Submission 545
Submission to Community Affairs Legislation
Committee on National Disability Insurance Scheme
Amendment (Securing the NDIS for Future
Generations) Bill 2026
The need to act
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We recognise that it is in the interests of the intended beneficiaries of the National Disability Insurance Scheme (NDIS) that Government takes deliberate and timely action to address scheme scope and cost.
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We also acknowledge and support Government’s genuine intention to ensure those dependent on the scheme to be safe from harm and neglect should not be impacted by these changes.
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This intent is reflected in the consideration of options which minimise the impact to daily living activities critical to a person’s health and wellbeing (p. 231) Significant unintended consequences
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The Impact Analysis prepared by Health, Disability and Ageing acknowledges that this change will disproportionately affect participants who: o are in Supported Independent Living (SIL) who are dependent on 24x7 supports to support their health and wellbeing (p. 227) o with visual impairment, Down syndrome, and Intellectual Disability (p. 229)
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For this cohort there is significant risk if an unintended consequence is that this change affects daily living activities critical to a person’s health and wellbeing.
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We are concerned that the analysis undertaken has not represented an accurate picture of how 24x7 supports are funded and therefore fails to accurately assess the impact of these changes.
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SIL alone does not fund 24x7 support for people with a disability.
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For the hours between 9am and 3pm on weekdays essential daily living support including is commonly funded as Social, Civic and Community Participation (SCCP). This is because people in SIL are encouraged to leave home during this time and the intention is to increase participation in the community. Those who stay at home are still commonly funded through this support category.
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It is false that reducing SCCP will only impact people with disability ability to undertake discretionary activities in the community. These people would require support whether they are supported in the community or at home.
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For those in 24x7 supports, a 50% reduction in SCCP will impact daily living activities critical to a person’s health and wellbeing.
Submission 545
Illustrative Analysis
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Outside the home people in 24x7 supports nearly always receive support at the lowest ratio they can be safely supported. Commonly people may be supported at a ratio of 1:3 in SIL. People with more complex needs may need to be supported at higher ratios due to risk.
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Funding for this support consists of funding for the support worker, and funding for the physical space where support is provided.
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The below graph shows horizontal lines which reflect the average annual costs for support at a range of ratios including 1:3 (common), 1:2 (more intensive) and 1:1 (very intensive).
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The bars demonstrate the impact of the changes to Social, Civic and Community Participation funding to this cohort.
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It should be noted that we believe few participants in 24x7 support are funded at the average figure. The figure used in the DHDA analysis is potentially misleading as it is a mean average derived from cohorts supported at the lowest safe ratio which varies based on complexity.
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Because people in 24x7 are almost always already supported at the lowest safe ratio, a 50% cut will impact the support required to keep people safe. Support at lower ratios than 1:5 is not safe or practical. For people who require 1:1 supports for their safety, this will present significant risk to them or to the community.
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The mid-point in this diagram illustrates how the Department’s impact analysis made a reasonable assessment but is informed based on a false understanding derived from considering average plan values. If the average participant did receive $84,000 support, they may have discretionary component of this funding that would allow them to have supports reduced and still receive 24x7 support.
Submission 545
Conclusions
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It is our assertion that average participant values do not represent typical support and that most SIL participants do not have support which genuinely provides discretionary community participation which could be reasonably reduced.
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Implementing this cut will lead to many people who need 24x7 supports no longer having supports 24x7. We know this is unintended.
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It is the experience of SIL providers that when supports in the community fail participants are left at home unfunded - which creates significant risk for SIL provider viability - an area Government is trying to resolve.
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We also observe that for those who do have sufficient funding to support such a cut, it will remove all reasonable support to access the community other than in group congregate settings and approaches.
Representation to Government
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We have made representations to both the Department and the NDIA. We believe that this issue is understood and the need to take action is recognised. Questions the Committee should ask
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Can you provide the Committee with evidence to support the fact that changes to SCCP funding will not impact the 24x7 support of people with significant disability?
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If cuts to SCCP funding have the impact on an individual that they will no longer receive 24x7 supports, how will the Minister fulfil his obligations under 34A(3) to ensure participants are not at risk of neglect, crisis or loss of essential functioning? Proposed safeguards in the legislation
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We recognise that the Proposed new subsection 34A(3) will provide that in making a support determination, the Minister must consider the safety of participants.
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We agree that considerations must include whether a reduction in funding for groups of supports could place participants at risk of neglect, crisis, or loss of essential functioning (p. 32)
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We are concerned that such considerations will be made based on analysis and advice which does not represent the complexity of this issue as we believe has been demonstrated in the Explanatory Memorandum.
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We believe a stronger control is required to explicitly protect people who are dependent on 24x7 support. It should specifically require that changes made under s34A must be assessed on an individual basis to ensure it does not impact on the provision of 24x7 supports. We identify that this aligns with Governments’ intent, but we are not confident it will be consistently applied by the NDIA without a specific legislative safeguard.
Submission 545
Who is Bonorigo?
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Bonorigo is a specialised consultancy with 50 years combined senior experience in community services. We partner with NDIS providers, community organisations, government agencies, and peak bodies to solve complex problems and drive meaningful change.
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Principal Consultant, John Rowland, has 15 years’ experience in leading 24x7 supports for people with disability, including 8 years as an executive, COO and interim CEO of a large national NDIS provider.
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In his capacity as a representative for Alliance20, John provided expert advice to the NDIS Review on Home and Living and continues to play an active role in shaping Home and Living policy with a specific interest on ensuring quality services to people with significant and complex needs.
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As a provider John was a constructive and active partner with the NDIA supporting them to understand pricing policy and shape scheme design.
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John is currently leading the Sustainability Network for National Disability Services (NDS), supporting organisations redesign their service and operating models to be sustainable and achieve the intent of the NDIS.,
References
All page references in this document refer to Commonwealth of Australia. (2026).
Explanatory Memorandum, National Disability Insurance Scheme Amendment
(Securing the NDIS for Future Generations) Bill 2026. Canberra: Parliament of the Commonwealth of Australia. Workings which support the illustrative analysis have been provided to the Department and can be provided directly on request.