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Submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 (Provider advocacy)

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Submission 431

Submission on the National Disability Insurance Scheme

Amendment (Securing the NDIS for Future Generations) Bill 2026

The Australasian Association and Register of Practicing

Nutritionists (AARPN)

Thursday May 28, 2026

AARPN Submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 1

Submission 431

Contents Submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 …. 3

About AARPN ……………………………………………………………………………………………………………………………………………………………. 3

Initial remarks …………………………………………………………………………………………………………………………………………………………… 3

Core recommendations………………………………………………………………………………………………………………………………………………. 3

The social contract issue …………………………………………………………………………………………………………………………………………….. 5

Schedule 1: Access and planning measures …………………………………………………………………………………………………………………… 5

Functional capacity — Schedule 1, Part 1, item 4, proposed s 9B …………………………………………………………………………………. 5

Unscheduled plan reassessments — Schedule 1, Part 2 ………………………………………………………………………………………………. 7

Linking supports to eligible impairment — Schedule 1, Part 3 ……………………………………………………………………………………… 7

Support determinations and underfunding — Schedule 1, Part 4, proposed s 34A …………………………………………………………. 8

Plan renewal by operation of law — Schedule 1, Part 5, proposed s 50A and item 59 …………………………………………………….. 9

Reasonable and necessary supports, sustainability and family responsibility — Schedule 1, Part 6 ………………………………….. 9

Suspension and non-contactability — Schedule 1, Part 7 ………………………………………………………………………………………….. 10

Permanence, treatment and alternative supports — Schedule 1, Parts 8 and 9 …………………………………………………………… 10

Schedule 2: Provider, fraud and integrity measures ……………………………………………………………………………………………………… 11

Provider definition and risk-proportionate registration — Schedule 2, Part 1 ………………………………………………………………. 11

A professional governance body for support workers ……………………………………………………………………………………………….. 11

Fraud, civil penalties, information gathering and participant protection — Schedule 2, Parts 2 and 3 …………………………….. 12

Record retention and claim timeframes — Schedule 2, Parts 4 and 5 …………………………………………………………………………. 12

Registered plan management providers and vertical integration — Schedule 2, Part 6 …………………………………………………. 13

Schedule 3: Governance arrangements ………………………………………………………………………………………………………………………. 13

Maximum pricing and ministerial pricing power — Schedule 3, Part 1, proposed ss 34B and 45C ………………………………….. 13

Automation of administrative action — Schedule 3, Part 2, proposed ss 59B–59E ……………………………………………………….. 14

Schedule 4: New framework planning ………………………………………………………………………………………………………………………… 15

Schedule 5: Transitional rules and the problem of future misuse …………………………………………………………………………………… 15

Conclusion ………………………………………………………………………………………………………………………………………………………………. 16

References………………………………………………………………………………………………………………………………………………………………. 17

AARPN Submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 2

Submission 431

Submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future

Generations) Bill 2026

About AARPN

AARPN (The Australasian Association and Register of Practicing Nutritionists) is the professional association and register for the Certified Practicing Nutritionist (CPN) profession. AARPN is a full member of Allied Health Professions Australia and a full member of the National Alliance of Self Regulating Health Professions (NASRHP). Certified Practicing Nutritionists are university-qualified clinically trained primary care nutrition professionals who provide evidence informed therapeutic nutrition supports and capacity-building interventions where disability factors affect eating, drinking, meal planning, and nutrition self-management.

Initial remarks AARPN thanks the Community Affairs Legislation Committee for the opportunity to contribute to the inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

AARPN supports the objective of securing the NDIS for current and future participants. We understand that preventing fraud, market stewardship and clearer provider accountability are important public policy objectives, and that fraud and poor quality service provision harm participants, their families, ethical providers, and the NDIS Scheme itself when they erode the public confidence on which the Scheme depends. We further understand that sustainability of the Scheme is also important because a financially unsustainable NDIS would fail future participants who would seek to rely on it. However, we have respectfully observed that the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 (Cth) while it contains useful reforms, also concentrates significant executive, ministerial and AI/algorithmic power while weakening participant-facing safeguards. In key respects, the Bill appears at risk of converting the sustainability objective from a system-level stewardship obligation into a participant-level rationing mechanism.

We note that the Explanatory Memorandum frames the Bill as responding to two vulnerabilities: Scheme growth and fraud, and that it has drawn on the NDIS Review, the NDIS Provider and Worker Registration Taskforce, ANAO reports and the Disability Royal Commission (Explanatory Memorandum, National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 (Cth), pp. 2–3). Our concern is that the Bill does not consistently translate its stated reform objectives into a human rights-oriented legislative design. Several provisions would seemingly allow supports to be underfunded, access to be narrowed by reference to theoretical treatment or alternative systems, plans to be renewed by operation of law, automated systems to take administrative action, and broad powers to be exercised through delegated instruments.

AARPN’s submission seeks to suggest changes that would allow the Parliament to pursue sustainability, fraud prevention and provider accountability without shifting disproportionate risk onto participants, families, ethical providers and thin markets.

Core recommendations Recommendation 1: The Bill should be amended to ensure/require that sustainability, fraud control and market stewardship are implemented through transparent, reviewable, and human rights compatible mechanisms.

Recommendation 2: Schedule 1, Part 1, proposed s 9B should be amended so that functional assessment reflects real-world functional capacity, including environmental barriers, support context, communication needs, fluctuating/episodic disability, cultural context, rurality and family/support sustainability. Rules should not be able to exclude relevant contextual evidence where that evidence is necessary to understand functional impact.

Recommendation 3: Schedule 1, Part 2 should retain a practical right to urgent reassessment where a plan becomes unsafe, insufficient or impossible to implement because of changed need, carer collapse, provider failure, market failure, crisis or risk of harm.

AARPN Submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 3

Submission 431

Recommendation 4: Schedule 1, Part 4, proposed s 34A and Schedule 4, proposed ss 32K(3B)-(3E) should not allow support determinations or budget methods to knowingly produce funding below the cost of essential reasonable and necessary supports unless a transparent exception, top-up and urgent review pathway is available.

Recommendation 5: Schedule 1, Part 6 should make clear that parental and family responsibilities cannot be used as a substitute for NDIS-funded supports where the level of unpaid care is unsafe, unsustainable or inconsistent with ordinary family life.

