work. It should demonstrate that they do.

Recommendation 1 – Readiness Before Reliance

Government should demonstrate that the systems required to support the proposed reforms are operational, accountable and capable of delivering their intended outcomes before participants are expected to rely upon them.

Submission 429

AUSTRALIAN

Autism Alliance

This should include demonstrated readiness across foundational supports, mainstream interfaces, implementation oversight, accountability arrangements, workforce capacity, No-Gap Transition Guarantee, continuity-of-support protections and harm-monitoring mechanisms. Government should also publicly identify the criteria by which reform readiness, success and participant outcomes will be measured.

Hence the Bill should not proceed in its current form or proposed implementation timeframe.

4 The Alliance’s Position Which Has Remained Consistent

(2024 Inquiry)

The Alliance does not support progression of the Bill in its current form.

Some provisions may be capable of amendment and improvement. However, several elements are unacceptable as they are fundamentally problematic, including:

broad Ministerial powers;
support determination and support-capping powers;
reliance on systems that are not yet operational;
unresolved functional assessment architecture;
inadequate accountability arrangements;
insufficient continuity protections.

4.1 Specific Legislative Concerns

The Alliance’s detailed legislative analysis is in Attachment A.

The Alliance categorises provisions as:

Unacceptable in Current Form

Broad Ministerial support reduction powers.
Unsupported functional assessment architecture.
Non-reviewable plan renewal arrangements.
Reliance upon theoretical mainstream availability without demonstrated readiness.

Requiring Significant Amendment

Reassessment restrictions.
“Directly arising” support tests.
Family responsibility provisions.
Automated decision-making provisions.
Suspension and revocation powers.

Potentially Supportable with Safeguards

Fraud measures.
High-risk provider regulation.
Pricing transparency. 12 © 2026 Australian Autism Alliance: Submission to Inquiry to National Disability Insurance Scheme Amendment (Securing the NDIS

Submission 429

AUS T RAL IA N

Autism Alliance

Conflict-of-interest reforms. 4.2 Cross-cutting themes across all schedules These are the major overarching concerns that cut across the entire Bill.

No enforceable safeguard against worsening No-harm protections absent outcomes S stem readiness not demonstrated Controls increasingly placed on disabled Participant restriction vs system reform people

Cost shifting to families Increased unpaid care burden Administrative attrition Shift from participation to expenditure Sustainability reframing mana ement

Analysis, risk assessment and proposed safeguards are outlined in Attachment A.

The Alliance notes that many of the concerns raised in this submission are not new.

During consideration of the previous NDIS Amendment legislation, the Alliance cautioned Parliament against approving broad legislative powers where the operational detail, safeguards and implementation arrangements had not yet been developed.

The Alliance’s concern was not dependent on which Government exercised those powers.

Rather, the concern was that Parliament should not be asked to approve broad future powers without knowing:

how those powers would operate;
what safeguards would apply;
how impacts would be monitored;
how participants would be protected; and
how unintended consequences would be identified and addressed. The Alliance remains concerned that Parliament is again being asked to approve significant enabling powers before the systems, safeguards and accountability arrangements required for their safe implementation have been demonstrated.

Recommendation 2 - Parliament Should Not Approve Undefined Future Powers

Parliament should not approve broad future powers before the detail is known.

Submission 429

AUSTRALIAN

Autism Alliance

The Bill should not confer broad enabling powers where the operational framework, safeguards, implementation arrangements, monitoring mechanisms and accountability requirements have not yet been developed, publicly released and subject to consultation and parliamentary scrutiny. Parliament should only be asked to approve powers where it is able to understand how those powers will operate, how participants will be protected, how impacts will be monitored and how unintended consequences will be identified and addressed

Submission 429

AUSTRALIAN

Autism Alliance

5 Potential Impacts for Autistic People and their Families

Autistic people may be particularly affected by several aspects of the proposed reforms.

Autism is a lifelong neurodevelopmental condition. Support needs are often influenced not only by an individual’s intrinsic capacity but also by environmental factors, support scaffolding, communication demands, sensory impacts, co-occurring conditions and life transitions.

The Alliance is concerned that reforms which rely heavily on functional assessments, standardised decision-making or assumptions regarding family and community capacity may fail to adequately recognise the complexity and variability of Autistic people’s support needs.

Particular areas of concern include:

lifelong nature of autism
functional assessment methodologies;
masking and camouflaging behaviours;
fluctuating support needs over time;
executive functioning impacts;
communication differences;
assumptions regarding family capacity and informal supports;
access to developmental and capacity-building supports;
interactions between autism and mental health;
transitions across education, employment and adulthood;
community participation and social inclusion;
co-occurring conditions; and
the cumulative impacts of disadvantage across a person’s life. The Alliance is particularly concerned that support needs may be underestimated where assessments fail to adequately consider environmental context, support scaffolding, masking, cumulative impacts across a person’s life.

The Alliance is further concerned that proposed functional assessment arrangements appear to separate functioning from environmental context. Contemporary disability frameworks, including

the World Health Organisation International Classification of Functioning, Disability and Health

Submission 429

AUSTRALIAN

Autism Alliance

(ICF), recognise that disability and functioning occur through the interaction between impairments, environmental factors, supports and personal circumstances.

For many Autistic people, functioning varies significantly according to sensory environments, communication supports, executive functioning demands, support scaffolding, familiarity of settings, Autistic burnout and masking. Assessing functioning in isolation from these factors risks systematically underestimating support needs and producing outcomes inconsistent with real world functioning.

Early Intervention, Development and Access to Supports

Furthermore, the Alliance is concerned by any approach that would require Autistic people or their families to exhaust treatment options, mainstream services, educational interventions or informal supports before disability supports become available.

Autism is a lifelong neurodevelopmental condition, not a condition that should be viewed through a treatment-failure model.

The evidence consistently demonstrates that timely access to appropriate supports, accommodations and developmental interventions improves participation, independence, wellbeing, educational outcomes and long-term life opportunities.

Conversely, delays in access to support can contribute to escalating needs, family stress, educational disengagement, mental ill-health, social isolation and future reliance on more intensive and costly interventions.

The Alliance supports approaches that provide support at the point of need rather than requiring individuals and families to demonstrate that all other options have first been exhausted.

Early support should be viewed as an investment in future participation and outcomes, not as a cost to be deferred.

The Alliance’s detailed autism-specific legislative analysis and recommended safeguards are contained in Attachment A.

Recommendation 3 – Autism-Informed Design and Implementation Government should ensure that all assessment methodologies, support determination processes, implementation arrangements and transition pathways associated with the reforms are informed by contemporary autism evidence and expertise.

