Submission 503
SUBMISSION TO THE SENATE STANDING COMMITTEE ON
COMMUNITY AFFAIRS
Inquiry into the National Disability Insurance Scheme Amendment (Securing the
NDIS for Future Generations) Bill 2026
I am a 25-year-old Autistic adult with ADHD, a self-advocate, and a Certified Practising Speech Pathologist. I have been an NDIS participant since 2021, with Autism as my primary disability. I currently receive support worker assistance for daily living and community access, capacity-building allied health supports, and low-cost assistive technology. These supports have been essential to enable me to study, work, participate in the community, and live with dignity. I am writing to express my deep concern about the NDIS Amendment Bill and the harm it will cause to people like me if passed in its current form.
What the NDIS makes possible for me
With NDIS support, I completed my university degree, secured part-time employment, and built the capacity to participate in environments that would otherwise be overwhelming or inaccessible. Support workers help me manage daily living tasks and access the community independently. Allied health supports reduce Autistic burnout, help me manage executive functioning demands, and allow me to maintain employment. Low-cost AT, such as noise-cancelling headphones and tinted lenses, enable me to safely enter environments that are usually inaccessible due to my Autism. Without these supports, I would not be able to work, study, or participate socially. They are not luxuries; they are the foundation of my independence and well-being.
Concerns about specific provisions in the bill
- s 25A(2) — Access test change This clause allows the NDIA to treat a disability as not permanent if any “appropriate treatment” exists, even if the person cannot access it due to cost, geography, cultural barriers, or because the “treatment” is not available. This is deeply concerning for neurodevelopmental disabilities such as Autism, ADHD, Down syndrome, and intellectual disability, which do not have “treatments” that remedy or reverse them. Medication for ADHD, for example, may alleviate some innate challenges, but not all. It also does not remove the disability itself or its functional impacts.
This clause risks excluding people with lifelong disabilities, people with fluctuating support needs, and people with progressive conditions such as Parkinson’s or Motor Neuron Disease. It represents a return to deficit-based, medical-model thinking that contradicts the NDIS’s stated commitment to the human rights model of disability.
- s 25B(4) — Alternative Supports
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This provision allows the Minister to declare certain supports as “alternative supports,” which can then be used to exclude people from the NDIS, even if those alternatives are not yet operational or do not meet the person’s needs. As someone with multiple co-occurring disabilities, I know firsthand that other service systems (mental health, medical, community health) are often inappropriate or unsafe for Neurodivergent people.
Research clearly shows that co-occurring neurodevelopmental disabilities interact with one another in complex ways, and generic services are rarely equipped to address this (Astle et al., 2022). Neurodivergent people are also at heightened risk of receiving harmful or unsuitable care in mainstream systems, including eating disorder treatment that is not adapted for autistic or ADHD individuals (Cobaert & Rose, 2024). This clause risks pushing people into systems that cannot meet their needs.
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Section 33(2EA) — Minister can cap any support, by cohort. Our allied health workforces are already stretched. Funding for supports should be based on need not an arbitrarily set numerical amount. This seems like we are reverting back to the days of block funding. This will see a mass exodus of so many allied health workers from our industry, not to mention the increased risk of harm for participants who rely on these supports to stay alive!
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s 34A — Funding below total cost This clause allows the NDIA to fund less than the total cost of a support if a cheaper option exists, even if the cheaper option does not meet the person’s needs. This is dangerous. Funding decisions about whether supports are “reasonable and necessary” should be based on the recommendations and presenting evidence, based on the person with disability themselves, allied health professionals, their family members and caregivers, and relevant empirical research.
For example, AAC devices deemed cheaper may have inappropriate software or hardware that lacks crucial features. This may result in an increased risk of device abandonment and physical damage, costing more in the long run. And what about home modifications? If cheaper options have been suggested that are not aligned with the person’s presenting mobility and access needs, this may increase their risk of falls and hospitalisations. This clause undermines the principles of the Disability Discrimination Act 1992 and exposes people with disabilities to unnecessary and preventable risk.
