National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 488 - Attachment 1
Evidence Addendum: NDIA Administrative Burden and Downstream Cost Risk
For the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Prepared by Jessica Schafer-Wilson | Heart Worx | May 2026
Purpose
This addendum supports parliamentary consideration of the Bill. It highlights why further participant-level restrictions should not proceed without stronger safeguards, staged evaluation and public reporting.
Core argument: Before Parliament accepts further participant-level restrictions, it should require the Government and NDIA to show the full balance sheet: participant spending, NDIA administrative delay, complaints, review burden, legal cost, provider instability, thin-market risk, unpaid carer pressure and recent reforms that have not yet been properly measured.
- NDIA administrative burden and review cost • Service guarantee reporting shows delay across access, reassessment, plan variation and internal review.
• Ombudsman and ANAO material has identified concerns with complaints management, decision-making controls and merits review pressure.
• ART and Legal Aid material show significant review burden and legal cost pressure.
- Recent reforms already tightened the Scheme • The October 2024 reforms introduced a new NDIS supports definition, stricter spending rules, funding periods, claim controls and increased payment integrity activity.
• The system is already undergoing substantial operational tightening and behavioural change.
- Downstream cost transfer • If supports are reduced before mainstream and foundational systems are funded, accessible and operating, the need does not disappear.
• It shifts into unpaid care, family systems, hospitals, mental health services, housing, justice, legal aid, tribunal review and provider collapse.
- Regional and thin-market risk • Regional markets cannot absorb blunt reform in the same way metropolitan markets can.
• A pricing change, provider exit, travel restriction, claim risk or loss of trusted support coordination may remove practical choice altogether.
- Rights, review and safeguards • Review rights, human oversight and clear legal definitions are safeguards, not obstacles.
• Disability Royal Commission, CRPD, Ombudsman merits review work and Robodebt lessons all point toward stronger safeguards.
Recommended Committee action
The Committee should recommend that the Bill not proceed in its current form. At minimum, it should recommend amendments requiring:
• public reporting on NDIA delay, complaints, review burden and legal costs
• public evaluation of the October 2024 reforms before further restrictions commence
• statutory safeguards for functional capacity assessment and evidence weighting
• clear limits on executive-made Rules for core eligibility and assessment concepts
• protection of review rights, reasons, privacy and human oversight
• regional impact assessment and downstream cost modelling
• safeguards around digital payment systems, automation, debt recovery and data sharing
Source anchors
APH inquiry and membership pages; NDIA quarterly reports and Participant Service Guarantee reporting; Commonwealth Ombudsman and ANAO reports; ART annual reporting and National Legal Aid NDIS appeals evaluation; NDIS October 2024 legislation updates; Disability Royal Commission, CRPD and Robodebt Royal Commission.
Closing line: The Committee should not assess this Bill only by projected NDIS savings. It should assess the cost and harm that may be shifted into other systems if safeguards are not built into the legislation itself.
Prepared by Jessica Schafer-Wilson | Heart Worx | Page 1