This should include recognition of masking, executive functioning, communication differences, sensory needs, fluctuating support needs, co-occurring conditions and developmental support needs.

People should not be required to exhaust treatment options, mainstream services, educational interventions or informal supports before accessing disability supports where evidence demonstrates that timely support improves long-term participation, independence and wellbeing outcomes. 16 © 2026 Australian Autism Alliance: Submission to Inquiry to National Disability Insurance Scheme Amendment (Securing the NDIS

Submission 429

AUSTRALIAN

Autism Alliance

Recommendation 4 – Autism Co-Design and Shared Accountability Autistic people, families and autism representative organisations should be actively involved in the design, implementation, oversight, monitoring and evaluation of reforms.

This involvement should extend beyond consultation and include ongoing participation in governance, implementation oversight, evaluation and continuous improvement processes. Reforms affecting Autistic people should not be designed for the autism community. They should be designed with the autism community.

6 Systems That Work: The Foundation for Reform

The Alliance has consistently advocated for systems that work.

The Alliance is concerned that discussion surrounding reform is increasingly focused on expenditure, efficiency and financial sustainability.

These considerations are important.

However, the question should not simply be whether systems are financially sustainable.

A system is successful when people experience improved outcomes, greater autonomy, meaningful participation and genuine choice and control.

Most importantly: Systems that work are built before people are expected to rely on them.

To assist Government and Parliament assess whether reforms are ready and accountable, the Alliance has developed:

the Systems That Work Readiness Index (Attachment B); and
the Systems That Work Accountability Index (Attachment C). The Alliance submits that reforms should demonstrate readiness and accountability before implementation, rather than relying on assumptions that systems will operate as intended

Recommendation 5 – Demonstrate Readiness and Accountability Government should demonstrate that the proposed reforms satisfy the Alliance Systems That

Work Readiness Index and Alliance Systems That Work Accountability Index before

implementation.

7 Cumulative Impact Lens

The Alliance is concerned that the reforms proposed within this Bill continue to be assessed largely in isolation.

Submission 429

AUSTRALIAN

Autism Alliance

People do not experience reforms in isolation.

Autistic people and their families experience the interaction between:

NDIS reforms;
health systems;
education systems;
housing systems;
mental health services;
employment systems;
family capacity;
community supports; and
broader economic pressures. Participants may also experience the combined effects of multiple reform measures including functional assessments, reassessments, support determinations, foundational supports, workforce shortages and changing family circumstances.

The cumulative effect of these changes may be significantly different from the effect of any individual measure considered in isolation.

The Alliance is concerned that cumulative impacts have not been adequately assessed.

Major disability reform should be assessed not only by the impact of individual measures but also by their combined effect on people with disability, families, carers and communities.

Recommendation 6 – Cumulative Impact Assessment

Government should undertake and publicly release cumulative impact assessments before implementing major disability reforms, including assessment of impacts across disability, health, education, housing, employment and community support systems

Recommendation 7 – Legislative Safeguards and Amendments The Committee should have regard to the legislative concerns including autism-specific, risks, safeguards and proposed amendments contained in Attachment A and recommend amendment, strengthening or removal of provisions accordingly. This includes Broad Ministerial powers relating to support determinations and caps be removed or significantly amended.

Recommendation 8 – Functional Capacity Framework Safeguards

No functional capacity assessment framework should be implemented until:

the methodology has been publicly released;
independently validated;
impacts across disability cohorts have been assessed;
autism-specific impacts have been evaluated;
workforce capability requirements have been demonstrated;
implementation arrangements independently reviewed; and
Parliament has had the opportunity to scrutinise the completed framework. 18 © 2026 Australian Autism Alliance: Submission to Inquiry to National Disability Insurance Scheme Amendment (Securing the NDIS

Submission 429

AUSTRALIAN

Autism Alliance

Any assessment framework should align with contemporary disability frameworks including the WHO International Classification of Functioning, Disability and Health (ICF) which recognises that functioning occurs in interaction with environmental and personal factors.

Lessons from Previous Reforms

8.1 A Consistent Lesson Across Major Reviews and Inquiries

The Alliance notes that the concerns raised in this submission are not unique to the current Bill. Successive reviews, inquiries and reform processes have identified remarkably similar systemic risks, including:

fragmentation across systems;
poor coordination between services;
delayed responses to harm;
inadequate accountability;
workforce pressures;
people falling through service gaps; and
a lack of clear ownership when systems fail. These themes are evident throughout the Disability Royal Commission, the Independent NDIS Review and the National Autism Strategy.

Together they point to a consistent lesson:

Major reforms should not rely on assumptions that systems will work. They should establish mechanisms that ensure they do.

8.2 Disability Royal Commission

A central finding of the Disability Royal Commission was that people with disability experience harm when responsibility is dispersed across multiple systems and no agency is accountable for ensuring supports are delivered.

The Commission identified recurring failures associated with fragmentation, poor coordination, delayed responses to harm and people falling through gaps between systems.

The Alliance notes that the Disability Royal Commission recognised the need for ongoing accountability, oversight and system stewardship across government.

This included the recommendation for a National Disability Commission to provide independent oversight, monitoring and accountability for disability reform.

The Alliance further notes that a Disability Royal Commission Implementation Taskforce was established to coordinate and monitor implementation of the Government’s response.

The current reforms rely heavily on interactions between the NDIS and mainstream systems, including health, education, housing, mental health, employment and community supports.

Submission 429

AUSTRALIAN

Autism Alliance

However, the Alliance is concerned that Government is increasing reliance on mainstream and foundational systems at the same time that elements of the Disability Royal Commission implementation architecture have been reduced and the permanent National Disability Commission recommended by the Royal Commission has not yet been established.

As a result, Parliament is being asked to consider reforms that depend upon coordinated system performance without a clearly articulated whole-of-government mechanism responsible for monitoring whether those systems are collectively delivering the intended outcomes for people with disability.

This creates a significant accountability gap.

8.3 Independent NDIS Review and National Autism Strategy

The Independent NDIS Review did not simply recommend reducing reliance on the NDIS. Rather, it proposed an integrated ecosystem supported by:

foundational supports;
stronger mainstream systems;
navigation functions;
transition pathways;
accountability mechanisms;
monitoring arrangements; and
implementation safeguards. Similarly, the National Autism Strategy emphasises coordinated systems, early support, improved navigation, accountability and better outcomes across the lifespan.

The Alliance is concerned that legislative powers are progressing ahead of many of the safeguards, implementation mechanisms and supporting infrastructure intended to accompany them.

In particular, foundational supports, navigation arrangements, accountability mechanisms and system readiness measures remain at varying stages of development despite being central assumptions underpinning the reforms.

