National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 453
Submission Regarding the NDIS Future Generations Reforms
I am writing to express serious concerns regarding the proposed changes under the NDIS Future Generations reforms and the broader direction of current NDIS policy. My concerns arise both from professional experience supporting people with disabilities and from observing the real-world impacts of existing systemic failures within the scheme. I am an occupational therapist working within the scheme since its inception. I work with adults with significant and permanent disabilities, many of whom require 24-hour support.
While I acknowledge the importance of ensuring the long-term sustainability of the NDIS, I am deeply concerned that the reforms place disproportionate emphasis on cost reduction and “value for money” measures without adequately considering participant outcomes, human rights, quality of life, or downstream costs to other systems. It appears that defence spending and support for gas exports has been prioritised over the lives of people with a disability.
There is little evidence that the disability community has been consulted in the development of this new bill which appears to be getting rushed through for political motivations.
Value for Money Versus Meaningful Outcomes
The increasing focus on “value for money” appears to prioritise spending less, even where this may result in poorer participant outcomes. Cost effectiveness cannot be assessed solely through immediate financial expenditure without considering broader social, health, and economic consequences.
For many participants, appropriate supports reduce hospital admissions, prevent mental health deterioration, maintain family stability, and enable participation in society including employment. A support that appears expensive in isolation may ultimately reduce costs elsewhere while significantly improving quality of life and safety.
A narrow interpretation of “value” risks reducing participants to budgetary considerations rather than recognising them as members of the community with equal rights to participation, dignity, and wellbeing.
Over reliance on Scientific Evidence While Discounting Lived Experience
I am concerned by the increasing emphasis on scientific evidence as the primary basis for funding decisions, particularly where robust evidence may not yet exist. There are many areas of practice which do not have any evidence at all, even for disabilities with a long history in medicine.
Many disability supports, especially those involving complex behavioural support, sensory regulation, social participation, or highly individualised interventions, are areas where formal research evidence is limited. This does not mean those supports are ineffective.
The lived experience of participants, families, disability support workers, allied health professionals, and carers should be recognised as valid and necessary evidence. Disability is highly individual, and outcomes cannot always be captured through standardised research models.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 453
An overreliance on formal evidence risks excluding people with rare, complex, or poorly researched disabilities from receiving appropriate supports.
Concerns Regarding Social and Community Participation Funding
The proposed restrictions and scrutiny around social and community participation funding send a concerning message that society does not value the presence of people with disabilities in public and community life.
Community participation is not a luxury. It is fundamental to inclusion, physical health, mental health, skill development, social connection, emotional regulation, and quality of life. It is required for people to attend appointments, use transport, complete grocery shopping, exercise, collect medication and work.
There also appears to be an assumption that participants only require support because they are leaving their homes. In reality, many participants would require similar levels of support regardless of location. Removing community access funding does not eliminate support needs; it simply confines people to their homes and increases social isolation.
This approach risks reinforcing segregation and exclusion rather than promoting inclusion and citizenship. The government is risking the gains made by disability advocacy in recent years, especially when the media communicate a distorted view of how these funds are actually utilised.
Failure to Address Existing Systemic Issues Within the NDIS
The reforms do not appear to adequately address many of the systemic issues currently causing harm within the NDIS, including:
excessive delays in access and plan decisions poor communication with participants and providers inconsistent decision-making unskilled or inadequately trained staff making decisions about highly complex disabilities lack of transparency and accountability barriers to timely review processes
Many participants are already experiencing significant distress due to administrative failures rather than the nature of their disabilities.
The system also requires mechanisms for rapid access pathways for people with degenerative or rapidly progressing conditions, where delays can result in irreversible decline before supports are implemented.
Functional Capacity Assessments and the WHO ICF Model
There are significant limitations in relying heavily on Support Needs Assessment and functional capacity without appropriately considering environmental and social factors.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 453
The WHO International Classification of Functioning, Disability and Health (ICF) recognises that disability is not solely determined by individual impairment, but also by the interaction between a person and their environment. A participant’s functioning may vary dramatically depending on sensory environments, social expectations, accessibility, support availability, communication demands, and physical surroundings. Assessments that fail to incorporate these contextual factors risk inaccurate representations of disability and support needs.
