Key Concerns with the Bill (Individual advocacy)

Submission 557

Joint Submission to the Community Affairs Legislation Committee

National Disability Insurance Scheme Amendment (Securing the NDIS for Future

Generations) Bill 2026

Prepared by:

Date: 26 May 2026

Table of Contents

Executive Summary…………………………………………………………………………………………………. 3 Introduction …………………………………………………………………………………………………………… 4 About the Authoring Organisation ………………………………………………………………………………. 4 Key Concerns with the Bill ………………………………………………………………………………………… 5 Co-Design and Consultation Failures ………………………………………………………………………….. 5 Definition of “NDIS Support” …………………………………………………………………………………….. 6 Foundational Supports and Sequencing Risks ………………………………………………………………. 7 Transition to New Framework Plans ……………………………………………………………………………. 8 Needs Assessment Framework………………………………………………………………………………….. 8 Psychosocial Disability and Mental Health Impacts ……………………………………………………… 10 Permanence Test Concerns …………………………………………………………………………………….. 11 Plan Management and Choice and Control ………………………………………………………………… 12 Support Coordination and Recovery Coaching ……………………………………………………………. 12 Provider Viability and Thin Markets ……………………………………………………………………………. 13 Reasonable and Necessary Budgets …………………………………………………………………………. 14 Human Rights Considerations …………………………………………………………………………………. 14 Fraud, Misuse and Integrity Safeguards ……………………………………………………………………… 14 Real-world examples of systemic integrity and reporting failure …………………………………… 15

Assistance Animal Integrity, Misuse and Regulatory Gaps ………………………………………….. 15

Position and Assistance Animal Standards Framework ……………………………………… 17

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Submission 557

Integrity Safeguards and System Improvements Required ……………………………………………… 18 Closing Statement ………………………………………………………………………………………………… 20 Summary of Recommendations ………………………………………………………………………………. 21

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Submission 557

Executive Summary

This submission responds to the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. While we acknowledge the need for long-term sustainability within the National Disability Insurance Scheme (NDIS), we are deeply concerned that the Bill, in its current form, risks undermining the human rights, autonomy, safety, and wellbeing of people with disability.

This submission draws upon concerns raised across the disability, psychosocial mental health, advocacy, and community sectors, including themes reflected in submissions from Disabled People’s Organisations (DPOs), psychosocial disability advocates, women with disabilities organisations, and community mental health providers.

The Bill introduces major structural reforms while leaving many operationally significant matters to future rules, instruments, and administrative processes that have not yet been developed or properly co-designed with the disability community.

We are particularly concerned about:

• The inadequate consultation timeframe and lack of genuine co-design;

• The absence of legislated safeguards requiring ongoing involvement of people with disability in reform design;

• The tightening of eligibility and permanence requirements before foundational supports exist;

• Risks to participants with psychosocial disability and fluctuating conditions;

• The proposed needs assessment framework and lack of procedural safeguards;

• The potential erosion of participant choice and control;

• Risks to self-management autonomy;

• Reductions to social and community participation supports;

• Provider viability risks in regional, rural, and thin markets;

• The transfer of burden onto unpaid carers and families;

• Risks of increased isolation, segregation, institutionalisation, and crisis escalation. We support sustainable reform. However, sustainable reform cannot be achieved through rushed legislation, incomplete systems, reduced safeguards, or reforms implemented before alternative supports are operational.

The reforms proposed in this Bill will have profound and potentially irreversible impacts on people with disability. These reforms must therefore be developed through genuine co-design, supported by transparent evidence, and implemented only once appropriate foundational infrastructure is in place.

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Submission 557

Introduction

We welcome the opportunity to provide feedback on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. This submission is grounded in a human-rights framework and informed by the lived experience of people with disability, families, advocates, support workers, trainers, community organisations, psychosocial disability services, and disability-led organisations.

Australia is a signatory to the United Nations Convention on the Rights of Persons with Disabilities (CRPD). As such, reforms to the NDIS must uphold the rights of people with disability to:

• autonomy and dignity;
• equality and non-discrimination;
• full participation and inclusion in society;
• freedom from exploitation, violence, and abuse;
• access to justice;
• liberty and security of person;
• community living;
• culturally safe and trauma-informed support. The reforms proposed in this Bill must be assessed not only on financial sustainability, but on whether they strengthen or weaken Australia’s compliance with its human rights obligations.