8.4 Lessons from Veterans Affairs Reform

The Alliance notes the Government’s response to the Royal Commission into Defence and Veteran Suicide.

That response recognised that reforms of significant scale require:

implementation oversight;
progress monitoring;
public reporting;
escalation pathways;
accountability mechanisms;
independent scrutiny; and 20 © 2026 Australian Autism Alliance: Submission to Inquiry to National Disability Insurance Scheme Amendment (Securing the NDIS

Submission 429

AUSTRALIAN

Autism Alliance

coordinated whole-of-government implementation. The Alliance notes that many of the systemic risks identified by the Royal Commission into Defence and Veteran Suicide are similar to those identified by the Disability Royal Commission, including fragmented systems, poor coordination, delayed responses to harm, unclear accountability and people falling through service gaps.

Government accepted that implementation architecture was necessary to ensure Veterans reforms could be monitored, adjusted and corrected where required.

The Alliance submits that people with disability deserve no less.

The proposed NDIS reforms similarly depend upon multiple systems working together, including the NDIS, health, education, housing, mental health, employment and community support systems.

Yet equivalent implementation architecture has not been clearly established for disability reform.

The Alliance therefore asks:

If assumptions underpinning these reforms prove incorrect:

who identifies the problem?
who owns the outcome?
who coordinates a response?
who reports publicly?
who fixes it? The Alliance believes these questions should be answered before reforms proceed, not after harms emerge.

8.5 Oversight Before Reliance

This is perhaps the Alliance’s central concern.

Government is increasingly asking people with disability to rely upon:

foundational supports;
health systems;
education systems;
housing systems;
community supports; and
broader mainstream services. However, the mechanisms required to monitor whether those systems are actually delivering 21 © 2026 Australian Autism Alliance: Submission to Inquiry to National Disability Insurance Scheme Amendment (Securing the NDIS

Submission 429

AUSTRALIAN

Autism Alliance

remain unclear.

Government should not ask people with disability to depend upon systems before:

accountability arrangements exist;
escalation pathways exist;
public reporting exists;
harm monitoring exists; and
independent oversight exists. If Government cannot identify harm, Government cannot prevent harm.

If Government cannot identify system failure, Government cannot correct it.

Oversight should precede reliance.

This principle underpins the Alliance’s Systems That Work Accountability Index (Attachment C). A comparative analysis of lessons arising from the Disability Royal Commission, Independent NDIS Review, National Autism Strategy and Veterans Affairs reform is provided in Attachment D.

Recommendation 9 – Oversight Before Reliance

The Australian Government should establish an independent disability reform implementation and oversight architecture before commencement of major NDIS reforms.

This should include:

public reporting of implementation progress and outcomes;
harm identification and monitoring mechanisms;
escalation pathways where reforms are not operating as intended;
corrective action mechanisms;
whole-of-government coordination across NDIS, health, education, housing, employment and community systems;
independent implementation oversight and evaluation; and
clear accountability for outcomes. In developing this architecture, Government should have regard to:
the Disability Royal Commission’s recommendation for a National Disability Commission;
the role previously undertaken by the Disability Royal Commission Implementation Taskforce;
the findings of the Independent NDIS Review;
the National Autism Strategy; and
lessons arising from the Government’s response to the Royal Commission into Defence and Veteran Suicide.

Submission 429

AUSTRALIAN

Autism Alliance

9 Sustainability Must Include Outcomes

The Alliance supports the long-term sustainability of the National Disability Insurance Scheme. However, sustainability cannot be measured solely by expenditure reduction.

Government has frequently focused on the costs of the Scheme.

Far less attention has been given to the benefits achieved through participation, inclusion, capacity building and long-term social and economic outcomes.

The Alliance submits that the relevant question is not simply:

What does the NDIS cost?

It is also:

What does the NDIS prevent?

What does success save?

and

What does effective support make possible?

9.1 Where Has Government Accounted for the Benefits? The NDIA itself regularly reports outcomes relating to participation, employment, education, independence and community engagement.

Yet the Explanatory Memorandum focuses heavily on projected expenditure reductions while providing limited visibility of:

avoided future costs;
productivity gains;
workforce participation gains;
carer workforce participation;
reduced crisis intervention;
reduced homelessness;
reduced hospitalisation;
reduced justice system involvement; and
reduced mental health costs. The Alliance is concerned that Parliament is being asked to consider projected savings without equivalent visibility of the benefits currently being achieved through investment.

9.2 Investment Delivers Returns. Under-Support Creates Costs. Autistic Australians experience significantly poorer outcomes across education, employment, housing, mental health and community participation when appropriate supports are unavailable.

Submission 429

AUSTRALIAN

Autism Alliance

These outcomes carry substantial costs for governments, communities, families and the broader economy.

Evidence previously submitted by the Alliance demonstrates that:

Autistic Australians experience unemployment rates almost six times higher than non- disabled Australians;
Autistic students are significantly less likely to complete secondary education, vocational training and university;
Preschool-aged Autistic children are ten times more likely to be permanently excluded from childcare settings;
Autistic people experience substantially higher rates of mental ill-health, emergency hospital presentations and homelessness;
Mental ill-health and suicide associated with autism are estimated to cost Australia approximately $6.1 billion annually;
Homelessness associated with autism is estimated to cost approximately $1.5 billion annually;
Informal carers experience significant losses in workforce participation, income and retirement security;
Carer lost income is projected to exceed $432 million annually by 2030, with associated taxation losses of approximately $129 million and welfare costs of approximately $254 million. The Alliance submits that these costs should be considered when assessing the sustainability of disability reform.

9.3 The Cost of Getting Reform Wrong

The Alliance is concerned that reforms implemented before systems are ready may generate short-term expenditure reductions while creating larger long-term costs.

If supports are reduced before replacement systems are operational, potential consequences include:

increased school disengagement and exclusion;
worsening mental health outcomes;
increased emergency department presentations and hospital admissions;
increased homelessness risk;
increased family breakdown and carer burnout;
reduced workforce participation by both Autistic people and their carers;
increased reliance on crisis and justice systems; and
greater future demand for intensive supports. These outcomes are not hypothetical.

They are the very outcomes successive inquiries, reviews and government strategies have sought to prevent.

The Alliance therefore submits that reform should be assessed not only against projected savings but also against the costs of preventable deterioration, exclusion and crisis.

Submission 429

AUSTRALIAN

Autism Alliance

A sustainable system is not one that simply spends less.

