National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 592
Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Submission to the Senate Community Affairs Legislation
Committee
National Disability Insurance Scheme Amendment
(Securing the NDIS for Future Generations) Bill 2026
Author: Ability Pathways Australia
Prepared by: Jodie Herbert
Date: 29 May, 2026
A disability advocacy and economic impact submission opposing passage of the Bill in its current form
Core Position
The Bill and associated Budget measures should not proceed until Parliament has been provided with full macroeconomic, disability cohort, state-system, provider-market and human rights impact assessments.
Contact Details:
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Table of Contents
SECTION TITLE PAGE
1 Executive summary 3
2 Recommendations to the Senate 5
3 Method and evidence base 7
4 What the Bill proposes 8
5 The 17 major risks identified in the Bill 13
5.1 Whole-economy modelling risk 15
5.2 False-economy and cost-shifting risk 17
5.3 Provider-market failure risk 19
5.4 Unemployment and labour-oversupply risk 22
5.5 Tax receipt, GDP and household consumption risk 25
5.6 Participant functional decline risk 26
5.7 SCCP reduction risk 28
5.8 CBDA implementation-loss risk 30
5.9 Family and informal-care substitution risk 33
5.10 24/7 critical daily living, intimate-care and dignity risk 35
5.11 Thriving Kids capped-funding and transition risk 38
5.12 Early-intervention market contraction risk 41
5.13 Schools, childcare and community-health cost-shift risk 45
5.14 Digital payments and automated payment-control risk 48
5.15 Robo-assessment and loss of effective appeal rights 51
5.16 Treatment-first and theoretical mainstream service substitution risk 54
5.17 Market consolidation and loss of participant choice risk 57
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
SECTION TITLE PAGE
6 Economic impact analysis: what the Government has not modelled 61
7 Disability cohort impact analysis: why uniform cuts create unequal harm 69
8 State-based and foundational support model risk 79
9 Budget comparison, fiscal governance and public trust 86
10 Political rhetoric, social licence and mental health impact 91APPENDICES
Appendix A Updated risk register 95
Appendix B Key data tables used in the submission 97
Appendix C Key quotations and relevance 101
Appendix D Legislative risk analysis matrix and legal tripwire register 102
Appendix E Cohort impact matrix 105
Appendix F Scenario failure analysis 107
Appendix G Questions for the Committee to put to Government witnesses 108
Appendix H Proposed safeguards / conditions before passage 110
Appendix I One-page evidence propositions for Senators 111
Appendix J Core bibliography 112
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
- Executive summary This submission opposes the proposed NDIS reforms in their current form.
The reform package is being presented as a sustainability measure, but its central weakness is that the Government has modelled the savings more clearly than it has modelled the consequences. The 2026–27 Budget identifies $37.8 billion in NDIS savings over four years, yet the public material does not provide a transparent whole-economy model of the impact on GDP, employment, tax revenue, small business viability, carer workforce participation or downstream public systems.
That is the core evidentiary failure.
The NDIS is not only a disability support scheme. It is a national economic ecosystem. NDIS funding flows into wages, sole traders, microbusinesses, allied health practices, transport, assistive technology, support coordination, administration, software, insurance, training and local spending. It also enables people with disability and unpaid carers to remain connected to work, education, community life and economic participation.
The risk is that the reforms treat NDIS spending as a cost to be reduced, rather than an enabling investment whose withdrawal creates consequences elsewhere. Using Per Capita’s estimate that every $1 of NDIS underfunding may reduce economic activity by approximately $2.25, the Government’s proposed $37.8 billion saving creates an illustrative exposure of around $85 billion in economic activity at risk. That does not prove the full loss will occur, but it clearly shows why whole economy modelling is essential before reforms of this scale are legislated.
The Government’s reform path appears to assume that participant numbers can continue growing at around 5–6 per cent per year while funding growth is held down. In practice, this means more participants sharing a tighter funding envelope, lower average support intensity, weaker utilisation, increased unmet need and higher pressure on families and providers.
The proposed reductions to social, civic and community participation and capacity-building daily activity funding are especially concerning. These supports are not optional extras. They help maintain routine, communication, skill development, employment readiness, therapy implementation, community access, informal connection, family resilience and functional capacity. Cutting them risks functional decline, isolation, carer burnout, provider failure and higher downstream costs.
The provider market is also at risk. The NDIS has built a decentralised disability-support economy made up of small providers, sole traders, microbusinesses, allied health professionals and community-based services. Many operate on thin margins and depend on participant continuity. When participant budgets fall, provider income falls immediately. In thin markets, this does not create efficiency; it creates market exit.
The economic risk intrinsic in the proposed Thriving Kids program is not that early support is a bad idea. It is that the Government is shifting children from an uncapped, individualised, participant-directed insurance model into a capped service system before proving that the replacement system has enough funding, workforce, providers, delivery capacity, local availability or will be equally if not more effective than the current system. And, if the capped model cannot meet demand, the cost does not disappear. It shifts to families, schools, community health, private out-of-pocket spending and delayed developmental intervention.
The impact will also be gendered. Women make up a large share of unpaid carers, primary carers and the paid disability workforce. If funded supports are reduced, women are likely to be hit twice: first through reduced paid work in the disability sector, and second through increased unpaid care when families are forced to replace lost supports at home.
This submission identifies 17 major risks across the reform package: whole-economy modelling failure; false-economy cost shifting; provider-market failure; labour-market disruption; tax receipt, GDP and household consumption loss; participant
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
functional decline; SCCP cuts; CBDA reductions; family and informal-care substitution; 24/7 critical daily living, intimate-care and dignity risk; Thriving Kids capped-funding and transition risk; early-intervention market contraction; schools, childcare and community-health cost shifting; digital payments and automated payment-control risk; robo-assessment and loss of effective appeal rights; treatment-first and theoretical mainstream service substitution; and market consolidation with loss of participant choice.
It also identifies legal tripwires that may trigger harm in practice, including category-wide support determinations, hidden caps, narrowed whole-person assessment, loss of capital funding continuity, weak emergency reassessment pathways, treatment-first access barriers, theoretical mainstream substitution, nominee risk, digital payment controls and automated decision-making.
The Senate should not assess these reforms only by their projected savings to the Commonwealth. It must also assess the costs likely to be transferred to participants, families, unpaid carers, women, small businesses, workers, states, hospitals, Medicare, Centrelink, housing, justice and the broader economy.
A sustainable NDIS must be financially responsible. But it must also be economically intelligent, socially protective and faithful to its original purpose: supporting Australians with significant disability to live with independence, dignity, safety and genuine participation.
“The Scheme provides funding for reasonable and necessary supports to allow people with disability to be independent, and participate in social and economic life.” - Office of Impact Analysis, NDIS Reforms, 2026
Per Capita multiplier sensitivity applied to the Budget saving. This is a sensitivity calculation, not a forecast, and shows why a full Treasury-level model is required.
These figures are illustrative, not a Treasury forecast. They show the scale of economic exposure the Government has not transparently modelled: employment loss, provider exit, reduced tax receipts, lower GDP activity, and the transfer of child development costs from individualised NDIS plans into a capped Thriving Kids model. The key issue is not whether the Commonwealth can reduce NDIA outlays. It is whether those savings are genuine net public savings, or whether they shift costs into families, schools, state services, health systems, unpaid care and the broader economy.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
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Recommendations to the Senate No. Recommendation Reason
1 Do not pass the Bill in its current form. The Bill should not proceed until macroeconomic, disability cohort, provider-
market, state-system and human rights impacts have been modelled and published.
2 Require a full macroeconomic impact The analysis must model GDP, employment, tax receipts, householdstatement. spending, regional economies, small business viability and downstream system costs.
3 Suspend SCCP and CBDA budget resets. The proposed 50% SCCP and 10% CBDA reductions should not proceed unlesscohort-specific harm modelling is published and participant safeguards are legislated.
4 Publish disability cohort impact The Parliament should receive specific analysis for autism, developmentalassessments. delay, intellectual disability, psychosocial disability, sensory disability, Down syndrome, acquired brain injury, neurological conditions, physical disability and high-intensity support cohorts.
5 Publish a Thriving Kids economic and Government must show how a capped Thriving Kids model will absorbcapacity model. demand from children aged 8 and under without shifting costs to families, schools, childcare, community health, allied health providers and state services.
6 Prohibit cost-shifting without funded service No participant should be moved out of NDIS-funded support unless anotheragreements. funded, enforceable and accessible service pathway exists.
7 Prevent unpaid family care being used as a Family, partner or parental support should not be treated as free 24/7 labourfunding substitute. that reduces funded supports, particularly for adult participants.
8 Require state and foundational supports to The pre-NDIS state-based model failed because it was rationed, fragmentedbe legislated, funded and independently and uncertain. The Senate should not approve a return to that model by monitored before NDIS reductions. another name.
9 Retain participant choice and control as a Commissioning and panels must not replace individualised budgets wherestatutory protection. individualised supports are required to maintain safety, capacity and participation.
10 Legislate safeguards for reassessment, Administrative efficiency must not override natural justice, disability access,suspension and automation. communication support, advocacy or human review.
11 Publish underlying modelling and Internal NDIA analysis, actuarial assumptions, Budget sensitivity modellingassumptions. and cohort-level impact data should be made available to the Committee in accessible formats.
12 Require an independent post- Evaluation should not occur after harm is entrenched. A real-time safety andimplementation harm monitor. economic impact monitor should report publicly every six months.
Additional legal safeguards required before passage
The table above sets out the core recommendations. The following additional safeguards are required because the Bill contains legal mechanisms that may reduce support, narrow access, weaken review rights, consolidate markets and shift risk onto participants, families, carers, providers and other public systems.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
A. Preserve individual merits review rights where category-wide cuts, support determinations, assessment outcomes or budget caps create unsafe, unreasonable or inappropriate outcomes.
B. Exempt participants with 24/7, complex health, behavioural, communication, airway, swallowing, absconding, intensive 1:1 or safety-related support needs from uniform percentage cuts.
C. Suspend any transition of children aged 8 and under from the NDIS into Thriving Kids unless the Government first publishes a funded demand model, age-level cohort forecast, per-child funding rate, workforce plan, state-capacity model and service guarantee.
D. Require that Thriving Kids and foundational supports be legislated, funded, enforceable and operational before any child loses NDIS-funded early intervention, therapy implementation or developmental support.
E. Prohibit cost-shifting to schools, childcare, community health, GPs, families or state systems unless those systems are funded, accessible, timely and legally responsible for meeting the child’s support need.
F. Require all cap values, ratio limits, intensity limits, assessment weightings, cohort definitions and funding formulas to be included in disallowable instruments.
G. Delete or qualify the word “directly” so interacting impairments, cumulative disability impact and whole-of-person functional need remain recognised.
H. Remove any presumption that parents, partners or informal supporters can provide substantial care, supervision, personal care, transport, emotional regulation, behavioural support or 24/7 availability without a clear reasonableness benchmark.
I. Protect bodily autonomy and dignity by ensuring intimate care and safety-related support are not forced back onto family or informal networks unless the participant freely chooses that arrangement.
J. Clarify the apparent contradiction between excluding family and informal supports from functional capacity assessment while allowing family and informal supports to be considered before funding approval. The Government must explain whether the participant is being assessed as an individual, or whether family labour is being treated as a substitute for funded support.
K. Protect one-off capital funding already quoted, ordered, approved or underway, including wheelchairs, home modifications, vehicle modifications, communication devices and assistive technology.
L. Create a 14-day emergency reassessment pathway for urgent safety, housing, behaviour, health, support collapse, provider failure or carer breakdown risk.
M. Define “reasonable attempts” to contact a participant before suspension or revocation and require accessible communication, nominee contact, advocacy support and human review before adverse action.
N. Do not require a person to exhaust “all appropriate treatment” where treatment is unaffordable, unavailable, geographically inaccessible, clinically inappropriate, traumatising, on a long waitlist or unlikely to remove substantial functional impairment.
O. Define “materially improve” so treatment only affects eligibility where it improves function to the point that the person no longer meets the access threshold.
P. Do not exclude impairment-related support because another scheme theoretically exists unless that scheme is actually available, timely, funded, enforceable and capable of meeting the support need.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Q. Retain a practical self-management claim window or create broad exceptions for disability, hospitalisation, bereavement, family violence, executive functioning impairment, nominee incapacity and administrative delay.
R. Protect good-faith unpaid family nominees from civil penalties and distinguish fraud from error, disability-related administration barriers and administrative incapacity.
S. Create a binding pre-purchase or pre-claim advice pathway so participants can confirm whether a support will be claimable before spending money.
T. Broaden replacement-support rules so participants can choose cheaper mainstream alternatives where those alternatives achieve the same or better functional outcome.
U. Ensure the evidence test recognises lived experience, clinical judgement, functional evidence and rare-disability realities, rather than allowing absence of peer-reviewed research to operate as a veto.
V. Require that any cheaper “comparable” support must achieve the same or better functional outcome. A cheaper support that fails is not value for money.
W. Require provider-market safeguards before registration, commissioning, panel arrangements or funding cuts cause sole-trader exit, thin-market failure, service gaps or loss of participant choice.
X. Require labour-market safeguards before reforms reduce funded demand for disability workers, allied health graduates, RTOs, trainers, support coordinators, plan managers and small providers.
Y. Make automated decision-making safeguards legally enforceable and require human review before adverse decisions about plans, payments, claims, suspension, revocation, eligibility, reassessment or pricing take effect.
Z. Require statutory quarterly public reporting on claim rejections, reassessment timeframes, suspensions, revocations, unmet need, safety incidents, hospitalisations, restrictive practices, review outcomes, provider exits, labour-market impacts, automated decisions and cohort impacts.
AA. Require an independent post-implementation review within two years, with a legislated remedial trigger if evidence shows increased unmet need, harm, hospitalisation, restrictive practice, carer collapse, provider exit, unemployment, market contraction or rights regression.
- Method and evidence base This submission uses a disability advocacy and public economics lens. It asks not only whether the proposed reforms reduce Commonwealth expenditure, but where the costs reappear, who carries them, and whether the claimed savings survive when broader economic and social impacts are counted.
The analysis draws on official government sources, parliamentary committee material, NDIS administrative data, ABS disability and carer statistics, AIHW employment material, the Productivity Commission’s original disability care and support findings, the NDIS Review, and third-party economic modelling by Per Capita commissioned by National Disability Services. The submission uses four analytical tests:
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Functional impact test: what happens to capacity, independence, community access, work, safety and daily living?
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Economic displacement test: what costs are transferred to carers, providers, states, Medicare, hospitals, Centrelink, schools, housing and justice systems?
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Submission 592
Submission to Senate Inquiry - Proposed NDIS Reforms 2026
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Market viability test: what happens to small providers, sole traders, regional markets, support workers and allied health providers?
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Rights and governance test: what powers are expanded, what review pathways are narrowed, and what safeguards are missing?
A key limitation is that several government figures referenced by the Impact Analysis rely on unpublished internal NDIA analysis. That itself is a governance concern. The Senate is being asked to consider substantial changes while some of the material used to justify and calibrate those changes is not publicly available for independent scrutiny.
“The number of participants impacted and the impact on Scheme costs have been modelled as a package.”
Office of Impact Analysis, NDIS Reforms, 2026
“DSS confirmed that the government is not currently undertaking work to model the economic benefits of the NDIS.” - Joint Standing Committee on the NDIS, Implementation, Forecasting and Sustainability
- What the Bill proposes The Bill is not a single technical amendment. It is a structural reset of access, planning, support determinations, reasonable and necessary decision-making, plan renewal, suspension, fraud powers, provider registration, pricing, automation, new framework planning and the interface between the NDIS, foundational supports, state systems and unpaid family care.
The Department’s fact sheet summarises the Bill across four schedules: Access and Planning Measures, Fraud measures, Governance arrangements and New framework planning. However, the economic and practical effect of the Bill is broader than these headings suggest. The following table identifies the core legislative changes and the principal risk lens applied in this submission.
Legal and Legislative Pathways from NDIS Cuts to Wider Public and Market Costs
These risks are not speculative. They arise from the Bill’s own architecture, including ministerial powers to reduce funding for groups of supports and expanded automation of administrative decisions.
Reform Element Bill Proposal Risk Lens
Functional capacity Access decisions based on Risk of narrow, tool-driven access decisions that under-recognise
framework substantially reduced functional fluctuating, episodic, psychosocial, neurodevelopmental andcapacity and a definition of functional invisible disability. capacity.
Family and informal Functional assessment may exclude Risk of internal contradiction: the assessment treats the person
supports interface family and informal supports, while as an individual, but the funding decision may assume family canfunding decisions may consider those provide the support. This shifts cost to unpaid carers and affects supports before funded supports are safety, stability, health, participation and everyday functioning. approved.
Limit to unscheduled Tighter criteria; only participants, Risk that crises, carer breakdown, provider failure and rapid
reassessments nominees or guardians can request; deterioration are not addressed in time.requires significant and ongoing change.
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Reform Element Bill Proposal Risk Lens
Link to support to Supports funded only where need Risk of excluding whole-person supports where disability
impairment arises directly from access interacts with housing, mental health, family, employment,impairment. education, transport or community safety.
Support Ministerial determinations to reduce Risk of group-based cuts overriding individual functional need
determinations funding for groups of supports, and creating avoidable decline, unpaid care and downstreamincluding SCCP and CBDA. public cost.
SCCP budget reset Proposed reduction to Social, Civic and Risk of reducing community access, employment readiness,Community Participation funding. psychosocial stability, informal connection, provider income and support-worker hours.
CBDA budget reset Proposed reduction to Capacity Risk of reducing therapy implementation, allied-health demand,Building Daily Activities funding. early intervention, functional skill development and graduate caseload viability.
Thriving Kids / Children aged 8 and under with Risk of moving a large early-childhood cohort from a demand-
foundational developmental delay and/or autism driven insurance model into a capped service model without
supports with low to moderate support needs published per-child funding, workforce, state-capacity or age-may be redirected from individualised level demand modelling. NDIS plans into capped foundational supports.
Plan renewal Legislated end dates and no carry-over Risk of penalising conservative, episodic or delayed use andof unspent funds. creating pressure to spend rather than plan.
Reasonable and NDIA must consider Scheme Risk that fiscal considerations dilute individual need, insurance
necessary sustainability and equity across principles and functional safety.participants.
Plan suspension and Plans can be suspended after failed Risk to people with unstable housing, communication disability,
revocation contact; participation can be revoked psychosocial disability, family violence, cognitive disability orafter 90 days. administrative vulnerability.
Permanence Access only where all appropriate Risk that people are forced through medical treatment pathwaystreatment has been undertaken and before practical disability supports are recognised no treatment is likely to materially improve impairment impact.
Other service Eligibility affected by access to Risk of interface gaps and cost-shifting to health, education,
systems compensation or other systems housing, state disability, families and unpaid care where noenforceable alternative service exists.
Provider registration Expanded mandatory registration and Fraud control is necessary, but compliance design may collapse
and civil penalties civil penalties. sole-trader and micro-provider markets if not proportionate.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Reform Element Bill Proposal Risk Lens
Provider-market Registration, panels, commissioning Risk of thin-market failure, labour oversupply, underemployment,
consolidation and funding reductions may reduce business exit and reduced participant choice.small-provider viability.
Information Stronger powers and record Risk for participants with cognitive, intellectual, psychosocial,
gathering and record obligations; debts where records are communication or executive-function disability.retention not kept.
Claim timeframe Claims required within 90 days. Risk of non-payment and debt for participants and providers inreduction complex administrative situations.
Ministerial pricing Commonwealth Minister becomes Risk of ministerial overreach, politicised pricing and reduced
decision decision maker on NDIS pricing. independent price-setting.
Automation NDIA may automate specific Risk of inaccessible, opaque or error-prone administration,administrative actions including claims especially where human context matters. and payments.
New framework Budget method rules, support needs Risk that critical settings move to rules and instruments rather
planning assessment rules and updated NDIA than direct parliamentary scrutiny.documents may be incorporated.
“Part 4 enables the Commonwealth Minister to make determinations to reduce funding for groups of supports.” - Department of Health, Disability and Ageing, Bill fact sheet, 2026
“Part 2 allows the NDIA to automate specific administrative actions.” - Department of Health, Disability and Ageing, Bill fact sheet, 2026
Economic Transmission Pathways from NDIS Cuts to Wider Public and Market Costs
The following table identifies how the proposed reforms may transmit beyond the NDIA ledger into the wider economy. The key issue is that reduced NDIS expenditure does not simply remove cost. It reduces participant purchasing power, provider revenue, allied-health demand, support-worker hours, small-business turnover and family workforce participation. Where supports are withdrawn before replacement systems are funded and operational, costs are likely to reappear in schools, childcare, community health, Centrelink, housing, unpaid care and other public systems.
The Senate must insist that the proposed NDIS reforms be assessed as a whole-economy risk, not only as an NDIA savings measure. The proposed changes operate through multiple channels at once: direct budget reductions, capped foundational supports, market consolidation, family substitution, provider compliance pressure and tighter eligibility. Taken together, these mechanisms may reduce visible Scheme expenditure while increasing hidden costs through unemployment, underemployment, unpaid care, reduced tax receipts, weaker local spending, service gaps and downstream pressure on mainstream systems. The Senate should therefore require a net public cost model before the Bill proceeds.
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Reform mechanism Likely economic effect Level of Risk1 = Low, 5 = Urgent
50% SCCP budget reset Direct reduction to social, civic and community participation funding. Reduces RISK = 5participant access, provider revenue and support-worker hours and community URGENCY = 5 participation.
10% CBDA budget reset Direct reduction to capacity-building daily activities funding. Reduces therapy RISK = 5implementation, allied-health demand, allied health caseloads and provider URGENCY = 5 viability.
Thriving Kids transition for Shifts some children with developmental delay and/or autism with low to moderate RISK = 5
children aged 8 and under support needs from individual NDIS plans into a capped foundational supports URGENCY = 4system. This reduces NDIS demand for early childhood intervention, allied health, therapy assistants and small private providers.
Capped foundational Foundational Supports are capped, unlike demand-driven individual NDIS plans. If RISK = 5
supports funding child demand exceeds funding, the unmet need is likely to appear as waitlists, URGENCY = 5rationed sessions, group programs, family out-of-pocket costs, school pressure and delayed intervention. The National Agreement says the first five-year funding envelope is capped at $10 billion across foundational supports, with Thriving Kids as the first cohort.
Early childhood allied- Reduces private demand for speech pathology, occupational therapy, psychology, RISK = 4
health market contraction physiotherapy, developmental educators, behaviour practitioners and allied-health URGENCY = 4assistants who currently rely on NDIS-funded children’s plans. This may create graduate underemployment and weaken the early-intervention workforce pipeline.
RTO and training-market If fewer early-childhood and disability providers are hiring, demand falls for RISK = 4
impacts disability, community services, allied-health assistant and early-childhood URGENCY = 3intervention training. RTOs may lose enrolments, trainers may lose work, and course offerings may contract.
Pressure on schools, Children moved out of individualised NDIS plans will still need support. If Thriving RISK = 5
preschools, childcare and Kids is not sufficiently funded, schools, early childhood settings, GPs, community URGENCY = 5community health health and state services may absorb the unmet need without equivalent staffing or funding.
Family cost shifting Families may lose individualised therapy budgets and instead rely on general RISK = 5supports, group services or limited targeted supports. This can increase out-of- URGENCY = 5 pocket therapy spending or unpaid parental labour, reducing workforce participation and household income.
Tighter reasonable and Future plans may fund fewer supports if supports are judged not reasonable and RISK = 5
necessary criteria from 1 necessary under the new test. This may reduce participant purchasing power and URGENCY = 4February 2027 provider income.
New framework planning / Budgets will be built through a new assessment process based on functional RISK = 5
support needs assessment capacity, life stage and environmental factors. This may reduce or redistribute plan URGENCY = 5from 1 April 2027 budgets and create funding volatility.
Clearer / tighter eligibility Some people may not enter or remain in the Scheme if access rules narrow, shifting RISK = 5
requirements demand into state systems, health, education, housing, families and unpaid care. URGENCY = 4
Tightening eligibility based Participants may be redirected to health, education, housing, state disability or RISK = 5
on access to other service other mainstream systems, even where those systems are not funded or equipped URGENCY = 5systems to provide disability-specific support.
Limits on unscheduled Participants may have less ability to seek funding increases when function declines RISK = 5
plan assessments or circumstances change, increasing crisis risk and downstream public cost. URGENCY = 4
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Reform mechanism Likely economic effect Level of Risk1 = Low, 5 = Urgent
Mandatory registration for May reduce use of unregistered providers, especially sole traders and small RISK = 4
higher-risk supports from providers, affecting thin markets and reducing participant choice. URGENCY = 41 July 2027, rolled out to Dec 2030
Plan management panel Participants using plan management must choose from a government panel, likely RISK = 4
from 1 October 2027 consolidating the market and reducing income for existing plan management URGENCY = 4businesses.
New commissioned Support coordination will no longer be purchased through participant plans; it will RISK = 4
support coordination / move to directly funded commissioned providers, reducing participant choice and URGENCY = 3connection service from 1 likely consolidating the provider market. July 2028
Pushback to parental, Shifts support costs from paid labour into unpaid 24/7 care. Families may be RISK = 5
partner and family expected to absorb personal care, supervision, transport, prompting, emotional URGENCY = 5responsibility regulation, administration and crisis response. This reduces workforce participation, especially for women, lowers taxable income, increases carer burnout and creates hidden economic cost outside the NDIA ledger.
Family and informal Creates a risk that everyday family assistance will be treated as available support RISK = 5
supports considered and used to reduce funded supports, even for adult participants. This converts URGENCY = 5before funding approval family care into a substitute for formal disability support and may reduce participant independence, carer employment and household economic security.
Contradiction between If the functional capacity assessment excludes family and informal supports, but the RISK = 5
functional assessment and funding decision later considers those same supports before approving funded URGENCY = 5funding decision support, the framework becomes internally inconsistent. The assessment may measure the participant as though the family does not exist, while the funding decision assumes the family can do the work.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
- The 17 major risks identified in the Bill This submission identifies seventeen major risks arising from the proposed NDIS reforms. These risks are grouped into four categories: economic and fiscal risks, participant and family harm risks, children and early-intervention risks, and legal, administrative and rights risks.
The purpose of this structure is to show that the Bill does not create one isolated risk. It creates a chain of linked risks: reduced participant funding, reduced provider demand, labour-market contraction, family cost-shifting, increased pressure on state and mainstream systems, and weakened legal safeguards.
Risk Risk Name Risk Statement Required Safeguard1 Whole-economy The Government has modelled the $37.8b Budget Require a full macroeconomic impact
modelling risk saving, but not the full economic consequences statement before passage.for GDP, employment, tax receipts, provider exits, household spending, carers, states and downstream systems.
2 False-economy risk and Reduced NDIA expenditure may reappear as Assess the Bill using net public cost, not
cost-shifting risk higher costs in hospitals, Medicare, Centrelink, NDIA outlays alone.housing, justice, child protection, state disability services and unpaid care.
3 Provider-market failure The NDIS provider market is heavily made up of Publish provider-exit modelling and
risk sole traders, microbusinesses and small protect thin markets beforeproviders. Funding reductions may cause implementing cuts or commissioning provider exit rather than efficiency. changes.