Recommendation 6: Schedule 1, Parts 8 and 9 should be amended so that access cannot be refused or revoked because treatment or another service system is theoretically “appropriate” where that treatment or support is unaffordable, geographically unavailable, subject to long waitlists, clinically unsuitable, culturally unsafe, practically inaccessible, or insufficient to meet disability-related needs.

Recommendation 7: Schedule 2, Part 1 should be implemented through a tiered model that recognises existing professional governance. AHPRA-regulated practitioners and members of robust self-regulating allied health professional bodies should be able to enter a light-touch enrolled provider pathway, while higher-risk services/providers remain subject to full registration and audit.

Recommendation 8: The Bill’s provider-registration reforms should be supported by a national support worker professional body to set role boundaries, codes of conduct, training expectations, CPD, supervision, complaints pathways, worker registers and safeguarding norms. This would resolve much of the regulatory burden currently falling to the NDIS because support work lacks an independent professional governance structure.

Recommendation 9: Schedule 2 should distinguish fraudulent or exploitative conduct from administrative mistakes, disability related recordkeeping difficulty, nominee dependence, digital exclusion and good-faith errors. Civil penalties and debt mechanisms should include reasonable-excuse, proportionality, hardship and accessible-review safeguards.

Recommendation 10: Schedule 2, Parts 4 and 5 should include exceptions for disability-related, family-violence, disaster, provider-failure, nominee-misconduct and administrative-delay circumstances, and should not create automatic debt or punishment where alternative evidence can substantiate the support.

Recommendation 11: Schedule 2, Part 6 is a useful start, but the conflict model should extend beyond registered plan management providers to support coordination, psychosocial recovery coaching, navigation/connection functions, assessment-linked services and any provider role that materially influences participant spending or service choice.

Recommendation 12: Schedule 3, Part 1 should require transparent methodology, publication of advice and reasons, consultation, regional and complexity loadings, and an independent or statutorily protected pricing advisory function.

Recommendation 13: Schedule 3, Part 2 should limit automation to low-risk, mechanical, objectively verifiable administrative action. Access, planning, funding, reassessment, suspension, revocation, debt, compliance and adverse claim decisions should require a human delegate who independently considers the material and remains accountable.

Recommendation 14: Broad delegated powers should be designed for future misuse, not current goodwill. Instruments affecting entitlements, pricing, funding methods, assessment tools, automation or transitional modification should be disallowable, time-limited, consultative, accompanied by human-rights impact analysis and subject to independent review.

Recommendation 15: The Act should require independent review of the implementation of the Bill’s access, planning, provider, pricing and automation measures within 12-18 months, with public reporting of participant impacts, market impacts, complaint trends, review outcomes and systemic errors.

AARPN Submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 4

Submission 431

The social contract issue The impact analysis contained in the Explanatory Memorandum describes the NDIS as a public value institution grounded in the expectation that government will provide social protection for people with disability. Hence, the NDIS rests on a social contract whereby participants disclose highly personal information, submit to assessments, accept planning controls, rely on government-controlled payment systems, and increasingly interact with digital and automated administrative systems, and in return, government promises a lawful, stable, transparent and reviewable scheme that provides reasonable and necessary disability supports to enable autonomy, participation, safety and ordinary life. Scheme sustainability is part of the social contract in that a scheme that becomes financially unsustainable cannot protect future participants. However, the social contract is breached if government retains the coercive, surveillance, compliance and enforcement features of the Scheme but weakens the corresponding entitlement, transparency, accountability and remedy features. The United Nations Convention on the Rights of Persons with Disabilities requires dignity, autonomy, participation, equality, accessibility and inclusion to be respected in law and administration (United Nations, 2006). The Disability Royal Commission also reinforced that safeguarding must be embedded in systems, not left to individual participants to manage through complaint, advocacy or review after harm has occurred (Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, 2023). This submission therefore frames the Bill as requiring a parliamentary test: does each provision distribute legal and practical risk fairly between government, the Agency, providers, participants and families? Where the answer is no, the provision needs to be re-examined even if its policy purpose is legitimate.

Schedule 1: Access and planning measures

Functional capacity — Schedule 1, Part 1, item 4, proposed s 9B Schedule 1, Part 1, item 4 introduces a definition of functional capacity for the purposes of the Act. The proposed s 9B defines a person’s functional capacity, in relation to an activity, as the person’s ability to undertake that activity without assistance from other people, assistive technology or modifications, and in a context that excludes, as far as possible, the impact of the person’s environmental and personal circumstances. Proposed s 9B(2) and (3) then allow NDIS Rules to prescribe methods, criteria, classifications, thresholds and matters that may, must or must not be taken into account when assessing functional capacity.

AARPN accepts that a nationally consistent approach to functional assessment is a legitimate policy objective. The current access and planning system has produced inconsistent outcomes, and a clearer assessment framework may improve transparency, comparability and administrative fairness. However, the way functional capacity is defined in proposed s 9B appears to do more than clarify language - it appears to define functional capacity in a way that is capable of being operationalised through a standardised assessment tool, scoring method, classification or threshold. That is important because the validity of any assessment tool depends on the construct it is designed to measure. If the intended assessment tool, whether I-CAN or another functional assessment instrument, is designed to isolate a person’s baseline impairment related capacity by removing assistance, assistive technology, modifications and environmental variation, then the definition in proposed s 9B may be necessary to make the tool internally consistent. In that limited sense, the Bill appears to be defining functional capacity in a way that allows a tool to produce comparable scores across participants. However, while a definition designed to make a standardised tool work may produce a valid measure of a narrow construct, that does not mean it produces a valid assessment of the person’s real-world disability support needs. Functional capacity in everyday life is not merely what a person can theoretically do in a neutralised environment without assistance. It is what the person can reliably, safely, repeatedly and sustainably do in the environments in which they live, learn, work, communicate, eat, travel and participate.

The proposed definition may be defensible if it is used to identify a baseline impairment-related functional profile for access purposes, however, it can become much more problematic if that tool-derived profile is then treated as the complete basis for planning, funding, support classification or budget allocation. A standardised tool may assist decision-making, but it should not replace clinical reasoning, disability expertise, participant evidence, family and carer evidence, or real-world medical or allied health assessment of functional ability and support need.