A sustainable system is one that prevents future costs, increases participation, strengthens communities and enables people to contribute

Recommendation 10 – Sustainability Must Include Outcomes

Government should publicly release the assumptions underpinning projected savings associated with the Bill, including:

anticipated reductions in supports;
projected impacts on participant outcomes;
cost-shifting assumptions;
expected impacts on health, education, housing, employment and community systems; and
modelling of avoided future costs associated with maintaining effective supports. Government should also publicly report both expenditure outcomes and participant outcomes, including employment, education, participation, wellbeing, family impacts and long-term cost avoidance.

Reforms should be evaluated not only by what they save, but also by what they prevent and what they make possible

10 Reform Must Remain Anchored in Principles

The Alliance recognises that reform is necessary. However, reform should remain anchored in the principles that have guided disability policy and reform in Australia for decades. These include:

person-centred approaches;
trauma-informed practice;
supported decision-making;
choice and control;
participation;
inclusion;
dignity of risk; and
accountability. These are not optional design features.

They are foundational principles underpinning modern disability policy and support systems. They are reflected throughout:

the NDIS Act;
the Convention on the Rights of Persons with Disabilities;
the Disability Royal Commission;
the National Autism Strategy; and
the Independent NDIS Review. The Disability Royal Commission repeatedly identified the consequences of systems that: 25 © 2026 Australian Autism Alliance: Submission to Inquiry to National Disability Insurance Scheme Amendment (Securing the NDIS

Submission 429

AUSTRALIAN

Autism Alliance

failed to listen;
failed to recognise individual circumstances;
failed to respond to trauma;
prioritised administrative convenience over individual needs; and
removed decision-making from people with disability. Similarly, the National Autism Strategy emphasises choice and control, meaningful participation, person-centred supports and coordinated, accountable systems.

The Alliance is concerned that some elements of the proposed reforms may create tension with these principles if implemented without stronger safeguards.

In particular, concerns arise where reforms rely upon:

broad Ministerial powers;
standardised support determinations;
restrictive support definitions;
limited review pathways; or
unsupported transitions to other systems. The Alliance submits that this Bill should be assessed not only against its administrative objectives, but also against the extent to which it preserves and strengthens the principles that underpin contemporary disability policy.

Reform should strengthen these principles, not diminish them.

Recommendation 11 – Preserve Disability Rights Principles

The Bill should be amended and implemented in a manner that explicitly preserves and strengthens:

person-centred approaches;
trauma-informed practice;
supported decision-making;
choice and control;
participation and inclusion;
dignity of risk; and
accountability. All future rules, instruments, operational policies and implementation arrangements arising from the Bill should be demonstrably consistent with the NDIS Act, the Convention on the Rights of Persons with Disabilities, the Disability Royal Commission, the National Autism Strategy and the Independent NDIS Review.

11 Consistency with the Independent NDIS Review Government has frequently referred to the Independent NDIS Review in support of reform.

Submission 429

AUSTRALIAN

Autism Alliance

The Alliance agrees that the Review identified the need for significant reform and supported the development of a more sustainable and effective disability support ecosystem.

However, the Review did not recommend simply reducing reliance on the NDIS.

Rather, the Review proposed a broader reform architecture including:

foundational supports;
stronger mainstream systems;
navigation functions;
coordinated pathways;
implementation safeguards;
transition protections; and
accountability mechanisms. The Alliance is concerned that legislative powers are progressing ahead of many of the guardrails, implementation arrangements and supporting infrastructure intended to accompany them.

The Alliance submits that reforms should be implemented in a manner that is consistent with both the recommendations and the intent of the Independent NDIS Review. This includes ensuring that safeguards, accountability mechanisms and supporting systems are established before participants are expected to rely upon them.

Recommendation 12 – Implement the NDIS Review as a Complete Reform Package Government should not implement elements of the Independent NDIS Review in isolation.

Legislative reforms that increase reliance on foundational supports, mainstream services or alternative pathways should only proceed where the corresponding safeguards, transition protections, navigation functions, accountability mechanisms and supporting infrastructure are demonstrably in place

12 Conclusion The Australian Autism Alliance supports reform.

The Alliance supports long-term sustainability of the NDIS.

The Alliance supports stronger mainstream systems, foundational supports, improved participant outcomes and action against fraud, exploitation and poor-quality practice.

However, the Alliance does not support transferring risk from systems onto individuals before replacement systems, safeguards and accountability mechanisms are demonstrably in place.

The Alliance’s position is not based on opposition to reform.

Submission 429

AUSTRALIAN

Autism Alliance

It is based on lessons repeatedly identified through the Disability Royal Commission, the

Independent NDIS Review, the National Autism Strategy, the Alliance’s previous NDIS

Amendment submissions and the Government’s response to the Royal Commission into Defence and Veteran Suicide.

Those lessons are remarkably consistent.

Major reforms require:

readiness;
safeguards;
accountability;
oversight;
transition protections;
outcome monitoring; and
mechanisms to identify and respond to harm. The Alliance is concerned that the Bill seeks to progress significant legislative powers ahead of many of the safeguards, implementation mechanisms and supporting systems intended to accompany them.

Some elements of the Bill may be capable of amendment and improvement. Other elements—including broad enabling powers, insufficient safeguards, unsupported implementation assumptions and reliance on systems that have not yet been demonstrated to exist or operate effectively—are not appropriate in their current form and should not proceed.

The question before Parliament is not whether reform should occur.

The question is whether Parliament can be confident that:

systems are ready;
safeguards are in place;
accountability is clear;
harms can be identified and addressed;
cumulative impacts have been considered; and
outcomes will improve. The Alliance believes reform should proceed only when Government can demonstrate the characteristics of a system that works:
ready;
accountable;
coordinated;
measurable;
transparent;
safe; and
focused on outcomes. The Alliance further submits that sustainability should be measured not only by what reforms save, but also by what they prevent and what they make possible.

Submission 429

AUSTRALIAN

Autism Alliance

Ultimately, systems should be judged not by what they promise, but by whether they work for the people who rely on them.

For this reason, the Alliance’s central message to Parliament is simple:

Readiness should precede reliance.

Oversight should precede reliance.

And reforms should improve outcomes before they reduce supports

Submission 429

AU STRA LIAN

Autism Alliance

Attachment A - Detailed Legislative Analysis and Autism

Specific Safeguards

The Australian Autism Alliance supports reform that improves outcomes, strengthens safeguards and ensures the long-term sustainability of the NDIS.

However, the Alliance is concerned that several provisions within the Bill may create significant risks for Autistic people and their families if enacted without removal or substantial amendment.