About the Authoring Organisation

is a disability-led organisation committed to advancing ethical, inclusive, and evidence-informed approaches to disability support, assistance animals, accessibility, and community participation.

develops and maintains comprehensive national frameworks, including codes of practice, professional standards, policy and procedure frameworks, guidance materials, charters, and best-practice implementation documents designed to strengthen consistency, safety, and quality across the assistance animal and disability support sectors in Australia.

These frameworks are designed to be used by trainers, handlers, allied health professionals, service providers, organisations, and individuals, including those working in self-training and community-based assistance animal models. ’s materials are grounded in internationally recognised standards and adapt and expand upon leading frameworks including Assistance Dogs International (ADI) and the International Guide Dog Federation (IGDF), with a focus on accessibility, practical implementation, and Australian legislative contexts.

works with people with disability, assistance animal handlers, trainers, allied health professionals, advocates, support workers, and community organisations across Australia.

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Submission 557

supports reforms that strengthen accountability, transparency, safeguarding, and sustainability within the NDIS. However, reforms must not compromise participant rights, autonomy, access to supports, or the broader social inclusion objectives of the Scheme.

works with people with disability, assistance animal handlers, trainers, allied health professionals, advocates, support workers, and community organisations across Australia.

supports reforms that strengthen accountability, transparency, safeguarding, and sustainability within the NDIS. However, reforms must not compromise participant rights, autonomy, access to supports, or the broader social inclusion objectives of the Scheme.

Key Concerns with the Bill The primary concerns identified in this submission include:

1. Insufficient consultation and lack of genuine co-design;
2. Excessive reliance on future rules and instruments rather than primary legislation;
3. Tightening of eligibility before foundational supports are operational;
4. Risks to participants with psychosocial disability and fluctuating conditions;
5. Inadequate procedural safeguards in the needs assessment process;
6. Risks to participant choice and control;
7. Significant discretionary powers granted to the CEO;
8. Potential increases in institutionalisation, segregation, and isolation;
9. Reductions in community participation supports;
10. Increased burden on unpaid carers and families;
11. Provider viability risks, particularly in rural and thin markets;
12. Lack of cumulative impact assessment across reforms.

Co-Design and Consultation Failures

The consultation process for this Bill has been inadequate.

The scale and complexity of these reforms require genuine, accessible, disability-led consultation processes. The compressed consultation window has prevented meaningful engagement from many people with disability, particularly:

• people with psychosocial disability;
• people requiring supported decision-making;
• people in rural and remote communities; 5

Submission 557

• First Nations people;
• culturally and linguistically diverse communities;
• women with disabilities;
• people with intellectual disability;
• people with communication barriers. Several measures within the Bill were identified in the Explanatory Memorandum as not having undergone specific consultation.

This creates a fundamental contradiction between the Government’s stated commitment to co design and the actual legislative process.

Nothing about us without us must be embedded legislatively.

Recommendation 1

Amend Section 4 to mandate the involvement of people with disability and representative organisations in leadership roles throughout the design, implementation, monitoring, and evaluation of all NDIS reforms, associated legislation, rules, and policy frameworks.

Recommendation 2

Extend consultation and implementation timeframes for reforms that have not undergone genuine co-design and accessible consultation.

Definition of “NDIS Support” The proposed definition of “NDIS support” does not adequately reflect the full range of human rights protected under the CRPD.

The definition should explicitly include supports necessary to:

• access work and employment;
• access justice;
• maintain liberty and autonomy;
• avoid institutionalisation;
• prevent exploitation, violence, abuse, and neglect;
• support parenting and caring responsibilities;
• maintain social and community participation. We are also concerned about exclusions relating to household appliances and everyday supports that may function as legitimate disability supports.

For many people with disability, particularly women with disabilities and carers, household supports and adaptive appliances are essential for independence and participation.

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Submission 557

Recommendation 3

Amend subsection 10(a) to explicitly recognise supports connected to employment, justice, safety, liberty, parenting, caring responsibilities, and community inclusion.

Recommendation 4

Amend subsection 10(c) to specify that supports which promote or risk segregation, isolation, or institutionalisation cannot qualify as appropriate NDIS supports.