AARPN Submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 5

Submission 431

AARPN is particularly concerned that a tool-based definition may reduce ecological validity. It may make functional capacity easier to score, but less accurate as a description of how disability operates in practice. Environmental barriers, communication needs, sensory overload, psychosocial fluctuation, fatigue, behavioural risk, family capacity, cultural safety, housing instability, transport, rurality, digital exclusion, service availability and informal support sustainability are not peripheral matters - in many cases, they are the very factors that determine whether a person can function safely and participate meaningfully.

The risk is not simply that a tool may be imperfect. The deeper risk is that the tool(s) become the legal reality. Once a score, classification or threshold is embedded in rules, operational manuals or funding methods, it can begin to displace the individualised judgement required by a rights-based disability scheme. This may be administratively efficient, but it risks converting functional assessment from a means of understanding disability into a mechanism for standardised allocation/rationing.

AARPN therefore submits that proposed s 9B should distinguish between two related but different concepts:

  1. baseline impairment-related functional capacity, which may be assessed through a standardised tool for the purpose of consistency and access-threshold decisions; and

  2. real-world functional impact and disability-related support need, which must consider the person’s actual environment, supports, risks, sustainability, participation goals and implementation context, and any available and related medical or allied health assessments/reports and/or advice.

If Parliament accepts a definition of functional capacity that is designed to support a standardised tool, the legislation should also make clear that tool-based assessment is only one source of evidence. It should not be determinative of access, planning or funding where other credible evidence shows that the tool output does not adequately reflect the participant’s real-world disability support needs.

AARPN recommends that Schedule 1, Part 1 be amended or supported by clear statutory safeguards to ensure that:

  • proposed s 9B does not confine functional capacity assessment to a tool-derived measure of intrinsic capacity where real-world context is necessary to understand disability-related support need;

  • any assessment tool, scoring method, manual, threshold or classification used for access, planning or funding is published, validated, independently reviewed and subject to meaningful consultation with people with disability, families, carers and relevant clinical and disability experts;

  • any tool used, including I-CAN or any adapted version of I-CAN, is validated for the specific purpose for which it is being used within the NDIS;

  • the legislation preserves the ability of decision-makers to consider credible medical, allied health, developmental, behavioural, functional, family, carer and support-system evidence where it is relevant to the person’s functional capacity, real-world functioning or support needs;

  • tool outputs must be capable of being corrected, supplemented or overridden where they do not reflect real-world risk, sustainability, safeguarding concerns or support need;

  • functional assessment tools must not be used as intervention taxonomies or as the sole basis for determining which supports a participant may access; and

  • rules made under proposed s 9B(2) and (3) should not be able to exclude contextual evidence where that evidence is necessary to understand the person’s disability-related functional impact.

AARPN supports greater consistency in functional assessment. However, consistency should not be achieved by defining functional capacity only in the way needed to make a tool work. A tool may assist the Scheme to assess participants, but it should not be the only input.

  • Amend proposed s 9B to ensure that functional capacity includes real-world functional impact and contextual barriers. AARPN Submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 6

Submission 431

  • Require in the legislation that any assessment tool, scoring method, manual, threshold or classification used for access or planning to be published, validated, independently reviewed and subject to meaningful consultation with people with disability and relevant clinical/disability experts.

  • Require decision-makers to consider credible medical, allied health, developmental, functional, family and support- system evidence where it exists and is relevant to the person’s functional capacity and support needs.

Unscheduled plan reassessments — Schedule 1, Part 2 Schedule 1, Part 2 of the Bill limits who may request plan reassessment and requires stronger controls around unscheduled reassessments. The Explanatory Memorandum describes this as ensuring reassessments occur where there is a genuine and ongoing change in support needs. This appears appropriate in that providers should not be able to repeatedly drive plan reviews for commercial benefit, but the danger is that the same controls/narrow thresholds may trap participants in inadequate plans. We would respectfully posit that a provision designed to stop opportunistic reassessments must not prevent legitimate reassessment where support needs have materially changed or where an earlier plan was wrong. Further, a plan can become unsafe or unworkable because a key informal support collapses, a provider withdraws, a rural service disappears, a participant’s housing changes, family violence or neglect emerges, equipment fails, school or employment circumstances change, or a child’s developmental needs escalate. These circumstances may not fit neatly into a narrow conception of “genuine and ongoing change”, but they can make a plan inadequate or unsafe.

  • Preserve an urgent reassessment pathway where a plan becomes unsafe, insufficient or impossible to implement, including because of carer collapse, provider failure, market failure, crisis, safeguarding risk, family violence, housing breakdown, or other significant change in practical circumstances.

  • Require clear written reasons and preserve merits review rights for any decision that a requested reassessment will not proceed, including where the CEO is not satisfied that proposed s 48A is met.

  • Ensure that the persons able to request reassessment include, at minimum, the participant, the participant’s plan nominee and, for children, the person authorised under s 74, and consider whether additional guardians, correspondence nominees or appropriate representatives should be able to initiate reassessment where the participant’s disability, communication needs, age or circumstances make direct request impracticable.

Linking supports to eligible impairment — Schedule 1, Part 3 Schedule 1, Part 3 seeks to strengthen the link between a participant’s eligible impairment and the support need. The apparent policy aim is to clarify the boundary between NDIS-funded supports and mainstream services. The danger is that “arising directly from” may be applied too narrowly where support need results from the interaction between eligible impairment, co-occurring conditions, developmental factors, communication barriers, family-system fragility or environmental barriers. Disability support needs are often cross-domain and multi-causal. Many participants have interacting impairments, comorbidities, environmental barriers and social determinants that shape functional need. A support may be necessary because of the combined effect of impairments, even if one impairment is the gateway impairment and another is contributory. We would respectfully observe that an overly linear causation test may exclude real functional support needs that arise from the person’s disability as lived.

  • Clarify that supports may be funded where they are materially connected to, or made necessary by, an eligible impairment, including where the support need is compounded by co-occurring conditions, developmental disability, psychosocial disability, communication barriers, swallowing/mealtime risk, family-system risk or environmental barriers.