4 Unemployment and Reduced participant-directed funding may reduce Require labour-market modelling,
labour-oversupply risk shifts, caseloads, allied-health demand and small- including unemployment,business income, creating underemployment and underemployment, Centrelink exposure unemployment. and regional impacts.
5 Tax receipt, GDP and Reduced provider and worker income may lower Publish tax-revenue, GDP and
household consumption income tax, company tax, GST-linked household-consumption impact
risk consumption, superannuation, household modelling.spending and local business turnover.
6 Participant functional Supports maintain function, safety, dignity and Maintain supports for high-risk
decline risk participation. Removing supports may cause participants unless an individualdelayed decline, crisis, hospitalisation or higher functional impact assessment shows future support costs. reduction will not cause harm.
7 SCCP reduction risk Social, Civic and Community Participation is often Suspend SCCP reductions unlessfunctional infrastructure, not leisure. Cuts may cohort-specific harm modelling and reduce routine, safety, employment readiness, individual safeguards are legislated. community visibility and carer resilience.
8 CBDA implementation- Capacity Building Daily Activities funds therapy Suspend CBDA reductions unless
loss risk implementation, skill development and daily-life impacts on children, therapyexecution. Cuts may turn clinical implementation, remote participants recommendations into unfunded advice. and allied-health markets are modelled.
9 Family and informal care The reforms may shift paid disability support into Prohibit family or informal care being
substitution risk unpaid family labour, reducing workforce treated as a funding substitute withoutparticipation and increasing carer burnout. a clear reasonableness and sustainability test.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Risk Risk Name Risk Statement Required Safeguard10 24/7 care, intimate-care Participants with complex personal care, safety, Exempt high-risk and 24/7 support
and dignity risk behavioural, communication or health needs may participants from uniform cuts andbe exposed to unsafe reductions. protect bodily autonomy and intimate care choice.
11 Thriving Kids capped- Children aged 8 and under may be shifted from Publish the Thriving Kids demand,
funding risk individualised NDIS plans into a capped funding, workforce and state-capacityfoundational supports model without a published model before any child loses NDIS per-child funding model. funded support.
12 Early-intervention Reducing individualised early-childhood funding Model early-intervention provider
market contraction risk may reduce demand for speech pathology, OT, impacts, allied-health graduatepsychology, developmental educators, behaviour pathways and workforce capacity support and therapy assistants. before transition.
13 Schools, childcare and If Thriving Kids is underfunded, unmet child Do not move children out of NDIS
community health cost- support needs may shift to schools, childcare, supports unless replacement services
shift risk GPs, community health and families. are funded, enforceable, accessible andoperational.
14 Digital payments and Digital payments may delay, block or suspend Publish a Digital Payments Safeguard
automated payment- legitimate supports, creating cashflow, service- and Impact Statement before
control risk continuity and participant-safety risks. mandatory use.
15 Robo-assessment and Computer-generated budgets and reduced Preserve full merits review and require
loss of effective appeal tribunal powers may remove meaningful review all formulas, tools and rules to be
rights and scale assessment error across cohorts. transparent, independently validatedand disallowable.
16 Treatment-first and Supports may be refused because treatment or Require an actual-service test:
theoretical mainstream another service system theoretically exists, even available, timely, funded, accessible,
service substitution risk where it is unavailable, unaffordable, appropriate, enforceable and sufficient.inappropriate or incapable of meeting need.
17 Market consolidation Registration, panels, commissioned supports and Ensure fraud-control and
and loss of participant payment controls may consolidate the market commissioning reforms preserve
choice risk and reduce choice, especially in thin markets. legitimate small providers, planmanagers, support coordinators and participant choice.
Legal tripwires: how these risks are triggered
The risks above are not abstract. The combined effect may significantly affect the Australian Economy and Market. They are triggered by specific legal and administrative mechanisms in the Bill and reform package, including:
● group-based support determinations ● limits on unscheduled reassessment
● SCCP and CBDA budget resets ● suspension and revocation powers
● capped foundational supports ● 90-day claim timeframes
● new framework planning rules ● expanded information-gathering and record obligations
● functional capacity assessment design; ● civil penalties
● consideration of family and informal supports before funding ● provider registration changes
approval ● plan management panels
● tighter reasonable and necessary criteria ● commissioned support coordination
● treatment-first access settings ● ministerial pricing control
● reliance on other service systems ● automated administrative decisio
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
5.1 - RISK 1: Whole-economy modelling risk
The Impact Analysis contains useful information about Scheme costs, participant impacts, provider impacts and implementation issues. However, it does not provide a complete whole-economy model of what occurs when $37.8 billion is removed from the disability support ecosystem over four years.
The Government has quantified the saving. What it has not transparently quantified is the economic activity, employment, tax revenue, workforce participation, provider viability and avoided downstream costs that may be lost when that funding is withdrawn.
The NDIS is not simply a Commonwealth expense line. It is a national economic ecosystem. Funding flows into wages, sole traders, microbusinesses, allied health practices, support coordination, transport, assistive technology, administration, software, insurance, rent, training and local spending. It also enables participants and unpaid carers to participate in work, education and community life.
A model that counts only the Budget saving, but not the economic activity displaced by that saving, is only half a ledger.
The Joint Standing Committee record is critical. DSS confirmed that the Government was not undertaking work to model the economic benefits of the NDIS and instead referred to sector-commissioned Per Capita work. That is not adequate for reforms of this scale.
Per Capita estimated that every $1 billion of NDIS underfunding may result in:
- around 10,200 jobs at risk;
- around $2.25 billion in reduced economic activity;
- around 0.14 per cent lower GDP. These figures are not a Treasury forecast. That is precisely the point. If the Government disputes this modelling, it should publish its own.
Before legislating cuts of this scale, the Government should be required to model the impact on GDP, employment, underemployment, provider exits, regional markets, tax revenue, participant workforce participation, unpaid carer participation, household debt and downstream costs to hospitals, Medicare, Centrelink, housing, child protection, policing, justice, corrections and state disability systems.
The Senate should treat the absence of this modelling as an evidentiary failure.
The central question is not whether the Commonwealth can reduce NDIS expenditure on paper. It can. The real question is whether those savings are genuine savings, or whether they are costs transferred to families, women, states, hospitals, income support, justice systems and the broader economy.
No responsible government should withdraw $37.8 billion from a national disability insurance ecosystem without first modelling the full economic consequences. Otherwise, the reform is not fiscally responsible. It is fiscally incomplete.
Primary Safeguard: Require Treasury-level macroeconomic modelling before passage.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Illustrative GDP exposure scenario to 2034-2035: this chart is not a Treasury forecast. It is a sensitivity scenario showing why the Government should publish whole-economy modelling before passage.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
5.2 - RISK 2: False-economy and cost-shifting risk
The proposed reforms risk creating a classic false economy: a saving recorded in one government ledger while equal or greater costs are displaced into other parts of the public system, households and the broader economy.
The central economic question is not whether the NDIA can reduce outlays. It can. The real question is whether the reform reduces total public cost, or simply moves expenditure from planned, preventative disability supports into more expensive crisis systems.
The Government has identified $37.8 billion in NDIS savings. However, those savings are not automatically net savings to the Australian economy.
If reduced NDIS supports lead to higher hospital use, increased Medicare demand, greater reliance on pharmaceuticals, higher Centrelink payments, homelessness, justice contact, family violence service involvement, state disability pressure or unpaid carer withdrawal from paid work, then the Commonwealth has not reduced cost. It has transferred it.
Source for $37.8b: 2026-27 Health Portfolio budget statements. Weighted bottom bar is an advocacy visualisation based on likely cost shifting pressure, not a government forecast.
This distinction matters because NDIS supports are often preventative economic infrastructure. Personal care, transport, therapy implementation, behaviour support, psychosocial recovery, early childhood intervention, social participation, home supports and capacity-building assistance all help maintain function and avoid higher-cost interventions later.
-
A support worker that prevents a hospital admission.
-
Transport that preserves employment.
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Therapy implementation that prevents functional decline.
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Behaviour support that prevents police involvement or restrictive practice.
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Community participation that prevents isolation, deterioration and Carer collapse.
-
Support coordination that prevents housing breakdown or service failure. These are not soft social benefits. They are avoided public sector costs. And the proposed reforms target precisely the supports most likely to perform this preventative role. The Government has stated that social, civic and community participation budgets will be reduced by 50 per cent, while capacity building daily activity budgets will be reduced by 10 per cent. These supports help people maintain routines, community access, emotional regulation, skill development, employment readiness, therapy carryover and family stability.
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Submission 592
Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Cutting them may reduce NDIS payments in the short term, but it increases the probability of higher downstream costs.
Economically, this creates three forms of cost leakage.
-
Costs shift into higher-cost public systems. Hospitals, emergency departments, mental health services, housing services, courts, corrections and child protection generally respond after deterioration has occurred. They are more expensive, less personalised and less likely to restore independence than early disability support.
-
Costs shift into unpaid labour. Families, especially women, absorb the gap through unpaid personal care, supervision, transport, emotional regulation, administration and crisis response. This reduces workforce participation, household income, superannuation, tax receipts and long-term economic security.
-
Costs shift out of a labour-intensive private service economy. NDIS funding currently circulates through a decentralised private and community-service market, creating wages, small-business income, local purchasing, provider growth, tax receipts and workforce participation. If that funding is withdrawn from participant-directed supports and later reappears in hospitals, Centrelink, crisis housing, policing, justice or state systems, the economy loses liquidity, flexibility and productive local circulation.
Money that was previously flowing through workers, sole traders, microbusinesses, allied health providers, transport services and households is redirected into slower, more centralised, crisis-driven public systems. That shift reduces private-sector turnover, weakens local service markets, increases underemployment, lowers household spending and suppresses business growth.
The false economy is that the Government may record a saving inside the NDIA ledger while weakening the economic activity the NDIS has spent a decade building: a labour-intensive, demand-led disability marketplace that supports jobs, sole traders, allied health practices, small businesses, household income, tax receipts and local economic circulation.
In macroeconomic terms, this is not a clean reduction in cost. It is a transfer from enabling expenditure to reactive expenditure.
Money currently flowing through participant-directed supports, wages and private-sector providers is likely to reappear in public systems such as hospitals, Medicare, Centrelink, housing, justice, child protection and state disability services. Those systems are not designed, staffed or funded to absorb this level of displaced disability need. They are already stretched, largely crisis-responsive, and less able to generate independence, workforce participation or productivity. The result is weaker private-sector liquidity, slower provider growth, reduced employment, greater pressure on public services and lower economic efficiency overall.
This is cost shifting disguised as fiscal discipline.
Primary Safeguard: Model cross-system cost transfer and require intergovernmental funding guarantees.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
5.3 - RISK 3: Provider-market failure risk
The NDIS has not only funded disability supports. It has created a decentralised national service market.
Since the Scheme commenced, disability support has moved from a largely state-funded, block-funded model into a participant-directed market made up of registered providers, unregistered providers, sole traders, microbusinesses, allied health practices, support workers, plan managers, support coordinators, transport providers and community services. This market now forms part of the broader Australian care economy, and it feeds into the wider economy through wages, tax receipts, software, payroll, accounting, legal services, insurance, banking, vehicles, fuel, property, telecommunications, utilities, training and local retail spending.
The Government’s own Impact Analysis shows the scale and fragility of this market. It identifies around 276,000 active NDIS providers in the December 2025 quarter. Of these, 111,000 delivered SCCP supports, 100,800 SCCP providers were unregistered, and around 56,000 SCCP providers delivered supports to only one participant. It also identifies around 82,000 CBDA providers, with only about 9,000 registered NDIS providers in that category.
This is not a mature institutional market with deep reserves. It is a decentralised small-business network. The wider Australian business data supports this concern: the ABS reported that Health Care and Social Assistance grew by 6.6% to 213,177 businesses in 2024–25, making it one of the fastest-growing business sectors in the country. The Australian Small Business and Family Enterprise Ombudsman also reports that 64% of Australian businesses are self-employed/non employing, with another 25% employing 1–4 people. In other words, the NDIS provider market sits inside a national small-business economy, not outside it.
The policy error is treating NDIS savings as though they only reduce public expenditure. In practice, the proposed 50% reduction to SCCP budgets and 10% reduction to CBDA budgets reduce the purchasing power of participants in the very categories that sustain small providers, sole traders and allied health practices. When participant budgets fall, provider revenue falls immediately. Workers lose hours. Contractors lose income. Sole traders lose viability. Microbusinesses contract or close. In thin markets, this does not produce efficiency; it produces service disappearance.
The risk is especially acute for allied health. Government policy settings, workforce strategies, universities, training programs and NDIS demand have collectively encouraged expansion of the care and allied-health workforce over the past decade. The Centre for Inclusive Employment NDIS National Workforce Plan estimated that the Scheme needed around 83,000 net additional workers by 2024, a 31% increase in the workforce. AIHW data shows allied health professions had the highest workforce growth among registered health professions between 2013 and 2022, increasing by 67%. The Department of Health, Disability and Ageing reports the current National Allied Health Workforce Strategy explicitly exists because Australia still has allied-health shortages and maldistribution.
That creates a serious planning contradiction. Government policy has encouraged students, universities and providers to expand allied-health supply, while the proposed NDIS reforms now reduce one of the major demand streams that allows those graduates to obtain work, supervision, caseloads and viable private practice income. Cutting CBDA may therefore undermine the economic scale of the allied-health sector just as new graduates enter the labour market. The result may not be an efficient reallocation of labour; it may be graduate underemployment, lower private-practice viability, weaker supervision pathways and more pressure on hospitals and public community-health systems that are not funded to absorb this workforce or the displaced participant need.
The macroeconomic consequences are material. Job and Skills Australia report that Health Care and Social Assistance is Australia’s largest employing industry, with around 2.409 million workers, 16.3% of the workforce, and a 76% female workforce share. If NDIS demand is deliberately compressed, the first effect may appear as underemployment rather than unemployment, because many disabled and allied-health workers are casual, part-time, self-employed or working across multiple clients. Hours fall before jobs disappear. Income falls before businesses formally close.
That matters for public revenue. Sole traders pay tax through the individual income tax system, companies pay company tax, and businesses over the GST threshold participate in the GST system. Reducing NDIS-funded provider income
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
therefore reduces income tax, company tax, GST-linked consumption, superannuation contributions and local spending. If workers or sole traders then move onto income support, the fiscal position worsens again. Services Australia’s JobSeeker rate from March 2026 is up to $808.70 per fortnight for a single person with no children and $866.00 for several higher-need categories, meaning displaced employment can quickly become a direct Commonwealth cost.
Per Capita’s modelling reinforces the scale of the risk. It estimated that every $1 billion of NDIS underfunding may reduce employment by around 10,200 jobs, reduce economic activity by $2.25 billion, and reduce GDP by 0.14%. The Parliamentary record has also noted this evidence, including the finding that the NDIS employs more than 270,000 people across more than 20 occupations and contributes to wider indirect employment.
The central economic error is that the Government appears to be modelling savings inside the NDIA ledger without fully modelling the market it is contracting. Provider failure is not simply a disability-sector inconvenience. It is a labour market, small-business, tax-revenue and service-capacity risk. Once sole traders and microbusinesses leave, capacity is not easily rebuilt. Participants lose trusted supports. Graduates lose viable pathways. Thin markets become thinner. Families absorb unmet needs. Public systems inherit crisis demand.
The Senate should therefore treat provider-market failure as an economic risk, not merely an implementation issue. A proper assessment should quantify provider exits by support category, allied-health graduate underemployment, sole trader income loss, regional thin-market effects, tax-revenue loss, Centrelink exposure, and the cost of rebuilding market capacity after it has been allowed to collapse.
In summary, the Government is attempting to cut NDIS expenditure after spending a decade building the workforce, businesses and allied-health supply needed to deliver it. That is not disciplined market stewardship. It is demand destruction inside a sector government policy deliberately created.
Primary Safeguard: Model provider exits, service gaps and regional viability as a result of the proposed 2026 NDIS Reform Cuts.
Provider series uses NDIA/NDIS public reporting on provider-market size. Earlier years reflect available registered-provider / market measures during trial and transition. Later years reflect active provider counts in NDIA quarterly dashboards. Participant series shows active NDIS participants at 30 June each year based on NDIA/NDIS public reporting.
From 2026 onward, the graph projects contraction in the NDIS provider market as participant-directed demand is reduced. Many providers are sole traders or microbusinesses whose income depends directly on participant budgets. If SCCP and CBDA funding is cut at scale, revenue falls, workers lose hours, and thin markets become less viable. The result is fewer services, lower employment, reduced tax receipts and more unmet need shifting back to families, hospitals, Centrelink and state systems.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Conservative Scenario: the provider market contracts gradually, creating rising underemployment before large-scale job losses appear in official unemployment data.
Moderate Scenario: the contraction becomes a clear labour-market shock: sole traders close, casual workers lose shifts, allied health graduates struggle to build viable caseloads, and regional markets lose service capacity.
Severe Thin-Market Scenario: the reforms risk mass displacement across the disability workforce, with provider exits translating into widespread underemployment, business closures and unemployment. In this scenario the economic damage would not stop at the NDIS and would seep into the larger Australian economy across all sectors. Lower provider income means lower wages, weaker household spending, reduced tax receipts, and more unmet disability need shifting back to families, hospitals, Centrelink and state systems.
Source note: Actual provider-market figures are assembled from NDIA/NDIS public reporting used in this submission work, including rollout-era provider market counts and later active-provider counts, with the 2025-26 anchor based on the Government’s Impact Analysis identifying around 276,000 active providers in the December 2025 quarter. NDIA does not publish a full annual small-provider / sole-trader series, so the broader provider-market count is used as a proxy for the market dominated by small providers, sole trader and microbusinesses. The three post-2026 lines are illustrative reform scenarios, not official forecasts. They model contraction driven by reduced participant demand, 50% SCCP cuts, 10% CBDA cuts, thin-market, underutilisation, labour underemployment and provider failure.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
5.4 - RISK 4: Unemployment and labour-oversupply risk
The proposed reforms create a measurable labour-market risk because they reduce demand in a sector the Commonwealth has spent the past decade deliberately expanding.
The NDIS is not only a transfer-payment scheme. It is a labour-intensive service market. The Government’s own Impact Analysis identifies approximately 276,000 active NDIS providers in the December 2025 quarter, including around 111,000 SCCP providers, 100,800 unregistered SCCP providers, 56,000 SCCP providers delivering to only one participant, and around 82,000 CBDA providers. This indicates a provider base heavily exposed to small-business, sole-trader and micro provider risk.
The direct published percentage cuts are SCCP at 50% and CBDA at 10%. But the broader reforms contain multiple additional cost-control mechanisms: tighter eligibility, tighter reasonable-and-necessary rules, new framework planning, limits on reassessments, provider registration changes, plan management commissioning and support coordination commissioning.
The proposed reductions therefore operate as a demand shock. They do not merely reduce access and budgets; they reduce the funded hours available to purchase labour. In economic terms, the reform shifts the disability labour market from demand expansion to demand contraction.
The first labour-market effect is likely to be underemployment rather than immediate unemployment. Disability support workers, allied health assistants, sole traders, subcontractors and new allied health graduates may remain technically employed while losing hours, clients, billable sessions and income. This matters because official unemployment data can lag the actual economic damage. A worker who loses 40% of their weekly shifts is not unemployed, but their household spending, mortgage capacity, tax contribution and economic participation are materially reduced.
This risk arises at a poor point in the cycle. The ABS reported that in April 2026 the unemployment rate rose to 4.5%, with unemployed people increasing by 33,000 to 692,500. Youth unemployment rose to 11.1%. Displacing disability workers, support workers, allied health graduates and sole traders into a softening labour market risks adding labour supply exactly when the economy has less capacity to absorb it.
The fiscal consequences are direct. NDIS provider income currently generates taxable income, PAYG withholding, GST linked consumption, company tax, sole-trader tax, superannuation contributions and business turnover. ATO guidance confirms that sole traders must lodge tax returns even where income is below the tax-free threshold, and businesses may also carry GST and PAYG obligations depending on structure and turnover.
If NDIS-funded work disappears, the Commonwealth does not only save money inside the NDIA ledger. It also loses revenue from wages, business income and consumption. If displaced workers move onto income support, the Commonwealth incurs additional expenditure. Services Australia lists JobSeeker Payment from 20 March 2026 at up to $808.70 per fortnight for a single person with no children and $866.00 for several higher-need categories.
The wider economy is also exposed. Disability-sector income flows into rent, mortgages, school fees, groceries, fuel, utilities, insurance, car loans, cafés, restaurants, retail, professional services and local business spending. If providers close and workers lose jobs, the effect is not contained only within the NDIS. It reduces household consumption and weakens adjacent industries across the national landscape.
The same logic applies to participants. Reduced funded support means fewer participants supported to work, study, attend appointments, access the community and spend in the marketplace. This reduces disability-led economic participation. Families may also reduce paid work to replace lost funded supports, further reducing labour supply, household income and tax receipts.
There is also a second-order training-market effect. The NDIS has created demand for trained disability workers and allied health staff. That demand supports RTOs, VET providers, compliance trainers, first aid training, manual handling, medication assistance, behaviour support training and disability-specific induction. If providers stop hiring, training
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
demand falls. RTO revenue falls. Trainers lose work. Course offerings contract. The workforce pipeline weakens. This is economically significant because rebuilding a skilled care workforce later is slower and more expensive than maintaining one.
The GDP risk is material. Per Capita’s False Economy modelling estimated that every $1 billion of NDIS underfunding may reduce employment by around 10,200 jobs, reduce economic activity by $2.25 billion, and reduce GDP by 0.14%. Applied cautiously to the Government’s $37.8 billion savings target, this indicates illustrative exposure of approximately $85 billion in economic activity and up to 385,000 job-equivalent positions over the reform period. This is not a Treasury forecast. That is precisely the issue: the Government has published savings estimates without publishing a comparable employment, tax-revenue and GDP impact model. The Senate should therefore require modelling across three labour market pathways:
Scenario Labour-market effect Fiscal and GDP effect
Conservative Rising underemployment; some workers Lower tax receipts, weaker consumption, modestabsorbed by adjacent sectors GDP drag
Moderate Provider exits, sole-trader failures, graduate Higher Centrelink claims, lower householdunderemployment, regional labour oversupply spending, reduced business turnover
Severe Large-scale displacement across disability Material GDP leakage, lower revenue, highersupport and allied health markets, thin-market income-support and crisis-system costs failure
The national labour market is already softening. The ABS reported that the unemployment rate rose to 4.5% in April 2026, with unemployed people increasing by 33,000 to 692,500. Youth unemployment rose to 11.1%. A reform that displaces disability workers and small providers into this labour market risks worsening unemployment and underemployment at precisely the wrong time.
The fiscal consequences are also direct. Sole traders pay tax through the individual income tax system, companies pay company tax, and businesses collect and remit GST where applicable. The ATO makes clear that sole traders must lodge tax returns, and business structures carry income tax and reporting obligations. When NDIS-funded work disappears, the Commonwealth loses income tax, company tax, GST-linked consumption, PAYG withholding, superannuation contributions and business turnover. If displaced workers move onto income support, the Commonwealth also incurs new expenditure. Services Australia lists the maximum JobSeeker Payment from 20 March 2026 as $808.70 per fortnight for a single person with no children, and $866.00 for several higher-need categories.
The GDP risk is not speculative. Per Capita’s False Economy modelling estimated that every $1 billion of NDIS underfunding may reduce employment by around 10,200 jobs, reduce economic activity by $2.25 billion, and reduce GDP by 0.14%. The Parliamentary record also refers to this modelling and the economic consequences of NDIS underfunding. Applied cautiously to the Government’s $37.8 billion savings target, this indicates an illustrative exposure of around $85 billion in economic activity and up to 385,000 job-equivalent positions over the reform period. This is not an official Treasury forecast. That is precisely the problem: the Government has modelled savings but has not transparently modelled employment loss, business exit, tax loss or GDP drag. The Senate should not accept savings modelling without labour-market modelling. A reform of this scale should quantify expected unemployment, underemployment, provider exits, RTO losses, graduate employment impacts, Centrelink exposure, tax-revenue loss, household consumption effects and GDP drag over the ten years following implementation.
In summary, the reforms do not only reduce NDIS expenditure. They risk withdrawing demand from a labour-intensive sector the Commonwealth spent a decade building. That is not productivity reform. It is a publicly induced contraction in employment, business activity and economic participation.
Primary Safeguard: Model local labour markets, not only national care-sector demand.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Comparative Employment Growth Before and After the NDIS Rollout
ABS employment growth, 2005–2014 vs 2015–2025, adjusted for population growth
Disability sector employment growth to 2025 and projected decline after NDIS 2026 reforms to 2035
Source note: Actual values use published anchor estimates from the NDIS Review, NDIS National Workforce Plan, McKell Institute, Jobs and Skills Australia, and ABS labour-market context used in the submission analysis. Because there is no single official annual ABS time series for the NDIS workforce from 2015-2026, intermediate years are interpolated. The 2026-2035 reductions, provider exits, allied health caseload loss and thin-market failure. A moderate reform scenario was used to model the decline of employment in the disability sector, showing employment falling from about 376,000 workers in 2026 to about 263,000 by 2035, with the important caveat that underemployment would likely appear before headline unemployment.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
5.5 - RISK 5: Tax receipt, GDP and household consumption risk
The proposed reforms create a fiscal risk that has not been adequately modelled in the public material. The Government proposes to remove $37.8 billion from NDIS expenditure, but NDIS funding is not a static transfer. It is income to workers, sole traders, allied health professionals, small providers, companies and local suppliers. Removing that funding from a labour-intensive service market is likely to reduce taxable income, business turnover, household consumption and GDP activity.
The scale matters. ABS data shows total Australian taxation revenue reached $839.0 billion in 2024–25, equal to 30.2% of GDP. ATO Taxation Statistics show the Commonwealth tax base is heavily dependent on individual income tax, company tax and GST: in 2022–23, 51.6% of Commonwealth tax came from individual income tax, 24.2% from companies and 14.2% from GST. These are precisely the revenue streams affected when wages, billable hours, company revenue and household consumption fall.
The disability workforce is large enough for this to matter. Jobs and Skills Australia reports 376,300 employed Aged and Disabled Carers in 2026, with median weekly earnings of $1,761. That implies an estimated annual gross earnings pool of approximately $34.5 billion for Aged and Disabled Carers alone, and likely household-spending exposure of approximately $25.8 billion to $29.3 billion if 75–85% of earnings are spent through the ordinary economy. This excludes allied health professionals, plan managers, support coordinators, administrators, trainers, transport providers, business owners and software, insurance, accounting, property and compliance suppliers servicing the NDIS market.
The proposed $37.8 billion saving therefore sits beside a very large labour-income and consumption base. If participant directed funding is reduced, the immediate effect is not only lower NDIA outlays. It is lower provider revenue, fewer worker hours, fewer billable sessions, weaker sole-trader income, lower private-practice turnover and reduced household expenditure. That affects income tax, company tax, GST-linked consumption, PAYG withholding, superannuation contributions and business viability.
There is also a family-side consumption effect. If funded supports are reduced, participants may have less support to work, study, attend appointments, access the community and spend in the marketplace. Parents, partners and family carers may reduce paid work to replace withdrawn supports. That reduces household income twice: first through lost provider income, and second through reduced carer and participant workforce participation.
