Submission 502
24 May 2026
Submission regarding the National Disability Insurance Scheme Amendment (Securing
the NDIS for Future Generations) Bill 2026
I am writing both as an Occupational Therapist and as a person with lived experience of disability, burnout, and caring responsibilities within the disability community. I urge the government to reconsider and amend aspects of this Bill that risk increasing harm, reducing accessibility, and undermining the principles on which the NDIS was founded.
I am a late-diagnosed AuDHD Occupational Therapist who has worked clinically for over 25 years, including 8 years supporting people with complex disabilities, including psychosocial disability.
Due to ongoing burnout and the cumulative impact of working within increasingly difficult systems, I have had to give up full-time clinical practice and reduce the complexity of the clients I can support. This is not because the need for support has reduced, but because the administrative burden, systemic pressures, and lack of meaningful support for both participants and providers have become unsustainable.
I am deeply concerned that the proposed changes in this Bill will disproportionately harm people with hidden, fluctuating, psychosocial, and neurodevelopmental disabilities — the very people who already struggle most to navigate administrative systems and who are least well served by standardised approaches to assessment and support.
The proposed “not contactable” provisions are especially concerning. Many participants are not “non-compliant”; they are overwhelmed, burnt out, hospitalised, in crisis, experiencing executive functioning difficulties, or lacking appropriate support to manage communication. Autistic people, people with psychosocial disability, people experiencing trauma, cognitive fatigue, housing instability, or mental health crises may temporarily lose capacity to engage with rigid administrative processes. Punitive responses to this are not supportive, trauma informed, or disability-responsive.
Professional Example: In the past week, I visited an NDIS participant, and one of my few remaining clients, in a mental health ward in a Melbourne hospital. During the early stages of admission, I noticed her autism and communication disabilities were not adequately accommodated by ward staff, and access to required supports was restricted because she was only allowed to use registered support workers.
This participant requires significant support to communicate her needs and navigate admission in a medical setting in a way that is affirming and does not result in further trauma or deterioration.
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Submission 502
As both a clinician and a disabled person, I know that communication capacity for many NDIS participants with psychosocial and neurodevelopmental impairments is not constant or consistent. The people most likely to miss deadlines or fail to respond to NDIA requests are often the people with the highest support needs and the least capacity to advocate for themselves.
Lived Experience Example: I am a late-diagnosed AuDHD person, an NDIS participant, and the parent of a teenage daughter who is also on the NDIS. Over the past one to two years, I have had to navigate increasingly complex systems, plan restrictions, inflexible review decisions, and repeated incorrect assumptions about my capacity that fail to recognise the reality of masking and hidden disability. This has made engagement with the NDIS not only deeply frustrating, but at times actively obstructive to accessing supports that would genuinely assist me and my family, including core supports for me and exercise physiology and specialist education supports for my daughter, who is unable to attend school.
I am also deeply concerned about the increasing reliance on standardised functional assessments and automated or computer-assisted decision-making processes. The concerns raised by disability advocacy organisations regarding these reforms are valid and urgent. Disability cannot be accurately understood through decontextualised assessments that attempt to separate impairment from the real-world environmental, social, cognitive, sensory, and psychological barriers people experience every day.
Assessing what a person can theoretically do “without support” or outside their actual lived context risks producing an artificial and misleading picture of disability. Functional capacity is not static, and it is profoundly influenced by access to support, assistive technology, environmental modifications, mental health, fatigue, trauma, sensory load, financial stress, and social circumstances.
For autistic people, people with psychosocial disability, ME/CFS, chronic illness, intellectual disability, complex trauma, or fluctuating conditions, functioning can vary dramatically from day to day or hour to hour. Standardised or algorithm-driven systems are poorly equipped to capture this complexity.
I am particularly concerned that increased automation and standardisation may disproportionately disadvantage people whose disabilities do not fit neatly into simplified assessment frameworks. There is significant risk that automated or highly standardised systems will reinforce existing inequities and fail people with complex, intersecting, fluctuating, or less visible disabilities.