  • Require decision-makers to consider whole-person disability impact rather than narrowly isolating impairments in a way that risks mischaracterising support needs.

AARPN Submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 7

Submission 431

Examples of multiple domains and multiple professions:

Example 1 — Autism, sensory-sensitivity eating (texture/smell/temperature avoidance) Functional presentation: restricted eating due to sensory processing differences; high distress at meals; limited variety → nutrient gaps risk. Domains affected (functional): eating/drinking (self-care), routines (general tasks), communication (instructions/AAC), and sometimes senses/mental health/behaviour (depending on tool/modules). Professionals might include but are not limited to: Speech Pathologist, Occupational Therapist, Developmental Educator, allied health credentialed Nutritionist (CPN). Therapy bundle required (interventions):

  • sensory-compatible nutrition plan (safe food base + gradual “food chaining”)
  • structured routine + scripts for consistent prompting
  • carer/support worker training for implementation across shifts
  • monitoring (intake, bowel function, growth/weight where relevant) If eligible functional impairment is tightly linked via the assessment mechanism to only one domain/category of therapy support, the participant may lose coverage for essential enabling activities (e.g., supporter training and routine design) that make for example, the nutrition plan. workable.

Example 2 — ABI / dementia with executive dysfunction (can’t plan meals or shop safely) Functional presentation: can’t initiate/sequence tasks; forgets meals; unsafe food choices; fluctuating capacity. Domains affected: routines/tasks, domestic life (shopping/cooking), self-care (eating/drinking), sometimes behaviour/mental health. Professionals might include but are not limited to: Occupational Therapist, allied health credentialed Nutritionist (CPN).

Therapy bundle required:

  • simplified meal structure + “minimum viable intake” plan
  • environmental supports (visual schedules, prompts, pre-portioning)
  • supporter training + handover protocols across rosters
  • monitoring and rapid adjustment as function fluctuates If “planning/shopping” sits in a different bucket than “eating/drinking” or “health maintenance,” linking the eligible functional impairment to a single category allocation or therapy support can underfund the integrated supports that keep the person safe and nourished.

Support determinations and underfunding — Schedule 1, Part 4, proposed s 34A The proposed s 34A permits the Minister, by legislative instrument, to reduce funding component amounts for specified groups of supports. The determination operates without requiring individual plan alteration. Although the Minister must have regard to participant safety, the Bill does not require individualised assessment of whether the reduction will leave a participant unable to purchase essential supports. The Bill states that a determination may have effect even if the result is that funding for reasonable and necessary support, or for all reasonable and necessary supports funded under the plan taken as a whole, is less than the total cost of those supports (sch 1 pt 4 item 34, proposed s 34A(5)). This is one of the most significant provisions in the Bill because it creates a legal gap between what the Scheme accepts is reasonable and necessary and what it funds. That creates a de facto rationing mechanism that may be invisible to participants because the plan text is not necessarily altered, yet the amount available to purchase supports is reduced. It may also create indirect cost-shifting to families, unpaid carers, state systems, charities, service providers and participants themselves.

If Parliament intends to introduce a co-contribution or partial-funding model for certain supports, that should be done openly and directly. It should not be achieved by a mechanism that maintains the language of reasonable and necessary supports while allowing the funded amount to be less than the cost of acquiring those supports.

AARPN Submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 8

Submission 431

  • Require any reduction determination to be disallowable, accompanied by reasons, consultation, impact modelling, human-rights impact analysis, thin-market analysis and a clear exception/top-up pathway.

  • Require individual notice where a determination materially affects purchasing power, including accessible explanation of review and exception rights.

Plan renewal by operation of law — Schedule 1, Part 5, proposed s 50A and item 59 Schedule 1, Part 5 creates a plan-renewal mechanism, including automatic renewal of some old framework plans as new plans by force of the proposed s 50A. Item 59 also deals with renewal of old framework plans approved before 9 October 2024, including treatment of support groups, funding component amounts and funding periods for plans that do not contain the newer matters required by s 33(2A). The Explanatory Memorandum states that plan renewals replicate existing plans subject to specified alterations.

Participants should not be left without a plan because the Agency cannot complete reassessment on time, however, automatic renewal can also reduce visibility on any aspects of the plan that have been impacted by ministerial determinations, pricing instruments, indexation methods, removal of one-off supports, or other instruments that might change the real or practical value of a plan. If a plan is renewed by operation of law, participants may not understand what has changed, what has been carried over, what funding components now mean, or specifically how the renewal interacts with indexation, pricing, support determinations and claim rules.

  • Require clear participant-facing notice before and after renewal, identifying what has been renewed, what funding components and periods apply, whether any amount has changed, and what review or reassessment rights are available.

  • Preserve and clearly explain review rights for any practical change in entitlement, funding amount, support category, plan flexibility or purchasing power arising from renewal, even where the technical mechanism is renewal by operation of law.

  • Ensure automatic renewal cannot be used to avoid substantive reassessment where a plan is unsafe, outdated, exhausted, unworkable or inconsistent with current support needs.

  • Retain and strengthen the Bill’s protection for existing review rights where an old framework plan is renewed by force of the proposed s 50A, including by requiring accessible notice, urgent review, continuation of critical supports and review of any later revocation.

  • Retain and strengthen the protection that existing plan review proceedings should not be extinguished by renewal and require that this be clearly explained in renewal notices.

Reasonable and necessary supports, sustainability and family responsibility — Schedule 1, Part 6 Schedule 1, Part 6 amends the reasonable and necessary support framework, including by making financial sustainability more explicit in the objects and support criteria. The Bill also includes more detailed matters relevant to value for money, efficacy and beneficial effect, including emphasis on published, peer-reviewed and generalisable evidence. The Bill gives priority, where multiple forms of evidence are being considered, to research and evidence that is published, peer-reviewed and generalisable. This may improve the consistency of evidence reviewed, but it may also disadvantage supports where the best available evidence is individualised, functional, developmental, behavioural, observational or practice based. We have further noted the context of this requirement in that under the CRPD (United Nations, 2006), a reduction may be justified only if it is lawful, evidence-based, proportionate, transparent, targeted, non-discriminatory and the least rights-restrictive option available.