Foundational Supports and Sequencing Risks

The Bill proposes significant eligibility tightening and funding reforms before foundational supports are operational.

This creates substantial risks for people who may lose access to the NDIS without having viable alternatives available.

This risk is particularly acute for:

• people with psychosocial disability;
• people with fluctuating conditions;
• people in rural and remote areas;
• people already unable to access adequate mainstream supports. The NDIS Review recommended that eligibility reforms only occur once foundational supports are established.

This sequencing principle has not been consistently applied.

Without operational foundational supports, the reforms risk simply shifting people into crisis systems, emergency departments, homelessness services, and unpaid family care.

Recommendation 5

Eligibility tightening measures should not proceed until foundational supports are funded, designed, independently evaluated, and operational across all jurisdictions.

Recommendation 6

A transparent implementation readiness assessment should be published before eligibility reforms commence.

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Submission 557

Transition to New Framework Plans

Participants transitioning from old framework plans to new framework plans should not be required to undergo reassessment of NDIS eligibility.

Repeated reassessment processes can be retraumatising and destabilising, particularly for:

• people with psychosocial disability;
• people with trauma histories;
• people with fluctuating conditions;
• children and families;
• people with communication barriers. The Bill currently lacks sufficient clarity regarding reassessment requirements during transition.

Recommendation 7

Insert a legislative requirement that participants transitioning to new framework plans, including Early Intervention participants, must not be reassessed for NDIS eligibility.

Needs Assessment Framework

The proposed needs assessment framework raises major concerns regarding procedural fairness, participant autonomy, and systemic bias.

Participants must have the right to:

• review draft assessment reports;
• request amendments;
• provide additional evidence;
• challenge inaccurate or incomplete findings;
• access independent advocacy and support. The Bill currently fails to provide sufficient safeguards.

There is also inadequate clarity regarding:

• assessor qualifications;
• trauma-informed practice requirements;
• cultural safety;
• disability-specific expertise;
• lived experience inclusion. 8

Submission 557

Assessment processes must not reproduce medical gaslighting, diagnostic overshadowing, gender bias, or cultural bias.

Needs assessments must be grounded in:

• the social model of disability;
• human rights principles;
• trauma-informed practice;
• intersectional analysis;
• participant-centred approaches. Recommendation 8

Require assessors to provide draft needs assessment reports to participants before submission to the CEO.

Recommendation 9

Make decisions relying on needs assessment reports reviewable decisions under Section 99.

Recommendation 10

Legislate minimum qualification, training, trauma-informed practice, and disability expertise requirements for Needs Assessors.

Recommendation 11

Require assessors to engage with participants’ existing treating teams and support networks wherever possible.

Recommendation 12

Legislate that assessment tools must be:

• human-rights based;
• culturally safe;
• trauma-informed;
• evidence-based;
• co-designed with people with disability;
• responsive to fluctuating disability;
• responsive to intersectional disadvantage. 9

Submission 557

Psychosocial Disability and Mental Health Impacts

The Bill creates disproportionate risks for people with psychosocial disability.

The proposed reductions to social and community participation supports risk increasing:

• isolation;
• relapse;
• hospitalisation;
• homelessness;
• family breakdown;
• crisis presentations;
• institutionalisation;
• suicide risk. Community participation supports are not optional extras for people with psychosocial disability.

They are core recovery supports.

The proposed reductions appear inconsistent with the evidence base acknowledged within the Explanatory Memorandum itself.

The Bill also risks destabilising psychosocial recovery coaching and support coordination arrangements that are critical for participants with complex mental health needs.

Recommendation 13

Defer reductions to social and community participation budgets for participants with psychosocial disability until:

• specific impact assessments are completed;
• alternative supports are operational;
• cumulative effects are independently assessed. Recommendation 14

Develop a dedicated psychosocial stream within future commissioned support coordination models.

Recommendation 15

Undertake a cumulative impact assessment examining the interaction of:

• funding reductions;
• eligibility tightening;
• new planning frameworks; 10

Submission 557

• support coordination reforms;
• foundational supports gaps.

Permanence Test Concerns

The proposed permanence framework is ill-suited to many psychosocial and fluctuating conditions.

The requirement that participants undertake “all appropriate treatment” before an impairment is considered permanent creates substantial risks.

