Lack of NDIA evidence review and systemic underfunding (Individual advocacy) | External submission

Submission 51

Submission to the Senate Community Affairs Legislation Committee

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

2026

Preliminary Observations: What This Bill Is Built On Top Of

The following observations are not exhaustive. They represent issues that are rarely, if ever, reported in mainstream media coverage of the NDIS, yet are fundamental to understanding why this Bill fails to address the all scheme’s real problems.

I am a relatively small provider. I do not have a large policy team or a peak body behind me. What I have is years of direct experience supporting participants, a genuine concern for the people who rely on this scheme, and the time I spent reading this Bill from cover to cover. I am writing this submission because the participants I support cannot always advocate for themselves, and because someone should.

I am also an Australian taxpayer. This Bill affects me on that side of the equation too. The government is projecting $37.8 billion in savings from this legislation. As I will outline below, those are not savings. They are costs shifted from one government ledger to several others, all of which are also funded by taxpayers. I have a stake in this as a provider, as an advocate, and as someone whose taxes will absorb whatever the NDIS drops.

This Bill is not fixing a working system. It is dismantling a broken one without addressing everything that broke it.

The NDIA does not read the evidence it mandates. In February 2025, NDIA CEO Rebecca Falkingham publicly acknowledged that NDIA staff often do not have time to read the medical reports submitted by participants. Participants are required to fund and provide clinical evidence at every turn. That evidence is not being read. Plans produced without reference to that evidence are consistently wrong. This is not disputed. The CEO said so publicly.
Government agencies are among the NDIS’s largest beneficiaries. FOI Document FOI-25/26-0656, Top 1,000 Providers by Direct Payments from 1 July 2024 to 1 July 2025, released by the NDIA itself, shows the following:

Organisation Amount Billed from NDIS

(2024-25) Department of Health, Disability and Ageing $190,695,787.74 Department of Human Services $123,425,472.57

Department of Families, Seniors, Disability Services and Child Safety $74,120,569.31

Department of Families, Fairness and Housing $37,692,555.19

Disability Services Commission $29,257,363.76

Metro North Hospital and Health Service $7,667,781.23

Eurobodalla Shire Council $6,713,952.31

Gilgandra Council $5,485,409.85

TOTAL $475,078,892.02

The Department of Health, Disability and Ageing, the department that oversees the NDIS, billed nearly $191 million from the scheme it administers in a single year. These payments may reflect legitimate services. But they have never once been mentioned in the government’s public narrative about scheme sustainability. The government is announcing the removal of 160,000 current participants from a scheme it calls unaffordable while its own departments draw half a billion dollars from it annually. The Committee should require the government to address this directly.

Submission 51

The NDIA’s own legal spending demonstrates systematic underfunding. According to the NDIA’s own Independent Expert Review Program Evaluation Report from October 2023, the average cost of a 2.5 day hearing at the Administrative Review Tribunal is $29,899, hearing days only, not including pre-hearing legal costs. According to the AAT Quarterly Report for 2020-21, 98 per cent of cases never reach a hearing. They settle or overturn before that point.

If the NDIA’s decisions are correct, why are 98 per cent of cases settling or overturning before a hearing? If the decisions are defensible, why are they not being defended? And if they are settling because the decisions were wrong in the first place, why is the answer to introduce legislation that makes it harder for participants to challenge them?

The Committee should require the government to release the total amount spent at the Administrative Review Tribunal and the win/loss record of the NDIA in those proceedings. That information is directly relevant to assessing whether this Bill addresses the right problems.

The Local Area Coordinator service is not functioning. The LAC service is funded at $2.76 billion through contracted partner organisations to December 2024. Its stated purpose is substantial, ongoing, individualised engagement with every participant throughout their NDIS journey. In practice, across two branches of our organisation, the vast majority of participants only hear from their LAC when their plan end date is approaching. The ongoing engagement the role was designed to provide is not occurring.

Support Coordinators currently fill much of the gap the LAC model leaves. This Bill proposes to cut Support Coordination spending by 30 per cent and move to a commissioned panel model. It also proposes to auto renew plans with no human review.

The Committee should ask the government what ongoing participant engagement will look like when plans auto-renew without review, LAC engagement is already minimal for most participants, and Support Coordination is being reduced. This Bill does nothing to address that question.