Per Capita’s False Economy modelling estimated that every $1 billion of NDIS underfunding may reduce employment by around 10,200 jobs, reduce total economic activity by $2.25 billion, and reduce GDP by 0.14%. Applied cautiously to the Government’s $37.8 billion savings target, this indicates illustrative exposure of approximately $85.05 billion in economic activity and up to 385,560 job-equivalent positions over the reform period. This is not a Treasury forecast. That is the issue: the Government has published a savings figure without publishing the corresponding model for tax revenue loss, GDP drag, household-consumption loss, provider exits or income-support offsets.
The Senate should require the Government to publish tax-revenue, GDP and household-consumption modelling before passing the Bill. That modelling should quantify the expected effect of the reforms on income tax, company tax, GST linked spending, superannuation, household expenditure, provider turnover, participant workforce participation, carer employment and Centrelink expenditure.
In summary, a dollar removed from the NDIS is not a dollar saved if it also removes taxable income, reduces household consumption, lowers GDP activity and increases reliance on income support and crisis systems.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
5.6 - RISK 6: Participant functional decline risk
The NDIS exists because disability support is not discretionary. It is not ordinary welfare spending. It is functional infrastructure. For many participants, funded supports maintain personal care, mobility, communication, emotional regulation, behaviour stability, daily routines, community access, employment readiness, health management and safety.
From an economic perspective functional capacity is a form of human capital. When supports maintain function, they preserve independence, reduce reliance on crisis systems, support carer workforce participation and avoid more expensive intervention later. When supports are removed, functional decline is often delayed and hidden. A participant may appear to cope after a funding reduction because family members, friends, unpaid carers or informal supports absorb the shortfall. A parent may reduce work. A spouse may take on supervision. A sibling may provide transport. A participant may stop leaving the house, cancel activities, miss therapy implementation, or withdraw from work, study and community life. On paper, expenditure falls. In reality, risk is accumulating.
The damage may appear months later as carer burnout, mental health deterioration, loss of routine, skill regression, social isolation, unemployment, hospitalisation, homelessness, behavioural escalation, emergency service contact or increased reliance on medication and crisis supports. By the time those costs are visible in government data, the harm has already occurred.
This risk is especially acute because the reform package targets supports that directly maintain function. Social, civic and community participation funding supports routine, connection, community access, regulation, confidence, communication and informal support networks. Capacity Building Daily Activities funding supports therapy implementation, skill development, independence, behaviour strategies, daily living skills and functional carryover. Personal care and home supports maintain safety, dignity and basic daily functioning. Transport supports access to work, appointments, education and community participation. These are not optional extras. They are the scaffolding that allows people to function outside hospitals, crisis systems and institutional settings.
The risk is particularly high for participants with:
- Psychosocial disability
- Autism
- Intellectual disability
- Acquired brain injury
- Complex communication needs
- Behavioural support needs
- Physical disability requiring personal care
- Progressive or fluctuating conditions
- Limited informal supports
- Ageing carers
- Unstable housing
- Regional or thin-market service access
- Children and young people requiring early intervention. For these cohorts, a reduction in support may not reduce need. It may simply reduce the funded mechanism that was keeping the person stable, healthy and safe.
The Government’s own analysis shows the scale of exposure. The proposed social, civic and community participation reset affects 393,401 participants with SCCP funding. The Capacity Building Daily Activities reset affects 752,454 participants, or 99 per cent of participants with CBDA funding. These figures show that the reforms are not confined to a small number of outlier plans. They affect the functional support architecture of the Scheme.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
The economic consequence is that functional decline creates compounding cost. A participant who loses support early may later need more intensive and expensive intervention: hospital care, inpatient mental health, crisis accommodation, behaviour support escalation, additional medications, police response, child protection involvement, family violence services, higher future NDIS supports or state disability intervention. The longer the decline continues, the more expensive it becomes to reverse.
This is why “evaluation later” is not an adequate safeguard. Evaluation after implementation may tell government that harm occurred, but it does not prevent the harm. It does not restore lost employment, rebuild provider relationships, reverse carer burnout, recover lost developmental time for children, or undo the trauma of crisis, hospitalisation or family breakdown. A serious reform process would assess functional risk before supports are reduced, not after. For high-risk cohorts, supports should not be reduced, unless an individual functional impact assessment shows that the reduction will not cause harm. That assessment should ask:
- Does the support maintain daily function, personal care, safety or health?
- Does the support prevent deterioration, crisis or hospitalisation?
- Does the support enable work, study, communication, community access or routine?
- Does the participant have informal supports that are available, capable and sustainable?
- Would the reduction increase carer burden or reduce carer workforce participation?
- Would the reduction increase risk to housing, mental health, behaviour or family stability?
- Would the reduction create higher downstream public cost? The burden should not fall on participants to prove harm after supports have already been removed. If the Government proposes to reduce a support that maintains function, the Government should first demonstrate that the reduction is safe, reasonable and economically sound.
In summary, the NDIS does not merely fund services. It preserves function. When functional supports are withdrawn, the cost does not disappear. It reappears as decline, unpaid care, lost participation, crisis response and higher future public expenditure.
Primary Safeguard: Protect existing supports unless functional evidence shows reduction will not cause harm.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
5.7 - RISK 7: SCCP reduction risk
The proposed reset of Social, Civic and Community Participation funding is one of the most consequential elements of the reform package because it targets a support category that is often misunderstood. The Government’s own Impact Analysis states that the reset affects 393,401 participants with SCCP funding. This is not a marginal adjustment. It is a structural intervention into the way hundreds of thousands of participants maintain community access, daily routine, social connection, family resilience and functional participation.
The policy error is treating social participation as though it is discretionary. For many people with disability, social and community participation is not leisure. It is functional infrastructure. It is the mechanism through which people practise communication, maintain routine, manage sensory and emotional regulation, generalise therapy strategies, build employment readiness, sustain informal networks, reduce isolation and remain visible to their community.
From an economic perspective, this matters because participation is not only a social outcome. It is a protective factor. A participant who is supported to leave the house, maintain routine, access safe activities, practise communication, build confidence and remain socially connected is less likely to deteriorate into crisis. SCCP funding can prevent higher-cost interventions later by reducing mental health decline, carer burnout, behavioural escalation, social withdrawal, family breakdown and loss of work or study readiness.
Cutting SCCP therefore does not simply reduce “outings.” It removes part of the infrastructure that keeps people functioning outside hospitals, crisis systems and institutional settings.
The risk is especially acute for participants whose disability affects communication, cognition, psychosocial functioning, behaviour, sensory regulation, mobility, social confidence or independent travel. For these participants, community participation is often where functional skills are tested and maintained. A therapy session may teach a strategy, but the community is where that strategy is practised. A behaviour support plan may identify triggers, but supported participation is where those triggers are managed in real life. A participant may want to work, but employment readiness often begins with basic routine, transport, social stamina, communication and confidence outside the home.
The proposed cut also creates a hidden transfer of labour. When funded community participation is reduced, the need does not disappear. Someone still has to provide transport, prompting, supervision, planning, personal care support, emotional regulation and crisis prevention. In many households, this work will shift to unpaid carers, particularly women. That increases carer burden, reduces workforce participation and converts formal economic activity into unpaid labour.
There is also a provider-market risk. SCCP supports a large number of support workers, sole traders, microproviders and community-based services. If participant budgets are reduced at scale, provider income falls immediately. In thin markets, this does not necessarily create efficiency. It may cause providers to exit, leaving participants with fewer options and increasing underutilisation, unmet need and future crisis costs.
A blunt percentage reduction is therefore economically and functionally unsafe. It assumes that all SCCP funding is equivalent, when in practice it performs very different roles depending on the participant. For one person it may support recreational activity. For another, it may be part of a 24-hour safety framework, behaviour prevention plan, psychosocial recovery strategy, communication plan, family respite arrangement or pathway toward employment.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Source note: Based on Office of Impact Analysis, Figure 9, using 2025 SCCP allocation data by primary disability. Estimated actual spend applies an approximate 80% payment to-commitment ratio based on NDIA June 2025 Core – Social and Civic payment data. The 50% cap is an illustrative application of the proposed SCCP reduction and should not be read as an official participant-level forecast.
The Senate should not accept the assumption that SCCP can be cut safely because it is labelled “social.” Social participation is often the mechanism through which people remain connected, regulated, skilled, visible and safe. Removing it may reduce NDIA expenditure in the short term, but increase costs elsewhere through functional decline, hospital presentations, carer burnout, unemployment, homelessness, justice contact and demand on state systems.
Recommendation: SCCP reductions should not proceed through a blunt category-wide reset. Any reduction should require an individual functional impact assessment that considers whether the support maintains safety, communication, routine, regulation, employment readiness, family sustainability, community access or prevention of crisis. Participants with complex support needs, psychosocial disability, behavioural risk, communication needs, limited informal support, regional access barriers or 24-hour support requirements should be exempt unless it is clearly demonstrated that the reduction will not cause harm.
In summary, SCCP is not optional for many participants. It is the infrastructure through which people remain visible, connected, functional and safe. Cutting it at scale risks turning community participation into isolation, family resilience into unpaid care, and preventative support into downstream public cost.
Primary Safeguard: Suspend the SCCP reset and require cohort-specific harm analysis.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
5.8 - RISK 8: CBDA implementation-loss risk
Capacity Building Daily Activities funding is where assessment becomes daily-life function. It is the part of the NDIS that helps participants translate allied health advice, reports and recommendations into practical skill development, daily routines, independence, communication, emotional regulation, behaviour strategies and real-world execution.
The Government’s Impact Analysis proposes that Capacity Building Daily Activities budgets be reduced by 10 per cent. This may appear small when compared with the proposed 50 per cent reduction to social, civic and community participation funding, but it is not small in functional terms.
CBDA is already a limited support category. The Government’s own Impact Analysis states that 752,454 participants, or 99 per cent of participants, currently have CBDA funding. It also states that the average annualised CBDA budget is $13,460 per participant, which according to the NDIA equates to around 69 hours of therapy supports per year, or approximately 1.3 hours per week, at the NDIS hourly rate of $193.99.
CBDA funding is diluted by provider travel because therapy-related travel time, and in many cases associated non-labour travel costs, are claimed from the participant’s plan funding linked to that support. This means the headline CBDA budget overstates the actual therapy and implementation hours available, particularly for rural, regional, remote and thin-market participants.
A 10 per cent CBDA reduction therefore cuts into an already constrained pool that may also be paying for travel, assessment, reporting and implementation — leaving participants with fewer real hours of therapy, coaching and skill-building.
This funding cut to the CBDA budget is therefore not an abstract accounting adjustment. It is a reduction of approximately $1,346 per participant per year, or around 6.9 therapy hours annually. For a participant already receiving only 69 therapy hours per year, that is a material loss. It may represent several occupational therapy, psychology, speech pathology, physiotherapy, behaviour support or implementation sessions.
The Government’s analysis argues that the reduction is unlikely to materially affect most participants because overall CBDA utilisation was 61 per cent as at 31 December 2025. However, this assumption is economically and functionally weak. Low utilisation does not necessarily mean low need. It can reflect workforce shortages, provider unavailability, long waitlists, regional and remote service gaps, administrative friction, plan-management delays, participant executive functioning barriers, difficulty finding suitable providers, or the cost of reports and assessments consuming available funding before implementation can occur.
In other words, underutilisation may be evidence of market failure, not spare capacity.
The central problem is that CBDA is the implementation bridge. A participant may have a therapy report identifying strategies, but still require support to practise and embed those strategies across home, school, work and community settings. Without funded implementation, reports remain paper. Recommendations do not become routines. Skills do not generalise. Families are left to interpret clinical advice without the support needed to apply it safely and consistently.
This matters most for participants whose disability affects learning, communication, self-regulation, planning, initiation, social understanding, mobility, behaviour, executive functioning or daily living skills. For these participants, capacity building is not a one-off clinical event. It is repeated, scaffolded practice.
The Government’s own age data shows why children are particularly exposed. As of 31 December 2025, 166,507 children aged 0 to 8 had CBDA funding, representing 100 per cent of participants in that age group. Their average CBDA funding was $9,900, and CBDA made up 69 per cent of their total committed supports. For children aged 9 to 14, 152,322 participants
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had CBDA funding, again 100 per cent of that age group, with average CBDA funding of $6,800, making up 42 per cent of total committed supports.
This means the proposed CBDA reduction lands heavily on children because CBDA is not a marginal part of their plan. It is often the dominant mechanism through which early intervention, parent coaching, communication support, sensory regulation, daily living skill development and behaviour strategy implementation occur.
The economic risk is that cutting early capacity building increases long-term cost. If children lose therapy implementation during key developmental windows, the result may be slower skill acquisition, greater family stress, increased school difficulty, more behavioural escalation, higher reliance on informal care, and higher future support needs. What appears as a modest saving in the current Budget may become higher lifetime support costs.
There is also a regional and remote equity risk. The Impact Analysis notes that the CBDA reduction may more significantly affect participants in remote MM6 and very remote MM7 areas because they have higher average CBDA budgets and higher proportions of their total supports assigned to this category. The data shows average CBDA budgets of $8,600 in remote MM6 areas and $9,000 in very remote MM7 areas, with CBDA representing 15 per cent and 19 per cent of total committed supports respectively.
A 10 per cent reduction therefore has a larger dollar impact in remote communities, where the cost of service delivery is already higher and provider availability is thinner. Participants in those locations may not have alternative services to absorb the gap. Families may be forced to travel, pay privately, delay therapy, or go without.
The reduction also interacts with other parts of the reform package. The Impact Analysis itself notes that interactions between reforms will need to be monitored for unintended consequences, including increased unscheduled reassessment requests for daily activity funding or Capacity Building SCCP funding. If SCCP is cut by 50 per cent and CBDA is cut by 10 per cent at the same time, participants may lose both the setting where skills are practised and the support that helps them build those skills. That is not a minor efficiency measure. It is a compression of the functional support architecture of the Scheme.
For adults, CBDA reductions can reduce independence and increase reliance on Core supports, family members or crisis services. Participants may receive less support to manage personal routines, appointments, budgeting, communication, home tasks, employment readiness, emotional regulation, psychosocial recovery or behaviour planning. In practice, this can mean more dependence, not less.
For families, the burden shifts into unpaid implementation work. Parents, partners and carers are expected to become the therapy assistant, behaviour support worker, executive function coach, communication partner, transport organiser and crisis responder. That has workforce participation consequences, particularly for women.
From a macroeconomic perspective, CBDA reductions are also poor value if they reduce functional capacity. Capacity building is the part of the Scheme most directly linked to future independence. It is supposed to reduce long-term support intensity by building skill and capability. Cutting it to save money now risks increasing future reliance on personal care, crisis supports, income support, health services and informal care.
The Senate should therefore reject the assumption that a 10 per cent CBDA reduction is safe because it appears small. In implementation terms, it can remove nearly seven hours of therapy per year from an already limited average budget. For children, remote participants and people with complex functional needs, the effect may be much greater.
Recommendation: CBDA funding should not be reduced through a blunt percentage cut. Any reduction should require an individual functional impact assessment, particularly for children, participants with developmental delay, autism, intellectual disability, psychosocial disability, acquired brain injury, communication disability, behaviour support needs, remote participants and participants with limited informal support. CBDA is not merely therapy funding. It is the bridge between
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
assessment and independence. Cutting it risks turning clinical recommendations into unfunded advice, shifting implementation burden onto families, weakening early intervention and increasing long-term public cost.
Primary Safeguard: Exempt children and participants with capacity-building goals from blanket reductions.
Source and assumptions: OIA / DHDA Reforms Impact Analysis, Figure 11, participants with CBDA funding, average CBDA funding, and CBDA share of committed supports by age group at 31 December 2025. The blue bars show 2025 CBDA allocation exposure based on the relevant age cohort’s average CBDA funding and participant count. The orange bars estimate actual spend by applying an approximate CBDA payment-to-commitment ratio. The 10% cut line shows the proposed CBDA reduction applied as an illustrative scenario and should not be read as an official participant-level forecast. Actual plan impacts will vary by participant, provider access, utilisation, travel costs, reporting costs and implementation needs.
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5.9 - RISK 9: Family and informal-care substitution risk
The proposed reforms create a material economic risk if funded disability supports are reduced on the assumption that parents, partners, adult children, siblings or other informal supports can absorb the gap.
Australia already relies heavily on unpaid care. ABS data shows 3.0 million Australians were carers in 2022, representing 11.9% of Australians living in households, up from 10.8% in 2018. ABS also reported 1.2 million primary carers in 2022. This means the reforms are not shifting support into unused household capacity. They are shifting it into an already large, economically constrained and unpaid care system.
The NDIS is also not replacing family care at scale. NDIA data at 31 December 2025 shows 761,442 active participants. Core Daily Activities and Core Social and Civic supports together represented $45.048 billion in annualised committed supports and $37.010 billion in actual payments over the year to 31 December 2025. Using the standard weekday support-worker rate as a rough conversion, this equates to approximately 16 hours per participant per week allocated, or approximately 13 hours per participant per week actually paid — less than two hours per day.
So, the NDIS is not funding 24-hour care for the average participant. It is funding a limited contribution toward daily living, personal care, supervision, transport, community access and participation. Any reduction to these supports removes part of the bare minimum daily respite available to unpaid carers: time for paid work, sleep, mental health, personal care, grocery shopping, caring for siblings, feeding babies, helping with homework and completing ordinary household tasks.
Cutting these hours even further does not remove the need for support. In fact it reallocates the need. Families may provide more showering, dressing, prompting, supervision, transport, emotional regulation, behavioural support, appointment management, crisis response and administration. For adult participants, if their family are alive and capable of providing care, this means the NDIS Reforms will require parents or partners to absorb support that would otherwise be paid labour in the formal economy.
The economic value of this unpaid labour is substantial. Deloitte Access Economics estimated the replacement value of unpaid care in Australia at $77.9 billion in 2020. PM&C records that unpaid carers’ lost earnings were estimated at $15.3 billion, or 0.8% of GDP, in 2020. These figures pre-date the current reform package and the 2022 increase in unpaid carers.
A policy that shifts funded supports into unpaid care should therefore be treated as an economic transfer, not a Budget saving.
The Government’s own Impact Analysis recognises the economic reality that informal support is not fixed or guaranteed. It notes that changes in informal support may require safeguards such as plan variations to avoid placing participants at risk. If a temporary change in informal support can materially alter a participant’s support needs, then informal care cannot be treated as a permanent, free substitute for funded support.
The gendered effect is also material. Primary carers are disproportionately women, and any shift from paid support into unpaid care is likely to reduce women’s labour force participation, earnings, superannuation accumulation and long-term financial security. This is not a marginal social issue; it is a workforce, tax-base and household-income issue.
A conservative fiscal scenario illustrates the scale. If only 1% of the 2020 replacement value of unpaid care were added through NDIS cost-shifting, that would represent approximately $779 million in additional unpaid care value. A 5% shift would represent approximately $3.9 billion. A 10% shift would represent approximately $7.8 billion. These are not forecasts; they show the order of magnitude if funded support is displaced into unpaid labour.
Census data shows unpaid assistance is already substantial and growing. Between 2006 and 2021, the number of Australians aged 15+ providing unpaid assistance to someone with disability, long-term health condition or old age increased from 1.61
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million to 2.48 million. This does not mean unpaid carers are unemployed; many are also in paid work. The economic risk is that reducing funded NDIS supports will increase the unpaid care load on a population already providing significant care, reducing workforce participation, household income and tax receipts.
The Senate should therefore require the Government to model the cost of family substitution before the Bill proceeds. At minimum, that model should estimate additional unpaid care hours, lost carer earnings, reduced tax receipts, reduced household consumption, carer health impacts, increased Centrelink exposure and participant functional decline.
Required safeguard: Family and informal care should not be treated as a funding substitute unless a transparent reasonableness and sustainability test confirms that the support is voluntary, safe, realistic, non-coercive, economically sustainable and consistent with the participant’s autonomy, dignity and long-term wellbeing.
In summary, unpaid care is already a major part of Australia’s support system. For the average participant, the NDIS has never replaced family care. It is funding a small daily release valve of less than 2 hours per day. Cutting that release valve pushes more care, more stress and more economic loss back onto families.
Source note: ABS Census QuickStats and ABS Census unpaid work/care data. Measure: people aged 15 years and over who provided unpaid assistance to a person with disability, long-term health condition or due to old age during the two weeks before Census Night. Census data is not the same as the ABS SDAC unpaid carer estimate.
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5.10 - RISK 10: 24/7 critical daily living, intimate-care and dignity risk
This risk should not be treated as a narrow service-delivery issue. It sits at the intersection of fiscal policy, labour-market design, unpaid care, bodily autonomy and the real conditions of daily survival for people with profound or severe disability.
The scale of the issue is material. In 2022, the ABS reported that 5.5 million Australians had disability, including 7.9% of all Australians with profound or severe disability. Of the 3.2 million Australians with disability living in households who needed assistance, only 49.9% had their needs fully met, down from 59.7% in 2018. Among people with a profound limitation, only 36.7% had their needs fully met. This is the population context into which the reforms are being introduced: not a system where support needs are already comfortably met, but one where unmet and partly met need is already substantial.
For participants with high or critical daily living needs, personal care is not discretionary. Showering, toileting, dressing, transfers, meal assistance, communication support, continence care and medication prompting are not lifestyle supports. They are the difference between hygiene and neglect, safety and injury, dignity and exposure, participation and being trapped at home. The Government’s own Impact Analysis recognises that core daily functioning includes supports such as toileting, showering, meal preparation and household tasks, and says SCCP budget resets are not intended to change core daily living functional supports such as eating, drinking, dressing, toileting, medication assistance and incontinence-related supports. That acknowledgment is important, but it is not enough. The question for the Senate is whether the Bill, the assessment rules, mandatory registration and future planning decisions create pathways for those supports to be narrowed, rationed, delayed or shifted onto unpaid carers in practice.
A civilised disability scheme should not require an adult participant to argue for more than two baths per week. If a participant requires physical assistance to shower, toilet, dress, transfer or manage continence, the question should not be how little support the Scheme can fund. The question should be what level of support is required to preserve health, dignity, privacy, bodily autonomy and ordinary adult life.
The data shows that unpaid care is already carrying a major load. The ABS reported 3.0 million unpaid carers in Australia in 2022, representing 11.9% of Australians living in households. There were 1.2 million primary carers, and 43.8% of primary carers had disability themselves. Primary carers are not an unlimited reserve army of labour. Many are already older, disabled, financially constrained or caring because they feel family responsibility rather than because the arrangement is sustainable. The ABS found that the most common reason people became primary carers was feeling responsible for family, reported by 64.7% of primary carers.
The type of care being pushed onto families is also not minor. In 2022, 57.9% of primary carers provided self-care support, 68.1% provided mobility support, and 55.4% provided communication support. More specifically, 42.5% assisted with dressing, 35.6% assisted with bathing or showering, 27.5% helped the person get in or out of a bed or chair, and 17.2% assisted with toileting. These are intimate, bodily and dignity-sensitive tasks. They are not equivalent to helping with paperwork or transport.
From an economic perspective, shifting more of this work onto unpaid carers is not a saving. It is an accounting transfer. It removes the cost from the NDIS ledger and relocates it into unpaid household labour, lost workforce participation, carer illness, family breakdown, preventable hospital use and crisis response. The ABS data is already clear on the workforce effect: among primary carers aged 15–64, only 45.4% of those providing 40 hours or more of care per week were employed, compared with 71.6% of those providing less than 20 hours of care per week. 51.4% of primary carers providing 40 hours or more were not in the labour force.
That matters for this reform because 24/7 and high-intensity daily living support is labour-intensive by definition. If the Agency reduces funded personal care on the assumption that a parent, partner or family member can continue providing it, the Commonwealth may record a Scheme saving while the broader economy loses paid work, taxable income, superannuation accumulation and household stability. This is precisely the type of cost-shifting the submission has been
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warning about: fiscal savings are modelled, but the downstream economic and lived-experience harms are not transparently modelled.
The second data point Senators need to understand is market concentration and participant choice. The March 2026 NDIA Quarterly Report shows $17.986 billion in annualised committed supports for participants in Supported Independent Living, with an average annualised SIL committed support of $488,600 nationally. Payments for SIL were $16.398 billion, with average annual SIL payments of $447,100. SIL utilisation was 87%, compared with 68% for participants not in SIL. That high utilisation is not evidence of waste. It is evidence that participants with complex living-support needs use their funding because the support is essential and recurring.
Mandatory registration may improve safeguards, and the policy rationale is understandable. The Government has announced that mandatory registration for SIL providers and platform providers will begin from 1 July 2026, and that mandatory registration will be expanded to all providers delivering higher-risk supports to participants most at risk of abuse or exploitation. The NDIS Commission says registration increases oversight, reduces risk, responds to wrongdoing and fraud, and requires standards such as audits, worker screening and incident management.
But registration also changes market structure. The Government’s own Impact Analysis says there were around 276,000 active NDIS providers in the December 2025 quarter. Of the 111,000 providers delivering social, community and civic participation supports, 100,800 — or 91% — were unregistered, and around 56,000 providers delivered SCCP supports to only one participant, many being individual support workers operating as small providers. Although this statistic is for SCCP rather than personal care, it demonstrates the highly decentralised structure of the NDIS provider market and the importance of sole traders and small providers in participant-directed support.
That is the dignity problem. For high-needs participants, the worker is not interchangeable. A participant may need a worker of a particular gender for intimate care, a worker who understands their communication system, a worker who can manage transfers safely, or a worker who knows how to assist with showering, toileting, dressing or continence without causing distress, injury or humiliation. If mandatory registration narrows the provider pool without a thin-market and continuity model, the participant may be formally “protected” while practically losing choice over who enters their bathroom, bedroom and body space.
Speaking from the position of a high-needs participant with the cognitive capacity to argue their case: my ability to explain policy does not mean I can safely perform daily living tasks without support. I may be able to tell the Senate what the legislation gets wrong, but still require another person to help me shower, toilet, dress, transfer, communicate under pressure, prepare to leave the house or manage daily routines safely. Cognitive capacity is not physical independence. Advocacy capacity is not care capacity.
The legislation must therefore not allow the Agency to confuse existing family support with sustainable family capacity. If a parent helps a person with disability shower every morning before work, that is not proof that they do not need funded support. It may be proof that their family is already absorbing an unfunded public cost. Likewise, if a spouse/partner assists with toileting, transfers and dressing, that does not mean the State can permanently conscript them into intimate care. It is well documented that 24/7 care is exhausting, and in many cases the parent/partner may be ageing, untrained, unqualified, employed, terminally ill, geographically unavailable, unreliable, unsafe, abusive, or dead.
The NDIS should not build its fiscal repair strategy on the assumption that family members will keep doing whatever the Scheme no longer funds. Relationships can stall or dissolve completely. Only paid support can be 100% relied on in a disability setting.
This is the contradiction we identified in the earlier submission work: the assessment says the family does not exist; the funding decision says the family can do it. That contradiction is not technical. It determines whether an adult participant keeps privacy, safety and bodily autonomy, or whether essential intimate care is pushed back into unpaid family labour.
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The Senate should require a clear statutory safeguard: personal care, 24/7 support, intimate care and critical daily living funding must not be reduced merely because a family member has historically provided support. Informal support should only be considered where it is demonstrably willing, safe, sustainable, trained, proximate and compatible with the participant’s dignity and adult autonomy. For high and critical support participants, the default should be protection of funded support, not substitution by unpaid care.