We feel that particular care is needed in relation to children and families. The Bill’s approach should not allow “ordinary parental responsibility” to be stretched into an expectation that parents provide disability-level support that is unsustainable or incompatible with employment, family life, siblings’ wellbeing, parental health or child safety. The NDIS should not replace ordinary family care, but neither should it use families as the hidden safety net for refusal of supports or underfunding.

  • Make clear that financial sustainability is a scheme stewardship principle and cannot, by itself, justify refusal of an otherwise necessary individual support where refusal would create safety, neglect, family breakdown or human-rights risks.

AARPN Submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 9

Submission 431

  • Amend evidence provisions so that participant-specific clinical, functional, developmental, allied health, family-system and other observational/outcomes evidence can outweigh a lack of generalisable trial evidence where the support is clinically justified and risk-managed.

  • Require decision-makers to consider the sustainability of informal supports and the risks of unpaid-care substitution, especially for children, people with complex disability, regional participants and participants with limited family support.

Suspension and non-contactability — Schedule 1, Part 7 Although the proposed s 40A requires “reasonable attempts” to contact the participant and makes suspension reviewable, the Bill should specify minimum accessible-contact safeguards before suspension or revocation can occur. These should include multiple communication modes, contact with nominees or authorised representatives where appropriate, checks for hospitalisation, homelessness, family violence, incarceration, cognitive impairment, psychosocial crisis, digital exclusion, communication disability and known safeguarding risk.

Suspending a plan in those circumstances may remove supports at the very point the person is most at risk. The Bill should therefore treat non-contactability as a safeguarding trigger before it becomes a compliance trigger.

  • Although the Bill requires reasonable attempts to contact the participant before suspension, AARPN submits that “reasonable attempts” should be defined in disability-informed terms and should require documented accessible outreach using multiple communication methods, including contact through authorised representatives or support networks where appropriate and safe.

  • Require safeguarding risk assessment before suspension, including consideration of family violence, neglect, coercion, homelessness, communication barriers, cognitive impairment and nominee/provider misconduct.

  • The Bill should not permit whole-plan suspension where this would interrupt critical supports needed for safety, housing, personal care, eating and drinking, communication, behavioural stability, medication-related routines or protection from neglect. If suspension is retained, the Bill should create a partial-suspension or critical-support-continuity mechanism.

Permanence, treatment and alternative supports — Schedule 1, Parts 8 and 9 Schedule 1, Part 8 tightens the meaning of permanence where an impairment can be treated, including by providing that treatment can be considered appropriate even if financial or geographical circumstances affect whether the person can access or undertake that treatment. Schedule 1, Part 9 deals with eligibility based on access to other services and alternative supports. The proposed s 25B enables certain impairments or support needs to be treated as excluded where compensation systems, workers compensation systems or declared alternative supports are considered responsible. Although the relevant rule-making pathway may require state and territory agreement, the participant-facing risk remains that eligibility may be narrowed by reference to another system’s nominal responsibility rather than the person’s actual, timely and enforceable access to supports.

The legitimate aim is to ensure that the NDIS remains focused on permanent and significant disability and does not become a substitute for health, education, child development, mental health, housing, justice or other service systems. The danger is that treatment may be treated as “appropriate” for legislative purposes even where it is not practically available, affordable, timely, clinically suitable, culturally safe or accessible to the participant. A person should not be excluded from the NDIS because a treatment exists in principle if that treatment is unaffordable, geographically unavailable, waitlisted, contraindicated, culturally unsafe, age-inappropriate, clinically unsuitable or insufficient to address disability-related functional need.

Similarly, alternative supports must be real, funded, accessible and sufficient. The creation of foundational supports, including supports such as Thriving Kids, cannot be relied on as a basis to narrow NDIS access until those supports actually exist at scale and are demonstrably able to meet the relevant needs.

  • Amend the Bill so that treatment is “appropriate” only where it is clinically suitable, reasonably accessible, affordable or funded, available within a reasonable time, culturally safe and sufficient to address the impairment-related functional impact.

AARPN Submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 10

Submission 431

  • Require alternative supports to be real, available, funded, accessible, timely and sufficient before they can be relied on to refuse, narrow or revoke NDIS access or supports.

  • Require no participant to be exited or excluded on the basis of a theoretical mainstream or foundational support unless there is a warm transfer and continuity of essential supports.

Schedule 2: Provider, fraud and integrity measures

Provider definition and risk-proportionate registration — Schedule 2, Part 1 Schedule 2, Part 1 does not of itself establish the full provider-registration model. It amends the definition of NDIS provider and creates the legislative doorway through which future registration and regulatory settings may operate. AARPN therefore recommends that the rules and implementation framework built on the proposed s 10C adopt a risk-proportionate model that recognises existing professional governance.

A cost-effective model is professional-body coordination and verification-based provider enrolment. For regulated and robustly self-regulating professions, provider entry should be light touch where the practitioner is already subject to professional standards, qualification verification, codes of conduct, complaints mechanisms, CPD, insurance and recency requirements. For example, AHPRA-registered practitioners and practitioners credentialed by robust national self-regulating allied health bodies should be able to satisfy relevant NDIS provider-governance requirements through professional standing, subject to any service-specific NDIS safeguards.

The NDIS should reserve full registration, audit and intensive compliance for higher-risk services, such as supported independent living, high-intensity daily personal activities, behaviour support, restrictive practices, services involving high safeguarding risk, and providers with complex corporate structures or poor compliance history. This better aligns regulation to risk and reduces duplicative burden for small, ethical, clinically governed providers.

  • Create an “enrolled provider” tier for low to moderate-risk professional services where provider identity, qualification, insurance, complaints, CPD and conduct are verified through recognised professional bodies.

  • Allow the NDIS Commission to recognise professional bodies that meet minimum governance criteria, including single- profession competence, transparent standards, public complaints mechanisms, disciplinary powers, CPD, insurance and recency requirements.

  • Use full registration and audit for high-risk services and provider models including where there is vertical integration present, rather than applying the same regulatory load to all providers regardless of existing professional governance.