Mental health treatment pathways are often:

• non-linear;
• contested;
• episodic;
• inaccessible;
• financially prohibitive;
• geographically unavailable. The Bill appears to treat inaccessible treatment as equivalent to declined treatment.

This risks unfairly excluding participants due to systemic failures rather than individual circumstances.

Recommendation 16

Rules under Section 25A(5) must be co-designed with people with lived experience of psychosocial disability and community mental health providers.

Recommendation 17

The permanence test must explicitly account for:

• fluctuating disability;
• episodic conditions;
• treatment accessibility barriers;
• financial barriers;
• geographic barriers;
• trauma-related disengagement from systems. 11

Submission 557

Plan Management and Choice and Control

The proposed CEO discretion to override participant plan management preferences is concerning.

The Bill lacks sufficient safeguards, definitions, and thresholds regarding:

• “financial harm”;
• “mental harm”;
• non-compliance;
• participant consultation requirements. Participants experiencing domestic and family violence, coercive control, exploitation, or abuse may require additional supports to continue self-management safely rather than losing autonomy.

Choice and control must remain central to the Scheme.

Recommendation 18

Legislate clear thresholds and procedural safeguards governing CEO overrides of participant plan management preferences.

Recommendation 19

Require involvement of the participant, advocates, carers, and support persons in decisions relating to plan management overrides.

Recommendation 20

Ensure participants have access to independent advocacy and supported decision-making before self-management rights are restricted.

Support Coordination and Recovery Coaching

The proposed commissioned model for support coordination may destabilise existing therapeutic relationships and community mental health infrastructure.

Participants with psychosocial disability often rely on long-term, trusted therapeutic relationships.

These relationships cannot simply be replaced through generic commissioning processes.

The reforms risk:

• provider exits;
• workforce instability;
• fragmentation of care;
• reduced continuity of support. 12

Submission 557

Recommendation 21

Co-design future support coordination and psychosocial recovery coaching models with:

• people with lived experience;
• Psychosocial Recovery Coaches;
• community mental health providers;
• disability-led organisations. Recommendation 22

Protect continuity of therapeutic relationships during any transition process.

Provider Viability and Thin Markets

The Bill may significantly destabilise providers operating in thin markets.

This includes:

• rural providers;
• psychosocial disability services;
• culturally specific providers;
• small disability-led organisations;
• specialised support services. Provider exits may reduce participant choice and increase service deserts.

Once specialised providers exit the market, rebuilding infrastructure is difficult and slow.

Recommendation 23

Undertake detailed provider viability and thin-market impact assessments before implementing major funding reductions or commissioning changes.

Recommendation 24

Develop targeted continuity-of-service protections for rural, remote, psychosocial, and specialist providers.

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Submission 557

Reasonable and Necessary Budgets

The proposed funding period limitations may undermine participant autonomy and flexibility.

Rigid funding periods do not reflect the realities of fluctuating disability, episodic needs, or self managed supports.

Further co-design is required.

Recommendation 25

Undertake genuine co-design with people with disability regarding funding period requirements and flexible budgeting arrangements.

Human Rights Considerations

This Bill engages numerous obligations under the CRPD, including:

• Article 5 — Equality and non-discrimination;
• Article 6 — Women with disabilities;
• Article 12 — Equal recognition before the law;
• Article 13 — Access to justice;
• Article 14 — Liberty and security of person;
• Article 16 — Freedom from exploitation, violence and abuse;
• Article 19 — Living independently and being included in the community;
• Article 25 — Health;
• Article 26 — Habilitation and rehabilitation;
• Article 27 — Work and employment. Any reforms that reduce access to supports, increase institutionalisation risks, or undermine participant autonomy must be carefully scrutinised against Australia’s international obligations.

Fraud, Misuse and Integrity Safeguards

This submission recognises that the integrity of the National Disability Insurance Scheme (NDIS) is essential to its long-term sustainability, participant safety, and public confidence. Strong safeguards against fraud, misuse, and inappropriate billing practices are necessary and supported in principle.

However, integrity measures must be implemented in a way that does not unintentionally shift evidentiary burden onto participants, or create barriers to justice, accountability, and fair review

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processes. In practice, current integrity systems can be reactive rather than preventative, and participant-driven rather than provider-accountable.