Assessments which do not allow the person to communicate in the way they can (AAC, support person, interpreter, extra time, face to face) due to time restrictions are not reliable or person centred. Assessments which rely on the subjective report of a person or caregiver may not be reliable, without any corroboration. This is certainly the case for many participants with cognitive or intellectual impairments.
Inadequately trained or staff with no practical understanding of disability should not be completing these critical assessments and making decisions that will significantly impact the daily lives of the participant.
Shifting Burden Onto Unpaid Supports
Reducing funded supports frequently shifts responsibility onto unpaid carers and family members rather than removing the need itself. This approach is unsustainable and risks:
carer burnout family breakdown increased mental health crises preventable hospital admissions increased emergency service use greater reliance on Supported Independent Living (SIL), STR and other out-of-home care
The long-term costs of inadequate early and community-based support are likely to exceed any short-term savings generated through funding reductions. People are less likely to be able to remain living at home with informal supports.
Barriers to Accessing Healthcare and Treatment
The reforms must also acknowledge that many people with disabilities face substantial barriers to accessing healthcare and treatment that may technically be “available” to the broader population.
In my professional experience, I support individuals with severe intellectual disabilities and significant sensory processing differences who are unable to safely attend dentists, GP clinics, imaging centres, or other healthcare environments. Some cannot even attend a park, gym or pool to exercise. These situations can result in extreme distress and behaviours that place the individual, staff, carers, and others at risk of harm.
In practice, this means many participants cannot simply access “mainstream” treatment options without substantial disability-specific support, environmental modification, behavioural support strategies, specialised practitioners, or sedation pathways.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 453
Policy assumptions that participants can independently engage with mainstream healthcare systems to exhaust all treatments fail to reflect the realities faced by many people with complex disabilities. It also does not recognise that many of the disabilities faced by this cohort on the NDIS are not going to be cured or fixed, which is an ableist view in itself.
Increased oversight
I support the increased scrutiny of providers to ensure all people under the scheme remain safe. I am a registered provider (verification pathway). Regulation pathways should continue to be relevant to the size of the organisation and complexity of supports provided so that registration is not limited to large organisations. It should be acknowledged this is a huge change that will impact on the day to day supports of people with a disability, who followed the rules setup initially to implement flexible individual supports which work for them. The size or registration status of a provider unfortunately does not eliminate the risks to a participant. Adequate time should be allowed for people to setup replacement supports where they are affected by these changes – the disability community must be consulted about suitable time frames.
Capacity building
I acknowledge the proposed cuts to capacity building which may affect me as a provider and the outcomes of my participants who access capacity building suppots. It is unknown the effect of these funding cuts due to the lack of information available as yet. Occupational therapists, as a female dominated profession, are frequently called upon to fill the gaps in service, fix the most difficult problems and are often expected to do this by donating our time for free.
A further price cut will further reduce the occupational therapy workforce within the NDIS. OT’s working in the NDIS have not received any price rise since the start of the scheme despite rising costs personally and professionally. Travel costs have been reduced. OT’s work in participant’s ‘natural environments’ such as home or community, for most effective outcomes. Interventions including home modifications, equipment prescription, manual handling/support plans and skill building for people with intellectual impairments simply must be delivered at home to be effective. I work with a number of participants who are unable to safely access community locations especially clinic environments, therefore service delivery must be in their home.
Conclusion
The NDIS should remain grounded in the principles of inclusion, dignity, individualised support, and recognition of the full humanity of people with disabilities.
Financial sustainability is important, but reforms that prioritise short-term cost reduction over participant outcomes risk creating greater long-term social and economic costs while diminishing the rights and quality of life of people with disabilities.
I urge policymakers to ensure that:
lived experience is valued alongside formal evidence social and community participation remain recognised as essential supports
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 453
environmental and social factors are properly considered in assessments systemic administrative failures are addressed carers already under stress are not relied upon to absorb funding gaps participants with complex disabilities are not excluded due to difficulties accessing mainstream services reforms are assessed based on participant outcomes and long-term wellbeing, not solely immediate expenditure reduction
People with disabilities deserve not only survival, but meaningful inclusion and participation in society. These changes seem to be in contradiction to the foundational values of the NDIS.
*Prepared with the assistance of AI for ease of reading