A professional governance body for support workers The Bill uses provider definition, registration, compliance and enforcement powers to compensate for a structural weakness in the NDIS market such as support worker lacking an independent professional governance body. Government seed funding for a national support worker professional body would reduce the regulatory burden otherwise falling on the NDIA and NDIS Commission by creating role boundaries, minimum training expectations, a code of conduct, CPD expectations, supervision norms, complaints pathways and a worker register. In the absence of such a body, the NDIA and NDIS Commission are forced to take on functions that professional bodies usually perform including role definition, practice expectations, ethical standards, credentialing, complaints referral, supervision norms, CPD, and potentially workforce identity. The establishment of a professional body for NDIS Support Workers, would also allow the NDIS provider-registration model to distinguish between risks created by the worker, the provider organisation and the service environment. It would also reduce the pressure to regulate all support worker-related risk through provider registration alone.

  • Establish a seed-funded, independent national support worker professional body with governance independent of employers, platforms and training providers.

  • Require the body to develop support worker role standards, levels of practice, a code of conduct, CPD expectations, safeguarding and escalation standards, supervision principles, complaints triage and a public register.

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  • Enable NDIS enrolled-provider models to rely on support worker professional membership/registration as part of workforce assurance, while retaining provider accountability for supervision, employment, rostering, incident management and restrictive-practice compliance.

Fraud, civil penalties, information gathering and participant protection — Schedule 2, Parts 2 and 3 AARPN recognises that the Bill includes some participant-facing safeguards, including exclusions from compliance notices and enforceable undertakings, and a requirement for conditions before monitoring or investigation powers are exercised in relation to participants or prospective participants. However, these safeguards should be extended across the broader integrity architecture, including information-gathering, record-retention, debt, claim-timeframe and adverse administrative consequences.

The Disability Royal Commission documented the vulnerability of people with disability to violence, abuse, neglect and exploitation (Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, 2023). AARPN supports strong action against fraud, exploitation and deliberate misuse of NDIS funds. Fraud has a direct human cost and undermines participant safety, provider trust and public support for the Scheme. However, fraud measures must distinguish deliberate exploitation from disability-related difficulty, administrative error, provider failure, nominee misconduct and good faith misunderstanding.

  • Insert proportionality, reasonable-excuse, disability-accessibility, hardship and safeguarding requirements before civil penalties or debt recovery are applied to participants or nominees.

  • Require the NDIA or Commission to consider whether non-compliance reflects provider misconduct, nominee coercion, digital exclusion, cognitive impairment, communication barriers, family violence, homelessness or administrative complexity.

  • Ensure information-gathering powers are targeted, privacy-protective, accountable and subject to clear reasons, timeframes and review pathways.

Record retention and claim timeframes — Schedule 2, Parts 4 and 5 Schedule 2, Part 4 deals with retention of records and Part 5 reduces claim times. Providers may face civil penalties for failure to retain required records. Participants and other individuals who receive NDIS amounts may face debt consequences where records are not retained. Further, a 90-day claim timeframe may be reasonable for ordinary claims administration, but the Bill should include exceptions where late claiming results from disability-related incapacity, family violence, disaster, provider failure, nominee misconduct, hospitalisation, administrative error, digital exclusion, platform failure or other circumstances beyond the participant’s control.

Records integrity and timely claiming (and invoicing) are reasonable objectives; however, NDIS participants may face difficulties for reasons unrelated to fraud, including disability, cognitive impairment, reliance on nominees, provider closure, platform failure, family violence, homelessness, disasters, digital exclusion or service disruption.

The ANAO has identified the importance of effective controls around NDIS participant plans and claimant compliance (Australian National Audit Office, 2020, 2025). Those controls should be targeted and risk-based, and they should not create a blunt rule where an otherwise legitimate support becomes a debt or penalty merely because documentation is imperfect.

  • Permit alternative evidence of support delivery, including provider records, bank records, appointment records, care notes, clinical notes, communications, statutory declarations or other credible evidence.

  • Provide exceptions or extensions where records or claims are affected by disability-related barriers, nominee or provider misconduct, family violence, disasters, serious illness, digital exclusion or administrative delay outside the participant’s control.

  • Apply retrospective penalties cautiously and proportionately, with safeguards for good-faith participants and small providers.

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Registered plan management providers and vertical integration — Schedule 2, Part 6 Schedule 2, Part 6 introduces restrictions and obligations relating to registered plan management providers, including related party concerns. Schedule 2, Part 6 is a useful and necessary start because it recognises the conflict-of-interest risk where a plan manager can also influence or benefit from participant spending. However, the conflict model should not stop at plan management. Comparable controls should apply to support coordination, psychosocial recovery coaching, navigation or connection functions, assessment-linked services, nominee-linked services and provider group structures where a provider materially influences participant choice, support design, assessment evidence or expenditure.

This is a positive recognition that intermediaries who control or influence participant spending can create conflicts of interest. However, the Bill’s response is too narrow if it is limited to registered plan management providers. Vertical integration can be harmful where the same corporate group, related parties or financially connected entities influence a participant’s plan, recommend services, control claims, provide support coordination or psychosocial recovery coaching, and then supply the downstream services. This can reduce participant choice, inflate utilisation, obscure quality problems and make it harder for participants to change provider. It can also convert the participant’s plan into a revenue pipeline for a vertically integrated provider group.

  • Extend conflict-of-interest controls to support coordination, psychosocial recovery coaching, navigation/connection functions, assessment-linked services and any provider role that significantly influences participant spending or provider choice.

  • Prohibit a provider, related party, key personnel or common-control entity from both influencing participant purchasing decisions and supplying downstream direct supports unless a narrow exception applies.

  • Permit exceptions only for genuine thin markets, cultural safety, participant preference after independent advice, or emergency continuity, and require disclosure, informed consent, time limits, independent oversight and audit.

  • Require public disclosure of ownership, related-party relationships, referral arrangements, cross-directorships, subcontracting and financial benefit where an intermediary role and downstream support role are connected.

Schedule 3: Governance arrangements

Maximum pricing and ministerial pricing power — Schedule 3, Part 1, proposed ss 34B and 45C Schedule 3, Part 1 creates a legislative pricing mechanism, including indexation and pricing determinations. Although proposed s 45C allows differentiated pricing by support type, provider type, remoteness, delivery mode and other circumstances, it does not require transparent publication of the methodology, evidence, assumptions, market modelling or reasons. The Bill should therefore require pricing determinations to be supported by published methodology, independent advice, consultation outcomes and explicit consideration of regional viability, thin markets, complexity, safeguarding obligations and workforce quality.