A key structural concern is the imbalance in evidentiary expectations when allegations of over servicing, non-delivery of supports, or inappropriate billing arise. Participants are often required to demonstrate non-provision of services, despite limited access to records, significant power asymmetries between providers and participants, and the administrative burden of substantiating lived experience of non-delivery.

Real-world examples of systemic integrity and reporting failure These concerns are not theoretical. They reflect repeated lived experience within the Scheme, including:

• A gardening service provider billing approximately eight hours per week over a 26-week period (plus transport costs to and from their base over 60 minutes away from the participants residence), invoiced as a lump sum, despite only attending approximately 40 minutes per month in practice. When concerns were raised with the NDIA, the participant was advised they were required to prove the service was not delivered. Photographic evidence of garden size and condition was not accepted as sufficient verification. The gardening service received full payment, and spent 6 weeks harassing the participant and threatening them with defamation. The participant had numerous support workers who were present at the premises and attested to the fact the claimed gardening hours did not occur.

• An occupational therapist charging approximately $4,000 for a home assessment that was no longer clinically relevant, as the participant was expected to remain in the property for only a further six weeks. The provider was aware of this timeframe, and the participant explicitly stated they did not want or require the assessment. The service proceeded and was billed in full. The provider then claimed another $4,000 for a home assessment at the new premises just 7 weeks later. The NDIA took the stance that the service was provided and would therefore be paid from the participants plan, even when the participant provided a copy of emails clearly stating they did not wish the first report to be written.

These examples highlight a disconnect between the Scheme’s stated integrity framework and the participant experience of enforcement in practice.

Assistance Animal Integrity, Misuse and Regulatory Gaps

A particularly high-risk area within broader integrity concerns is assistance animal funding and assessment. This sector involves complex clinical, behavioural, and welfare considerations, yet currently operates with inconsistent application of standards and limited post-funding verification.

Examples of reported concerns in assistance animal funding and practice

Across the sector, recurring concerns include:

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• Assistance animal funding being approved or claimed without sufficient evidence of task-based training or alignment with recognised assistance animal standards or the federal Disability Discrimination Act 1992 (Cth) which defines what an assistance animal must be trained to do. This has included animals who are matted to the bone and have sores across the body, and requiring veterinary care, animals who are not desexed and pregnant, and others with a bite history. These animals do not meet the threshold for public access rights under the Disability Discrimination Act 1992 (Cth). Nevertheless, the NDIS continues to fund maintenance for these animals.

• Assistance animal funding is being claimed for two dogs who have been classified as menacing and dangerous respectively by local councils, as recorded on the animals microchip. NDIS continues to fund these assistance animals for maintenance. This has been reported on numerous occasions to NDIS and no action taken as NDIA claim they have no way to view the animal’s microchip. This is incorrect, they can simply request copies of the animals registration papers from the participant or local council. There are other cases where the assistance animal being funded has been proven to be a restricted breed by a canine DNA test, yet the animal retains maintenance funding from the NDIS. These animals do not meet the threshold for public access rights under the Disability Discrimination Act 1992 (Cth).

• Documentation submitted that appears inconsistent, unverifiable, or not traceable to recognised training benchmarks. In several cases forged letterhead has been used to provide proof of training, when does not provide training of assistance animals. This has been reported numerous times and no action taken. There are numerous NDIS funded assistance animals who are not sufficiently toilet trained. These animals do not meet the threshold for public access rights under the Disability Discrimination Act 1992 (Cth).

• Animals presented as assistance animals while functioning as therapy or companion animals, without demonstrated disability-related task performance or public access readiness. These animals do not meet the threshold for public access rights under the Disability Discrimination Act 1992 (Cth).

• Use of aversive or prohibited equipment, including prong collars and electronic collars, in jurisdictions or contexts where such practices are restricted or inconsistent with humane working animal standards. These animals do not meet the threshold for public access rights under the Disability Discrimination Act 1992 (Cth) and violate state-based animal welfare and protection laws yet continue to receive NDIS funding.

• Animals in purported assistance programs presenting with welfare concerns such as obesity, injury, poor conditioning, or behavioural profiles inconsistent with operational working animal requirements. These animals do not meet the threshold for public access rights under the Disability Discrimination Act 1992 (Cth). We acknowledge part of the problem being the lack of national standards, however, the fact that the NDIA continues to provide funding for such animals dilutes the acceptability and best practice standards of the industry.