The fraud enforcement gap is not a power problem. It is a will problem. The NDIS Quality and Safeguards Commission’s own Compliance and Enforcement Policy stated clearly that it had the power to investigate registered and unregistered providers. Only 0.22 per cent of over 7,000 fraud reports led to prosecutions. Did the Commission choose not to use the powers it already had? This Bill gives more powers to the same agency. The Committee should ask why those powers were not used before legislating new ones.

Schedule 1, Part 1: Functional Capacity Definition

The Bill introduces a new definition of functional capacity assessed without assistive technology, without home modifications, without help from other people, and excluding personal and environmental circumstances.

In principle, this approach is correct. Assessing functional capacity without supports gives a truer baseline of underlying disability than assessing with them. Done properly, this should produce more accurate funding.

However, the Committee should require the government to answer the following before this provision passes.

If the assessment correctly identifies the true extent of someone’s disability, what guarantee exists that the rest of this Bill will fund it adequately? The treatment requirement in Part 8 may exclude the impairment entirely. The “directly from” wording in Part 3 may exclude supports for its cascading effects. The ministerial determination in Part 4 may cut the funding category by any percentage the Minister chooses. The auto renewal in Part 5 may lock in an inadequate plan indefinitely.

Submission 51

There is also a fundamental internal contradiction between Part 1 and Part 6. Part 1 excludes informal supports and family from the functional capacity assessment. Part 6 requires the CEO to consider what family, and informal supports can provide before approving funded supports. The assessment says the family does not exist. The funding decision says the family can do it. The participant is assessed as if alone and funded as if supported. The government must explain how these two provisions can coexist.

Schedule 1, Part 2: Unscheduled Reassessments

The Bill changes the reassessment response time from 21 days to 90 days and introduces a high threshold requiring proof of significant and ongoing change in functional capacity that substantially reduces the ability to perform daily activities.

Minister Butler’s justification was that one in five plans are reassessed annually at an average 20 per cent increase in plan value. The Committee should note that participants do not have the power to change their own plans. NDIA staff do. Every reassessment resulting in a 20 per cent increase is a NDIA employee correcting another NDIA employee’s work. Butler is not describing a participant behaviour problem. Is he therefore describing a NDIA accuracy problem? The proposed solution restricts participant access rather than addressing NDIA accuracy.

The Committee should also ask the government whether the one in five figure includes plans corrected through proceedings at the Administrative Review Tribunal. If it does, the government is counting tribunal wins by participants as evidence of a reassessment problem, and its solution to participants successfully challenging wrong decisions is to make it harder to challenge them.

Does The NDIA’s own legal spending at the Administrative Review Tribunal, where 98 per cent of cases settle or overturn before a hearing, confirm that plans are consistently wrong? Restricting reassessments does not reduce the cost of correcting wrong plans. It redirects that cost from an internal administrative process to an external legal one, at significantly greater cost to the taxpayer and significantly greater burden on the participant.

The answer to undertrained planners producing wrong plans is to train planners. Require demonstrated understanding of disability. Require mandatory engagement with clinical evidence. Make planners accountable for decisions inconsistent with the evidence placed before them. This Bill instead seems to remove human judgement from the process entirely and replaces it with an algorithm.

The Committee should also note that under Part 5, the auto-renewal of a plan explicitly does not constitute a reviewable decision. A participant whose auto-renewed plan is inadequate cannot challenge the renewal itself. Their only recourse is to request an unscheduled reassessment. But this Bill simultaneously raises the threshold for that reassessment to require proof of significant and ongoing deterioration. A participant with an inadequate auto-renewed plan who cannot clear that threshold has no mechanism to correct it. They are trapped between an unreviewable renewal and an unreachable reassessment threshold. For participants with degenerative conditions, fluctuating needs, or changing circumstances, this is not an administrative inconvenience. It is a direct risk to their safety, health, and ability to live independently.

This provision also contains a fundamental internal contradiction with Section 25 of the existing Act, which this Bill does not repeal. Section 25 requires the scheme to fund supports before deterioration occurs, to prevent crisis rather than respond to it. This provision requires proof of substantial deterioration before a reassessment can be requested. Both cannot be true simultaneously.