We have seen that the existing price guide can operate as a de facto market price and can distort service models, especially where providers price to the cap rather than to cost, quality or participant outcome. However, maximum prices set below the cost of safe and competent service delivery also need to be avoided because they can create a situation where participants may retain funding on paper but be unable to purchase supports. In this instance, providers may exit thin markets, reduce face-to-face time, substitute less qualified workers such as assistants, refuse complex participants, or geographically concentrate in profitable metropolitan markets. This risk is acute for regional, remote, and specialist allied health services.

The Bill also gives the Minister significant market-shaping power. Ministerial accountability is democratic, but statutory design must recognise that Ministers change. A power that appears benign in one office-holder’s hands may be used differently by another under fiscal, political or media pressure. Pricing should therefore be supported by independent evidence and transparent constraints.

  • Create an independent or statutorily protected pricing advisory function, with published methodology, reasons, consultation outcomes and advice, subject to appropriate confidentiality for commercial data.

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  • Require pricing determinations to consider participant outcomes, provider viability, workforce quality, regional and thin markets, complexity, safeguarding obligations, clinical risk, cultural safety obligations/requirements, and administrative burden.

  • Require loadings or exceptions for complexity, rurality, thin markets, culturally safe delivery, high-intensity supports and services requiring specialised clinical expertise.

  • Prohibit pricing determinations that knowingly make essential supports unavailable in a participant’s market unless an exception/top-up mechanism is available.

Automation of administrative action — Schedule 3, Part 2, proposed ss 59B–59E Schedule 3, Part 2 is one of the most serious governance risks in the Bill. Although the initial designated provisions are ss 33, 45, 45A and 45C, the proposed s 59C would allow the Minister, by legislative instrument, to add further provisions. The Bill should therefore prohibit future designation of provisions affecting access, participant status, plan content, funding components, budget amounts, reassessment, suspension, revocation, debt, compliance action or adverse claim decisions unless a human delegate independently considers the evidence and makes the final decision.

Automation can be appropriate for low-risk, mechanical and objectively verifiable tasks such as arithmetic calculations, duplicate detection, routing, reminders, date checks and payment matching. It is dangerous when it determines or materially influences access, participant status, plan content, funding amounts, claim refusal, compliance action, debt, suspension, revocation or whether a participant can obtain the supports needed to live safely. An algorithmic system used to allocate NDIS funding is not neutral because by its very construction, it encodes policy choices, thresholds, assumptions, training data, proxy variables, budget constraints and design decisions. Further, if the model or algorithm is wrong, the error is not isolated to one delegate and can be replicated at scale across thousands of participants before anyone understands the pattern. There is also a practical disability-specific risk in that disability support needs are contextual, fluctuating and relational. A system may not detect informal support breakdown, coercion, communication barriers, episodic psychosocial disability, fatigue, pain, sensory overload, masking, behavioural risk, environmental barriers, degenerative change, intersection with child protection, cultural safety needs, regional service failure or carer burnout.

The Explanatory Memorandum identifies safeguards such as standard operating procedure instruments, CEO oversight, notices, publication and annual reporting. These are useful but inadequate - a standard operating procedure instrument is a notifiable instrument, not a legislative instrument. Failure to comply with certain oversight and notification safeguards does not affect the validity of automated action (proposed ss 59E(3) and 59E(5)).

The Robodebt Royal Commission demonstrates the danger of automated or automated-adjacent administrative systems that create an appearance of objectivity while weakening legal reasoning, human judgement, accountability and remedy (Royal Commission into the Robodebt Scheme, 2023). In the NDIS, the stakes are high and errors are not merely financial; they can produce neglect, harm, service withdrawal and loss of independence.

  • Prohibit full automation of administrative action affecting access, participant status, plan content, funding components, budget amounts, reassessment, reasonable and necessary supports, claim refusal, debt, compliance action, suspension, revocation or any adverse decision.

  • Limit automation to low-risk, mechanical and objectively verifiable administrative tasks unless a human delegate independently considers the evidence and makes the final decision.

  • Require plain-English notices to state whether automation was used, what data and rules were applied, what version of the tool was used, how to obtain human review, and how to challenge the decision.

  • Require pre-deployment algorithmic impact assessment, human-rights impact assessment, bias testing, accessibility testing, disability-specific risk assessment, independent audit, version control, error reporting and suspension powers for tools producing systemic error.

  • Make non-compliance with core automation safeguards affect validity for adverse decisions. Safeguards whose implementation does not matter legally are not real safeguards for participants.

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Submission 431

Schedule 4: New framework planning The Explanatory Memorandum states that new framework planning is intended to support more person-centred and consistent budgets, reduce expensive reports, simplify plans and provide longer plan periods. Schedule 4 amends the framework for support needs assessment and budget setting so that NDIS Rules and methods may identify support needs, classify levels of need and specify funding amounts, including by applying, adopting or incorporating assessment tools, questionnaires, manuals or other documents.

Functional assessment tools can describe support needs, but they are not necessarily intervention taxonomies or budget calculators. The selected I-CAN tool classifies functional capability and support needs, not interventions. The I-CAN tool has domains of functional capability; however, one therapy activity often targets multiple domains, and one domain often requires multiple intervention types and sometimes multiple professions. If NDIA uses domain-grouping as a gate or silo (rather than a guide), it risks misclassification and restricted access. Disability support needs frequently cross domains (e.g., executive function + sensory + behaviour + health-interface). A rigid domain-linked category system can “orphan” supports that address upstream drivers (e.g., routines/decision supports that enable eating/drinking). Determining “assessed need for therapy,” selecting the right intensity, and interpreting evidence is a clinical reasoning task in practice. If the assessor workforce is not clinically qualified, the system needs strong safeguards: clinical escalation, governance, and robust validation of the decision pathway, and these safeguards likely need to be included in this Bill. Functional assessment tools require clinical and disability-informed interpretation, or they may miss cross-domain needs, informal-support fragility, communication barriers, episodic symptoms, family-system constraints, rurality, provider availability, cultural safety, trauma, safeguarding risk and the cumulative needs of multiple impairments.