• Participants and organisations reporting concerns receiving limited follow-up or unclear outcomes after raising potential misuse. On many occasions have been promised a call back or other communication which has never been received. As a peak body of

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assistance animal welfare we consider it a priority to address animal welfare concerns. By providing funding for these animals. The NDIA continues to indicate the handlers that the condition of their animals is acceptable, even when these animals do not meet the threshold for public access rights under the Disability Discrimination Act 1992 (Cth).

In recent months several participants have lost their assistance animal funding due to the NDIA deciding that an assistance animal was not value for money. In each of these circumstances the participant then required 24/7/365 in-home care support at approximately $70 per hour. The downstream cost to the system was significantly higher than the cost of early intervention assistance animal support would likely have been, costing under $4,000 per annum total.

In several cases this has contributed to system escalation and breakdown in informal care arrangements, including the social admission for hospitalisation of participants. In one case, the participant is now costing the health department over $2,500 per day in funding to remain hospitalised, whereas their daily in-home support (including assistance animal upkeep) totalled under $1,000 per day.

Another participant is being driven 200 km round trip to hydrotherapy several cities over 3 times each week at a cost of $70 per hour for a support worker, plus transport costs. This is in place of the NDIA providing one-off funding for a chair lift for the participant to use their own in-home swimming pool. The allied health practitioner is also forced to claim additional time to travel to this location, claiming over $500 a week in transport alone. If the participant was able to be services at their premises, the practitioner states that they would not charge transport fees at all.

These examples illustrate not only potential misuse, but also misclassification and misunderstanding of assistance animal function within assessment and funding decisions, with direct impacts on participant wellbeing, carers, and system expenditure.

Position and Assistance Animal Standards Framework

is a disability-led organisation committed to advancing ethical, inclusive, and evidence-informed approaches to disability support, assistance animals, accessibility, and community participation.

works with people with disability, assistance animal handlers, trainers, allied health professionals, advocates, support workers, and community organisations across Australia. We are staffed by qualified, accredited and experienced veterinarians, allied health professionals, mental health and medical practitioners and animal behaviourists.

supports reforms that strengthen accountability, transparency, safeguarding, and sustainability within the NDIS. However, reforms must not compromise participant rights, autonomy, access to supports, or the broader social inclusion objectives of the Scheme.

Importantly, has already developed and made publicly available a comprehensive suite of national frameworks, including:

• professional standards and practice codes
• policy and procedure frameworks 17

Submission 557

• ethical charters and governance guidelines
• assistance animal assessment and training guidance
• welfare and handling standards
• applied best-practice documents suitable for both professional and self-training pathways

These frameworks draw upon and integrate internationally recognised best practice models, including the following and could easily be utilised by the NDIA to make informed assistance animal funding decisions.

• Assistance Dogs International (ADI) standards
• International Guide Dog Federation (IGDF) standards builds on these established models to ensure applicability within the Australian context, including diverse disability presentations, psychosocial disability needs, and self-training environments.

These frameworks prioritise:

• functional task-based assessment of assistance animals
• clear distinction between pets and legitimate assistance animals
• humane, non-aversive training methodologies
• animal welfare, health, and behavioural suitability standards
• public access readiness and safety requirements
• ongoing accountability, documentation, and review mechanisms Despite the existence and accessibility of these frameworks, there is limited evidence that the NDIA has systematically embedded or adopted them into national assessment, funding, or compliance systems for assistance animals. This represents a missed opportunity to improve consistency, reduce fraud risk, streamline assessment processes, and strengthen both participant and animal welfare outcomes.