The Committee should require the government to explain how these two provisions coexist, specifically in relation to:

 People with degenerative conditions where early support prevents deterioration  Children with a disability transitioning out of school whose structured environment disappears overnight  Participants whose informal support arrangements change due to carer illness or death  Any participant whose circumstances change in ways that do not meet the substantial deterioration threshold, but whose current plan is no longer adequate

Submission 51

Schedule 1, Part 3: Strengthening the Link to Impairment

The Bill changes the wording from supports “arising from an impairment” to supports “arising directly from an impairment.”

The government has provided no guidance on what “directly” means in practice. This single word change has potentially enormous consequences for participants with multiple or cascading conditions.

Disability rarely operates in a straight line. An intellectual disability creates communication difficulties. Communication difficulties create social isolation. Social isolation creates anxiety and depression. Anxiety and depression create sleep disorders. Sleep disorders worsen the intellectual disability. Every link in that chain currently arises from the impairment and is fundable. Under the new wording, whether any of those secondary supports arise directly enough from the primary impairment will be determined by a planner or an algorithm with no guidance, no definition, and no accountability.

For autistic people, anxiety arises from the interaction between autism and an environment not designed for them. Under a strict reading of “directly,” anxiety supports may not be directly arising from the autism itself. Before this provision passes, the Committee should require the government to provide:

A legal definition of “directly from an impairment”
Guidance on how cascading conditions will be treated
Clarification of whether secondary mental health conditions caused by living with a primary disability will be fundable
Details of how the automated planning system will be programmed to interpret this provision

Schedule 1, Part 4: Support Determinations

The Bill gives the Minister power to reduce funding for entire categories of supports by a set percentage across all plans simultaneously by legislative instrument, with no individual assessment, and explicitly states this is valid even if the result is that a participant’s plan no longer covers the full cost of their reasonable and necessary supports.

These determinations are exempt from sunsetting provisions. They do not expire. They do not need parliamentary review.

The entire foundation of the NDIS Act is that supports are reasonable and necessary for the individual. This provision does not bend that principle. It legislatively overrides it. The Minister can reduce every participant’s community participation budget by any percentage at any time, regardless of individual need, regardless of clinical evidence, regardless of what any planner assessed.

This power is unchecked, unsunsetted, and unilateral. The Committee should not recommend this provision pass without independent oversight mechanisms, mandatory consultation requirements, and sunset clauses that require parliamentary review.

The Committee should also note that this provision gives the Minister power to reduce what individual participants can access from the scheme, while the government has provided no equivalent mechanism to scrutinise or reduce what its own agencies and councils draw from the scheme annually. As outlined in the preliminary observations, government agencies and councils billed approximately $475 million from the NDIS in 2024-25. The same Bill that gives the Minister unchecked power to cut participant funding contains no equivalent accountability for government billing from the scheme.

Schedule 1, Part 5: Plan Renewal

The Bill introduces automatic plan renewal as an identical copy with no review, no reassessment, and no rollover of unspent funds.

Unspent funds in a disability plan are not always excess. They are often contingency. They allow participants to respond to unexpected health events, equipment failures, or increased needs without waiting months for formal reassessment. Removing them removes the safety net. And given that this Bill

Submission 51

simultaneously requires participants to prove substantial deterioration before a reassessment can be requested, removing that contingency buffer is particularly alarming. A participant whose needs increase cannot access their unspent funds. They cannot easily trigger a reassessment. And their plan auto-renews as if nothing has changed.

Combined with the Part 4 ministerial determination power, this creates a further alarming outcome. A ministerial determination can reduce what a participant is able to spend within a support category by any percentage the Minister chooses. No individual assessment preceded that decision. No consideration of specific needs. No parliamentary vote. And the plan auto-renews with that reduction in place indefinitely, with no human ever reviewing whether the result is adequate.

As noted in the analysis of Part 2, the auto-renewal of a plan does not constitute a reviewable decision. A participant whose renewed plan is inadequate has no direct mechanism to challenge the renewal itself.

Schedule 1, Part 6: Reasonable and Necessary Supports

This schedule makes three significant changes that the Committee should scrutinise carefully.

Financial sustainability as a legal test. The Bill amends Section 3(1)(d) to add “so far as is consistent with the financial sustainability of the scheme.” These words have never been in the Act before. The budget is now part of the legal test for whether a support is reasonable and necessary. The Committee should require the government to explain how this is consistent with the founding rationale of the scheme as articulated by the Productivity Commission.

