Submission 584
National Disability Insurance Scheme Amendment (Securing the NDIS for Future
Generations) Bill 2026
Lotus Consultancy and Support Submission
Lotus Consultancy and Support is a registered provider of Support Coordination,
Psychosocial Recovery Coaching, and Specialist Support Coordination services
operating across the South East Corner of Queensland. As a provider delivering services under the NDIS, we submit the following comments and concerns for your consideration in relation to the drafted Bill. Lotus Consultancy and Support supports amendments that strengthen the Scheme by addressing fraud, non-compliance, and unsafe service provision. However, as currently drafted, the Bill appears to enact limited and effective changes to address these issues while introducing broader measures that reduce supports, restrict access, and limit individualised planning decisions. The consultation timeframe, together with the demands of operating a small business while maintaining service quality and effectiveness, has limited our capacity to fully consider and respond to every aspect of the Bill. As such we submit our key points for consideration below.
Schedule 1 Part 2 - Unscheduled Plan Reassessments
The expanded timeframe for deciding to approve an unscheduled plan reassessment from 21 days to 90 days is unreasonable. When a person meets the conditions listed in Section 48A, it is entirely unreasonable to expect them to wait up to three months for a decision from the NDIA to confirm the unscheduled reassessment has been approved. For participants with ageing parents who, more often than not bear the responsibility for the majority of support needs, this represents an unreasonable risk to the care and safety of participants. We also know that once a decision is made, the subsequent reassessment meeting and development of a plan to reflect the changed situation can take a further two months. In our experience, any change of situation submitted already reflects the conditions listed in Section 48A. The increase of plans funds following this process is typically as a result of unmet needs in the original plan not a reflection of unnecessary increases. Making it more difficult to request an unscheduled reassessment places further burden on people with disability to “prove” their needs exist.
We submit that the timeframe for a decision on a request for an unscheduled review is retained at 21 days.
Lotus Consultancy and Support
Ph: (07) 3319 7444 Email: info@lotusndis.com.au
PO Box 360, Jimboomba QLD 4280
Submission 584
Schedule 1 Part 4 - Support Determinations
The power to cap or reduce categories and classes of supports and participants represents a significant overreach. While the Bill references safety, it does not provide sufficient detail to give participants, providers, or families any certainty about how these powers will be applied. Further, the Bill disguises large-scale, broad brush funding reductions as sustainability measures, when their practical effect will be to eradicate choice, control, and individualised funding. The decision to reduce social and community budgets will result in people being unable to access health and therapy appointments, attend to mainstream services and carry out daily activities such as shopping. These activities are not “optional extras” and their removal or reduction will result in longer term impacts to health and well being with a likely longer term financial impact on other mainstream services. Further, the ability to develop and build social skills often requires community access to practice and embed skill development. Removing the ability to develop these skills further segregates and marginalises participants with behaviours of concern and complex support needs. For a participant who lives in supported independent living (SIL) and is accessing support in the community at a 1:3 ratio and funding is cut by 50% will the funding for SIL be increased to enable the individual to be supported at their usual place of residence and if not, how is this safe and what unintended outcomes are likely to arise? The Explanatory Memorandum acknowledges the disproportionate impact this will have on certain groups indicating the safety consideration has been acknowledged but disregarded prior to implementation. The Explanatory Memorandum also notes “In some cases, what is reasonable to fund may be less than the actual cost of a support. It is a different concept to the prevailing one, which is often what participants expect to receive from the NDIS”. In our experience, participant expectations are notoriously low and reflect a longstanding systemic bias towards limited or unsuitable funding. As drafted, the Bill further enforces the treatment of people with disability as second class citizens forced to battle bureaucracy, discrimination, stereotypes and system design to achieve a standard of living comparable to that of non-disabled Australians.
We submit that any support determinations require extensive consultation with participants and include comprehensive risk assessments and detailed impact analysis studies.
Lotus Consultancy and Support
Ph: (07) 3319 7444 Email: info@lotusndis.com.au
PO Box 360, Jimboomba QLD 4280
Submission 584
Schedule 1 Part 7 - Plan Suspensions
NDIA contact is frequently inconvenient and often dismisses the preferred method of contact recorded on a participant’s file. In our experience, NDIA will make multiple call attempts within a short timeframe. Where a text message advises that a NDIS representative will call within a one-hour window, this effectively requires participants and families to place their lives on hold in anticipation of contact. This is neither reasonable nor respectful, and repeated calls within a short period should not be treated as an adequate or an appropriate contact attempt.
On a practical note, will current providers be notified of any plan suspensions? If a participant is unable to be contacted how will a provider be notified and advised of any changes to funded supports?
We submit that this section of the Bill is removed.