Integrity Safeguards and System Improvements

Required

A more effective and balanced integrity framework should include:

• proportionate and timely investigation of suspected fraud or misuse

• provider-side accountability for accurate service records and transparent billing practices

• accessible, trauma-informed complaint and dispute resolution pathways 18

Submission 557

• acceptance of multiple forms of evidence, including contextual and environmental evidence where appropriate

• safeguards ensuring participants are not required to meet unreasonable evidentiary thresholds to validate lived experience

• protection against retaliatory impacts or withdrawal of supports following good faith complaints

• proactive compliance monitoring rather than complaint-driven enforcement For assistance animals specifically, integrity reform should also include:

• formal adoption of ADI, IGDF, and GHAD-aligned standards as baseline national benchmarks

• clear national criteria distinguishing companion animals from task-trained assistance animals, including adoption of such endorsed criteria to be utilised for making NDIA funding decisions

• improved post-approval auditing and verification mechanisms

• transparent and timely investigation outcomes for fraud and misuse reports

• reduced evidentiary burden on complainants acting in good faith Without these reforms, integrity systems will continue to rely heavily on participant reporting without delivering consistent, timely, or transparent enforcement outcomes. This is particularly problematic in high-risk and complex domains such as assistance animals, where welfare, safety, and disability rights intersect.

Recommendation 26

Introduce mandatory post-funding verification and audit mechanisms for high-risk supports, including assistance animals, home modifications, and high-value allied health interventions, to ensure services align with approved plans, lawful requirements, and evidence of delivery.

Recommendation 27

Require the NDIA to provide transparent, timely, and accessible investigation outcomes for all fraud and misuse reports, including whether action was taken and the rationale for decisions, subject to appropriate privacy protections.

Recommendation 28

Reduce the evidentiary burden placed on complainants acting in good faith by formally recognising contextual, environmental, and third-party corroborative evidence in fraud and service non-delivery investigations.

Recommendation 29

Require the NDIA to formally adopt or recognise existing sector-developed frameworks, including Assistance Dogs International (ADI), International Guide Dog Federation (IGDF), and Global Helpful Animals in Disability (GHAD)-aligned standards, as baseline guidance for assistance animal funding, assessment, and compliance decisions.

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Recommendation 30

Require that NDIS funded assistance animals be trained and assessed by an individual who is a credentialed member of , in much the same was a counsellor is required to be a member of the national peak body PACFA or ACA prior to providing NDIS services. is a completely independent accreditation body whose credential system can be used to independently asses the training, working and living standards for assistance animals. Membership or accreditation must be verified prior to eligibility for NDIS billing rights to ensure accountability, professional standards compliance, and alignment with recognised ethical and practice frameworks.

Closing Statement

We support sustainable reform of the NDIS.

However, sustainability cannot come at the expense of human rights, participant autonomy, procedural fairness, or community inclusion.

The NDIS was created to move Australia away from crisis-driven, institutional, and paternalistic disability systems.

Reforms that reduce support without ensuring accessible alternatives risk reversing that progress.

The people most affected by this Bill are among the least able to absorb policy failure.

For reforms of this magnitude, co-design is not optional. Safeguards are not optional. Foundational supports are not optional.

We urge the Committee to carefully consider the cumulative impacts of these reforms and to ensure that the rights, dignity, and safety of people with disability remain central to all legislative changes.

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Summary of Recommendations

1. Mandate co-design and disability leadership in all reforms.
2. Extend consultation timeframes for unconsulted measures.
3. Expand the definition of “NDIS support” to include broader human rights protections.
4. Exclude supports that promote isolation or segregation.
5. Delay eligibility tightening until foundational supports exist.
6. Publish implementation readiness assessments.
7. Prevent reassessment during framework transitions.
8. Provide participants with draft assessment reports.
9. Make reliance on needs assessments reviewable.
10. Legislate assessor qualification requirements.
11. Require engagement with existing support teams.
12. Mandate human-rights-based assessment tools.
13. Defer psychosocial funding reductions.
14. Develop a dedicated psychosocial support stream.
15. Conduct cumulative impact assessments.
16. Co-design permanence test rules.
17. Recognise treatment accessibility barriers.
18. Limit CEO discretion over plan management.
19. Require participant consultation in override decisions.
20. Ensure access to advocacy and supported decision-making.
21. Co-design support coordination reforms.
22. Protect therapeutic continuity.
23. Assess provider viability impacts.
24. Protect thin-market continuity of service.
25. Co-design funding period reforms.
26. Post-funding verification and audit processes.
27. Transparent investigation outcomes for fraud reports.
28. Reduce evidentiary burden on complainants.
29. Require NDIA adoption or recognition of existing sector frameworks. 21

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30. Establish mandatory membership with an assistance animal peak body for all assistance animals prior to being funded by NDIA.

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