  • Require assessment tools, manuals, scoring methods, algorithms, funding-level methods and budget conversion rules to be published, validated, independently audited and subject to parliamentary scrutiny where they materially determine funding.

  • Require human clinical and functional interpretation before assessment outputs are converted into budget amounts, especially for complex disability.

  • Require an exception/escalation pathway where tool output is inconsistent with observed function, risk, participant evidence, specialist evidence, family sustainability, or environmental barriers.

  • Prohibit budget methods that knowingly produce funding below the level needed to acquire essential supports, unless an individual top-up and urgent review mechanism is available.

Schedule 5: Transitional rules and the problem of future misuse Schedule 5 permits the Minister, by legislative instrument, to make transitional rules and to prescribe modifications to the operation of provisions of the NDIS Act and transitional provisions in the Bill. The power is limited in that rules cannot be made after 12 months and are repealed after 12 months unless an earlier time is specified. The Bill also includes that transitional rules cannot create offences or civil penalties, provide arrest/detention or entry/search/seizure powers, impose a tax, set an appropriation amount or directly amend the text of an Act. Although Schedule 5 is time-limited and includes some express limits, it still permits transitional rules to modify how provisions of the NDIS Act and the Bill operate during transition. We respectfully suggest that such power should not be capable of narrowing review rights, validating unlawful administrative action, expanding automation, imposing new information burdens or altering eligibility or planning standards in a way adverse to participants.

  • Provide that transitional rules cannot narrow review rights, validate unlawful administrative action, expand automation, impose new information burdens, or alter eligibility/planning standards in a way adverse to participants.

  • Require consultation with disability representative organisations and relevant professional/provider bodies before transitional rules affecting participants, providers or markets are made.

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Conclusion

AARPN supports the objective of securing the NDIS for future generations. It is appropriate for Parliament to address fraud, conflicts of interest, poor record keeping, unsafe provider behaviour, inconsistent decision-making, market distortions and the long-term sustainability of the NDIS. Participants themselves are harmed when funds are siphoned away through fraud, overcharging, collusion or poor-quality services. However, the Bill as drafted places too much legal and practical risk on participants. It narrows access and support entitlement, permits funding constraints by instrument, treats some reductions as matters of law rather than reviewable decisions, potentially allows alternative service systems to operate as eligibility gates even where those systems may not be accessible or practically meet need, and authorises automation of administrative action in ways that are not sufficiently confined. Further, functional capacity is intended to be assessed as intrinsic ability; reasonable funding may be less than actual cost; future rules and instruments will fill critical detail; computer programs may make evaluative determinations; and failure to comply with some automation safeguards will not affect validity. AARPN recognises that government has both the authority and responsibility to manage NDIS expenditure in the public interest. AARPN accepts that government has a responsibility to control public expenditure and ensure the NDIS remains financially sustainable. The key closing question for the Inquiry to consider is whether this Bill achieves that responsibility by strengthening the Scheme itself, or whether some provisions secure budget control in ways that may weaken the safeguards, transparency and access to reasonable and necessary supports needed to preserve the Scheme’s legitimacy.

Natasha Radcliffe AARPN Chair & CEO

CPN (AARPN)

29/05/2026.

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References

Attorney-General’s Department. (2024). Use of automated decision-making by government: Consultation paper.

Australian Government. https://consultations.ag.gov.au/integrity/adm/

Australian Human Rights Commission. (2021). Final report: Human rights and technology. https://humanrights.gov.au/resource-hub/by-resource-type/publications/technology-and-human-rights/final-report human-rights-and-technology

Australian Human Rights Commission. (2025). Use of automated decision-making by government. https://humanrights.gov.au/resource-hub/by-resource-type/submissions/use-of-automated-decision-making-by government

Australian National Audit Office. (2020). Decision-making controls for NDIS participant plans (Auditor-General Report No. 14 2020–21). Commonwealth of Australia. https://www.anao.gov.au/work/performance-audit/decision-making controls-ndis-participant-plans

Australian National Audit Office. (2025). National Disability Insurance Agency’s management of claimant compliance with National Disability Insurance Scheme claim requirements (Auditor-General Report No. 48 2024–25). Commonwealth of Australia. https://www.anao.gov.au/work/performance-audit/ndia-management-claimant compliance-ndis-claim-requirements

Department of Health, Disability and Ageing. (2026). NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 fact sheet. Australian Government. https://www.health.gov.au/resources/publications/ndis-amendment-securing the-ndis-for-future-generations-bill-2026-fact-sheet

NDIS Review. (2023). Working together to deliver the NDIS: Final report. Australian Government. https://www.ndisreview.gov.au/resources/reports/working-together-deliver-ndis

Office of Parliamentary Counsel. (2026). Instruments handbook. Australian Government. https://www.opc.gov.au/publications/opc-instruments-handbook

Royal Commission into the Robodebt Scheme. (2023). Report of the Royal Commission into the Robodebt Scheme. Commonwealth of Australia. https://robodebt.royalcommission.gov.au/publications/report

Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability. (2023). Final report. Commonwealth of Australia. https://disability.royalcommission.gov.au/publications/final-report

United Nations. (2006). Convention on the Rights of Persons with Disabilities. https://www.ohchr.org/en/instruments mechanisms/instruments/convention-rights-persons-disabilities

Legislation and Bill materials cited

Explanatory Memorandum, National Disability Insurance Scheme Amendment (Securing the NDIS for Future

Generations) Bill 2026 (Cth).

https://www.aph.gov.au/Parliamentary Business/Bills Legislation/Bills Search Results/Result?bId=r7487

Legislation Act 2003 (Cth). https://www.legislation.gov.au/C2004A01224/latest/text

National Disability Insurance Scheme Act 2013 (Cth). https://www.legislation.gov.au/C2013A00020/latest/text

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National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Act 2024 (Cth). https://www.legislation.gov.au/C2024A00081/asmade/text

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 (Cth).

https://www.aph.gov.au/Parliamentary Business/Bills Legislation/Bills Search Results/Result?bId=r7487

Privacy Act 1988 (Cth). https://www.legislation.gov.au/C2004A03712/latest/text

Regulatory Powers (Standard Provisions) Act 2014 (Cth). https://www.legislation.gov.au/C2014A00093/latest/text

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