This attachment identifies:

the relevant reform measure;
the Alliance’s position;
autism-specific risks; and
required safeguards. No Legislative Alliance Position Autism-Specific Risks and Impacts Required Safeguards

Issue / Amendments

1    Permanence   Do not support in                                                                  • Retain recognition of

and Access     current form.                                                     autism as a lifelong

Requirements neurodevelopmental Creates unacceptable risks for Autistic condition. people and families. • Preserve access pathways consistent Autism may be reframed through a with participation, treatment-compliance lens rather than a inclusion and support, accommodation, participation support needs and inclusion framework. This risks objectives. inappropriate access restrictions and loss • Access to disability of supports. supports does not depend upon This also risks delaying support during exhaustion of critical developmental periods and may treatment options, reduce future participation, independence therapies, and wellbeing. Effectively a loss of life educational chances. interventions, family supports or mainstream services (to maintain the integrity of best practice regarding earlv intervention).

2    Other         Removal of                                                                          • Remove Schedule 1,

Available       Schedule 1, Part 9 of   High risk of support exclusion based on        Part 9 of the Bill

Support         the Bill, which           theoretical availability of supports that are      including the

Systems        includes the removal   unavailable, inaccessible, unaffordable or     proposed s25B rule-

(s25B)           of the proposed rule-   not autism-capable.                       making power.

making power under • No participant

section 25B.            Participants may be directed to theoretical    should lose access

alternative supports and required to to supports based on

Submission 429

AU STRA LIAN

Autism Alliance

No   Legislative      Alliance Position     Autism-Specific Risks and Impacts      Required Safeguards

Issue / Amendments

pursue multiple systems before receiving theoretical system disability supports. responsibility or future service Besides the human impact while there availability. may be short-term saving there will be • Participants should increased costs in the long terms and not be required to poorer outcomes. exhaust other systems before disability-related support needs can be recognised and addressed (particularly in the context of early intervention)

3     Functional     Oppose. Do not       Parliament is being asked to approve a        • Publication of

Assessment    support                 future assessment framework that does      methodology;

Framework     implementation of a    not exist and therefore before                    • Independent clinical

Readiness       functional             methodology, clinical validation, workforce     validation;

assessment             capability requirements and                       • Disability cohort

framework.            implementation safeguards have been          testing.

Implementation        demonstrated                                         • autism-specific

cannot proceed until testing; methodology, • workforce capability safeguards, assessment; workforce capability, • independent implementation implementation arrangements and review; validation have been • parliamentary publicly released, scrutiny prior to independently implementation clinically evaluated and subjected to parliamentary scrutinv.

4     Functional     Oppose. Do not       Functional capacity is highly dependent    Assessment

Capacity        support as it          on environmental context, communication   approaches must

Definition         is unacceptable if       supports, executive functioning demands,   include:

: assessed     assessed in artificial   sensory environments, support scaffolding   • real-world

without        unsupported         and personal circumstances. Assessing      environments and

supports/envi   conditions.             functioning in isolation risks                 circumstances such

ronment                               underestimating support needs.             as the WHO

International

Assessments conducted outside real- Classification of world environments risk: Functioning,

overestimating capability; Disability and Health
hidden disability underestimating need; (ICF), which
masking being misinterpreted as recognises that independence; disability and
overlooking burnout as its invisible; functioning arise through interaction 31 © 2026 Australian Autism Alliance: Submission to Inquiry to National Disability Insurance Scheme Amendment (Securing the NDIS

Submission 429

AU STRA LIAN

Autism Alliance

No   Legislative      Alliance Position     Autism-Specific Risks and Impacts      Required Safeguards

Issue / Amendments

failing to recognise fluctuating support between requirements; impairments,
overlooking cumulative fatigue; environmental
family scaffolding being ignored; factors and supports;
cumulative fatigue/burnout Risks created: consideration;
exclusion from access; • •masking/camouflagi
underfunding; ng consideration;
delayed support until crisis; • support scaffolding
increased hospitalisation; recognition;
school exclusion; • environmental and
family collapse. sensory impacts;
fluctuating presentation recognition.

Additional legal safeguard Require:

publication of assessment methodology;
inter-rater reliability testing;
cohort validation for autism/psychosocial disability;
access to raw assessment outputs;
review rights. Alternative approach Use:
supported functioning;
sustainable participation; and . real-world functioning over time rather than unsupported snapshot performance.

5 Autism- Requires autism- Autism may be misunderstood where • Autism-specific

Specific specific safeguards assessments fail to recognise masking, validation.

Assessment to be embedded in Autistic burnout, communication • Autism

Safeguards assessment design, differences, executive functioning representation on

implementation, challenges, sensory impacts, support advisory and

Submission 429

AUS T RAL IA N

Autism Alliance

No   Legislative      Alliance Position     Autism-Specific Risks and Impacts      Required Safeguards

Issue / Amendments

governance and • Lived experience

evaluation             Functioning may appear significantly            plurality.

and oppose              different across environments and over        • Recognition of non-

approaches that fail    time.                                      medical expertise.

to recognise the Recognition of diversity of Autistic masking, burnout experience. and co-occurring conditions.

6     Directly       Do not support the   The "directly arising" test risks             Supports should

Arising Test     current wording. This   fragmenting support needs and excluding   remain fundable

is an unacceptable     legitimate supports:                      where:

risk.                          • anxiety-linked supports;                         • disability is a

It is too narrow and      • sensory regulation;                          substantial

mechanistic.               • behavioural supports;                        contributing factor;

social communication supports; • supports prevent
executive functioning supports; deterioration;
trauma-related impacts; and • supports maintain
environmental demands. participation and safety.

Autism support needs are often: Alternative wording

cumulative; Replace:
intersecting; “directly arising”
relational; and with:
inseparable from co-occurring “substantially related conditions. to” or “materially connected to”. The risks created are:
fragmented supports; Replace:
disputes over causation; “directly arising”
increased tribunal burden; with broader wording • artificial separation of co-occurring such as

conditions “substantially related to” or “materially connected to”

7    Reasonable    Removal of         The provision risks creating a narrower    Remove provision.

and            proposed subsection    interpretation of disability-related support

Necessary  -    34(1A).               needs, may undermine whole-of-person     Additional safeguards:

Proposed                           approaches and reduce individualisation      • independent human

s34(1A)        Unacceptable in          in practice.                                       rights assessment;

current form. 34(1 B) • safeguarding

and (1C) requires     Support decisions need to reflect a           assessment;

qualification.          person's overall circumstances rather than    • disability impact

artificial segmentation of support needs. assessment;

public transparency , regarding impacts;

Submission 429

AU STRA LIAN

Autism Alliance

No   Legislative      Alliance Position     Autism-Specific Risks and Impacts      Required Safeguards

Issue / Amendments

post-implementation review;
participant notification;
written reasons;
merits review rights;
parliamentary scrutiny

8 Reasonable Require further May contribute to cumulative narrowing of • Public guidance

and safeguards. supports and reduced individualisation. • Decision-making

Necessary should remain (34(1 B)-(1 C)) transparent

Independent review rights.
Monitoring of cumulative impacts.
Preservation of review rights

9 Reasonable Remove from the Bill Narrow effectiveness tests may Remove the provisions

and as the current disadvantage preventative, developmental or substantially

Necessary Supports Rules and participation-focused supports. broaden interpretation

(34(1 E)-(1 F)) provide an of effectiveness.

appropriate structure for the ‘effective and beneficial’ consideration. ,

10   Family        Oppose              Risks creating an overly restrictive          Family capacity should

Capacity and   assumptions that       interpretation of support need, treating      never be presumed.