Disability support cannot be effectively delivered through rigid compliance systems designed primarily around financial sustainability and expenditure reduction. The NDIS was founded on principles of individualisation, choice, control, dignity, and participation. These reforms appear to represent a significant philosophical shift away from those principles and toward cost containment and administrative control.
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I am also deeply concerned about proposed powers allowing broad reductions to funding categories and limitations on reassessment and review processes. Many participants already experience significant distress, delays, and adversarial interactions when trying to access appropriate supports. Reducing opportunities for review or increasing barriers to reassessment risks entrenching harm and leaving people without the supports they need during periods of deterioration, crisis, or life transition.
Lived Experience Example: As the parent of an autistic teenager who has been unable to attend school for the past five years because of disability-related barriers, I know personally how exhausting and overwhelming it is to navigate fragmented systems while trying to protect your child’s wellbeing and safety. I also know what it means to carry that load while trying to keep working, hold family life together, and continue when there is very little left to give. Like so many families, mine is living that exhaustion every day. I have significant concerns about her transition from school to higher education and employment. She is already flagging she may require social support and not be able to work. This is devastating for both of us!
Increasing administrative complexity and compliance obligations will further disadvantage those (including me and my family) with the least capacity and resilience to manage them.
I am also concerned that these reforms continue to place scrutiny and compliance obligations primarily on participants, while failing to adequately address longstanding NDIA governance and accountability failures. Many of the current issues within the NDIS stem not from participant misuse, but from systemic inefficiency, inconsistent decision-making, poor communication, excessive delays, lack of transparency, inadequate co-design processes, and adversarial systems that create distress for participants and providers alike.
Professional Experience: A key factor in my decision to reduce my clinical caseload from 100% to 20% was that, over the past 12 months, my functional capacity assessments and support letters were ignored by NDIA planners, and clients’ plans were arbitrarily cut. However, when I attended the Administrative Review Tribunal, my expert witness reports and testimony were clearly understood and accepted as professional, independent, evidence-based, and my recommendations were supported as reasonable and necessary.
This has led me to conclude that there is significant inconsistency in internal NDIA policies and procedures, and that occupational therapy evidence is not being given appropriate weight in internal decision-making. The result has been inconsistent plan reductions and the withdrawal of supports and programs, contributing to some of my clients presenting to hospital and shifting the burden and cost of care to the health system. This is not a genuine cost saving. It is a shifting of costs from one system to another.
As noted by disability advocacy organsiations such as the Australian Neurodivergent Parents Association (ANPA), NDIS Professionals Union and the Occupational Therapy Society for
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Hidden and Invisible Disabilities (OTSI), all of which I am a member of, the solution to these problems is not to make the system harder for disabled people to access and navigate.
A genuinely person-centred and disability-responsive system should be reflected in this Bill and its implementation. At a minimum, the legislation and associated processes should:
recognise fluctuating capacity and communication barriers
ensure meaningful human oversight and clinical judgement in decision-making
avoid overreliance on automated or standardised assessment systems
recognise the impact of environmental and social barriers on functioning
reduce administrative burden on participants and providers
improve NDIA accountability, transparency, and consistency
prioritise accessibility, trauma-informed practice, and relational support
protect the rights and dignity of people with hidden, fluctuating, and psychosocial disabilities
ensure genuine co-design with disabled people and representative organisations
I urge the government to carefully consider the real-world impact of these changes on disabled people, families, and frontline clinicians, and to amend the Bill so it does not entrench harm through compliance, automation, and administrative efficiency at the expense of accessibility, clinical judgement, and disability-responsive support.
Disabled people should not be punished for struggling within systems that were supposed to support them.
Australians should not lose access to experienced therapists with lived experience who can provide meaningful, evidence-based disability support.
The trajectory of the proposed Bill, together with likely future reforms under current and future governments, risks driving more therapists away from the sector and pushing Australia back toward outdated, harmful approaches to disability care.
That would be a profound loss for disabled people, families, and the broader community.
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