New evidence hierarchy. Peer reviewed published research is elevated above individual clinical evidence. Many therapies for rare conditions, complex presentations, or newer approaches have limited peer reviewed literature. This creates a mechanism to deny supports that clinical evidence supports but bureaucratic or algorithmic assessment cannot verify through published research. The Committee should require the government to explain how this will apply to rare conditions and complex presentations where peer reviewed evidence is limited by definition.

Parental responsibility. The Bill codifies an exhaustive list of what parents are legally expected to provide, and requires the CEO to consider the desirability of maintaining informal supports before approving funded ones.

The NDIS was created because informal support systems were collapsing. The Productivity Commission’s founding rationale was that investing in formal supports reduces the catastrophic cost of informal carer breakdown. It keeps carers in the workforce. It keeps families intact.

This provision legislatively reverses that rationale.

The Committee should ask the government whether any modelling was done on the impact of this provision on carer workforce participation rates before it was drafted. When parental responsibility becomes the legal default, carers leave paid employment. That is not just a cost to Centrelink. It is a loss to the broader economy.

The same question applies to the disability support workforce itself. The NDIS has generated a significant employment sector across Australia. Support workers, allied health professionals, coordinators, and providers all contribute to local economies, particularly in regional areas. Cuts to the scheme do not just reduce supports for participants. They reduce employment, reduce tax revenue, and reduce economic activity in communities that often have few alternative industries. The government’s $37.8 billion savings figure does not appear to account for any of this. The Committee should require it to.

The downstream costs of this provision will not appear in the NDIS budget line. When parental responsibility becomes the legal default for everything, parents leave the workforce. Centrelink pays carer payments and disability support pensions. Mental health services absorb the carer who breaks down.

Submission 51

Emergency departments absorb the participant in crisis. The justice system absorbs the participant who falls through every gap.

The government is projecting savings of $37.8 billion over four years. That figure represents savings from the NDIS budget only. The Committee should require the government to provide whole of government cost accounting that includes the projected costs to Centrelink, Medicare, state mental health services, hospitals, housing services, and the justice system of the supports being removed from the NDIS.

Schedule 1, Part 7: Plan Suspension and Revocation

The Bill allows the CEO to suspend a plan if a participant is not contactable after reasonable attempts, and to revoke participant status after 90 days of suspension with no hearing, no formal decision, and no tribunal review.

The revocation of participant status under this provision does not constitute a reviewable decision. A participant who loses their NDIS access because they were not contactable has no formal decision to appeal and no tribunal to take their case to. The Committee should require the government to explain why a decision of this magnitude, the complete loss of access to a government scheme, does not attract the same procedural fairness protections as other administrative decisions of far lesser consequence.

“Reasonable attempts” is not defined in the Bill. The Committee should require the government to define this before the provision passes, including the minimum number of attempts, the channels required, and whether known providers and support workers must be contacted.

The Committee should also consider the impact of this provision on:

Participants with mental health conditions who may be hospitalised and unable to manage communications
Participants whose communication needs require support from a carer who may themselves be unwell
Participants in rural and remote areas with limited communication access
Any participant whose disability affects their ability to respond to contact attempts during business hours

Schedule 1, Part 8: Permanence and Treatment

The Bill requires participants to try every appropriate treatment before their impairment is considered permanent, and explicitly states that financial circumstances and geographical location do not excuse a participant from this requirement.

The Committee should note that this provision does not reduce demand on health and treatment services. It redirects it. Services already operating at capacity, with waitlists of six to twelve months in many areas, will now receive every person who needs to prove they have tried treatment before NDIS eligibility is confirmed.

The Committee should also note that Minister Butler acknowledged at the National Press Club on 22 April 2026 that mainstream health and treatment services have failed Australian families. His solution is to make access to the NDIS conditional on first accessing services he has already publicly admitted are not working. This provision does not solve the problem of inadequate mainstream services. It uses their inadequacy as a barrier to NDIS access.

For rural and remote Australians, this provision creates a geographic lottery for NDIS access. The services required to prove treatment have been tried do not exist in many regional areas. Financial barriers are legally irrelevant under this provision. Geographic barriers are legally irrelevant under this provision. The NDIS was designed to reduce inequality of access. This provision entrenches it.