Explanatory Memorandum Support Coordination Reform Options
As a registered provider of Support Coordination services, Lotus Consultancy and Support welcomes any review of the quality, effectiveness, accessibility and consistency of these services. Lotus C&S commenced as an unregistered provider and completed the registration process for Support Coordination services in 2022. While originally registered for Core supports and Therapeutic supports in addition to Support Coordination, the business made the strategic decision to withdraw from Core supports to further demonstrate a commitment to a separation of business and to avoid raising a conflict of interest. While Lotus C&S retains registration as a Therapeutic service provider, these services are managed with strict protocols and restricts the delivery of both support coordination and a therapeutic support from Lotus C&S.
Support Coordinators are tasked with building participant capacity to navigate the NDIS, understanding and managing funding allocations, negotiating prices, understanding Service Agreements, connecting and navigating community and mainstream supports and review and monitor service quality and effectiveness. These tasks are completed in an environment where the Scheme is complex, policy and operational changes are frequent, and the funding available to keep participants and their supports informed and up to date is limited. Support Coordinators are therefore being asked to undertake increasingly complex work with insufficient resources. Our
Lotus Consultancy and Support
Ph: (07) 3319 7444 Email: info@lotusndis.com.au
PO Box 360, Jimboomba QLD 4280
Submission 584
Support Coordinators provide services to people who experience varying capacity to independently undertake this work themselves. This capacity is not fixed in time and varies as much as the individuals we support. We meet people where they are and respond as needs arise. This is not a frivolous or futile use of resources; it is a necessary and critical part of effective Support Coordination. Removing local Support Coordination providers who know the people and communities in which participants live, work and socialise would create further systemic barriers to accessing services and supports. We are concerned that the drafted Bill will remove the individualised support for people experiencing the greatest levels of disadvantage leading to even deeper inequity and exclusion. This includes First Nations peoples, culturally and linguistically diverse communities, LGBQTIA+ community, people with low literacy, non traditional communicators, individuals involved with the justice and child safety systems, and those experiencing, escaping, or surviving domestic and family violence. Our Support Coordinators are required to meet people in their local community or residence as we understand in person coaching and capacity building delivers better outcomes and improved understanding. This is particularly the case for people who use alternative communicate methods, do not speak English as their first language and for those with low literacy.
Over time, it has become clear that the scale of operations required to remain a viable Support Coordination provider under a pricing structure frozen for six consecutive years must evolve. Lotus C&S has demonstrated its capacity to successfully adapt to this shift. The knowledge, expertise, and historical understanding held by the organisation’s personnel cannot be quickly or easily replicated within a new service model. Furthermore, the costs associated with establishing, implementing, and operating an alternative model would, in themselves, contribute to increased expenditure.
Lotus Consultancy and Support acknowledges workforce turnover as one of the most significant drivers of increasing costs to the business. Turnover rates are increasing and, while the business remains committed to improving conditions that support longer term employment, the reality is that the role of Support Coordinator is becoming increasingly undervalued and criticised. Lotus C&S does not claim to get everything right all the time; however, it is committed to learning when things do not go as planned and to addressing errors where they occur. The drafted Bill, and the narrative used to build support for it, undermines the effort invested and the quality of outcomes achieved to date. It positions stakeholders and supporters as adversaries and creates false conflict where collaboration and shared purpose previously existed.
Lotus Consultancy and Support
Ph: (07) 3319 7444 Email: info@lotusndis.com.au
PO Box 360, Jimboomba QLD 4280
Submission 584
As a small business, Lotus C&S continues to absorb the costs of State based portable leave schemes, registration costs, rising wages and superannuation and for the most part, travel costs. We employ locals who contribute to their local economy and share their knowledge, expertise and experience across the community, regardless of any available funding source. Lotus C&S was originally built with a workforce consisting of personnel from a LAC/NDIS background and this knowledge should be an important consideration for the future structure and direction of Support Coordination. Building rapport and helping participants to understand NDIS while enhancing their functional capacity and skills is a critical purpose for Support Coordination.
While the matters outlined above may be used to justify a shift to a commissioned model of support, the reality is that small, local providers can, and do, deliver equitable, effective and high-quality outcomes at a lower cost. What is needed is not the removal of local providers, but appropriate indexation of funding and the release of a transparent costing model so businesses can better understand cost drivers and make informed decisions about service viability. Commissioning a new model alone would require significant investment, and any oversight of how funds are used is likely to be diminished within the bureaucracy of a large-scale operation.
We submit that the government open a Support Coordination workgroup that is available to reputable registered Support Coordination providers and participants to ensure future decisions are well informed. We propose an increase to the current price limit for Support Coordination to better reflect the skills, experience and expertise required to deliver this role effectively. Further, a Commissioned Model must offer participants choice and the ability to access local and familiar registered providers.
Lotus Consultancy and Support
Ph: (07) 3319 7444 Email: info@lotusndis.com.au