In summary, the reform risk is not simply that personal care funding may be cut. The deeper risk is that the Scheme will record savings by narrowing provider choice and increasing reliance on unpaid intimate care. The data shows unpaid carers are already carrying substantial self-care, mobility and communication support; many primary carers are themselves disabled; and heavy caring is strongly associated with reduced employment. A reform that pushes more 24/7 daily living support back onto families does not eliminate cost. It hides it.
The below chart shows the proportion of Australian primary carers providing core personal-care and daily-living assistance. These are not discretionary supports. They include bathing, dressing, toileting, transfers, mobility and communication. Reducing funded personal care by assuming families can absorb these tasks would shift public cost into unpaid labour, carer health risk, lost workforce participation and loss of participant dignity.
A participant who requires assistance to bathe should not be reduced to two baths per week because the Scheme assumes unpaid family labour can replace funded personal care.
Source note: ABS Survey of Disability, Ageing and Carers, 2022. Approximate counts use ABS rounded total of 1.2 million primary carers. This chart shows why shifting personal care from funded supports to families is cost-shifting, not cost removal.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
5.11 - RISK 11: Thriving Kids capped-funding and transition risk
The published Thriving Kids model provides more detail than was previously available, but it does not remove the central risk. It confirms the policy direction: children aged 8 and under with developmental delay and/or autism who are assessed as having low to moderate support needs may be supported through a new foundational supports system rather than relying on individualised NDIS plans.
The model has strengths. Early identification, a “no wrong door” approach, reduced reliance on costly diagnosis, supported playgroups, parenting programs, developmental checks, navigation and allied-health-informed help are all sensible design features. If implemented properly, Thriving Kids could reduce diagnostic gatekeeping, identify developmental concerns earlier, and provide practical help to families before crisis. However, the existence of a better-described model is not the same as evidence that the receiving system is ready to replace individualised NDIS support.
The critical issue is that Thriving Kids remains a block-funded and capped service model, not an individualised entitlement model. It describes categories of support, but it still does not answer the key economic and child-development questions: what does an individual child receive, how often, for how long, from which provider, in which location, and with what enforceable right to review or escalation?
Gap / pitfall Why it matters
No per-child funding model A national funding envelope does not show whether each child receives adequate support. Families cannot compare Thriving Kids with existing NDIS-funded early intervention.
No guaranteed service intensity “Time-limited blocks” may suit some children, but the model does not define minimum hours, duration, frequency, review points or escalation triggers.
No clear boundary between low, Children may be classified downward into Thriving Kids when family compensation is masking moderate and high need substantial functional impairment.
No published national demand The Senate cannot test whether funding is adequate without knowing expected child numbers model by need, age, geography and intensity.
No national workforce-capacity The model depends on allied health, early childhood, health, education, navigation and proof community-support workforces that are already stretched.
Geographic equity risk Children in regional, rural, remote and thin-market communities may receive a very different version of “foundational support” than children in metro areas.
State-by-state variation A state-delivered model risks eight different systems, with uneven procurement, waitlists, provider markets and escalation pathways.
No clear review or appeal Families need a transparent way to challenge inadequate supports, escalate need, or re-enter pathway the NDIS quickly.
No transition certainty for families Families do not yet know what changes, who delivers support, whether existing therapy relationships continue, or how to prepare their children.
Existing disability workforce not The government has invested in growing the NDIS and care workforce, but the model does not clearly integrated clearly explain how trained disability support workers will be used, supervised or transitioned.
Allied health bottleneck risk If targeted supports rely too heavily on direct allied health delivery, scarce clinicians may become the bottleneck, especially outside metropolitan areas.
Capped-program rationing risk If demand exceeds supply, the system may queue, thin, group, delay or exclude children rather than expand to assessed need.
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From an economist’s perspective, this is a classic capped-program risk. The NDIS is imperfect and administratively difficult, but its individualised funding model at least links support to assessed functional need. A capped foundational supports model reverses that logic. Once a fixed funding envelope is allocated, support becomes dependent on total demand, state and territory capacity, local provider supply, workforce availability and commissioning decisions. If demand exceeds supply, the model does not automatically expand to meet need. It queues, thins, groups, time-limits, redirects or excludes.
That matters because early childhood intervention is time-sensitive. For children with developmental delay, autism, sensory needs, communication differences or emotional regulation challenges, delay is not neutral. Reduced or interrupted support can affect communication, behaviour, school readiness, family stress, parental workforce participation and the later intensity of support required. If Thriving Kids provides less support than an individual child needs, the cost does not disappear. It may reappear later through school adjustment costs, parental workforce withdrawal, family breakdown, child mental health presentations, behavioural escalation, crisis services or future NDIS re-entry at higher intensity.
The workforce issue is especially important. Thriving Kids relies on allied health, GPs, early childhood educators, teachers, family navigators, parenting-support workers, state-commissioned providers and local services. Yet the published model does not demonstrate that there will be enough providers to service Thriving Kids across every part of Australia. A child in a regional, rural or remote area does not benefit from a national portal if there is no speech pathologist, occupational therapist, psychologist, physiotherapist, developmental practitioner, supported playgroup or family-support provider available within reach.
Nor does the model adequately explain how the existing disability support workforce will be used. This is a material economic and implementation gap. The Commonwealth has spent years growing the NDIS workforce and subsidising care sector training pathways to meet disability and care demand. If children are redirected from individualised NDIS plans into Thriving Kids, the government must explain whether experienced disability support workers will be integrated into supervised delivery roles, retrained, redeployed or excluded.
This is not an argument that disability support workers should replace speech pathologists, occupational therapists, psychologists, physiotherapists, developmental paediatricians or early childhood educators. They should not. But trained disability support workers could play a useful supervised role in therapy carryover, routine-building, supported playgroups, childcare or school transition support, sensory and regulation strategies, community participation and helping families embed allied-health recommendations into daily life.
That would be consistent with the Thriving Kids principle of support in natural environments — where children live, learn and play. It would also be economically efficient. The most scarce and expensive clinical workforce should be used for assessment, intervention design, supervision and review. Routine practice, environmental scaffolding and daily implementation can often be supported by a trained, supervised non-clinical workforce. Without that workforce architecture, Thriving Kids may become bottlenecked by allied health shortages while simultaneously stranding disability workers whose skills were developed to meet NDIS demand.
This is a poor use of public investment. The government should not build one workforce with public money, then design the replacement system as if that workforce does not exist.
The state-delivery model creates a further accountability risk. The Commonwealth may fund and coordinate aspects of Thriving Kids, but states and territories will deliver substantial parts of the service system. This creates the risk of eight different implementation models, with uneven access, different procurement quality, different waitlists, different provider markets and different escalation pathways. Families need to know who is accountable when support is delayed, inadequate or unavailable: the Commonwealth, the state, the NDIS, the commissioned provider, the GP, the early childhood system, or the school system.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
For families, the practical uncertainty remains high. They do not know what support their child will receive, whether it will be individual or group-based, how much allied health will be available, whether existing therapy relationships will continue, how children will be prepared for transition, or what happens if a child is wrongly classified as low to moderate needs. For autistic children and children with developmental delay, abrupt service change can itself cause distress, regression and behavioural escalation. Families need time, continuity and clear explanation. They should not be asked to prepare children for a system whose practical operation remains only partly visible.
The strongest concern is misclassification. A child may appear to have low or moderate needs because parents are heavily compensating. The child may be functioning only because the family is organising therapy, adapting routines, managing sensory triggers, reducing demands, providing communication support, managing sleep disruption and preventing behavioural escalation. If those informal supports are mistaken for low need, the child may be redirected out of the NDIS into a lower-intensity capped system, even though the apparent stability is being produced by unrecognised family labour.
From an economist’s perspective, this is the same modelling problem seen across the broader reform package: the saving pathway is visible, but the downstream cost pathway is not adequately modelled. The public model explains the architecture of supports, but it does not yet demonstrate the demand, funding, workforce, geographic coverage, service intensity or escalation modelling required to prove that children will not be worse off.
The Senate should assess Thriving Kids by evidence of readiness, not policy intention.
The appropriate safeguard is clear. No child should be moved from individualised NDIS-funded support into Thriving Kids until the Commonwealth, states and territories have published the full operating model, including per-child funding assumptions, eligibility rules, assessment pathways, service intensity, provider-capacity modelling, allied-health workforce modelling, disability-support workforce integration, rural and remote coverage, waitlist safeguards, transition protections, review rights and rapid NDIS re-entry pathways for children whose needs are higher than first assessed.
A safer reform sequence would be:
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build and publish the Thriving Kids operating model;
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publish the per-child funding, demand and workforce assumptions;
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demonstrate state and territory provider capacity;
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define how allied health, early childhood workers, family navigators and trained disability support workers will work together;
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protect children already receiving NDIS supports during transition;
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create a rapid escalation and NDIS re-entry pathway;
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only then change NDIS access settings. Recommendation: Before any child is redirected from individualised NDIS-funded supports into Thriving Kids, the Commonwealth and states should publish a Thriving Kids workforce transition model showing how allied health professionals, early childhood educators, family navigators and trained disability support workers will be used together. This model should include supervision requirements, scope boundaries, child-safety safeguards, training pathways, regional workforce supply, and protections against replacing clinical intervention with unsupported low-cost labour.
In summary, Thriving Kids identifies the right problem: children need help earlier, and families should not need a costly diagnosis before support begins. But the published model has not yet proven that the receiving system will be funded, staffed, geographically available or accountable enough to replace individualised NDIS support. Without a transparent demand, funding, workforce and state-capacity model — including a plan for the existing disability workforce — Thriving Kids risks becoming a capped substitute for early intervention rather than a genuine expansion of support.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
5.12 - RISK 12: Early-intervention market contraction risk
The proposed reduction or redirection of individualised early-childhood NDIS funding creates a material provider-market risk. The issue is not only whether children receive support under a replacement model. The economic question is whether Australia’s early-intervention workforce, which has expanded in response to NDIS demand, remains viable if individualised paediatric disability funding contracts.
This risk affects speech pathologists, occupational therapists, psychologists, physiotherapists, developmental educators, behaviour support practitioners, therapy assistants, allied-health assistants, paediatric clinics, sole traders and small multidisciplinary practices. These are not peripheral suppliers. They are the delivery infrastructure through which early intervention occurs.
The scale of the client base is significant. As at 31 March 2026, the NDIS had 774,456 active participant plans nationally. Children aged 0 to 8 accounted for 167,787 active plans, or about 22% of all active NDIS participants. Children aged 9 to 14 accounted for a further 155,702 plans. Together, children aged 0 to 14 represented more than 323,000 participants, or about 42% of the Scheme. Autism was the largest primary disability group, with 338,099 active participant plans, or 44% of all active plans.
That matters because children under 9 are not a marginal part of the allied-health market. They are a major demand base for paediatric speech pathology, occupational therapy, psychology, behaviour support, developmental education and therapy assistant services. If individualised funding for this cohort is reduced, capped, redirected or replaced by lower-intensity block funded services, the demand shock will not be limited to families. It will flow directly into the provider market.
Government policy settings have sent clear demand signals to the workforce over the past decade. The NDIS National Workforce Plan described around 270,000 workers supporting NDIS participants across 20 occupations, with projected Scheme workforce demand rising to almost 353,000 workers by 2024. At the same time, the Commonwealth has prioritised care-sector training through Fee-Free TAFE and the National Skills Agreement. Fee-Free TAFE priority areas include care, including disability care, and the Prime Minister reported 131,000 Fee-Free TAFE enrolments in care, including disability and aged care.
The registered allied-health workforce has also grown. In 2024/25, AHPRA reported 34,423 occupational therapists, up 7.4% from the previous year, including 2,789 first-time registrants. The Psychology Board reported 50,409 psychologists, with 3,740 first-time registrants. The Physiotherapy Board reported 47,761 physiotherapists, with 4,125 first-time registrants. Speech Pathology Australia represents more than 15,000 speech pathologists, and speech pathology remains a core profession in paediatric developmental support.
Government policy has encouraged workforce expansion to meet NDIS-driven demand. Reform may now reduce the demand base before modelling what happens to that workforce, its graduate pipeline, and the small-provider market that employs it.
This is not a simple case of labour moving smoothly from one funding stream to another. Paediatric allied health is a specialised market. Clinicians build caseloads, supervision structures, therapy rooms, school and childcare relationships, assessment tools, therapy resources, referral pathways and family trust over time. Small practices employ graduates, train junior clinicians, provide supervision, and often service local communities that larger providers do not prioritise. If demand falls suddenly, practices may reduce staff, stop taking graduates, close waitlists, shift away from disability work, or exit the market.
That would weaken the very workforce Australia needs for early intervention.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Market- Why Senators should care contraction risk
Reduced If children under 9 receive less individualised funding, paediatric allied-health caseloads may fall, individualised especially for speech pathology, OT, psychology and behaviour support. demand
Small-provider Sole traders and small paediatric clinics may not have the scale, cashflow or tender-writing exposure capacity to survive a shift from individual plans to state-commissioned contracts.
Graduate pathway Universities and training systems have expanded graduates into allied health and care work. If risk paediatric demand contracts, new graduates may face fewer entry-level roles and supervision opportunities.
Loss of supervision Early-career clinicians need senior supervision. If small clinics contract, graduate training capacity capacity contracts with them.
Regional market In thin markets, losing one paediatric OT, speech pathologist or psychologist can materially fragility reduce access for an entire region.
Allied-health If the replacement system relies on fewer commissioned providers, families may face longer waits bottleneck even if the program appears funded on paper.
Therapy-assistant A poorly designed model may fail to use therapy assistants and trained support workers for underuse supervised therapy carryover, reducing workforce leverage.
Public training Government has subsidised care and disability training; market contraction may waste part of investment risk that public investment.
Market consolidation Larger providers may be better positioned to win block-funded contracts, while small local practices lose demand and bargaining power.
Downstream fiscal Reduced early intervention can increase later costs in schools, child mental health, family support, risk crisis systems and future NDIS re-entry.
From a whole-of-economy perspective, the policy risk is a demand-side shock to a specialised human-capital market. Allied health labour cannot be turned on and off like a budget line. It takes years to train, accredit, supervise and retain clinicians. Once clinicians leave paediatric disability practice, move interstate, shift into aged care, hospitals, adult work, private mental health, insurance, education, or non-clinical roles, that capacity may not return quickly.
This is especially dangerous where the reform assumes that early intervention will still occur through “the community” or state-commissioned services. A new program cannot deliver early intervention if the existing provider ecosystem has contracted before the replacement system is fully operational.
The graduate pathway risk is particularly serious. First-time registrants are entering occupational therapy, psychology and physiotherapy in significant numbers, and speech pathology remains a major paediatric profession. Many graduates rely on early-career roles in private practices, multidisciplinary clinics, community providers and NDIS-funded services. If individualised paediatric disability demand falls, the impact will not only be on business revenue. It will affect employment, supervision, professional development, placement capacity and the future supply of experienced paediatric clinicians.
The Government should therefore not assume that reduced NDIS spending equals system efficiency. A reduction in individualised funding may produce an accounting saving while creating hidden losses in workforce retention, small-business viability, local service supply and child-development outcomes.
There is also a regional equity problem. The AIHW notes that health workforce shortages already exist across health professions, including specific allied-health professions, and that projected demand for health services may worsen
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
shortages. In a city, a family may be able to change providers. In regional or outer-suburban areas, there may be no substitute provider. If an NDIS-funded paediatric practice becomes unviable, the “market correction” may look like no service at all.
The Senate should also recognise the difference between cutting excessive billing and destabilising a legitimate care economy. Fraud control, value-for-money testing and evidence-based practice are necessary. But broad funding contraction without workforce modelling can damage legitimate providers along with poor-quality or opportunistic ones. The correct policy response is not to shrink the market blindly. It is to model the market, remove bad actors, preserve skilled capacity, and ensure children continue to receive timely early intervention.
The central concern is that the early-intervention market was built around individualised demand. If that demand is reduced before the replacement system is funded, staffed and contracted, Australia risks losing skilled paediatric capacity before it knows whether the new model can replace it. The Government should be required to publish an early-intervention market impact model before transition. That model should include:
Required modelling Why it is needed
Current paediatric allied-health To quantify how much NDIS-funded work currently supports speech pathology, OT, demand psychology, physiotherapy, behaviour support and developmental education.
Provider exposure by business To identify risks to sole traders, small clinics, multidisciplinary practices and regional size providers.
Graduate employment To assess how demand contraction affects new graduates, supervision and early-career pathways development.
Workforce supply by To identify thin markets where provider loss would create service failure. geography
State-commissioned demand To test whether replacement contracts will absorb the displaced workforce or concentrate work in fewer providers.
Therapy assistant and support- To determine how lower-cost supervised workers can support implementation without worker utilisation replacing clinicians.
Transition timing To prevent demand falling before the replacement system is operational.
Downstream cost modelling To estimate costs shifted into education, health, family support, carer workforce withdrawal and future NDIS re-entry.
Recommendation: Before reducing or redirecting individualised early-childhood NDIS funding, the Commonwealth should publish an early-intervention market impact model covering allied-health labour demand, graduate pathways, small-provider viability, regional workforce capacity, therapy-assistant utilisation, and the risk of market consolidation under state procurement.
In summary, Australia has spent years growing the allied-health and disability workforce to meet NDIS demand. The Government should not now reduce the individualised early-childhood funding base without modelling whether the paediatric provider market, graduate pipeline and regional workforce can survive the transition. A reform that weakens the early-intervention workforce will not save money; it will shift cost into schools, families, health systems and future disability support.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Source Note: Client series uses NDIA age-group data where available. NDIA introduced a 0-8 age group in late 2024; earlier years are estimates from published 0-6 and 7-14 data or rollout interpolation and should be treated as directional. Funding bars are broad public workforce/training commitments relevant to health/care/disability workforce supply, not an allied-health-only or NDIS-only university funding series. Projection lines are scenarios, not official forecasts.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
5.13 - RISK 13: Schools, childcare and community-health cost-shift risk
Thriving Kids should be assessed as a whole-of-government delivery risk. The policy assumes many children under 9 with developmental delay and/or autism can be redirected from individualised NDIS supports into mainstream, community and group-based settings. But reduced NDIS funding does not reduce developmental need. A child who needs support to communicate, regulate, participate, transition, learn or cope in daily life will still need that support — whether it is funded through an NDIS plan or pushed into childcare, preschool, school, GP clinics, community health services, supported playgroups and family homes.
Who will provide practical implementation support when the child’s difficulty occurs in real life?
A parenting program can tell a family what to do – It does not put another trained adult beside them when a child is dysregulated at 7.30am, refusing childcare, unsafe in a car park, unable to tolerate the supermarket, or melting down before school.
Group-based support may help some children – It is not a substitute for one-to-one communication support, sensory regulation support, behavioural intervention, therapy carryover, or coaching in the environments where the child and family are actually struggling.
The data shows the receiving systems are already under pressure.
Schools are already carrying a large and rising disability-adjustment load. In 2025, 1,125,502 Australian school students received an educational adjustment due to disability, representing 27.0% of total enrolments, up from 18.0% in 2015. That is a heavy load given most schools have little or no allied health staff to support the students in need.
1 in 4 Australian school students already requires disability-related adjustment
Childcare is also not a spare-capacity system.
In the March quarter of 2025, more than 1.4 million children aged 0–12 attended Child Care Subsidy approved services, representing 35.0% of Australian children aged 0–12. More than 50% of children aged 0–5 attended approved childcare services, the highest proportion in the previous decade.
Community health access is uneven, especially outside major cities. AIHW reports poorer health service access in remote and very remote areas. In 2022, very remote areas had 205 clinical medical practitioners FTE per 100,000 people, compared with 427 FTE per 100,000 people in major cities. While this is a medical workforce indicator rather than an allied-health-specific measure, it demonstrates the wider geographic access problem in the systems families may be redirected into.
The proposed sequencing heightens the risk. Thriving Kids state services are expected to commence rollout by 1 October 2026 and be at scale from 1 January 2028, ahead of access changes for young children. That sequence is only safe if the receiving systems are already built, staffed, funded and accountable before children are redirected.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Policy feature Delivery failure risk
Group-based Some autistic children and children with developmental delay cannot tolerate group environments supports due to sensory, communication, anxiety, behavioural or regulation needs.
Supported Useful for connection and parent confidence, but not a substitute for direct speech pathology, OT, playgroups psychology, behaviour support or one-to-one implementation where required.
Parent education Families may receive advice without practical support to apply strategies during daily routines, model transitions, community access or behavioural escalation.
Natural-environment Schools and childcare centres may be expected to implement strategies without matching funding, delivery staffing, ratios, training or time.
“No wrong door” Families may be referred between NDIS, health, education, childcare, GPs and community services without one system owning the outcome.
NDIS safety net The safety net only works if higher-needs children are identified quickly and can enter or re-enter the NDIS without delay.
Regional delivery Families in thin markets may be given a pathway on paper but no real local provider.
The Economic Flaws of Supply Capping and Provider Restrictions. The block-funded design also changes provider incentives.
Under individualised NDIS funding, support is linked to the assessed needs of the child. Under a capped, directly commissioned model, providers must operate within fixed contracts, fixed service volumes and program specifications. This creates a rationing problem. If demand exceeds the funded supply, providers cannot simply expand support to meet need. They must manage scarcity through triage, waitlists, short intervention blocks, group delivery, parent-led strategies and exit points. That may control government expenditure, but it creates a waitlist externality: the cost of delay is transferred to families through lost work time, private therapy costs, deterioration in child functioning and increased pressure on childcare, schools and community health.
There is also a provider-market risk. If contracts are concentrated in a small number of state-commissioned organisations, and subcontracting to private allied-health providers is restricted, the model may create localised bottlenecks rather than true service access. This is especially risky in regional and thin markets where private speech pathologists, occupational therapists, psychologists, behaviour practitioners and therapy assistants may already be the only practical capacity available. A capped model that limits flexible use of that workforce may look orderly on paper but inefficient in practice. It risks replacing family choice and local provider diversity with a contract-managed system where providers are accountable primarily to government throughput requirements, not to the child’s actual developmental need.
The most serious failure point is the gap between instruction and implementation. Many children do not struggle because families lack information. They struggle because daily life requires repeated, skilled, in-context support. If the model provides advice or group-based support but not practical implementation support, the unpaid labour shifts to parents and the operational burden shifts to schools and childcare.
The misclassification risk is substantial. A child may appear to have low or moderate needs because parents are already heavily compensating — managing sensory triggers, sleep disruption, transitions, behaviour, communication, therapy appointments and childcare breakdown. If that unpaid labour is mistaken for low need, the child may be shifted into a lower intensity support model. The apparent saving is then achieved by transferring the practical burden to family, childcare, school and state systems.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Receiving system Likely cost pressure if individualised supports are reduced
Schools More disability adjustments, behaviour support needs, learning support, reduced attendance, suspensions, exclusions and teacher workload.
Childcare and Higher inclusion needs, ratio pressure, staff stress, safety concerns and service refusal risk. preschool
Community health Longer waitlists for developmental checks, child psychology, allied health and family support.
GPs More referrals, care coordination, parental distress presentations and administrative burden.
Families More unpaid coordination, therapy carryover, private therapy costs, reduced work hours and carer burnout.
States and Greater demand across education, health, child development and family services. territories
Future NDIS Children may re-enter later with higher needs if early intervention is insufficient.
Lack of Government Transparency
The Government appears to be relying on broad categories such as “low-to-moderate” and “high support needs” for children with autism and developmental delay, yet there is no clearly published national dataset mapping children under 9 by DSM-5 autism support level, functional capacity, co-occurring disability, behavioural risk, communication needs, or actual support intensity. Without that data, the Senate cannot test how many children may be redirected into Thriving Kids, how many may remain NDIS-eligible, or how many sit in the grey zone between “moderate” and “high” need.
If the Government cannot publish the distribution of support need inside the under-9 autism cohort, it cannot credibly assure families that only children with genuinely low-to-moderate needs will be redirected out of individualised NDIS supports.
The Senate should not assess this reform only through the NDIS budget. The correct economic test is whole-of-system cost. If a child loses individualised support and then requires more school adjustments, GP visits, community health referrals, parental time out of the workforce, crisis response, reduced childcare attendance, school exclusion or later NDIS re-entry, the saving has not been achieved. It has merely been moved.
Recommendation: Before changing NDIS access for children under 9, the Commonwealth and states should publish a full schools, childcare and community-health cost-shift model. This model should quantify additional demand across education, early childhood, community health, GPs, allied health and families; identify workforce and funding gaps; and establish enforceable escalation pathways for children whose needs cannot be met through mainstream, community or group-based supports. It should also explain who provides practical in-home and community implementation support when parent education or group programs are insufficient.
In summary, Thriving Kids is a whole-of-government delivery failure risk. If individualised early-intervention supports are reduced before schools, childcare, community health and families are funded and supported to absorb the need, the reform will not remove cost. It will transfer cost into classrooms, childcare centres, GP clinics, community health waitlists and family homes. Group-based support can help some children, but it is not a substitute for individualised implementation support when a child cannot function in the group or when the family needs help in the real environments where disability affects daily life.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
5.14 – RISK 14: Digital payments and automated payment-control risk
The proposed digital payment system should not be treated as a neutral administrative upgrade. It is a major shift in the power relationship between the NDIA, providers, plan managers and participants. The Government says it will invest $358.5 million over five years to develop and implement a new enrolment and digital payment system to improve payment integrity and reduce fraud and non-compliant payments. This sits within a broader $1.7 billion over five years NDIS reform package that also includes $280.1 million for the Fraud Fusion Taskforce, $270.1 million for framework planning implementation, $182.6 million for mandatory registration of high-risk providers, and $49.4 million for commissioned plan management and support coordination.
Fraud control is necessary. The ANAO reported that in 2023–24 the NDIA paid $41.85 billion in NDIS participant plan expenses, and that the Government had committed more than $495 million over eight years to combat NDIS fraud and non compliance. The ANAO also reported that the NDIA estimated 6% to 10% of outlays could be non-compliant, fraudulent or incorrect. Those figures justify stronger payment integrity systems. They do not, however, justify a system that blocks legitimate supports, delays payment, removes participant choice, or treats vulnerable people as compliance risks before their needs are met.
The policy rationale extends beyond fraud prevention.
Digital payments create a centralised control mechanism over claims, providers, timing, evidence and payment approval. But at what cost?
A digital payment system allows the NDIA to move from a “pay and review later” model toward pre-payment control, real time claim checking, provider enrolment, data matching, automated flags, transaction blocking and tighter visibility over what is purchased, from whom, when and under which budget rule. That may reduce leakage, but it also creates a new vulnerability: if the system is wrong, slow, poorly coded, inaccessible, or overly rigid, participants may lose access to supports in real time.
For vulnerable participants, this risk is not theoretical. A payment delay can mean a support worker is not paid. A blocked claim can mean a provider stops attending. A system error can mean therapy is paused, personal care is disrupted, transport is cancelled, assistive technology is delayed, or a small provider walks away because they cannot carry the cashflow risk. The participants most exposed are those with communication barriers, cognitive disability, psychosocial disability, limited digital literacy, no informal support, unstable housing, high daily support needs, or reliance on small trusted providers.