Informal         family members can    informal supports as unlimited and         Parents should be

Supports       provide unlimited,      permanent, inappropriate thresholds and    supported to be

(34(1G),34      ongoing or substitute  may fail to recognise legitimate disability-    parents.

(1H), 34(1J),     support in place of      related support requirements with

34(1 K))         funded supports.       underestimating cumulative caring needs,   The legislation should

co-regulation, supervision and emotional recognise the role of

34(1 H) requires       support needs, sibling impacts;             supports in

removal.            and ageing carers.                         maintaining

sustainable family and

Rest              As a result risks workforce withdrawal,       caring arrangements

requires substantial  burnout, family breakdown, financial       and informal supports

amendment.           stress and future support failures.          should not be treated

as a substitute for funded supports in a Parents should not be expected to number of become quasi: circumstances. • therapists;

support coordinators; So the legislation or • case managers; supporting rules • book keepers/ contract managers; requires explicit • svstem naviaators. 34 © 2026 Australian Autism Alliance: Submission to Inquiry to National Disability Insurance Scheme Amendment (Securing the NDIS

Submission 429

AU STRA LIAN

Autism Alliance

No   Legislative      Alliance Position     Autism-Specific Risks and Impacts      Required Safeguards

Issue / Amendments

consideration of the Autistic children frequently require following or related: substantially greater support than same- • willingness; age peers across: • exposes to harm;

• communication;                                                                                                                           • sustainability;                                                                • regulation;

executive functioning; • workforce
participation; participation
safety; impacts;
community engagement. • health impacts;
family wellbeing/ burn out/ breakdown;
financial impact;
future caring capacity;
ageing carers;
sibling impacts;
cumulative caring needs;
co-regulation needs;
supervision needs;
emotional needs;
changed circumstances including illness, death
reliance on unsupported caring arrangements to compensate for failures in formal service systems; and
long-term viability of caring arrangements particularly of the appropriateness of expecting a particular individual to provide supports.

Submission 429

AU STRA LIAN

Autism Alliance

No   Legislative      Alliance Position     Autism-Specific Risks and Impacts      Required Safeguards

Issue / Amendments

family functioning, reduce distress or maintain stability within the home environment.

The sustainability of caring arrangements should be regularly reviewed over time.

Requires autism specific safeguards to be embedded in assessment design, implementation, governance and evaluation.

11   Support       Oppose.             Fundamentally inconsistent with                 • Support

Determinatio   Unacceptable in        individualised support principles.              determinations

ns and           current form. Cannot   Risks scheme-wide reductions, loss of        through Category A

Support Caps  have broad or           individualisation, erosion of choice and       Rules process

Scheme-wide           control, inequitable outcomes and harm       • Human rights

application and there   for those with essential supports for         assessment

is no independent      health, safety and isolation.                       • Safeguarding

oversight/ assessment.

transparency or       Concerned about:                                   • Independent

resolution pathways.    • insufficient parliamentary scrutiny;            disability impact

reduced transparency; assessment.
scheme-wide impacts; *Assessments provide
lack of right to review for immediate • inability to account for individual overrides

circumstances • Public transparency

ability to make harmful decisions with regarding anticipated no consequences impacts.
Disability-led consultation
Participant notification.
No harm certification
System Readiness

Certification

Written reasons with impact and financial analysis.
Merits review rights.
Mandatory post- implementation review to assess

Submission 429

AU STRA LIAN

Autism Alliance

No   Legislative      Alliance Position     Autism-Specific Risks and Impacts      Required Safeguards

Issue / Amendments

unintended harm and system consequences.

Parliamentary scrutiny.
Resolution pathways
Consequences for those making negligent or lack of good faith/ reasonable and necessary decisions resulting in harm, safety or longer term unfavourable consequences.

12 Reassess men Requires Support needs may change because of: • Remove

Autistic burnout; “unanticipated” ts and Review amendment. • Pathways requirement exclusion including school exclusion; • • Recognise masking,

masking; • delayed presentation

sensory overload of distress, •

loss of supports including family cumulative •

collapse and ageing carers; deterioration and

Autistic burnout.                                               mental health deterioration;                                          •                                                         • Urgent

cumulative deterioration rather than a                                          •                                       reassessment

single event; pathways for

delayed presentation of distress;           escalation.                                          •

loss of informal supports .                     • Reinstate deemed                                          •                                                                                                      refusal provisions.

These changes may be foreseeable but • Crisis reassessment mechanisms does not make them less serious

Reinstate deemed refusal provisions
Temporary stabilisation funding

13 Review Oppose removal of Reduced review rights increase risk of • Independent review

Rights and legislative incorrect decisions remaining uncorrected rights to challenge

Procedural protections that and disproportionately affect participants decisions affecting

Fairness support facing communication or advocacy eligibility, supports,

individualisation, barriers. funding,

participation, choice reassessments and and control, right to support review unless determinations. equivalent • Access to reports, protections are evidence used and

Submission 429

AUS T RAL IA N

Autism Alliance

No   Legislative      Alliance Position     Autism-Specific Risks and Impacts      Required Safeguards

Issue / Amendments

explicitly preserved understanding of elsewhere in the Act. reasons.

Receive draft reports Requires strong review rights and required safeguards are essential.

14 Repeal of Oppose removal Weakens legislative recognition of Retain Section 31

Section 31 unless equivalent individualisation, participant direction, principles or explicitly

Principles protections are participation, choice and control, tailored preserve equivalent

explicitly preserved supports and community inclusion. protections elsewhere

elsewhere in the Act. in the Act.