Submission 51

Schedule 1, Part 9: Excluded Impairments and Ministerial Declaration Power

The compensation exclusion provisions have arguable intent in the short term. However, compensation is not always lifelong. It covers loss of wages, medical expenses, and economic loss. It has caps and time limits. When compensation runs out, the person is left with a permanent disability, no compensation, and no NDIS eligibility because their impairment is excluded.

More concerning is the third category buried within this provision. The Minister can declare any support an alternative support for any impairment by legislative instrument. Not limited to compensation schemes. Not limited to motor vehicle accidents or workplace injuries. Any impairment. Any support. By ministerial decree. No parliamentary vote required. No sunset.

The scope of this power is unlimited and the consequences are potentially extraordinary. If the Minister declares that public psychiatry services are an alternative support for schizophrenia, that impairment is excluded from NDIS eligibility. If the Minister declares that public occupational therapy services are an alternative support for intellectual disability, that impairment is excluded. If the Minister declares that any existing government service, however inadequate, underfunded, or inaccessible, is an alternative support for any disability, that disability can be excluded from the scheme. By legislative instrument. No parliamentary vote. No sunset. No requirement to demonstrate that the declared alternative actually meets the participant’s needs.

This power is unlimited in scope and permanent in effect. The Committee should not recommend it pass without defined limits on what can be declared an alternative support, mandatory consultation requirements, and sunset provisions.

Schedule 2: Fraud and Integrity Measures

Schedule 2 introduces new civil penalties, expanded investigation powers, information gathering powers, record retention requirements, claim time limits, and conflict of interest rules for plan managers.

The fraud problem in the NDIS is real and the enforcement gap is real. Many of the measures in Schedule 2 are overdue and warranted. Record retention requirements, claim time limits, and conflict of interest rules for plan managers are sensible accountability measures that apply to providers and participants alike. Both can defraud the scheme. Both should be accountable.

However, the Committee should note that the NDIS Quality and Safeguards Commission already had the power to investigate registered and unregistered providers under its own Compliance and Enforcement Policy. Only 0.22 per cent of over 7,000 fraud reports led to prosecutions. Did the Commission choose not to use the powers it already had? This Bill gives more powers to the same agency. The Committee should require the government to explain why those powers were not used before legislating new ones, and what structural changes will ensure they are used now.

The government has announced that mandatory registration will be expanded to cover personal care, daily living supports and supports in closed settings. Much of that expansion will be implemented through instruments after this Bill passes rather than through primary legislation. The Committee should note that mandatory registration, whether or not it prevents fraud, carries a significant unintended consequence the government has not addressed.

Registered providers have defrauded the NDIS at significant scale. Registration did not prevent it. Enforcement would have. The Committee should require the government to explain how expanding mandatory registration will produce different outcomes from an agency that has demonstrated a consistent failure to enforce the powers it already holds.

Mandatory registration also carries a significant unintended consequence that the government has not addressed. Smaller providers, many of whom operate in regional and rural areas where larger organisations do not, will exit the scheme because the compliance costs and administrative burden are prohibitive. The result is reduced participant choice, reduced service availability in already underserviced areas, and a market increasingly dominated by larger organisations, some of which have already demonstrated they are capable of rorting the scheme at scale.

Submission 51

Registration is not a guarantee of quality. It is a compliance threshold that smaller ethical providers may not be able to meet, while larger unethical ones navigate with ease.

Schedule 3: Pricing and Automation

Pricing.

Pricing decisions now sit with the Minister by legislative instrument with no sunsetting. Combined with the Part 4 power to cut funding categories by percentage, this gives one person unchecked, unsunsetted, unilateral power over what the NDIS pays for and how much it pays. Forever. Without parliamentary review. Without mandatory consultation.

Automation.

The Bill gives computer programs the legal power to make decisions, exercise discretionary powers, and form what the legislation literally calls a “state of mind” on behalf of the CEO. The Standard Operating Procedure instruments governing how the algorithm makes evaluative decisions are notifiable but not disallowable. Parliament cannot strike them down.

Minister Butler said in his second reading speech: “This government will not repeat those mistakes.” He was referring to Robodebt. The Royal Commission into Robodebt handed down its findings in 2023. This Bill introduces an algorithm with the legal power to form a state of mind about a disabled person’s support needs, with no requirement for human review of any particular decision, governed by instruments Parliament cannot disallow.