The economic risk is that the system may reduce visible fraud while creating hidden costs elsewhere. If legitimate providers leave because payment becomes too risky or administratively burdensome, the market contracts. If small providers cannot manage delayed or disputed claims, participants lose choice. If participants cannot navigate digital disputes, unpaid supports shift back to families. If essential supports stop, costs reappear through crisis care, hospital presentations, behavioural escalation, complaints, reviews and tribunal appeals.
The NDIA’s own digital history should make the Senate cautious. The Parliamentary Joint Committee examining the PACE platform reported that the initial Salesforce contract was approximately $27 million, but Salesforce costs were around $100 million over four years, and NDIA later stated the total Salesforce contract value as at 31 December 2023 was $125.95 million. The Committee also noted the contract had expanded considerably through variations, including additional functionality and licences. It was “perplexed” that the procurement’s value-for-money assessment gave no explicit weighting to price, and recommended further reporting on value for money, productivity, user experience and improved outcomes.
That history matters because the same system logic is now being expanded into payments. The PACE procurement shows that large NDIA digital systems can grow in scope, cost and risk while participants and providers are expected to absorb
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
implementation problems. The Senate should therefore require independent assurance before any digital payment system becomes mandatory, particularly where payment blocking could interrupt essential supports.
There is also a civil-rights risk. Digital payment systems can easily become behavioural control systems. If the NDIA can decide in advance which providers, supports, invoices, hours, prices, evidence and categories are acceptable, then participant choice and control becomes conditional on the software accepting the transaction. The question is not only whether a support is lawful. The question is whether the participant has a practical pathway to get a legitimate claim paid when the system says no.
Statutory Payment Suspension and Cashflow Risk
Section 45 now creates a direct payment-continuity risk. The legislation states: “The Agency must not pay an amount under the National Disability Insurance Scheme to any person in respect of a participant’s plan if the person who made a claim under section 45A for payment of the amount has not given the CEO the information or documents requested under subsection (3B) within the specified period.” It also provides that the CEO may require the claimant to give “such further information or documents in relation to the claim as the CEO reasonably requires,” and that the notice must allow a period “which must not be less than 14 days.” This is not merely an anti-fraud provision; it is a statutory payment gate. A legitimate service may already have been delivered, wages may already be owed, and a small provider may already have incurred the cost, but payment can be stopped if further information is requested and not supplied within the specified period. For participants, this creates support-continuity risk. For providers, especially sole traders and small businesses, it creates cashflow risk. Repeated claim suspensions may lead providers to refuse NDIS work, reduce services, demand upfront payment, or exit the Scheme altogether.
This is why disability advocates are worried about the balance of investment. People with Disability Australia’s Acting CEO, Megan Spindler-Smith, was quoted as saying: “We are concerned the $1.7 billion… is focused on fraud, digital systems, and registration instead of people.” That is the central policy concern. The Government is investing heavily in control infrastructure while participants are being asked to accept reduced supports, tighter assessments, provider restrictions and less individualised flexibility.
Digital payment risk Why it matters
Legitimate claims blocked Essential supports may stop while participants or providers dispute an automated decision.
Payment delays Small providers and sole traders may exit because they cannot carry cashflow risk.
Reduced choice and Participants may only be able to use providers or supports the system recognises. control
Digital exclusion Participants with cognitive, communication, psychosocial or literacy barriers may struggle to challenge errors.
Automated rigidity Software rules may not understand complex real-life disability support needs.
Provider-market Compliance burden may favour large providers and push out small trusted providers. contraction
Privacy and surveillance Payment data can become a behavioural monitoring tool if safeguards are weak.
Appeal burden Incorrect blocks may create complaints, internal reviews, ART matters and advocacy demand.
Cost displacement Delayed supports can create costs in health, housing, crisis care, families and future NDIS needs.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Recommendation: Before any digital payment system becomes mandatory, the Commonwealth should publish a full Digital Payments Safeguard and Impact Statement. This should include the system design, evidence requirements, claim-blocking rules, participant appeal rights, provider cashflow protections, accessibility testing, privacy protections, human review timeframes, small-provider impact modelling, and safeguards for urgent and essential supports such as personal care, transport, therapy, behaviour support, communication support and assistive technology.
In summary, digital payment integrity is necessary, but payment control is not the same as participant protection. A system designed to stop fraud must not become a system that delays, blocks or narrows legitimate disability support. The Senate should require transparency, independent testing and enforceable human review rights before the NDIA is given a mandatory digital payment gatekeeping system over the daily supports of vulnerable Australians.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
5.15 - Risk 15: Robo-assessment and loss of effective appeal rights
This is wrong.
A democracy does not protect vulnerable people by replacing individual assessment with opaque tools, then removing the practical right to challenge the result. If the NDIS adopts computer-generated planning, rigid assessment instruments or formula-driven budgets, participants must retain a real right of appeal. Not a procedural loop. Not a reassessment by the same agency using the same tool. A real merits review, with power for an independent tribunal to correct the funding decision.
Public reporting of Senate estimates evidence indicates that, under new framework planning, most NDIS participants may lose the ability to externally appeal the total funding amount in their plan. NDIA executives reportedly confirmed that the Administrative Review Tribunal would not be able to alter a plan or reinstate funding, but would only be able to send the matter back to the NDIA for reassessment. When Senator Jordon Steele-John asked whether the total funding amount would no longer be a reviewable decision, the response reported was: “That’s correct, senator.” (The Guardian)
That is not a minor technical change. It removes the remedy.
A participant may still be told they have “review rights,” but if the tribunal cannot change the funding amount, cannot substitute a correct decision, and cannot reinstate supports, the right is hollow. A right to be sent back through the same assessment machinery is not an appeal. It is administrative recycling.
The risk is even more serious when combined with automated or computer-generated planning. The NDIS has stated that new framework planning will use a new support needs assessment process and budget method, with rollout delayed until 1 April 2027 to allow more consultation, testing and transition detail. (NDIS) Public reporting has also said plans may be generated by a computer program with NDIA staff having no discretion to amend the generated budgets, and that the ART would only be able to return cases for reassessment rather than alter funding directly. (The Guardian)
That creates a dangerous governance model: automated assessment, limited human discretion, and reduced independent correction.
A wrong human decision can harm one participant. A wrong assessment formula can harm thousands.
This is not theoretical. NDIS participants are not a uniform population. Disability support needs are complex, fluctuating and highly contextual. A person may appear more capable because family support is masking need. A participant may perform well in a structured assessment but fail in ordinary daily life. A tool may underweight sensory regulation, communication, behavioural risk, carer burnout, informal support collapse, trauma, housing instability, or the cumulative effect of multiple disabilities.
If that tool produces a budget that is too low, the participant must be able to challenge the outcome effectively. The tribunal must be able to look at the evidence and change the plan. Anything less is not procedural fairness.
The official consultation material says participants will keep review rights, and that reviewers or the ART will consider whether the support needs assessment accurately captured the person’s disability support needs. (Citizen Space) But that does not resolve the core problem. If the tribunal can only test the inputs and send the matter back for recalculation, rather than determine the funding required, then the participant is trapped inside the same framework. The legal form of review remains, but the practical power of review is weakened.
This goes against the basic democratic principle that government decisions affecting a person’s life, liberty, dignity, safety and participation must be open to independent review. NDIS plans decide whether people can shower, eat, communicate,
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leave home, work, study, avoid institutionalisation, maintain relationships, and live safely. These are not ordinary administrative payments. They are life-structure decisions.
The Senate should not allow critical budget settings to be hidden inside assessment tools, budget methods, rules, incorporated documents or automated systems that Parliament, participants and advocates cannot properly scrutinise. If the formula determines the funding, the formula is the decision. It must be transparent.
Key risks
Risk Why it matters
Loss of effective appeal A review right is hollow if the tribunal cannot change the funding decision.
Reassessment loop Sending a participant back to the same agency using the same tool may reproduce the same error.
Opaque formulas Participants cannot challenge a budget if they cannot see how it was calculated.
Automated error at scale A flawed tool can underfund entire cohorts, not just individual participants.
Reduced human Complex needs may be missed if staff cannot depart from the tool’s output. discretion
Evidence sidelined Clinical, functional and family evidence may be outweighed by assessment scores or formula rules.
Informal support Tools may treat family compensation as participant capacity, reducing funding unfairly. distortion
Increased downstream Underfunding leads to crisis, complaints, reviews, hospitalisation, carer collapse and future costs reassessment costs.
Weakening external merits review undermines procedural fairness and democratic accountability
External merits review is not a fringe safeguard in the NDIS. It is a major accountability mechanism used by thousands of participants each year. External review applications rose from 1,220 in 2018–19 to 7,935 in 2024–25. The ART reported that NDIS lodgements in 2024–25 increased by 95% from the previous year, with 5,839 NDIS cases on hand at 30 June 2025. In the same year, 6,141 lodgements were plan-related and 1,794 were access-related, showing that the majority of external disputes concern plan decisions, not merely entry to the Scheme.
This matters because appeal rights are not symbolic. The ART reported that 71% of NDIS cases finalised in 2024–25 were finalised by consent. That means the review process operates as a practical correction mechanism. Many cases resolve because the evidence, negotiation or tribunal process changes the outcome before hearing. If the new framework prevents participants from appealing the total funding amount, or prevents the Tribunal from substituting the correct funding decision, the reform removes a working accountability safeguard from a system already producing thousands of disputed decisions each year.
The Senate should read this data as a warning. If thousands of participants already need external review to correct access and plan decisions, then moving to computer-generated budgets, rigid support needs assessments and reduced tribunal powers will not reduce error. It will scale error. It will also redirect unresolved disputes into complaints, reassessments, advocacy demand, political pressure, family crisis and court-adjacent administrative churn. A reform that weakens appeal rights does not make the Scheme more efficient. It makes incorrect decisions harder to correct. I could not verify a consistent public annual series for all access applications received. The NDIA quarterly dashboards report June-quarter access decision
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volumes, including 26,943 in June 2020, 25,935 in June 2021, 25,717 in June 2022, 31,263 in June 2023, 16,274 in June 2024 and 33,700 in June 2025.
This chart compares NDIA access decision workload with external merits review applications lodged with the AAT/ART. The NDIA line uses access decisions made in the June quarter of each financial year, not annual access applications received, because a consistent public annual series for all access applications received was not verified. The external review line shows AAT/ART applications lodged across each financial year. The rise to 7,935 external review lodgments in 2024–25 shows that independent review is a major accountability mechanism, not a marginal safeguard.
Source notes: NDIA line uses access decisions made in the June quarter of each financial year, not annual access applications received. A consistent public annual series for all access applications received was not available. External review line shows AAT/ART external merits review applications lodged in the financial year.
External merits review applications rose from 1,220 in 2018–19 to 7,935 in 2024–25. This demonstrates that independent review is a major accountability mechanism in the NDIS, not a marginal safeguard. Any reform that restricts participants’ ability to challenge funding outcomes must be assessed against this existing demand for review.
Recommendation: Participants must retain the right to meaningful merits review of their funding. The Administrative Review Tribunal must retain power to vary, substitute or correct funding decisions where the evidence shows the plan is inadequate. All assessment tools, budget formulas, weighting rules, cohort definitions, incorporated documents and automated decision processes must be public, independently validated, disability-tested and disallowable by Parliament.
In summary, Risk 15 is a procedural fairness and democratic accountability risk. The NDIS must not become a system where a computer-generated budget determines a person’s life, while the participant is denied an effective independent remedy. If the government uses automated tools to set funding, then transparency, human discretion and a full merits review rights are not optional safeguards. They are the minimum standard in a democracy.
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5.16 - RISK 16: Treatment-first and theoretical mainstream service substitution
Basic failure of public administration
A support must not be refused because another service theoretically exists. A referral is not a support. A waitlist is not a support. A GP care plan is not a support. A state service that is underfunded, unavailable, unaffordable, geographically inaccessible, clinically inappropriate or not legally responsible for meeting the disability need is not a real substitute for NDIS funded support.
The Bill and associated reform material create a serious risk that participants will be denied access to, or funding from, the NDIS because medical treatment, compensation, health, education, housing, state disability, mental health, community health or another mainstream pathway is said to exist. The Department’s fact sheet says Part 9 clarifies where a person is not eligible for the NDIS if they access other service systems, including where applicants are eligible for or accessing workers’ compensation or motor vehicle accident scheme supports for relevant impairments. Public reporting has also identified a proposed “treatment-first” access pathway, requiring people to exhaust “all appropriate” treatment options before qualifying for NDIS access.
That approach may sound administratively tidy, but it is dangerous in real life. Disability support and medical treatment are not the same thing. Treatment may reduce pain, stabilise symptoms, improve mobility, address mental health, or support recovery. But treatment does not necessarily remove the functional impact of disability. A person may complete physiotherapy and still need personal care. A person may attend psychology and still require psychosocial recovery support. A child may receive paediatric care and still need communication support. A person with neurological disability may exhaust treatment and still need help with mobility, continence, transport, meals, behaviour, executive function, community access or supported decision-making.
The old risk register already identified this as a major legal tripwire: a person should not be required to exhaust “all appropriate treatment” where treatment is unaffordable, unavailable, geographically inaccessible, clinically inappropriate, traumatising, on a long waitlist or unlikely to remove substantial functional impairment. It also warned that supports should not be excluded merely because another scheme theoretically exists. The real test is to see if that scheme is actually available, timely, funded, enforceable, accessible and capable of meeting the support need.
Mainstream service substitution risk
The same problem applies to mainstream service substitution. Governments may point to health, education, housing, mental health, child development, compensation or community services as alternatives. But many of these systems are already under capacity, rationed, waitlisted, geographically uneven and not designed to provide ongoing disability support. If the NDIS refuses support because another system exists “in theory,” the participant may be left with no service in practice.
This creates a false economy. The Commonwealth may reduce NDIS expenditure by saying another system should pay. But if that system is not funded or legally required to provide the support, the cost is not solved. It is shifted. It may reappear as emergency department presentations, school exclusion, homelessness, mental health crisis, family breakdown, unpaid care, justice contact, income support reliance, or future NDIS re-entry at higher intensity. This repeats the core problem identified throughout this submission: the reform measures the saving, but not the displaced cost.
The risk is especially high for people with complex, interacting or poorly understood needs: psychosocial disability, autism, intellectual disability, acquired brain injury, chronic illness, neurological disability, trauma, complex communication needs, fluctuating conditions, rare disability and people in regional or remote areas. These participants are often told to move between systems. Health says it is disability. Disability says it is health. Education says it is behaviour. Housing says it is support. Mental health says it is social care. The participant is left carrying the gap.
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Administrative rationing risk
The treatment-first approach also risks turning access to disability support into a test of money, geography and advocacy capacity. A person who can afford private treatment, obtain reports, travel to specialists and wait months for appointments may be able to prove they have exhausted treatment. A person without money, transport, literacy, family support, digital access or clinical availability may fail the test, not because their disability is less significant, but because the evidence pathway is harder to complete. That is not equity. It is administrative rationing.
The Senate should also reject any assumption that treatment must be attempted where it is unsafe, unsuitable or disproportionate. For some people, repeated treatment requirements can be traumatising, clinically inappropriate or futile. A participant should not be forced through cycles of therapy, medication, surgery, psychological intervention or rehabilitation merely to prove that their disability remains permanent enough for support. The test should be functional reality, not bureaucratic exhaustion. The core issue is whether the alternative service is real.
Claimed alternative pathway Risk if treated as a substitute for NDIS support
Medical treatment May be unavailable, unaffordable, clinically unsuitable, traumatising, waitlisted or unable to remove functional impairment.
Medicare / GP care plans Limited session models do not replace ongoing disability support, therapy implementation, personal care or daily living assistance.
Community health Often waitlisted, geographically uneven and not designed to provide long-term disability support.
Education systems Schools provide educational adjustments, not full disability support across home, community, transport and daily living.
Housing systems Housing programs do not replace personal care, tenancy support, behaviour support or supported decision-making.
Mental health services Clinical treatment does not replace psychosocial recovery, daily support, community access or functional assistance.
Workers compensation / motor accident May be narrow, contested, time-limited, adversarial or limited to specific impairments. schemes
State disability / foundational supports May be capped, block-funded, rationed, waitlisted or unavailable in thin markets.
Family and informal supports Not enforceable, not guaranteed, not always safe, sustainable, willing, trained or nearby.
The correct safeguard is simple. No NDIS support should be refused because another pathway exists unless that pathway is actual, timely, funded, accessible, enforceable and capable of meeting the participant’s functional need.
Referral loop risk
This should apply to both access and planning. It is not enough to say a participant can “try health,” “ask the school,” “use Medicare,” “go to community health,” “seek compensation,” or “access family support.” The decision-maker should be required to identify the alternative service, confirm that it is available within a reasonable timeframe, confirm that it is funded, confirm that the participant can access it, and confirm that it will meet the disability-related support need. If that cannot be shown, NDIS support should not be refused.
The same test should apply to treatment. Treatment should only affect NDIS eligibility or funding where it is actually available, clinically appropriate, affordable, accessible, not harmful, and likely to materially improve functional capacity to
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the point that NDIS-funded support is no longer required. Treatment should not become a barrier to support where it merely manages symptoms, produces partial improvement, or leaves substantial functional impairment.
Recommendation: The Senate should require a statutory “actual service” test before NDIS access or support is refused on the basis of treatment or another service system.
NDIS support should only be refused where the alternative pathway is:
- actually available;
- timely;
- funded;
- geographically accessible;
- affordable;
- clinically appropriate;
- legally or practically enforceable;
- capable of meeting the disability-related functional need; and
- sufficient to prevent harm, decline, crisis or unreasonable reliance on unpaid care. Treatment-first rules should also be limited by a functional safeguard: treatment should only affect access or funding where it is likely to materially improve the impairment’s functional impact to the point that the person no longer requires NDIS support.
In summary, this is an interface and human rights risk. The NDIS must not become a system that refuses real support because another service exists on paper. A theoretical pathway is not a safeguard. If health, education, housing, compensation, community health or state services are not actually available, timely, funded and capable of meeting the person’s disability-related need, then using them to deny NDIS support is not reform. It is abandonment by referral.
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5.17 - Risk 17: Market consolidation and loss of participant choice risk
The risk concerns the danger that the reforms do not simply regulate the NDIS market, but reshape it into a smaller, more centralised, government-controlled provider system. Mandatory registration, plan-management panels, commissioned support coordination, tighter payment controls, ministerial pricing and provider-compliance burdens may consolidate the market into fewer larger providers. That may look administratively cleaner, but it risks destroying the very thing the NDIS was created to deliver: participant choice and control.
Before the NDIS, Australia’s disability support system was widely recognised as failing. The Productivity Commission described the pre-NDIS system as “underfunded, unfair, fragmented, and inefficient” and said it gave people with disability “little choice” and “no certainty” of access to appropriate supports. That is the historical baseline. The NDIS was not created merely to increase funding. It was created to replace rationed, provider-controlled, state-based systems with individualised funding and participant-directed choice.
The NDIS has since created a large decentralised market. The NDIS Review reported a system with more than 610,000 participants, more than 16,000 registered providers, more than 154,000 unregistered providers, and more than 325,000 workers. The Government’s own later analysis identifies a far larger current market: over 260,000 NDIS providers, with only 7% registered with the NDIS Commission. The current submission also records approximately 276,000 active providers in the December 2025 quarter, including 111,000 SCCP providers, 100,800 unregistered SCCP providers, and around 56,000 SCCP providers delivering supports to only one participant.
That data matters. It shows the NDIS is not delivered by a small number of large institutions. It is delivered through a mixed ecosystem of registered providers, unregistered providers, sole traders, microbusinesses, family-led arrangements, allied health professionals, plan managers, support coordinators, support workers and local community providers. This is not a side feature of the Scheme. It is the practical mechanism by which participants escape dependency on a single service, a single organisation, a single group home, a single roster, or a single provider culture.
Market consolidation threatens that mechanism.
Mandatory registration may improve visibility and safeguards. That objective is legitimate. Abuse, neglect, exploitation, fraud and poor-quality services must be addressed. The Disability Royal Commission made 222 recommendations to improve laws, policies and systems so people with disability can live free from violence, abuse, neglect and exploitation. The NDIS Code of Conduct also states that participants have the right to safe and ethical supports. Safeguards are necessary. But safeguards must not be designed in a way that destroys choice, thins local markets, and forces participants into a smaller pool of approved providers.
Safety regulation is not the same thing as market restriction
A participant who has experienced abuse, neglect, coercion, poor care, restrictive practices, cultural disrespect, sexual misconduct, financial exploitation or unsafe personal care needs the ability to leave that provider. Choice is a safety mechanism. It is how a participant exits harm. It is how a family avoids a negligent service. It is how a person with complex communication needs finds a worker who understands them. It is how a woman requiring intimate care chooses a worker she feels safe with. It is how an autistic person avoids providers who cause sensory distress or behavioural escalation. It is how people in group homes, SIL settings or thin markets resist being trapped inside provider-controlled arrangements.
If reforms reduce the number of available providers, the participant’s “choice” becomes theoretical. A right to choose from one provider is not choice. A right to complain after harm occurs is not the same as the ability to leave before harm escalates.
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There is also an economic problem. Larger providers are more able to absorb registration costs, audit requirements, tendering, reporting, legal advice, HR systems, compliance staff and delayed payments. Small providers, sole traders and microbusinesses often cannot. If the compliance burden is not risk-proportionate, the reform will favour scale over quality. It may push out the local worker, the trusted sole trader, the small allied health practice, the niche provider, the culturally safe provider, the trauma-informed worker, or the person willing to service a thin regional market.
Market concentration is not efficient policy
The risk is sharper in plan management and support coordination. If plan management moves to panels, and support coordination is commissioned rather than purchased through participant plans, the participant loses direct purchasing power over the very services that help them navigate the Scheme. Plan managers and support coordinators are not neutral administrative extras. For many participants, they are the buffer between the person and Scheme complexity. They help detect billing problems, locate services, respond to provider failure, organise evidence, manage transitions, and keep supports running. If these functions are moved into government-selected panels or commissioned providers, participants may lose independence from the system they are trying to navigate.
That creates a principal-agent problem. Under participant-directed funding, the provider is accountable to the participant because the participant can leave. Under commissioned or panel-based models, the provider’s economic accountability shifts toward the government contract manager. The participant may still be called a “client,” but the provider’s survival depends on contract compliance, throughput, reporting and renewal. That can produce a system where services become easier for the government to manage, but harder for participants to control.
This is also where cronyism and procurement capture become real risks. The submission does not need to allege corruption. It only needs to identify the structural risk. When large contracts, closed panels and commissioned services replace open participant choice, the system becomes more vulnerable to insider access, tender advantage, lobbying power, large-provider dominance, and political preference in procurement design. Smaller providers may never get a fair chance to compete. Participants may never get a real chance to choose. In that environment, provider power can increase while participant power decreases.
The social consequences are serious. Market consolidation can increase isolation by reducing local, flexible and relationship based support. It can increase unemployment and underemployment by pushing sole traders and casual workers out of the Scheme. It can reduce private-sector and small-business growth by moving revenue from many small providers into fewer large organisations. It can make regional and rural markets thinner. It can weaken disability-led entrepreneurship. It can reduce participant safety by limiting exit options. It can also increase complaints and legal escalation if participants are trapped with unsuitable providers.
Reform mechanism Market consolidation risk
Mandatory registration May impose fixed compliance costs that larger providers can absorb but sole traders and microproviders cannot.
Plan-management panels May reduce participant choice and move market power to government-selected providers.
Commissioned support May remove a participant-directed service and replace it with contract-managed navigation. coordination
Digital payment controls May favour providers with administrative infrastructure and push out small providers unable to carry cashflow risk.
Ministerial pricing control May create politicised pricing pressure that reduces provider viability in thin markets.
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Reform mechanism Market consolidation risk
Civil penalties and record Necessary for fraud control, but may punish error, disability-related administration barriers obligations or small-provider incapacity if not proportionate.
Provider procurement May favour large organisations with tender-writing capacity and create risks of market capture or cronyism.
Reduced participant May reduce purchasing power, making small specialised providers commercially unviable. budgets
The Senate should be especially alert to the abuse and neglect dimension. The answer to abuse is not to trap participants inside fewer provider options. The answer is stronger safeguarding with preserved exit rights. The NDIS Quality and Safeguards Commission itself recognises that reportable incidents include death, serious injury, abuse or neglect, unlawful sexual or physical contact, sexual misconduct and unauthorised restrictive practices. These are not abstract risks. They are the types of harm that make participant choice and provider exit essential.
A centralised provider market may also recreate some of the failures the NDIS was designed to overcome. Before the NDIS, people with disability often had to accept what the state-funded or block-funded system offered. The Productivity Commission identified that system as fragmented and offering little choice. If reforms now move participants back toward panels, commissioning, block-like access pathways and approved-provider pools, the Scheme risks returning to the old model by administrative stealth.
Fewer providers does NOT mean better providers
The Senate should not confuse fewer providers with better providers. A smaller market is not automatically a safer market. A registered provider can still be poor quality. A large provider can still neglect people. A commissioned provider can still fail. A panel provider can still be unsuitable. Conversely, a small provider or sole trader may be the safest, most trusted and most effective support in a participant’s life.
The correct policy test is not whether government has more control over the market. The correct test is whether participants retain practical access to safe, suitable, local, culturally appropriate, trauma-informed and person-centred supports.
Required safeguards: Before implementing mandatory registration, plan-management panels, commissioned support coordination or provider-market restrictions, the Commonwealth should publish a market-consolidation impact assessment. That assessment should model:
Required modelling Why it is needed
Provider exits by business size To identify impacts on sole traders, microproviders, small allied health practices and family-run businesses.
Thin-market effects To prevent reforms leaving regional, rural, remote and low-density communities with no practical provider choice.
Participant choice loss To measure how many participants will lose current providers or be forced onto panels or commissioned services.
Abuse and neglect exit pathways To ensure participants can leave unsafe providers immediately and access alternatives.
Small-business and employment To quantify job loss, underemployment, business closures, tax loss and reduced local impacts spending.
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Required modelling Why it is needed
Plan manager and support To assess whether panels and commissioning reduce independence, conflict coordinator consolidation management and participant advocacy.
Procurement concentration To prevent large-provider dominance, tender capture and cronyism risk.
Quality versus access trade-off To ensure regulation improves safety without destroying real access.
Recommendation: Fraud-control, registration and commissioning reforms must be proportionate, risk-based and designed to preserve participant choice. The Senate should require safeguards that protect legitimate sole traders, microproviders, plan managers, support coordinators, allied health practices and small community providers. Participants must retain the right to choose, reject and change providers, especially where supports involve intimate care, behaviour support, communication, psychosocial safety, cultural safety, trauma history, family violence risk, or prior abuse and neglect.
The Government should not implement provider panels, commissioned navigation or mandatory registration in a way that reduces participants to a list of approved suppliers. Any provider reform must include participant exit rights, emergency provider-change pathways, independent advocacy, thin-market protections, small-provider transition funding, and public reporting on provider exits, market concentration, complaints, reportable incidents and service gaps.