15   Foundational   Support                Participants may lose supports before         • No-Gap Transition

Supports        foundational            alternatives exist. Risk of service gaps        Guarantee. Supports

Transition      supports only with     with loss of support before alternatives        should not be

stronger                exist and cost shifting. There is concern of    removed until

safeguards. Do not   mainstream system reliance, criticality of      replacement

support transition or    early intervention supports and system       systems are:

removing supports     readiness.                                      •operational;

before readiness      Government has not demonstrated:            •accessible;

workforce readiness;                       • affordable                     based on                •                      assumptions that                                                        •sustainable;                                                         service availability;                           future systems will        •                                                      • workforce-ready

waitlist capacity;                       operate effectively.        •                                                      • independently

autism capability.                      evaluated; and                     Cannot proceed until      •

demonstrated. •have accepted responsibility

Independent readiness assessment.
Demonstrated availability, accessibility and workforce capacity before transition .

16 Navigation, Support only with Autistic people and families may be left • Adequate./ Timely

Warm stronger navigating fragmented systems without Navigation functions,

Referrals and safeguards accountability due to mainstream • Warm referrals/

No Wrong interfaces, systems that are broken and independent

Door lack of system readiness advocacy

accessibility, Participants should not bear responsibility • No Wrong Door for resolving disputes between: accountability.

NDIS; • Escalation
education; pathways.
health; • Joint resolution
housing; mechanisms.
justice; 38 © 2026 Australian Autism Alliance: Submission to Inquiry to National Disability Insurance Scheme Amendment (Securing the NDIS

Submission 429

AU STRA LIAN

Autism Alliance

No   Legislative      Alliance Position     Autism-Specific Risks and Impacts      Required Safeguards

Issue / Amendments

community services. • Refer Australian

Autism Alliance

Thriving Kids

submission

17   Community     Strongly support     Community participation is safeguarding      • Preserve community

Participation    the availability,          infrastructure.                                    participation

Supports        accessibility and                                                    supports.

affordability of                  It protects against:                                   • Recognise

community                    isolation;                                     participation as                                          •

abuse;                                 safeguarding                           participation supports  •

exploitation;                                 infrastructure rather                      but do not support   •

mental ill-health;                        than discretionary                      removal of           •                             availability of                                                       expenditure.                                                              crisis escalation .                                          •                           individualised

supports due to Social isolation is one of the strongest individual differences predictors of deteriorating mental health,

and choice and                                                         crisis escalation, vulnerability to abuse                            control.

and reduced participation.

It supports belonging, confidence and participation

Community participation should not be treated as discretionary expenditure.

18   Outcome      Oppose            Harms may emerge without being               • Monitor and public

Measurement   implementation of       identified or addressed. Reforms may          reporting on

and Public     major reforms          unintentionally increase exclusion, crisis     outcomes including

Reporting       without mechanisms    intervention, cost shifting, family stress         participation,

to identify, monitor     and future costs including service             education,

and respond to       demand, without visibility.                  employment,

emerging harms. wellbeing and family The Alliance supports reform where sustainability, school

Major gap in current   Government can demonstrate:                exclusion,

reform architecture.       • systems are ready;                            hospitalisation,

Requires                   • supports exist;                          homelessness,

significant                 • accountability is clear;                          restrictive practices,

safeguard                  • harms can be identified;                      family breakdown,

strengthening.            • outcomes are measured; and               caregiver burnout,

people are not left to navigate system suicidality, justice Outcome monitoring failures alone. system contact and

should be cost shifting between established before systems. implementation. • Realtime resolution pathways Support public • Other reporting of safeguards/amendm participant outcomes. ents identified in this table

Submission 429

AU STRA LIAN

Autism Alliance

No   Legislative      Alliance Position     Autism-Specific Risks and Impacts      Required Safeguards

Issue / Amendments

19   Automated     Support only with    Hidden disability, masking and                   • Human oversight.

Decision       strong safeguards.   communication differences may be             • Bias auditing.

Making                                   misinterpreted. Risk of algorithmic bias        • Transparency.

and reduced transparency. • Explainability.

Review rights for all substantive decisions affecting eligibility, supports or fundina.

20 Administrativ Requires Reforms should not increase • Accessible

e Burden and amendment administrative burden on participants, processes.

Accessibility families and carers without clear evidence • Plain language

of benefit. communications.

Reduced duplication Executive functioning differences, of evidence communication differences, cognitive requests. overload, paperwork requirements, • Supported decision repeated evidence requests and complex making. administrative processes may create • Assistance with barriers to accessing or maintaining navigation and supports. reviews.
Reasonable Increased administrative burden and adjustments compliance requirements may throughout disproportionately impact Autistic people, administrative families and carers, small providers, sole processes. practitioners, regional providers. • Monitoring of participant Hence administrative processes should administrative be proportionate, accessible, burden and proportionate and disability-responsive. unintended impacts

Attachment A should be read alongside the Alliance’s Systems That Work Readiness Index (Attachment B), Systems That Work Accountability Index (Attachment C), and Comparative

Lessons from the Disability Royal Commission, Independent NDIS Review, National Autism

Strategy and Veterans Reform (Attachment D). The Alliance recommends that the provisions identified above be amended, strengthened or removed consistent with the positions and safeguards outlined in this Attachment.

Submission 429

AU STRA LIAN

Autism Alliance

Attachment B - Systems That Work Readiness Index

SYSTEMS THAT WORK

READINESS INDEX

IF SYSTEMS AREN’T READY,

REFORM ISN’T READY.

10 Point System Readiness Index

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READINESS IS THE FIRST TEST. ACCOUNTABILITY IS THE SECOND. n.-…-,._ __ … _ ,,.,.,_,,.oe~

AUS I AA LIA“

--·.,.,. 1..-.c•       ............... ...     mo

Submission 429

AU STRA LIAN

Autism Alliance

Attachment C - Systems That Work Accountability Index

SYSTEMS THAT WORK

ACCOUNTABILITY INDEX

IF GOVERNMENT CANT IDENTIFY HARM,

IT CANT PREVENT IT.

10 Point Reform Accountability Index

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CUMULATIVE IMPACT LENS & ACCOUNTABILITY LENS

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Tht-lOd!!JC..a&-ret>rmcan~cxmnenoe. ear, 11!1150UIOtp.w,e<1       --. .........            ....- - ·-·-·

CII O

Submission 429

AUSTRALIAN

Autism Alliance

Attachment D – Comparative Lessons from the Disability

Royal Commission, NDIS Review and Veterans Affairs Reform

Below is a DRC–NDIS Review-National Autism Strategy-Veterans–comparison table demonstrating why oversight, public reporting, escalation and accountability must be established before reliance on new systems is expected.

Table 2 provides a comparison of lessons of what successive inquiries have told Government demonstrating that the Alliance’s recommendations are based on the same lesson across all major reform agendas.

Table 3 provides a comparison of what was recommended versus what is currently visible in the NDIS Legislation.