- Section 40A / 30(1A) — suspension & revocation Again, this section seems to contradict the outlined requirements in the Disability Discrimination Act of 1992. I have experienced first-hand the lack of communication, disability knowledge, and inaccessibility from the NDIA, including
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having been deemed two phone calls as ‘reasonable attempts’ to contact me. This is in spite of my requesting multiple times not to cold-call me. To think I may now be fined for the NDIA’s incompetence is disgusting.
- s 59B(4) — Automated decision-making I have already experienced dehumanising and distressing interactions with the NDIA, including decisions made without consultation, incorrect information recorded about me, and letters that omitted key evidence. The idea that automated systems, algorithms with no clinical training, no lived experience, and no capacity for nuance, could make discretionary decisions about my life is terrifying.
Research shows that the use of artificial intelligence (AI) in clinical decision-making is inferior to human input and prone to hallucinations, misinformation, and bias (Cross et al., 2024). AI systems also lack personalisation and often miss critical participant information (Harrison, 2024). These tools are not safe or appropriate for determining disability supports, and their use without consent raises serious ethical and privacy concerns.
- Schedule 5 — Transitional protections not guaranteed I may well be one of the 300,000 people estimated to be affected by the access changes. The Bill does not guarantee transitional protections; they sit in temporary rules that expire after 12 months. If I lose access to the NDIS, I will very likely lose my job, my independence, my ability to access the community, and my allied health supports. I will become entirely reliant on the Disability Support Pension and other income supports, costing the government more in the long term. My mother, who is also disabled and experiencing Autistic burnout, will be forced into an unsustainable carer role. The human cost would be devastating.
What I am already experiencing under the recent changes
Even before this Bill, I have experienced significant reductions in support since the October 2024 legislative changes. My allied health funding was cut, my plan was changed without consent, my ability to use core supports flexibly was substantially restricted, and I was incorrectly switched from self-management to plan-management with no record of me requesting it. Evidence from my allied health team has been ignored. My requests for assistance animal funding have been repeatedly rejected despite meeting the criteria. My change-of-circumstances request was dismissed without consultation, with key documents missing from the decision.
These experiences make me fearful of what will happen if the Bill passes. The system is already failing to understand or respect my needs. These amendments would make that failure permanent.
What I am asking the committee to do
Submission 503
- Reject the Bill in its entirety.
- If the Bill proceeds, remove or significantly amend the most harmful provisions, including:
o s 25A(2)
o s 25B(4)
o Section 33(2EA)
o s 34A
o Section 40A / 30(1A)
o s 59B(4)
o Schedule 5
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Require an independent review of the scheme and mandate that the NDIA implement its recommendations.
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Require transparency about who developed these reforms, including whether disabled people, carers, and allied health professionals were genuinely involved.
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References
Astle, D. E., Holmes, J., Kievit, R., & Gathercole, S. (2022). Annual Research Review: The
transdiagnostic revolution in neurodevelopmental disorders. Journal of Child
Psychology and Psychiatry. https://doi.org/10.1111/jcpp.13481Digital Object
Identifier (DOI)
Cobbaert, L., & Rose, A. (2024, June 11). Why eating disorder care must be geared to
neurodivergent patients. UNSW Sydney.
https://www.unsw.edu.au/newsroom/news/2024/06/why-eating-disorder-care
must-be-geared-to-neurodivergent-patients
Cross, J. L., Choma, M. A., & Onofrey, J. A. (2024). Bias in medical AI: Implications for
clinical decision-making. PLOS Digital Health, 3(11), e0000651.
https://doi.org/10.1371/journal.pdig.0000651
Harrison, K. (2024, Dec 18). Automating NDIS support planning can dehumanise and
harm people living with disability. UNSW Sydney. https://www.unsw.edu.au/arts
design-architecture/our-research/research-impact/case-studies/automating-ndis
support-planning-can-dehumanise-and-harm-people-living-with-disability