In summary, this analysis demonstrates there is significant risk to choice, safety and market-structure. The NDIS was created because the old disability system was fragmented, rationed and gave people little choice. A reform that consolidates the market into fewer larger providers may reduce administrative complexity for government, but it can also reduce participant power, small-business viability, local flexibility, abuse escape routes and real service access. Fraud control must not become market consolidation by another name. Choice and control are not luxuries in disability support. They are safeguards against isolation, neglect, coercion and institutional capture.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
- Economic impact analysis: what the Government has not modelled
The central economic flaw in the reform package is that the Government has measured the saving at the point where money leaves the NDIA, but has not measured the cost at the points where unmet need reappears. A dollar removed from a participant’s plan does not vanish. It moves into unpaid care, provider income loss, school adjustments, community health waitlists, hospital presentations, Centrelink payments, lost tax receipts, reduced workforce participation, delayed child development and future NDIS re-entry. Until those costs are modelled, the claimed $37.8 billion saving is not a net public saving. It is an incomplete ledger.
The Government’s fiscal case is therefore only half an economic analysis. The Budget identifies the Commonwealth saving, but the public material does not transparently quantify the wider effects on GDP, employment, tax revenue, small-business viability, provider exits, unpaid care, state systems, schools, hospitals, housing, justice, mental health, community health, or future NDIS demand.
The Central Evidentiary Failure of the Reform Package
The Office of Impact Analysis itself acknowledges that a more qualitative multi-criteria approach was used because of the complexity involved in deriving a monetised net benefit. That admission matters. If the net benefit cannot be monetised with confidence, the Parliament should not treat the Budget saving as if it represents the net national effect. A saving to the NDIA is not necessarily a saving to Australia.
Disability support is not passive expenditure. It is an economic input. NDIS funding flows into wages, sole traders, microbusinesses, allied health practices, support workers, therapy assistants, plan managers, support coordinators, transport providers, equipment suppliers, software, insurance, administration, training organisations, rent, vehicles, fuel, payroll systems and local spending. It also enables participants and unpaid carers to remain connected to employment, education, family life and community participation.
Instead of asking “How much will the NDIA save?” the Senate Inquiry should be asking “Where does the cost reappear, who carries it, and does the reform reduce total public cost after those effects are counted?”
6.1 The Missing Net-Public-Cost Model
The Government has identified a $37.8 billion Budget saving over four years. That figure is material. But it is not a net-public cost model. A net-public-cost model should include:
Economic channel What should be modelled
GDP and economic activity Reduced economic activity from lower participant-directed spending, provider income and household consumption.
Employment and Lost shifts, reduced billable hours, sole-trader income loss, provider closures, allied-health underemployment caseload loss and graduate underemployment.
Tax receipts Reduced income tax, company tax, GST-linked consumption, PAYG withholding and superannuation contributions.
Provider-market viability Exits among sole traders, microproviders, small allied-health practices, plan managers, support coordinators and regional providers.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Economic channel What should be modelled
Participant workforce Reduced ability of participants to work, study, attend appointments and participate in the participation economy.
Carer workforce Increased unpaid care reducing paid work, income, superannuation and tax contributions, participation especially for women.
State-system impacts Additional demand on schools, childcare, community health, GPs, housing, mental health, child protection and justice.
Future NDIS costs Higher future support needs where early intervention, capacity building or daily support is reduced too early.
Administrative churn More reassessments, complaints, evidence disputes, payment suspensions, advocacy demand and tribunal-related costs.
Without this modelling, the Parliament is being asked to legislate a major fiscal contraction without knowing whether the saving is real, or merely displaced into less visible systems.
6.2 Per Capita sensitivity and Why the Exposure is Too Large to Ignore
Per Capita’s modelling has been used in this submission as a sensitivity calculation, not as a Treasury forecast. That distinction is important. The purpose is not to assert that every dollar of proposed saving will produce a fixed economic loss. The purpose is to show that the potential exposure is large enough to require government modelling before reform proceeds.
Using Per Capita’s estimate that every $1 of NDIS underfunding may reduce economic activity by approximately $2.25:
Measure Calculation Interpretation
Published Budget saving $37.8b over four years Budget 2026–27
Per Capita economic activity $2.25 per $1 underfunded Sensitivity onlysensitivity
Mechanical activity exposure $37.8b × 2.25 = $85.05b Illustrative exposure, not forecast
Jobs sensitivity 10,200 jobs per $1b Sensitivity onlyunderfunding
Mechanical employment exposure 37.8 × 10,200 = 385,560 jobs Illustrative job-equivalent exposure, notforecast
The point is not that exactly 385,560 jobs will be lost. The point is that the reform package is large enough to plausibly affect employment, GDP, tax receipts, provider viability and household income at a scale that Parliament should not ignore.
If the Government disputes the Per Capita sensitivity, it should publish its own Treasury-level macroeconomic model.
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6.3 Labour-market and underemployment effects
The disability sector is labour-intensive. A reduction in participant-directed funding does not only reduce Scheme outlays; it reduces funded hours.
The first labour-market effect may not appear as headline unemployment. It may appear as underemployment. Support workers lose shifts before they lose jobs. Sole traders lose clients before they close businesses. Allied health professionals lose billable hours before they leave the sector. Therapy assistants, support coordinators and plan managers may remain technically employed while losing income, caseloads and viability.
That matters because official unemployment data can understate the harm. A worker who loses 30 or 40 per cent of their weekly hours is not recorded as unemployed, but their rent, mortgage capacity, tax contribution, superannuation, household spending and economic security are materially affected.
The Government’s assumption that workers can move into other parts of the care economy is too broad. A national care sector shortage does not mean a local disability worker can automatically move into aged care, hospitals, childcare or health. Different roles require different qualifications, risk profiles, rosters, physical demands, supervision models, pay structures and work conditions. A regional town can experience disability-sector labour oversupply even where a national workforce model shows unmet demand elsewhere.
The Senate should require labour-market modelling at the level where the harm will occur: local markets, thin markets, small providers, sole traders, casual workers, allied-health graduates and regional workforces.
6.4 Provider-market failure and market consolidation
The NDIS has created a decentralised provider market. That market is not made up only of large institutions. It includes sole traders, microbusinesses, support workers, allied health practices, plan managers, support coordinators, therapy assistants, transport providers, equipment suppliers, community organisations and family-led arrangements.
This matters because small providers do not have unlimited reserves. When participant budgets fall, provider revenue falls immediately. When digital payment systems delay claims, cashflow weakens. When mandatory registration, audits, panels, commissioning and civil penalties increase fixed costs, larger providers are more able to absorb the burden than sole traders or microproviders.
Market consolidation risks provider exit, small-business failure and GDP loss
A smaller, more centralised provider market may be easier for government to administer, but it may be worse for participants. Choice and control are not luxuries. They are safeguards. They allow a participant to leave an unsafe provider, find a culturally appropriate worker, choose a person they trust for intimate care, avoid coercive or neglectful services, and access flexible support in thin markets.
Fraud control is necessary. But fraud control must not become market consolidation by another name
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
A proper economic model must quantify:
Provider-market question Why it matters
How many sole traders and microproviders are To measure likely exits from compliance cost, payment delay and exposed? reduced demand.
How many participants rely on single-worker or To identify continuity and safety risks. small-provider arrangements?
What happens in thin markets if small providers To prevent “choice” becoming theoretical. leave?
How will plan-management panels affect existing To assess market concentration and participant choice loss. plan managers?
How will commissioned support coordination affect To assess whether navigation becomes accountable to government independence? contracts rather than participants.
What happens to abuse-exit pathways? To ensure participants can leave unsafe providers quickly.
6.5 Allied-health and early-intervention market contraction
The reform also creates a specific risk to early-intervention and paediatric allied-health markets.
Children aged 0–8 are a large NDIS cohort and a major source of demand for speech pathology, occupational therapy, psychology, physiotherapy, developmental education, behaviour support, therapy assistants and allied-health assistants. If individualised early-childhood funding is reduced or redirected into a capped model, the effect will flow directly into paediatric allied-health caseloads.
This is not a simple shift from one funding stream to another. Paediatric allied health is a specialised human-capital market. Clinicians require training, supervision, experience, therapy resources, child-development knowledge, family trust, childcare and school relationships, and local referral networks. Small practices often train graduates and provide supervision pathways. If demand falls suddenly, practices may stop taking graduates, reduce staff, close books, shift away from disability work or leave the market.
The reform risks weakening the workforce needed to deliver early intervention
Government policy has spent years encouraging care and allied-health workforce growth to meet NDIS demand. A reform that reduces the demand base without modelling the graduate pipeline, supervision capacity, small-practice viability and regional workforce supply risks wasting public training investment.
The Senate should require an early-intervention market impact model before any reduction or redirection of individualised early-childhood NDIS funding.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
6.6 Unpaid care and family labour transfer
The unpaid care system is already carrying enormous load. ABS data cited in this submission shows 3.0 million carers in 2022, 1.2 million primary carers and substantial rates of self-care, mobility, communication, bathing, dressing, transfers and toileting support being provided by unpaid carers.
Unpaid labour is not a cost saving
When funded support is reduced, the fallback workforce is not “the community.” It is usually parents, partners, siblings, adult children, grandparents and exhausted families. Often it is women.
This has direct economic consequences. More unpaid care can mean fewer paid work hours, lower household income, lower tax receipts, reduced superannuation, greater mental health strain, higher carer payment reliance, increased family stress and reduced participant independence.
This is especially serious where the support is intimate or high intensity: showering, toileting, dressing, continence, transfers, medication prompting, communication support, behaviour support, supervision and 24/7 daily living assistance. Shifting these supports to families is not fiscal discipline. It is unpaid labour extraction.
A Budget model that counts reduced NDIS payments but does not count increased unpaid care is not an economic model. It is an accounting device.
6.7 Mainstream and state-system cost shifting
The reforms rely heavily on the assumption that other systems can absorb need: schools, childcare, community health, GPs, Medicare, mental health, housing, compensation schemes, state disability services and foundational supports.
The NDIS reform is based on untested assumptions and incomplete modelling
A theoretical service is not a support. A referral is not a support. A waitlist is not a support. A GP care plan is not a substitute for ongoing disability support. A school adjustment is not a replacement for personal care, communication support, behaviour support or therapy implementation. A mainstream service that is unavailable, unfunded, unaffordable, geographically inaccessible, clinically inappropriate, waitlisted or unenforceable cannot be used to justify removing NDIS support.
This is a whole-of-government fiscal risk
If the NDIS reduces support and the need reappears in schools, childcare, community health, housing, mental health, justice, child protection, Centrelink or hospitals, the Commonwealth has not saved money. It has shifted the cost to another ledger.
The Senate should require an “actual service” test before NDIS support is refused on the basis that another system exists. The alternative service must be actual, timely, funded, accessible, enforceable and capable of meeting the participant’s functional need.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
6.8 Schools, childcare and community health as receiving systems
The child-related reform risks show this problem clearly.
Schools are already carrying a large disability-adjustment load. Childcare is already a high-participation system. Community health access is uneven, especially outside major cities. If children under 9 lose individualised NDIS-funded support, their developmental needs will not disappear. They will move into classrooms, childcare centres, GP clinics, community health waitlists and family homes.
Group programs, parenting advice and supported playgroups may help some children. They do not replace practical in-home and community implementation support when a child is dysregulated at 7.30am, refusing childcare, unsafe in a car park, unable to tolerate the supermarket, or melting down before school.
The reform funds instruction, but not implementation
If parent education or group-based support does not come with practical support in the settings where disability affects daily life, the cost shifts to parents, teachers, childcare staff, GPs and state systems. That is not early intervention. It is cost transfer.
6.9 Digital payment and cashflow shock
The proposed digital payment system poses an economic risk.
A digital payment system may improve payment integrity, but if it blocks or delays legitimate claims, it creates a cashflow shock. Support workers may not be paid. Sole traders may lose weekly income. Therapy clinics may carry unpaid invoices. Small providers may stop accepting NDIS clients because they cannot absorb repeated payment delays, evidence requests or claim suspensions.
The legislation now creates a statutory payment gate. If the CEO requests further information or documents about a claim, and the claimant does not provide them within the specified period, which must not be less than 14 days, the Agency must not pay the amount.
That may be justified for fraud control. But for legitimate services already delivered, it creates a direct risk to wages, business income and service continuity. A support worker who is not paid may not return. A small provider that cannot carry unpaid debt may exit. A participant relying on that provider may lose support immediately.
Payment integrity must therefore be modelled not only as fraud reduction, but as provider-market and participant-continuity risk.
6.10 Appeal, assessment and administrative churn
The reforms risk increasing administrative churn.
If new framework planning, support needs assessments, automated tools or formulas produce budgets that participants cannot meaningfully appeal, disputes will not disappear. They will move elsewhere: complaints, reassessments, advocacy services, ministerial correspondence, community legal centres, ART remittals, service breakdown, crisis escalation and public pressure.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
External merits review data shows that independent review is already a major accountability mechanism, not a fringe safeguard. If review rights are narrowed while automated or formula-driven planning expands, the Government may reduce the number of formal funding remedies while increasing unresolved need.
This is not efficiency. It is suppressed correction.
A wrong human decision can harm one participant. A wrong assessment formula can harm thousands. If the formula determines the funding, the formula is the decision. It must be transparent, reviewable and subject to independent correction.
6.11 Population growth is not disability demand
The submission should reject any crude comparison between NDIS growth and population growth.
Population growth does not measure disability prevalence, functional support need, diagnostic visibility, ageing carers, mainstream-system failure, rural access gaps, provider availability, child development demand, psychosocial need, or the cumulative effect of under-support over time.
ABS data cited in the current draft shows disability prevalence rose from 17.7% in 2018 to 21.4% in 2022. That does not automatically justify every dollar of Scheme growth, but it does show why population growth alone is a weak benchmark for disability demand.
A national disability insurance scheme should be driven by functional need, prevention and economic participation, not by a crude population cap.
6.12 What the Senate should require
Before the Bill proceeds, the Senate should require the Government to publish a full net-public-cost model. At minimum, that model should include:
Required modelling Purpose
Macroeconomic modelling GDP, employment, tax receipts, household consumption and regional economic effects.
Labour-market modelling Underemployment, job loss, allied-health graduate impacts, sole-trader income loss and Centrelink exposure.
Provider-market modelling Provider exits, thin-market failure, plan-manager consolidation, support-coordination commissioning and small-business viability.
Unpaid care modelling Additional unpaid care hours, lost carer wages, superannuation impacts, carer health and gendered economic effects.
State-system modelling Costs shifted to schools, childcare, community health, GPs, housing, justice, mental health and child protection.
Child-development modelling Impact of reduced early intervention, delayed supports, school readiness, family stress and future support intensity.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Required modelling Purpose
Digital-payment impact Claim rejections, payment delays, cashflow risk, provider exits and participant support modelling disruption.
Appeals and administrative Complaints, reassessments, ART remittals, advocacy demand and error-correction costs. modelling
Treatment and interface Whether alternative systems are actual, timely, funded, accessible and enforceable. modelling
Post-implementation harm Real-time reporting on unmet need, hospitalisations, provider exits, school exclusion, monitoring carer collapse and NDIS re-entry.
Conclusion
The fiscal case for the reform package is incomplete. The Government has identified where it expects the NDIA to spend less. It has not transparently modelled where the unmet need, lost income and displaced cost will reappear.
This is the central economic problem.
A reform that reduces NDIS outlays while increasing unpaid care, provider exit, labour underemployment, school pressure, community health waitlists, hospital presentations, Centrelink reliance, lost tax receipts and future NDIS re-entry is not a saving. It is a transfer.
The Senate should not pass reforms of this scale until the Government publishes a whole-economy, whole-of-government and whole-of-life impact model.
A sustainable NDIS must be fiscally responsible. But fiscal responsibility requires a complete ledger. At present, the ledger is incomplete. The saving is visible. The damage is not.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
- Disability cohort impact analysis: why uniform cuts create unequal harm
The proposed reforms will not affect all participants equally. A uniform budget rule can create very different real-world consequences depending on disability type, age, communication capacity, functional impairment, informal support, geography, housing arrangement, provider access and administrative capacity. The same reduction that appears modest in a spreadsheet may remove the support that keeps one participant safe, another employed, another child developing, another family working, and another person out of hospital.
This is why the Senate should not assess SCCP, CBDA, assessment changes, treatment-first rules, payment controls, appeal limits or foundational supports as generic administrative reforms. Each mechanism lands differently across cohorts. The relevant test is not whether the reform is uniform. The test is whether it is safe for the people most exposed to harm.
The current draft already identifies the core principle: the same percentage cut does not produce the same functional impact. For some participants, SCCP is the difference between isolation and community access. For others, CBDA is the mechanism through which therapy recommendations become daily-life skills. For others, reassessment access is the difference between stability and crisis.
The reforms should therefore be tested through cohort-specific functional impact, not only through budget category. A 50 per cent reduction to social, civic and community participation does not mean a 50 per cent reduction in leisure. For many participants, it means reduced access to routine, communication, behaviour support, supported employment pathways, psychosocial stability, community visibility and carer relief. A 10 per cent reduction to CBDA does not mean a small administrative trim. For children and participants with complex functional needs, it may mean losing therapy implementation hours from an already limited pool of support.
The Government’s own reform mechanisms create cohort-specific risk. The Bill and reform package include group-based support determinations, SCCP and CBDA budget resets, functional capacity assessment design, tighter reasonable and necessary criteria, treatment-first access settings, reliance on other service systems, limits on reassessment, suspension and revocation powers, claim timeframes, information-gathering obligations, provider registration, commissioning, digital payments and automated administrative decisions. These mechanisms interact. A participant may not be affected by one reform in isolation; they may be affected by several at once.
7.1 Cohort Exposure Matrix
Cohort Main reform exposure Functional and economic Required evidence andimpact safeguard
Autism and Thriving Kids, CBDA/SCCP cuts, Misclassification, school refusal, Autism-specific assessment
neurodevelopmental disability assessment tools, group communication delay, validation; use home, school
supports. sensory/executive dysfunction, and family evidence; nofamily burnout; costs shift to unsuitable group substitution. families, schools and mental health.
Developmental delay / early Thriving Kids, CBDA cuts, state- Lost developmental window, No child loses support until
childhood system substitution. reduced parent coaching, funded, local, accessible anddelayed speech, motor, self- enforceable alternatives care and regulation skills; costs operate. shift to parents, childcare, schools and future NDIS.
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Cohort Main reform exposure Functional and economic Required evidence andimpact safeguard
Intellectual disability SCCP cuts, automation, appeal Skill regression, exploitation Easy Read, supported decision-
barriers, provider risk, isolation and reduced making, advocacy, continuity
consolidation. supported decision-making; safeguards and human review.costs shift to families and safeguarding systems.
Psychosocial disability SCCP cuts, treatment-first rules, Relapse, hospitalisation, No blanket SCCP reset without
reassessment limits. homelessness, police contact, recovery-oriented individualcarer distress; community assessment and actual-service participation is recovery testing. infrastructure.
Visual impairment SCCP cuts, transport/interface Unsafe community access, Protect orientation, mobility,
rules, provider restrictions. isolation, reduced transport and communityindependence and family access supports. transport burden.
Down syndrome SCCP/CBDA cuts and Reduced communication Cohort-specific modelling and
employment pathway risk. opportunities, supported protection for communicationemployment readiness, social and employment supports. participation and family respite.
Complex physical disability / CP Personal care, AT, transport, Reduced mobility, pressure Assess through health-
/ SCI therapy and SCCP reductions. injury risk, carer injury, prevention and participationisolation, health decline and lens; protect personal care, AT, loss of work/study access. transport and therapy implementation.
Acquired brain injury Reassessment limits, executive- Missed deterioration, ABI-informed assessment,
function barriers, automation. behavioural escalation, family executive-functionbreakdown, debt or support accommodations and rapid loss. reassessment pathway.
Progressive neurological Rigid planning and Delayed response to decline, Guaranteed rapid plan variation
conditions reassessment limits. falls, hospitalisation and carer for deterioration and episodiccollapse. decline.
Hearing / communication Inaccessible notices, Missed deadlines, exclusion, Accessible communication
disability automation, appeal barriers. debt, support loss and inability before adverse action: Auslan,to challenge decisions. captioning, interpreters, Easy Read, alternative contact and human review.
First Nations participants Evidence burden, geography, Underutilisation, distrust, Co-designed culturally safe
cultural safety and thin service gaps and cost shifting to pathways, local service
markets. families/community-controlled mapping and no substitutionservices. without actual access.
CALD participants Language barriers, evidence Misassessment, under-claiming, Interpreting, translated
burden, navigation. reduced culturally safe support materials, advocacy andand inability to challenge culturally appropriate decisions. assessment.
SIL/SDA and congregate SCCP cuts and provider Housing becomes containment; Protect community access,
settings consolidation. reduced community visibility independent advocacy,and abuse-exit options. provider exit pathways and incident monitoring.
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Cohort Main reform exposure Functional and economic Required evidence andimpact safeguard
Executive-function disability Claim windows, records, digital Missed deadlines, payment Reasonable adjustments,
payments, suspension. failure, debt and support loss reminders, nominee contact,caused by disability-related longer timeframes and administration barriers. supported human follow-up.
24/7 and intimate-care Personal care funding, family Loss of hygiene, privacy, bodily Exempt high-risk and
participants substitution and provider autonomy, safety and dignity; continuous supports; count
restrictions. unpaid family care and hospital informal care only if voluntary,risk increase. safe, trained, proximate and chosen.
Regional, rural and thin-market Provider exit, registration A pathway on paper becomes Thin-market continuity plans,
participants burden, payment delays, state no service in town; travel, provider-exit modelling and
substitution. family burden and provider rural service guarantees.closure increase.
This table should not be read as exhaustive. Its purpose is to show that reform harm is not evenly distributed. Participants with communication barriers, fluctuating disability, cognitive disability, limited informal support, regional access barriers or high reliance on community access supports face different risks from participants with stable conditions, strong advocacy, metropolitan provider access and family support.
7.2 Autism and Neurodevelopmental Disability Cohort
Autistic children, young people and adults are exposed to multiple reform pathways at once: access tightening, functional capacity tools, CBDA reductions, SCCP cuts, Thriving Kids diversion, treatment-first assumptions, school-system cost shifting and evidence burden. The current draft already identifies this cohort as exposed because their needs are functional, sensory, communication, behavioural and executive-function based, rather than easily captured by diagnosis alone or a brief assessment.
The scale of exposure is significant. As already used in this submission, the March 2026 NDIA data shows autism as the largest primary disability group, with 338,099 active participant plans, or 44 per cent of all active plans. Children aged 0–8 accounted for 167,787 active plans, and children aged 0–14 represented more than 323,000 participants. This means autism and neurodevelopmental disability are not marginal to the Scheme. They sit at the centre of the reform impact.
The risk is misclassification. An autistic child may appear “low-to-moderate” because parents are already compensating heavily: managing sensory triggers, sleep, routines, school refusal, communication, therapy appointments and behavioural escalation. If that compensating labour is mistaken for low need, the child may be moved into lower-intensity group-based or capped support. The apparent saving is then achieved by shifting implementation burden to parents, schools, childcare and community health.
For autistic adults, the risk is different but just as serious. An adult may be articulate enough to describe policy or advocate for themselves, but still be unable to manage sensory load, executive functioning, community participation, budgeting, daily routines, employment transitions, social communication or crisis prevention without support. Advocacy capacity is not functional independence. Cognitive capacity is not daily-living capacity.
Required safeguard: autism-specific validation of assessment tools; protection of early intervention, transition supports, communication supports and sensory-regulation supports; mandatory consideration of school, family, home and daily-life
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
evidence; and no redirection into group-based or mainstream supports unless those supports are suitable, funded, accessible and effective.
7.3 Developmental Delay and Early Childhood Cohort
Children with developmental delay and young children requiring early intervention are highly exposed because CBDA is central to their plans. This submission already records that children aged 0–14 have higher CBDA reliance as a share of total supports and that the proposed 10 per cent CBDA reset is therefore not evenly distributed across age groups.
The earlier risk analysis gives the harder data: children aged 0–8 had CBDA funding at 100 per cent of participants in that age group, average CBDA funding of $9,900, and CBDA made up 69 per cent of their total committed supports. Children aged 9– 14 also had CBDA funding at 100 per cent of the age group, with average CBDA funding of $6,800 and CBDA representing 42 per cent of total committed supports. This means CBDA is not peripheral for children. It is often the main mechanism for speech, motor, sensory regulation, parent coaching, daily living skill development, behaviour strategy implementation and school readiness.
A 10 per cent CBDA cut therefore has a different meaning for children than for many adults. It may remove direct therapy hours, parent coaching, report implementation or carryover support during a critical developmental window. Reduced early capacity building can delay speech, motor planning, self-care, regulation, play, social communication and family routines. In economic terms, this is poor timing: early intervention is a human-capital investment. Cutting it early may increase later costs in schools, family support, child mental health, crisis response and future NDIS intensity.
Required safeguard: no child should lose early intervention, therapy implementation or developmental support until funded, accessible, enforceable and operational alternatives exist in the child’s actual location.
7.4 Intellectual Disability Cohort
People with intellectual disability rely heavily on routine, repetition, supported decision-making, accessible communication, trusted relationships, skill practice and community access. The current draft correctly identifies that cuts can increase isolation, exploitation risk, skill regression, transport barriers and dependence on family or group settings.
This cohort is particularly exposed to reforms that increase administrative complexity. Digital payments, evidence requests, strict timelines, automated contact, claim windows, appeal limits and reassessment rules can create harm where participants require Easy Read information, supported decision-making, nominee support or independent advocacy. A participant with intellectual disability should not lose support because the system communicates in a way they cannot access.
Provider choice is also a safety issue for this cohort. People with intellectual disability may be vulnerable to coercion, neglect, exploitation or service capture. A smaller provider market, fewer support coordinators or government-selected panels may reduce the ability to leave an unsuitable provider. Choice and continuity must therefore be treated as safeguarding mechanisms, not consumer preferences.
Required safeguard: Easy Read communication, supported decision-making, advocacy, accessible evidence processes, continuity safeguards, and no plan reduction without an individual functional impact assessment.
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7.5 Psychosocial Disability Cohort
Psychosocial disability is one of the clearest examples of why SCCP cannot be treated as leisure. The current draft notes that the Impact Analysis identifies psychosocial disability as a cohort with high SCCP reliance, with 30 per cent of total plan budgets committed to SCCP among affected participants.
For psychosocial participants, community participation may maintain routine, reduce isolation, support recovery, prevent relapse, provide social connection, sustain tenancy, support work readiness and reduce carer distress. Removing or reducing SCCP can increase isolation, hospital use, homelessness risk, police contact and crisis-system reliance. In this cohort, “social” support is often preventative mental health infrastructure.
Treatment-first rules are also high risk. A person with psychosocial disability may be told to exhaust treatment, but treatment may be unavailable, unaffordable, traumatising, on a long waitlist, or insufficient to resolve functional impairment. Clinical treatment does not replace recovery coaching, community participation, daily support, housing stability, routine building or practical assistance.
Required safeguard: exempt psychosocial supports from blanket SCCP resets unless a recovery-oriented individual functional assessment shows no harm; require actual-service testing before refusing NDIS support on the basis of health or mental health pathways.
7.6 Visual Impairment Cohort
This submission already records that visual impairment has the highest SCCP share among selected groups, at 34 per cent of total supports. This is a critical data point. It shows that a category-wide SCCP cut does not land equally. For people with visual impairment, community access may involve orientation, mobility, transport, unfamiliar environments, safety support, assistance navigating public spaces, communication, technology use and confidence outside the home.