The Committee should require the government to answer before this provision passes:

What data will be entered into the automated system?
Who will enter it and what training will they receive?
How will the algorithm reach its conclusions on evaluative matters?
What happens when the data is wrong?
What happens when a participant’s circumstances do not fit the algorithm’s categories?
How does a participant appeal a decision made by a process they cannot see or understand?
What independent oversight will exist over the Standard Operating Procedure instruments?

Schedule 4: New Framework Planning

The new planning framework is barely outlined in Schedule 4. The detail will be determined by the Minister through instruments after the Bill passes. The disability community is being asked to accept a framework that will fundamentally reshape how 760,000 people access support without knowing what the assessment methodology looks like, how the funding amounts will be determined, or how decisions can be challenged.

The Committee should not recommend this schedule pass until the framework rules are published in draft form for public consultation prior to the Bill’s passage.

Conclusion and Questions for the Committee to Put to Government

This Bill addresses some real problems. The fraud measures in Schedule 2, record retention requirements, claim time limits, conflict of interest rules for plan managers, and accountability measures applying to both providers and participants, are largely overdue and warranted.

However, the Committee should note that the Commission already had the power to investigate and prosecute fraud. Did it choose not to use those powers? Giving more powers to the same agency without accountability for its past failures does not guarantee different results.

Submission 51

The remaining schedules represent a fundamental restructuring of the NDIS that the Committee should scrutinise carefully before recommending passage.

The following questions should be put to the government and answered on the public record before this Bill passes:

What does “arising directly from an impairment” mean in practice? Who decides? What guidance will be provided?
If the functional capacity assessment excludes informal supports, how is the Part 6 requirement to consider informal supports before approving funded supports consistent?
What guarantee exists that the functional capacity assessment in Part 1 will produce more accurate funding given the other restrictions in this Bill?
Does the one in five reassessment figure cited by Minister Butler include plans corrected through proceedings at the Administrative Review Tribunal? If so, is the government counting tribunal wins by participants as evidence of a reassessment problem?
What happens to people with degenerative conditions under a reassessment framework that requires substantial decline before review?
What happens when circumstances change in ways that do not meet the substantial deterioration threshold but render the current plan inadequate?
How does the reassessment threshold coexist with the early intervention provisions in Section 25 of the existing Act, which this Bill does not repeal?
Why does the auto-renewal of a plan not constitute a reviewable decision? A participant whose auto-renewed plan is inadequate and who cannot clear the reassessment threshold has no mechanism to correct it. How is this consistent with the scheme’s obligation to provide reasonable and necessary supports?
What constitutes reasonable attempts to contact a participant before suspension? What is the minimum number of attempts? What channels are required?
How will the automated planning system work? What data goes in? Who enters it? What training will they receive? How does the algorithm reach conclusions on evaluative matters? What happens when the data is wrong? How does a participant appeal?
What workforce participation modelling was done on the parental responsibility provisions before this Bill was drafted? What impact does the government project on carer workforce participation rates and the broader disability support workforce?
What is the whole of government cost accounting behind the $37.8 billion in projected savings? What does Treasury project Centrelink, Medicare, state mental health services, hospitals, housing services, and the justice system will spend absorbing what the NDIS drops?
Why have government agencies and councils drawing approximately $475 million annually from the NDIS not been addressed in the government’s public narrative about scheme sustainability?
What is the NDIA’s total legal spending at the Administrative Review Tribunal and its win/loss record? If 98 per cent of cases settle or overturn before hearing, what does this indicate about the quality of original decisions?
What impact will the expansion of mandatory registration have on smaller providers in regional and rural areas? What will the government do to mitigate service gaps where those providers exit the scheme?
What does the new planning framework in Schedule 4 actually look like in practice? Will draft rules be published for consultation before this Bill passes?
What limits exist on the ministerial power in Part 9 to declare any support an alternative support for any impairment? What consultation is required before such a declaration is made?

These are not unreasonable questions. They are the questions that 760,000 current participants, their families, their carers, and every Australian taxpayer deserves answered before this legislation becomes law.

I urge the Committee to recommend that this Bill not pass until these questions are answered, the automated planning system is subject to independent oversight with disallowable instruments, the new framework planning rules are published in draft for public consultation, and a whole of government cost accounting is provided for the projected savings.