The Critical Difference

The Alliance notes that Government’s response to the Royal Commission into Defence and Veteran Suicide included:

implementation architecture;
national oversight arrangements;
monitoring;
public reporting;
escalation pathways;
accountability mechanisms;
whole-of-government coordination. These mechanisms recognise that reform cannot simply assume systems will work. They create structures capable of identifying problems and correcting them when they occur.

By contrast, the proposed NDIS reforms rely heavily upon:

foundational supports;
health systems;
education systems;
housing systems;
community supports; without equivalent implementation architecture being clearly established.

The Alliance is concerned that people with disability are being asked to rely on systems before equivalent safeguards, oversight and accountability arrangements are in place.

Hence the question is why the implementation architecture considered necessary for Veterans Affairs reform has not yet been clearly established for disability reform despite successive inquiries identifying many of the same systemic risks?

Submission 429

AU STRA LIAN

Autism Alliance

Common           Disability      NDIS Review       National       Veterans Royal    Current Concern

System Failure    Royal                           Autism        Commission         with NDIS

Commission                       Strategy        Response     Amendment Bill

Whole-of-           Increased                                                RecognisesPeople fall                                                       government          reliance on                                              need forthrough gaps       Major finding     Major finding                       implementation       multiple systems                                                     coordinatedbetween systems                                                         oversight            without equivalent                                                systems                                                                         established           oversight

National                                                                   No clearPoor coordination                                                      implementation                   Major finding     Major finding      Priority area                           implementationbetween services                                                            architecture                                                                                                    architecture                                                                         established

National

Lack of                           Safeguards      Accountability    Commission and     Unclear

accountability      Major finding    and monitoring   and outcomes     oversight           ownership of

when systems fail                recommended   focus            arrangements       outcomes

established

Foundational     Early              Monitoring and       Limited harmDelayed                                    supports and     identification       reporting             monitoringidentification of     Major finding                                      navigation      and support      mechanisms       mechanismsharm                                  proposed       emphasised       established            visible

Reform

progressing                                                      Lifespan           IntegratedFragmented                         Navigators                                              before                   Major finding                      coordination       implementationsupports                       recommended                                           foundational                                                    focus            response                                                                                           supports are

operational

Reliance on                         Stronger         Better system     Coordinated         Risk remains on

individuals to       Major finding     monitoring       navigation        government          participants and

naviaate svstems                   proposed          identified         response             families

LimitedLack of                                          Data and                                                                           Public reporting      implementationtransparency and   Major finding     Major issue      accountability                                                                                           built into response    reportingpublic reporting                                 commitments                                                                                    arrangements

Early Same workforce

intervention                       Workforce reforms   expected to

Workforce            Identified as     and                                 included in          support reforms                                                  Major issuepressures          systemic issue   foundational                       implementation       without

supports                         response           demonstrated

emphasised readiness

Prevention and                       Monitoring and                                          Risk of waiting for                       Identified                          Early support      Prevention focusearly intervention                     evaluation                                                   deterioration                    repeatedly                         central objective  embeddedfailures                        recommended                                          before suooort

Systemic harms                               Outcome          Escalation        No equivalent

become visible     Major finding                       tracking          pathways             escalation

too late                                        emphasised       established         framework visible

Table 2: Comparative Lessons: What Successive Inquiries Have Told Government

Submission 429

AU STRA LIAN

Autism Alliance

i w

Whole-of-government                        Required      Recommended      Established         Unclearcoordination

Implemented

throughNavigation supports      Required      Recommended                        Not yet fully operational                                                                coordination

architecture

Built intoTransition safeguards    Required      Recommended                                       Still developing                                                          im lementation

Reform andReadiness before                          Strongly             Implementation-                          Implied                                                 implementation occurringrollout                             recommended          first approach                                                                                   simultaneous!

Accountability for                                            Clear oversight                        Required      Recommended                             Diffuse responsibilityoutcomes                                                     arran ements

AUSTRALIAN

Autism Alliance

Australian Autism Alliance

Submission to the Senate Community Affairs

Legislation Committee

Inquiry into the National Disability Insurance

Future Generations) Bill 2026

Ensuring Reform is Ready, Accountable and Safe

Submitted by: Australian Autism Alliance

Contact: Jenny Karavolos, Chair, Australian Autism Alliance

Generations) Bill 2026

AUSTRALIAN

Autism Alliance

Acknowledgements

Generations) Bill 2026

AUSTRALIAN

Autism Alliance

Contents

4 The Alliance’s Position Which Has Remained Consistent (2024 Inquiry) …………………………….. 12

Generations) Bill 2026

AUS TR AL I A N

Autism Alliance

About the Australian Autism Alliance

Autism Advisory Group, the NOIA DRCO Co-Design Advisory and Reform groups, NDIS

Commission Disability Sector Consultative group, the National Autism Strategy Oversight

AU STRA LIAN

Autism Alliance

1 Executive Summary

AUSTRALIAN

Autism Alliance

AUSTRALIAN

Autism Alliance

AU ST RA L IA N

Autism Alliance

AU ST RA L IA N

Autism Alliance

Table 1: Recommendation Summary Table

Commission, the Independent NDIS Review, the National Autism Strategy, previous NDIS reform

AUS T RAL IA N

Autism Alliance

AUSTRALIAN

Autism Alliance

3 The Alliance Supports Reform BUT

Recommendation 1 – Readiness Before Reliance

AUSTRALIAN

Autism Alliance

4 The Alliance’s Position Which Has Remained Consistent

4.1 Specific Legislative Concerns

Unacceptable in Current Form

Requiring Significant Amendment

Potentially Supportable with Safeguards

AUS T RAL IA N

Autism Alliance

Recommendation 2 - Parliament Should Not Approve Undefined Future Powers

AUSTRALIAN

Autism Alliance

AUSTRALIAN

Autism Alliance

the World Health Organisation International Classification of Functioning, Disability and Health

AUSTRALIAN

Autism Alliance

Early Intervention, Development and Access to Supports

AUSTRALIAN

Autism Alliance

6 Systems That Work: The Foundation for Reform

Work Readiness Index and Alliance Systems That Work Accountability Index before

7 Cumulative Impact Lens

AUSTRALIAN

Autism Alliance

Recommendation 6 – Cumulative Impact Assessment

Recommendation 8 – Functional Capacity Framework Safeguards

AUSTRALIAN

Autism Alliance

8.1 A Consistent Lesson Across Major Reviews and Inquiries

8.2 Disability Royal Commission

AUSTRALIAN

Autism Alliance

8.3 Independent NDIS Review and National Autism Strategy

8.4 Lessons from Veterans Affairs Reform