Reducing these supports risks isolation, loss of independence, reduced employment participation, greater family reliance and safety risk. A person with visual impairment may need support not because they lack motivation, but because the built environment is inaccessible, transport is complex, and unfamiliar settings create real safety barriers.
Required safeguard: protect orientation, mobility, transport and community access supports from blunt group-based reductions.
7.7 Down Syndrome Cohort
This submission records that participants with Down syndrome have high average SCCP funding and that SCCP can form 28 per cent of total supports among affected participants. This means SCCP is a significant support category for this cohort.
For participants with Down syndrome, community participation can support communication, social confidence, health routines, supported employment, independence, transport practice and family respite. Cuts may reduce opportunities to maintain skills, build routine, stay visible in community life and participate in employment pathways.
This is also a family-sustainability issue. If community access, transport and participation supports are reduced, families often absorb the transport, prompting, supervision and social-support role. That reduces carer workforce participation and increases unpaid care.
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Required safeguard: cohort-specific Down syndrome impact modelling, supported employment safeguards, communication support protections and individual functional review before SCCP reductions.
7.8 Cerebral Palsy and Complex Physical Disability Cohort
Participants with cerebral palsy and complex physical disability may rely on a combination of personal care, assistive technology, transport, therapy, SCCP, home supports and community access. The current draft correctly identifies the risk of reduced mobility, isolation, pressure injury risk, carer injury, missed therapy and loss of work or study access.
For this cohort, supports often prevent secondary complications. Reduced therapy, transport, personal care or equipment access can lead to pressure injuries, falls, pain, respiratory complications, carer injury, missed education or employment, and increased health-system use. This is not only a disability support issue. It is a health-prevention issue.
The treatment-first risk is also relevant. Medical or rehabilitation treatment may improve function, but it may not eliminate the need for personal care, transport, mobility support or assistive technology. Treatment should only affect eligibility where it materially improves functional capacity to the point that NDIS support is no longer required.
Required safeguard: assess physical disability supports through a whole-of-life participation and health-prevention lens; protect personal care, transport, AT, therapy implementation and community access from blunt reductions.
7.9 Acquired Brain Injury Cohort
Acquired brain injury often involves cognitive fatigue, executive dysfunction, behavioural change, communication issues, memory impairment, reduced insight, emotional regulation difficulty and fluctuating capacity. The current draft notes that administrative tightening and reassessment limits are high risk because needs can change suddenly after deterioration, family breakdown or loss of informal support.
This cohort is particularly vulnerable to administrative harm. A participant may miss notices, fail to retain records, misunderstand requests, forget deadlines, struggle with digital systems or be unable to organise evidence without support. If adverse action follows missed contact or incomplete information, the system may punish the disability itself.
Reassessment limits are also dangerous. ABI-related needs can change with fatigue, mental health deterioration, housing instability, family breakdown, provider failure or behavioural escalation. A static planning cycle may miss urgent changes.
Required safeguard: ABI-informed assessment; accessible contact; executive-function accommodations; nominee and advocacy support; and rapid reassessment rights for deterioration, behavioural escalation or carer breakdown.
7.10 Progressive Neurological Conditions Cohort
Progressive and fluctuating neurological conditions, including MS, stroke-related disability, Parkinsonian conditions and other neurological disorders, do not fit neatly into static planning cycles. The current draft correctly identifies that limiting reassessments can delay support after decline, increase hospital use and force family carers to manage risk without resources.
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The policy risk is timing. A participant may be stable at assessment, then deteriorate rapidly. A rigid reassessment rule may leave them without increased support when mobility, swallowing, communication, cognition, continence, fatigue or personal care needs change. Delayed support can increase falls, hospitalisation, carer injury and crisis admissions.
Required safeguard: guaranteed rapid plan variation for progressive deterioration, episodic decline, carer breakdown, health risk and provider failure.
7.11 Spinal Cord Injury Cohort
Spinal cord injury supports often involve personal care, assistive technology, transport, home modifications, equipment maintenance, therapy, pressure-care prevention, community participation and employment access. The current draft notes that reduced participation supports can increase isolation, reduce employment and recreation, and undermine physical and mental health.
For this cohort, community participation is not optional. Leaving home, accessing work, maintaining physical health, managing secondary complications and staying socially connected are part of long-term health preservation. A reduction in support may increase isolation, depression, physical decline, pressure injury risk and hospital use.
Required safeguard: do not treat SCCP as optional where it maintains independence, mental health, employment, physical activity and prevention of secondary complications.
7.12 Hearing Impairment and Communication Disability Cohort
Communication supports and accessible communication are central to autonomy, safety and participation. The current draft identifies the risk that administrative automation, inaccessible contact and reduced supports may create exclusion or debt risk.
This cohort is exposed to several reform mechanisms: automated notices, digital payment systems, evidence requests, claim suspensions, appeal limits, review processes and contact-based adverse action. If the NDIA communicates in inaccessible formats, the participant may miss a deadline, fail to provide evidence, lose payment, lose support or be unable to challenge an adverse decision.
This is not a minor procedural issue. It is procedural fairness. A person cannot exercise rights they cannot understand or access.
Required safeguard: accessible communication must be mandatory before adverse action. This includes Auslan, captioning, interpreters, Easy Read, plain English, supported decision-making, alternative contact methods and human review.
7.13 First Nations Participants Cohort
This submission recognises that the government’s Impact Analysis identifies the need for diverse cultural approaches to decision-making for First Nations participants, and that access barriers, geography, cultural safety and distrust of systems may mean administrative tightening disproportionately excludes participants.
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This cohort faces compounded risk from geography, thin markets, cultural safety, language, distrust of government systems, limited local providers, lower access to specialists, evidence barriers and mainstream service gaps. If the reform relies more heavily on formal evidence, digital contact, mainstream substitution, provider registration and centralised systems, First Nations participants in regional and remote communities may face reduced access even where functional need is high.
A theoretical service is not a support. A state, health or community service that does not exist locally, is not culturally safe, or cannot deliver disability-specific support should not be counted as an alternative to NDIS support.
Required safeguard: co-designed, culturally safe safeguards; community-controlled pathways; local service mapping; interpreter access; and no substitution to mainstream services unless they are actual, funded, timely, accessible, culturally safe and enforceable.
7.14 CALD Participants Cohort
Culturally and linguistically diverse participants may face language, documentation, advocacy and service-navigation barriers. The current draft correctly identifies that eligibility tightening and evidence requirements may disadvantage people with lower system literacy or less access to allied health reports.
The reform’s evidence burden may disproportionately affect this cohort. Participants may struggle to obtain reports, understand notices, challenge decisions, navigate plan changes, use digital systems or access culturally appropriate providers. If assessment tools underweight cultural context, migration history, trauma, language barriers or family dynamics, the participant may be mis assessed.
Required safeguard: guaranteed interpreting, translated information, culturally appropriate assessment, advocacy, community-based navigation and no adverse action without accessible communication.
7.15 Participants in SIL/SDA and Congregate Settings Cohort
Participants in SIL/SDA are particularly exposed to SCCP reductions and provider-consolidation risk. The current draft notes that the Impact Analysis identifies SIL participants as disproportionately impacted by SCCP because almost all SIL participants have SCCP budgets, and that SCCP may be the pathway out of the house. Cutting it can turn housing into containment.
This is a critical rights issue. Supported accommodation should not become isolation by budget design. If a participant lives in a congregate setting, SCCP may be the mechanism that provides community life, external relationships, employment access, recreation, family connection and visibility outside the home. Without it, the person may remain housed but not meaningfully included.
This also intersects with abuse and neglect risk. Participants in congregate or provider-controlled settings need independent community access and provider choice. Isolation increases vulnerability. Community visibility is a safeguard.
Required safeguard: protect community access for people in congregate or supported accommodation; monitor isolation, restrictive practices, reportable incidents and provider concentration; ensure participants can leave unsafe providers and access independent advocacy.
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7.16 Participants with Executive-Function Disability Cohort
Executive-function disability cuts across ADHD, autism, ABI, psychosocial disability, intellectual disability, neurological disability and trauma. The current draft identifies that people with executive-function disability may have difficulty meeting strict administrative timelines and that 90-day claim rules, record retention and contact-based suspension create risk of debt or support loss due to disability-related administrative barriers.
This cohort is directly exposed to digital payments, claim evidence requests, payment suspension, record obligations, automated notices, review deadlines and reassessment rules. A participant may understand a requirement but still be unable to initiate, sequence, remember, organise, upload or follow through without support. If the system treats that as non compliance rather than disability-related functional impairment, it will remove support from the very people whose disability makes administration difficult.
Required safeguard: executive-function accommodations, reminder systems, nominee contact, advocacy support, longer timeframes, human follow-up and no adverse action without accessible communication and reasonable adjustment.
7.17 Cross-Cohort Findings
The cross-cohort analysis leads to five findings.
-
Uniform cuts create unequal harm. SCCP, CBDA and daily living supports perform different functions across cohorts. A reduction may be minor for one participant and catastrophic for another.
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Disability need is often masked by family labour. Children, adults with high support needs, autistic participants, people with ABI, psychosocial disability and intellectual disability may appear more stable because families are absorbing the work. Assessment tools must not mistake compensation for independence.
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Mainstream service substitution is unsafe unless the alternative service is real. Health, education, housing, mental health, community health, compensation schemes and foundational supports should not be counted unless they are actual, timely, funded, accessible, culturally safe, enforceable and capable of meeting the functional need.
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Administrative reform has cohort-specific harms. Automation, digital payments, evidence requests, strict timelines and reduced appeal rights disproportionately affect people with communication disability, cognitive disability, executive-function disability, psychosocial disability, ABI, CALD backgrounds, First Nations participants and people without informal support.
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Participant choice is a safety mechanism. For people in SIL/SDA, people requiring intimate care, people with communication disability, First Nations and CALD participants, people with psychosocial disability and people with intellectual disability, the ability to choose, reject and change providers is not a luxury. It is protection against neglect, coercion, abuse, cultural unsafety, isolation and service capture.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
7.18 Required Cohort-Level Modelling Before Passage
The Senate should require the Government to publish disability cohort impact assessments before passage. These assessments should not be generic. They should model functional impact, economic displacement and rights risk by cohort. At minimum, the modelling should include:
Required modelling Purpose
Cohort exposure to SCCP cuts Identify which disability groups rely on SCCP for routine, safety, employment readiness, psychosocial stability and community access.
Cohort exposure to CBDA cuts Identify which groups lose therapy implementation, early intervention, behaviour support, communication support and daily living skill development.
Child and developmental Test Thriving Kids transition, CBDA reliance, school-readiness impacts, family burden and cohort modelling future support intensity.
Psychosocial cohort modelling Model relapse risk, hospitalisation, homelessness, police contact, carer distress and recovery impact.
Sensory disability modelling Model transport, orientation, communication access, technology, interpreter and community participation impacts.
Physical and high-intensity Model personal care, transport, AT, secondary health complications, carer injury and support modelling hospital risk.
ABI and neurological modelling Model fluctuating need, rapid deterioration, reassessment delays and executive-function barriers.
First Nations and CALD Model geography, cultural safety, language access, provider availability and evidence modelling barriers.
SIL/SDA and congregate living Model isolation, community access, provider capture, reportable incidents and abuse modelling exit pathways.
Administrative vulnerability Model digital exclusion, missed notices, claim failure, payment suspension, review modelling barriers and loss of supports.
7.19 Conclusion
The reforms should not be assessed only by support category or budget line. They must be assessed by cohort-specific functional impact.
A percentage reduction in SCCP, CBDA or daily living support does not have a percentage impact on a person’s life. For some participants, it removes the support that maintains communication, regulation, hygiene, mobility, work, school readiness, housing stability, safety, community access or carer sustainability.
Without cohort-level modelling, the Government cannot know whether the reforms are efficient, harmful or discriminatory in effect.
The Senate should not permit category-wide reductions, automated assessments, treatment-first barriers, mainstream substitution, payment controls or provider consolidation to proceed until the Government has published cohort-specific impact analysis showing that each affected group will remain safe, supported, connected and able to function in daily life.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
- State-based and foundational support model risk The proposed reforms must be assessed against the reason the NDIS was created.
Before the NDIS, disability support in Australia was not a coherent national insurance system. It was fragmented across states and territories, rationed through program budgets, uneven by postcode, difficult to navigate, and often unavailable until people reached crisis. The Productivity Commission’s 2011 finding remains the historical baseline: the old disability support system was “underfunded, unfair, fragmented, and inefficient.” The NDIS was created because disability risk could not be safely left to state rationing, family capacity, charity, waiting lists or local service availability.
That history matters because several elements of the reform package risk moving the system back toward the pre-NDIS model by another name. “Foundational supports” can be valuable if they are genuinely additional, nationally consistent, properly funded, locally available and enforceable. They become dangerous if they are used as a fiscal off-ramp from individualised NDIS support before the replacement system exists in practice.
The Senate’s Decision: Disability Insurance Model or Rationing
The Senate should distinguish between two very different policy choices:
- building a genuine ecosystem of supports around the NDIS; and
- reducing individualised NDIS supports and assuming other systems will absorb the need. The first is reform. The second is cost-shifting.
The NDIS Review recommended a connected ecosystem of supports. It did not recommend removing individualised supports before foundational supports were legislated, funded, staffed, commissioned, operational and accountable. It described foundational supports as preventative and fundamental. That principle is sound. But preventative supports only prevent harm if they exist before the individualised support is removed.
A theoretical service is not a support. A future program is not a support. A state promise is not a support. A waiting list is not a support. A capped block-funded program is not equivalent to an individualised entitlement unless the person can actually access the support they need, when they need it, in the place they live.
The risk is not that states and territories should have no role. They should. Schools, childcare, community health, housing, mental health, justice, child development services and community organisations all matter. The risk is that the Commonwealth reduces NDIS funding while assuming these systems can absorb unmet need without equivalent funding, enforceable obligations or workforce capacity.
That is not a national disability insurance model. It is a return to rationing.
8.1 Why the Pre-NDIS History Matters
The pre-NDIS model failed because access depended too heavily on geography, state budgets, service availability, program eligibility, provider discretion and crisis thresholds. Families could not plan. People with disability could not rely on portable support. Many people waited until they deteriorated before help arrived. Support was often controlled by systems rather than by the person. The proposed reforms risk recreating several of those features.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Pre-NDIS problem Current reform risk
Rationed state Supports may depend on capped program budgets rather than individual functional need. systems
Postcode inequity Access may vary by state, region, provider market and local commissioning decisions.
Block-funded services Provider menus may replace participant choice and individualised support design.
Lack of portability State-based or commissioned supports may be harder to move across jurisdictions.
Crisis-driven access Participants may lose preventative supports and re-enter systems only after decline.
Limited choice Panels, commissioning and provider restrictions may reduce the ability to choose, reject or change providers.
Institutional thinking Group-based efficiency may replace person-centred support where individualised help is required.
Weak accountability Families may be referred between systems without one agency legally responsible for the outcome.
This is the central warning: the NDIS was created because the old system rationed support. A reform that rebuilds capped, state-based, block-funded pathways must prove it is not recreating the same failure with new language.
8.2 Foundational Supports Must Be Additional, Not Substitutive
Foundational supports should sit around the NDIS, not become a way to push people out of it.
A well-designed foundational support system could provide earlier help, reduce diagnostic gatekeeping, support families, assist schools and childcare, improve navigation, reduce crisis and give people with disability better access to community based assistance. But that requires new funded capacity.
It cannot be achieved simply by relabelling mainstream systems as available support.
If foundational supports are capped, block-funded and state-delivered, then access will depend on demand, provider supply, local workforce, procurement decisions, eligibility thresholds and waitlists. If demand exceeds supply, the system will ration. It may ration through queues, short service blocks, group programs, triage, geographic limits, online information, parent-led delivery or administrative redirection.
That is the economic difference between an individualised insurance model and a capped service model.
Under an individualised NDIS plan, funding follows assessed need. Under a capped foundational supports model, need must fit within the funded supply. If the funded supply is not enough, unmet need is displaced.
8.3 The Thriving Kids Example
The Thriving Kids model illustrates the broader risk.
The issue is not whether earlier support for children is desirable. It is. The issue is whether children aged 8 and under with developmental delay and/or autism are being moved from individualised NDIS plans into a capped foundational supports
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
system before the Senate can see a full per-child funding model, demand model, workforce model, provider-capacity model, state-readiness model and escalation pathway.
The published model includes early identification, parent education, supported playgroups, group-based supports, targeted short-term interventions and natural-environment delivery. These supports may help some children. But they do not answer the critical implementation question: what does each child receive, how often, for how long, from whom, and with what right to challenge inadequate support?
If a child cannot tolerate a group setting, who provides one-to-one implementation support? If a parent is told what strategy to use, who helps them apply it at home, in the supermarket, at childcare drop-off, during meltdowns or before school? If childcare is expected to implement strategies, who funds the staff time, training, ratios and behaviour-support backup? If community health is the pathway, what happens where there are no local providers or long waitlists?
Without those answers, Thriving Kids risks becoming a capped substitute for individualised early intervention rather than a genuine expansion of support.
8.4 State Systems Are Ill-Prepared and Already Under Pressure
The Senate should not assume that schools, childcare, community health, GPs, mental health, housing and state services have unused capacity to absorb NDIS demand.
The submission has already identified that schools are carrying a large disability-adjustment load, childcare is a high participation system, and community health access is uneven, particularly outside major cities. Children redirected from individualised support do not stop needing communication support, sensory regulation, behaviour support, parent coaching, school transition help or therapy implementation. Those needs move into classrooms, childcare centres, GP rooms, community health waitlists and family homes.
The same principle applies to adults. A participant refused NDIS support because health, housing, mental health, compensation, education or another service system “exists” may still receive no practical support if that system is unavailable, unaffordable, waitlisted, geographically inaccessible, clinically unsuitable or not legally responsible for the disability-related need. This is why the submission has proposed an actual-service test. No NDIS support should be refused on the basis of another system unless that system is:
Test Requirement
Actual The service exists in the participant’s location.
Timely The service can be accessed within a timeframe that prevents harm or decline.
Funded The service has funding to meet the need.
Accessible The participant can practically use it, including transport, communication and cultural access.
Appropriate The service is clinically and functionally suitable.
Enforceable There is a legal or practical obligation to deliver the support.
Sufficient The service can meet the disability-related functional need, not merely offer advice or referral.
If these conditions are not met, the NDIS should not be allowed to treat the other system as a substitute.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
8.5 Capped Supports Create Rationing Incentives
A capped foundational supports model changes incentives.
When providers operate within fixed contracts and fixed service volumes, they must manage demand within the budget. If more people need help than the contract funds, the provider cannot automatically increase service intensity. The provider must ration.
That rationing may occur through:
- shorter intervention blocks;
- group delivery;
- parent-led or self-directed strategies;
- triage thresholds;
- waiting lists;
- referral back to mainstream systems;
- limited provider choice;
- mandatory exit points;
- reduced service intensity;
- refusal of complex cases. This may control expenditure, but it does not necessarily meet need.
The economic risk is a waitlist externality. The cost of delay is transferred to families, schools, community health, providers and future public systems. Families pay privately, reduce work, increase unpaid care, manage crisis, or wait until the person deteriorates enough to qualify for more intensive support.
That is not prevention. It is delayed expenditure.
8.6 Choice and Control are Safety Mechanisms
State-based, block-funded or commissioned systems also risk reducing participant choice.
Choice and control are not simply consumer preferences. In disability support, choice is a safeguard. It allows a participant to leave an unsafe provider, avoid a worker who is unsuitable for intimate care, choose a culturally safe service, maintain communication access, protect trauma boundaries, and avoid isolation inside provider-controlled systems.
The Disability Royal Commission provides the broader context. People with disability have experienced violence, abuse, neglect and exploitation across institutions, services, homes, schools, workplaces and communities. Any reform that reduces individual control and increases reliance on poorly specified service systems must be treated as a safeguarding issue, not only a fiscal adjustment.
A person with disability should not be forced to accept a group program, a state-contracted provider, a panel provider or a commissioned service where that model is unsuitable, unsafe or ineffective. A right to support is weakened if the person has no real choice over who provides it, how it is delivered, or how to leave when it fails.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
8.7 Portability and Postcode Inequity
A national disability insurance scheme should not depend on postcode.
The more the reform relies on state-based foundational supports, commissioned services, local provider markets and mainstream systems, the greater the risk that support becomes uneven across Australia.
A child in metropolitan Sydney may have access to allied health, supported playgroups, childcare-based programs and community health options. A child in a regional or remote area may have a website, a hotline, a waitlist and no provider. An adult in one state may receive community support; another in a different state may be told the program is not available or not funded locally.
That is the old problem returning: support by geography rather than need.
If the Commonwealth reduces NDIS support before state and foundational systems are nationally consistent, the reform will create postcode inequity. Participants may be eligible in theory but unsupported in practice.
8.8 Accountability Failure: Many Doors, No Responsible Door
“No wrong door” is not enough if there is no accountable door.
Families and participants may be referred between NDIS, health, education, housing, mental health, childcare, community health, compensation schemes, state disability services and local providers. Each system may say another system is responsible. The person is left carrying the gap.
This is already a known failure at service interfaces. The proposed reforms may intensify it by making NDIS access and funding more dependent on whether other systems theoretically exist.
The Senate should require clear responsibility rules. If a participant is redirected from NDIS support to another system, that system must be named, funded, available and accountable for the outcome. Otherwise the redirection should not occur.
8.9 Economic Consequences of Returning to Rationed Systems
The economic risk is that the reform reduces visible NDIS expenditure while recreating the inefficiencies that the NDIS was designed to overcome. Rationed systems do not remove cost. They delay it. They move it into:
Displaced cost Likely consequence
Families Increased unpaid care, reduced paid work, carer burnout and private therapy costs.
Schools and childcare More adjustments, behaviour support needs, reduced attendance, exclusions and staff stress.
Community health and GPs Longer waitlists, more referrals, parental distress and administrative burden.
Hospitals and mental health Increased crisis presentations, relapse and preventable deterioration.
Housing and homelessness Tenancy breakdown, crisis accommodation and supported housing pressure. systems
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
Displaced cost Likely consequence
Justice and police Behavioural escalation, psychosocial crisis and avoidable justice contact.
Provider markets Reduced demand, market exit, thinner local services and loss of specialist capacity.
Future NDIS Later re-entry at higher support intensity if early or preventative support fails.
This is the same economic flaw repeated across the reform package. The saving is counted where the NDIS stops paying. The cost is not counted where the unmet need reappears.
8.10 Required Safeguards
State-based and foundational supports should not be used to reduce NDIS supports unless the following safeguards are met.
Required safeguard Purpose
Legislation before Foundational supports must have a clear legal basis before they replace individualised substitution supports.
Published funding model The Senate must see per-person, cohort and jurisdictional funding assumptions.
Demand modelling Government must show expected demand by age, disability, geography and support intensity.
Workforce modelling Government must show there are enough providers, allied health workers, support workers and navigators.
State-capacity model Each state and territory must show service availability, waitlists, procurement and delivery readiness.
Enforceable service Participants must know what support they are entitled to receive and how to challenge guarantee failure.
Portability protection Support should not disappear when a person moves state or region.
Choice and control Participants must retain the ability to choose, reject and change providers. protection
Independent monitoring Public reporting should track waitlists, unmet need, service gaps, provider exits and harm indicators.
Rapid NDIS re-entry Participants whose needs exceed foundational supports must be able to enter or return to the NDIS quickly.
8.11 Recommendation
The Senate should not permit any reduction, redirection or refusal of NDIS support on the basis of state-based or foundational supports unless those supports are legislated, funded, enforceable, accessible, accountable and operational.
Before any participant is moved out of individualised NDIS support, the Commonwealth, states and territories should publish a full foundational supports implementation model, including:
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
- per-person and cohort funding assumptions;
- state and territory capacity;
- workforce and provider availability;
- rural and remote access;
- waitlist tolerances;
- eligibility and escalation pathways;
- review and complaint rights;
- service guarantees;
- portability protections;
- safeguards for First Nations and CALD participants;
- protections against group-based support being used where individualised support is required;
- rapid NDIS entry or re-entry where foundational supports are inadequate. 8.12 Conclusion
Foundational supports may be a valuable addition to the disability support ecosystem. But they are not a substitute for individualised NDIS funding unless they are real, funded, available and enforceable.
The NDIS was created because the old system was fragmented, rationed and inequitable. The Senate should not approve a reform pathway that recreates those conditions through capped state-based services, block-funded programs, provider menus, group delivery and theoretical mainstream substitution.
A national disability insurance scheme should not be replaced by a patchwork of promises.
If foundational supports are to be used as part of reform, they must be built first, tested first, funded first and made accountable first. Only then should government consider whether any individualised NDIS support can safely change.
Until then, reducing NDIS supports on the assumption that state-based or foundational supports will absorb need is not evidence-based reform. It is a return to the pre-NDIS rationing model under a new name.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
- Budget comparison, fiscal governance and public trust The fiscal governance problem is not only that the Government has failed to publish a full economic model. It is that life changing legislation is being advanced before the Parliament, participants, families, providers and states have been shown the full consequences. The reforms affect access, planning, assessment, payments, provider markets, appeal rights, early childhood supports, family care assumptions and state-system interfaces. These are not minor administrative changes. They determine whether people can shower, communicate, leave home, access therapy, work, study, stay housed, keep providers, and avoid crisis. Legislation of this scale should not proceed on partial modelling, unpublished assumptions or assurances that harms will be managed later.
The Government’s lack of transparency is itself a fiscal risk. The Senate is being asked to accept a quantified $37.8 billion saving without an equivalent public model of the costs transferred into unpaid care, schools, childcare, community health, housing, hospitals, Centrelink, justice, provider exits, lost tax receipts and future NDIS re-entry. That is not balanced fiscal governance. It is a one-sided ledger. A responsible Parliament should not approve a reform package that measures the saving clearly but leaves the damage dispersed, delayed and uncounted.
The rush also weakens public trust. People with disability and their families are being asked to trust that replacement systems will exist, that assessment tools will be fair, that payment systems will not block legitimate supports, that state services will be ready, that families will not be conscripted into unpaid care, and that appeal rights will still protect them. Yet the public material repeatedly leaves the critical questions unanswered: who receives what, when, from whom, under what rule, with what evidence, and with what enforceable remedy when the system fails?
This matters because public trust is part of Scheme infrastructure. The NDIS relies on participants disclosing need, providers staying in the market, families cooperating with planning, clinicians writing evidence, and states building complementary systems. Trust collapses when government appears to be legislating first and modelling later. Once participants believe the system is designed to remove support rather than understand need, engagement becomes defensive. Families over document, providers withdraw, advocates escalate, disputes increase, and administrative costs rise.
The downplaying of parental, partner and informal unpaid support is a particular governance failure. The reform narrative often treats informal support as if it were a stable background resource. It is not. Informal care is labour. It has cost, limits, health impacts and opportunity cost. It may be unavailable, unsafe, unwilling, ageing, exhausted, geographically distant, untrained, abusive, employed, disabled or deceased. Any fiscal model that assumes family support can absorb reduced funded support is not modelling savings. It is hiding labour transfer.
The Senate should therefore require a full transparency condition before passage: all major assumptions, assessment tools, funding formulas, cohort definitions, budget rules, state-capacity assumptions, provider-market assumptions, unpaid-care assumptions, appeal pathways and digital payment controls should be published and subject to parliamentary scrutiny. Public confidence cannot be maintained by asking people with disability to accept irreversible risk on trust.
The Government is asking Parliament to legislate first and discover the consequences later. That is not reform. It is a governance failure.
This submission does not argue that disability spending should be exempt from scrutiny. It argues that scrutiny must be equal. If the Government can defend major expenditure in defence, debt servicing, aged care, private health policy and digital compliance infrastructure, then disability supports should not be singled out for savings without the same standard of economic modelling.
The relevant parliamentary question is not: is the NDIS expensive? The correct question is: compared with what, over what timeframe, with what return, with what avoided cost, and with what displaced harm?
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
The 2026–27 Budget states that the NDIS reforms are expected to save $37.8 billion over four years. It also provides $2 billion to establish Thriving Kids as part of a $5 billion Foundational Supports commitment to be matched by the states. That shows the reform is not merely a technical Scheme adjustment. It is a major fiscal transfer: individualised disability supports are being reduced while replacement systems are still being built, negotiated and tested. (Budget Australia)
The Senate should not assess this as a simple spending reduction. It should assess whether the Commonwealth is reducing one visible Budget line while pushing costs into other ledgers: families, schools, childcare, community health, hospitals, housing, Centrelink, state systems, unpaid care and future NDIS re-entry.
9.1 Fiscal Discipline Requires a Complete Ledger
The Government’s fiscal case is incomplete because it measures the saving but not the displaced cost. This submission has already shown that NDIS funding is not passive expenditure. It flows into wages, sole traders, allied health practices, plan managers, support coordinators, small businesses, transport, assistive technology, software, training, insurance, rent, vehicles, fuel and local spending. It also enables participants and unpaid carers to work, study, maintain routines, access community life and avoid crisis systems. A disability support dollar therefore has two functions:
Budget view Economic reality
NDIA outlay Income to workers, providers, sole traders and local businesses
Participant plan funding Functional infrastructure for daily life, work, study, safety and care
Therapy and capacity building Human-capital investment and prevention of future support intensity
Community participation Protection against isolation, decline, carer burnout and crisis
Personal care and daily support Avoided hospital, family-care and institutional costs
A cut to NDIS spending is not automatically a national saving. It may reduce the NDIA ledger while increasing costs elsewhere. That is why this submission argues for net-public-cost modelling, not Budget-line accounting.
The original submission framework already identifies four tests: functional impact, economic displacement, market viability, and rights/governance. Those tests remain the correct framework for fiscal governance. The Senate should ask where the cost reappears, who carries it, and whether the claimed saving survives once broader economic and social impacts are counted.
9.2 Comparison With other Fiscal Choices
Major public expenditure is not automatically described as a blowout when government considers it strategically important. Debt servicing is treated as a macro-fiscal reality. Defence is treated as national security. Aged care is treated as dignity and system capacity. Health policy is treated as public infrastructure. The same standard should apply to disability support when it preserves function, employment, family stability, community participation and crisis prevention.
The Parliamentary Budget Office’s 2026–27 Budget Snapshot states that public debt interest payments remain the fastest growing major payment over the medium term, while NDIS growth is expected to slow because of Budget policy decisions. This matters because the NDIS is being publicly framed as a sustainability problem, while another rapidly growing payment — debt interest — is treated as a fiscal condition to be managed rather than a moral failure by its recipients.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
The 2026–27 Health Budget also commits $3.7 billion to aged care to deliver more beds, packages and improved care. That investment is appropriately framed as capacity, dignity and system reform. Disability support should be analysed through the same lens: not only as expenditure, but as the infrastructure that keeps people out of crisis, supports families, protects dignity and enables participation.
Private health policy also illustrates that government can restructure large spending areas without reducing the people affected to a fraud or cost narrative. Budget commentary reports $3.0 billion in savings over four years from changes to the Private Health Insurance Rebate, with savings reinvested into aged care. The point is not direct equivalence. The point is fiscal framing. Other policy areas are treated as systems requiring redesign, transition and reinvestment. Disability should be treated with the same seriousness.
Fiscal area How it is usually framed Fiscal governance question for NDIS
Debt interest A macro-fiscal pressure to manage Why is disability support framed more morally than other majorexpenditure?
Defence Strategic investment despite cost Why is disability not treated as national social infrastructure?uncertainty
Aged care Dignity, capacity and system reform Why are disability supports treated as excessive before harm ismodelled?
Private health Policy redesign and reinvestment Why are NDIS savings not tested against displaced costs and lostpolicy returns?
NDIS Cost growth, fraud, sustainability and Why is the Scheme’s economic return, workforce role andsocial licence prevention value under-modelled?
9.3 Disability Support is Preventative Infrastructure
The central fiscal error is treating disability support as consumption rather than prevention.
The NDIS funds supports that can prevent higher-cost public interventions: hospitalisation, mental health crisis, homelessness, school exclusion, police contact, family breakdown, carer collapse, restrictive practices and institutional care. It also supports employment, education, communication, mobility, routine, self-care, community access and family workforce participation.
This is why Budget comparison matters. The question is not whether the NDIS costs money. It does. The question is whether cutting supports creates larger costs later.
A support worker who prevents hospital admission has fiscal value. A communication support that prevents behavioural escalation has fiscal value. A therapy assistant who helps a child generalise skills has fiscal value. A support coordinator who prevents housing collapse has fiscal value. A community participation support that prevents isolation and carer burnout has fiscal value.
The Government’s own reform architecture acknowledges disruption: funding resets, new framework planning, digital payments, mandatory registration, commissioned services, tighter access, treatment-first logic and mainstream substitution. The submission’s earlier risk register shows these mechanisms can transmit costs into families, states, health, education, housing, providers and labour markets.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
9.4 Fiscal Hypocrisy and Social Value
The fiscal hypocrisy at the heart of the reform debate is not that government spends money elsewhere. It should. The hypocrisy is that disability support is being treated as a suspect cost before the Government has published a full model of its economic value, avoided costs and downstream effects. A responsible fiscal process would ask:
Question Why it matters
What GDP activity is supported by NDIS To test whether cuts reduce wider economic activity. expenditure?
What employment and underemployment To quantify support-worker, allied-health and small-business exposure. effects follow?
What tax receipts are lost? To test whether lower NDIA spending reduces income tax, company tax and GST-linked consumption.
What unpaid care increases? To quantify lost carer wages, superannuation, health and workforce participation.
What state costs rise? To identify pressure on schools, childcare, community health, housing and justice.
What provider markets contract? To prevent thin-market failure and loss of participant choice.
What future support costs increase? To test whether early cuts increase later NDIS intensity.
What appeal and administration costs rise? To quantify disputes, reviews, complaints and reassessment churn.
Without this modelling, the Senate cannot know whether the $37.8 billion saving is a net public saving or a transfer of cost into less visible systems.
9.5 Fiscal Governance Recommendation
The Senate should require that any major NDIS saving measure be accompanied by a fiscal governance statement equal in seriousness to the measure itself. That statement should include:
-
child-development and education-system impact ● Treasury-level macroeconomic modelling; modelling;
● tax-revenue modelling; ● health, housing, justice and Centrelink exposure;
● employment and underemployment modelling; ● digital payment and claim-suspension impact
● provider-exit modelling; modelling;
● small-business and sole-trader impact modelling; ● participant rights and review-impact modelling;
● carer workforce participation modelling; ● post-implementation harm triggers.
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state and territory cost-shift modelling; Submission to Senate Inquiry - Proposed NDIS Reforms 2026 | Ability Pathways Australia | Page 90
Submission 592
Submission to Senate Inquiry - Proposed NDIS Reforms 2026
9.6 Core Finding
A sustainable NDIS must be fiscally responsible. But fiscal responsibility does not mean cutting one ledger and ignoring the others.
The Senate should reject any fiscal case that treats the NDIS only as expenditure while failing to model its role as labour market infrastructure, small-business income, participant participation, carer workforce protection, early intervention, crisis prevention and avoided public cost.
Disability support should be scrutinised. But it should be scrutinised honestly. A Budget saving is not a national saving if the cost reappears as unpaid care, provider collapse, hospital demand, school pressure, Centrelink reliance, lost tax receipts and future disability support.
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Submission to Senate Inquiry - Proposed NDIS Reforms 2026
- Political rhetoric, social license and mental health impact Political language matters because it changes the conditions in which people with disability have to live. When national leaders repeatedly frame the NDIS through “rorts,” “fraud,” “shonks,” “grifters,” “crooks,” “broken systems” and “unsustainable costs,” people with disability and their families absorb the social consequences. Ministers may say participants are not the problem, but public rhetoric does not stay neatly inside policy categories. It shapes how neighbours, employers, schools, providers, media commentators and the broader public talk about disability support.
The Minister’s National Press Club speech framed the Government’s NDIS reform plan around four pillars: fighting fraud and stopping rorts, slowing rapid cost increases, clearer eligibility requirements, and delivering quality services and supports. The same speech stated that the Scheme should not be “an ATM for shonks, grifters, fraudsters and crooks.” Fraud control is necessary. Criminal exploitation, coercion, overcharging and non-compliant payments should be investigated and prosecuted. But fraud rhetoric must be precise. If the dominant public message about the NDIS is fraud, cost and social license, participants become socially suspect even when ministers say they are not the target.
This matters because NDIS participants are not abstract budget units. They are people whose daily lives depend on predictable support: showering, dressing, eating, communicating, leaving home, attending school, working, maintaining housing, managing behaviour, regulating distress, accessing therapy, staying safe and remaining connected to family and community.
A reform debate that centers fraud and cost without equal emphasis on dignity, function, rights and public trust creates fear. Families hear “sustainability” and ask which support will be taken next. Participants hear “eligibility tightening” and ask whether they will be pushed out. Providers hear “payment integrity” and ask whether legitimate invoices will be blocked. Workers hear “market reform” and ask whether their hours will disappear.
That fear is not irrational. It is a predictable response to a reform package that includes funding resets, tighter eligibility, new framework planning, digital payment controls, provider registration, plan-management panels, commissioned support coordination, Thriving Kids transition, treatment-first rules, mainstream substitution, automation and reduced effective appeal rights. The current draft section already identifies these reform signals and their likely social and psychological effects.
Reform signal Likely social and psychological effect
Eligibility tightening Fear of losing access to the Scheme.
SCCP and CBDA funding resets Fear of losing supports that maintain function, routine, therapy implementation and community access.
Digital payment controls Fear that legitimate supports will be delayed, blocked or subjected to evidence disputes.
Provider registration and Fear of losing trusted workers, plan managers, support coordinators and local providers. panels
Thriving Kids transition Fear that children will move from individualised plans into an unproven capped model.
Robo-assessment and appeal Fear that inadequate funding cannot be independently corrected. limits
Treatment-first rules Fear of being sent through inaccessible, unaffordable or unsuitable services.
Mainstream substitution Fear of being referred into systems that do not actually provide the support required.
Family substitution Fear that parents, partners and informal carers will be expected to replace funded support.
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The Government’s lack of transparency compounds this fear. People with disability and their families are being asked to trust that replacement systems will exist, that assessment tools will be fair, that payment systems will not block legitimate supports, that states will be ready, that appeal rights will still protect them, and that families will not be conscripted into unpaid care. Yet the critical questions remain only partly answered: who receives what, when, from whom, under what rule, with what evidence requirement, and with what enforceable remedy when the system fails?
This is a public trust problem. Public trust is not a public relations accessory. It is part of Scheme infrastructure. The NDIS depends on participants disclosing need, families cooperating with planning, providers staying in the market, clinicians writing evidence, and states building complementary systems. Trust collapses when government appears to legislate first and model later.
The Disability Advocacy Network Australia has already described the reform environment as one of personal uncertainty and professional responsibility for advocates, with people with disability, families and supporters trying to understand what the changes may mean for their lives. That uncertainty should be recognised as a real policy impact, not dismissed as misinformation or resistance to reform.
Mental health harm does not only arise after a support is removed. It can arise from uncertainty, stigma, repeated reassessment, administrative burden, fear of provider loss, fear of appeal rights being weakened, and the sense that one’s life has been reduced to a Budget problem. For people who rely on support to shower, eat, communicate, leave home, regulate behaviour, avoid isolation or remain employed, the threat of losing support is not abstract. It is existential.
The Courier Mail reported there is also an emerging and deeply serious warning from the disability community: some people with disability are publicly discussing suicide, despair or voluntary assisted dying in response to fears about NDIS cuts and a return to pre-NDIS life. Recent media reporting has cited disability advocates warning of increased distress, suicidal ideation and interest in voluntary assisted dying among some people with disability affected by reform fears. This is warning evidence, not a population-level dataset. The Senate should not treat it as proof of prevalence. But it should treat it as evidence that the reform process is creating severe distress that government has not adequately measured.
It is important to be legally precise. In Australia, voluntary assisted dying is not available because a person has disability alone. Queensland Health states that having a disability alone does not meet the eligibility criteria under Queensland’s Voluntary Assisted Dying Act, and Healthdirect explains that disability or mental illness alone does not qualify a person for VAD.
But that legal point does not remove the policy concern. If people with disability are saying they would rather die than return to isolation, rationing, neglect, family exhaustion, untreated need or institutional dependence, the Senate should treat that as a serious warning about fear, trust and social harm. The issue is not whether those people would meet VAD eligibility. The issue is that some people are experiencing the prospect of reform as a threat to a livable future.
Profound Failure of Public Policy Communication
A reform process has failed when people with disability begin discussing death as an alternative to returning to the pre-NDIS life. The Government does not need to intend that harm for the harm to be real.
The rhetoric of “social licence” also requires caution. The NDIS was created because people with disability have rights, not because their support depends on public popularity. Social licence cannot become a political test for whether people with disability deserve support. A national disability insurance scheme should be governed by need, evidence, rights and economic honesty, not by public resentment fuelled by selective stories of misuse. The Government must separate fraud control from participant legitimacy.
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Government responsibility Required standard
Fraud enforcement Target criminal exploitation, overcharging and non-compliance without stigmatising participants.
Public communication Use precise language that protects the dignity of people who rely on support.
Transparency Publish modelling, assumptions, assessment rules, funding formulas and transition safeguards.
Reform sequencing Build and prove alternatives before withdrawing individualised supports.
Mental health response Monitor distress, crisis contacts, complaints and support-loss fear during implementation.
Advocacy access Fund independent disability advocacy and accessible information before major changes commence.
Participant reassurance Provide clear, individualised, accessible explanations of what changes and what does not.
The downplaying of parental, partner and informal unpaid support is part of the same trust failure. Families are hearing government language about sustainability while seeing reform mechanisms that may shift care back onto them. Informal care is not a stable background resource. It is labour. It has limits, health impacts and opportunity costs. It may be unavailable, unsafe, unwilling, ageing, exhausted, geographically distant, untrained, abusive, employed, disabled or deceased. Any public message that implies families can simply absorb reduced funded support ignores the lived and economic reality of unpaid care.
The Senate should require the Government to publish a participant mental-health and public-trust impact response alongside any implementation plan. That response should include accessible communication, independent advocacy, crisis referral pathways, transparent transition guarantees, public reporting on distress indicators, and a clear commitment that fraud control will not be used to question the legitimacy of participants’ support needs.
Recommendation: The Government should be required to publish a Political Communication, Public Trust and Participant Distress Impact Statement before the reform package proceeds. That statement should include:
- a clear separation between participant need and provider fraud;
- accessible communication to participants and families about the specific effects of reform;
- transparent modelling of support reductions and transition pathways;
- independent disability advocacy funding;
- crisis and mental health referral pathways;
- monitoring of complaints, distress, support-loss fear, crisis contacts and participant disengagement;
- safeguards against stigmatising language in official communications;
- a public commitment that people with disability will not carry the reputational burden of provider misconduct or fiscal anxiety.
The Senate should not accept a reform process that extinguishes public trust and then treats fear as misinformation. Fear is rational when people cannot see the modelling, cannot see the replacement services, cannot see the appeal pathway, cannot see the provider safeguards, and cannot see whether family will be expected to replace funded support.
In summary, People with disability are not a budget problem to be managed. They are citizens whose rights, safety, dignity, participation and lives depend on the supports now being placed at risk. Fraud should be investigated. Waste should be reduced. Providers who exploit participants should be removed. But the public case for reform must not
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stigmatise the people the Scheme was created to support. People with disability should not be made to carry the reputational burden of provider misconduct, fiscal anxiety or political messaging. They should not have to defend their right to support because the public debate has confused fraud control with participant legitimacy.
Source note: This is an illustrative index chart derived from the themes argued sin Section 10 of the submission. It is not an official annual statistical series. It visualises the submission’s contrast: the original NDIS rollout was associated with rising trust and falling distress, while the proposed reform rollout is argued to increase uncertainty, administrative pressure, while stigmatising the participants and causing them harm and distress.
Conclusion
The NDIS was created under the Gillard Government because Australia made a decision about the kind of country it wanted to be. It was not only a funding reform. It was a social reform. It was designed to bring people with disability out of the shadows, make disability visible in ordinary Australian life, and give people the practical supports required to participate, work, study, communicate, leave home, build relationships and live with dignity.
That social purpose matters. Before the NDIS, too many people with disability were hidden inside family homes, trapped on waiting lists, dependent on charity, rationed by state systems, or made invisible by a society that treated disability as private misfortune rather than public responsibility. The NDIS changed that. It told Australians with disability that they belonged in the community, not outside it.
The current reform debate risks reversing that progress. When disability support is repeatedly framed through fraud, cost, rorts, sustainability and social licence, the public message shifts. People with disability are no longer seen first as citizens with rights, but as pressure on a Budget. Families begin to fear a return to the pre-NDIS life: isolation, rationing, unpaid care, service gaps, institutional thinking and exhaustion behind closed doors.
That is why the language and sequencing of reform matter. Fraud should be prosecuted. Waste should be reduced. Poor providers should be removed. But those goals must not be pursued in a way that extinguishes public trust, stigmatises participants, narrows choice, weakens appeal rights, shifts care back onto families, or makes people with disability feel they are being pushed back into invisibility. A reform process has failed if the people the Scheme was created to liberate now fear being returned to the shadows. The Senate should insist on a reform pathway that protects the original promise of the NDIS: not merely budget control, but inclusion, visibility, dignity, participation and respect.
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Appendix A: Updated risk register
No. Risk Core risk statement Required safeguard
1 Whole-economy The Government has modelled the $37.8b Require Treasury-level macroeconomic
modelling risk Budget saving but not the full economic modelling before passage.consequences for GDP, employment, tax receipts, provider exits, unpaid care, states and downstream systems.
2 False-economy and cost- Reduced NDIA expenditure may reappear as Assess the Bill using net public cost, not
shifting risk higher costs in hospitals, Medicare, Centrelink, NDIA outlays alone.housing, justice, child protection, state systems and unpaid care.
3 Provider-market failure Funding reductions may cause provider exit, Publish provider-exit modelling and
risk especially among sole traders, microbusinesses protect thin markets before cuts orand thin-market providers. commissioning changes.
4 Unemployment and Reduced participant-directed funding may Require labour-market modelling,
labour-oversupply risk reduce shifts, caseloads, allied-health demand including underemployment, Centrelinkand small-business income. exposure and regional impacts.
5 Tax receipt, GDP and Reduced provider and worker income may Publish tax-revenue, GDP and household-
household-consumption lower income tax, company tax, GST-linked consumption impact modelling.risk consumption, superannuation and local spending.
6 Participant functional Removing functional supports may cause Maintain supports unless an individual
decline risk delayed decline, crisis, hospitalisation or higher functional impact assessment showsfuture support costs. reduction will not cause harm.
7 SCCP reduction risk Social, Civic and Community Participation is Suspend SCCP reductions unless cohort-often functional infrastructure, not leisure. specific harm modelling and individual safeguards are legislated.
8 CBDA implementation- Capacity Building Daily Activities funds therapy Suspend CBDA reductions unless impacts
loss risk implementation, daily-life execution and skill on children, implementation, remotedevelopment. participants and allied-health markets are modelled.
9 Family and informal care The reforms may shift paid disability support Prohibit informal care being treated as a
substitution risk into unpaid family labour. funding substitute without areasonableness and sustainability test.
10 24/7 critical daily living, Participants with complex personal care, safety, Exempt high-risk and 24/7 support
intimate-care and dignity behavioural, communication or health needs participants from uniform cuts and
risk may face unsafe reductions. protect bodily autonomy.
11 Thriving Kids capped- Children under 9 may be moved from Publish the Thriving Kids demand,
funding and transition individualised plans into a capped model before funding, workforce and state-capacity
risk per-child funding, workforce and state capacity model before any child loses NDISare proven. support.
12 Early-intervention market Reduced individualised early-childhood funding Model early-intervention provider
contraction risk may reduce demand for speech pathology, OT, impacts, graduate pathways andpsychology, developmental educators, workforce capacity before transition. behaviour support and therapy assistants.
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No. Risk Core risk statement Required safeguard
13 Schools, childcare and Unmet child support needs may shift to schools, Do not move children out of NDIS
community health cost- childcare, GPs, community health and families. supports unless replacement services areshift risk funded, enforceable, accessible and operational.
14 Digital payments and Digital payments may delay, block or suspend Publish a Digital Payments Safeguard and
automated payment- legitimate supports, creating cashflow, service- Impact Statement before mandatory use.control risk continuity and participant-safety risks.
15 Robo-assessment and Computer-generated budgets and reduced Preserve full merits review and require all
loss of effective appeal tribunal powers may remove meaningful review formulas, tools and rules to be
rights and scale assessment error across cohorts. transparent, independently validated anddisallowable.
16 Treatment-first and Supports may be refused because treatment or Require an actual-service test: available,
theoretical mainstream another service system theoretically exists, even timely, funded, accessible, appropriate,
service substitution risk where it is unavailable, unaffordable, enforceable and sufficient.inappropriate or incapable of meeting need.
17 Market consolidation and Registration, panels, commissioned supports Ensure fraud-control and commissioning
loss of participant choice and payment controls may consolidate the reforms preserve legitimate small
risk market and reduce choice, especially in thin providers, plan managers, supportmarkets. coordinators and participant choice.
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Appendix B: Key data tables used in the submission
B.1 Fiscal and macroeconomic exposure
Measure Figure Relevance
Published NDIS Budget saving $37.8b over four years Core fiscal saving requiring net-public-costtesting.
Per Capita economic activity $2.25 per $1 underfunded Used as sensitivity, not forecast.sensitivity
Mechanical economic activity $37.8b × 2.25 = $85.05b Shows scale of potential economic exposure.exposure
Jobs sensitivity 10,200 jobs per $1b underfunding Sensitivity only.
Mechanical employment 37.8 × 10,200 = 385,560 job-equivalent Illustrative exposure requiring Government
exposure positions modelling.B.2 Participant and cohort scale
Measure Figure Relevance
Active NDIS participant plans, March 774,456 Scale of Scheme exposure.2026
Children aged 0–8 167,787 Major cohort affected by Thriving Kids and early-interventionchanges.
Children aged 9–14 155,702 Further paediatric / school-age exposure.
Children aged 0–14 combined Over 323,000 Approximately 42% of Scheme participants.
Autism primary disability 338,099 active Largest primary disability group; 44% of active plans.plans
B.3 SCCP exposure
Measure Figure Relevance
Participants with SCCP funding 393,401 Scale of proposed SCCP reset.affected
Proposed SCCP reduction 50% Major reduction to community participation supports.
Psychosocial SCCP share 30% of total SCCP is recovery infrastructure, not leisure.supports
Visual impairment SCCP share 34% of total Highest selected disability share; community access is coresupports support.
Down syndrome SCCP share 28% of total High reliance for participation, communication and supportedsupports employment.
Intellectual disability SCCP share 26% of total Routine, community access, safety and skill maintenancesupports exposure.
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B.4 CBDA exposure
Measure Figure Relevance
Participants with CBDA funding affected 752,454 99% of participants with CBDA funding.
Average annualised CBDA budget $13,460 Approximately 69 therapy hours per year at $193.99/hr.
Proposed CBDA reduction 10% Around $1,346 or 6.9 therapy hours annually on average.
Children 0–8 with CBDA 166,507 100% of this age group.
Average CBDA, children 0–8 $9,900 Core early-intervention funding.
CBDA share of total supports, children 0–8 69% CBDA is the dominant support category for young children.
Children 9–14 with CBDA 152,322 100% of this age group.
CBDA share of total supports, children 9–14 42% Significant school-age capacity-building exposure.B.5 Provider-market exposure
Measure Figure Relevance
Active NDIS providers, Dec 2025 quarter Around Large decentralised provider market.276,000
SCCP providers Around SCCP cuts directly affect provider revenue.111,000
Unregistered SCCP providers Around Registration changes may affect a large unregistered market.100,800
SCCP providers delivering to one Around 56,000 Shows sole-trader / microprovider / relationship-basedparticipant exposure.
CBDA providers Around 82,000 CBDA reductions affect therapy and capacity-buildingmarkets.
Registered CBDA providers Around 9,000 Indicates mixed registered / unregistered providerenvironment.
B.6 Unpaid care and disability context
Measure Figure Relevance
Australians with disability, 2022 5.5 million Reform occurs in a large disability population.
Australians with profound or severe disability 7.9% of High-support population context.population
People with disability needing assistance whose needs 49.9% Down from 59.7% in 2018; unmet need alreadywere fully met substantial.
People with profound limitation whose needs were fully 36.7% High-risk population already under-supported.met
Unpaid carers, 2022 3.0 million Family system already carrying major load.
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Measure Figure Relevance
Primary carers, 2022 1.2 million Direct unpaid care exposure.
Primary carers with disability 43.8% Many carers are themselves disabled.
Primary carers assisting with bathing/showering 35.6% Informal care includes intimate care.
Primary carers assisting with toileting 17.2% Bodily autonomy and dignity risk.
Employment among primary carers providing 40+ hours 45.4% Heavy care strongly reduces workforcecare participation.
B.7 Schools, childcare and community health
Measure Figure Relevance
Students receiving disability adjustment, 2025 1,125,502 Schools already carry major disability-adjustmentload.
Share of total school enrolments receiving adjustment, 27.0% Up from 18.0% in 2015.2025
Children aged 0–12 in CCS-approved care, March Over 1.4 Childcare is not spare capacity.quarter 2025 million
Share of children aged 0–12 in approved care 35.0% High system participation.
Children aged 0–5 in approved care More than 50% Highest proportion in previous decade.
Clinical medical practitioner FTE, very remote areas, 205 per Demonstrates geographic health access gap.2022 100,000
Clinical medical practitioner FTE, major cities, 2022 427 per Nearly double very remote rate.100,000
B.8 Digital payments, fraud and appeals
Measure Figure Relevance
New enrolment and digital payment system $358.5m over five Major payment-control infrastructure.years
Broader NDIS reform package $1.7b over five Significant investment in control infrastructure.years
Fraud Fusion Taskforce $280.1m Fraud control investment.
Framework planning implementation $270.1m New assessment and planning infrastructure.
Mandatory registration of high-risk providers $182.6m Provider-market restructuring.
Commissioned plan management / support $49.4m Shift away from participant-directed purchasing.coordination
NDIA participant plan expenses, 2023–24 $41.85b Fraud/non-compliance claims occur in large paymentsystem.
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Measure Figure Relevance
Estimated non-compliant, fraudulent or 6–10% Justifies fraud control, not blanket support reduction.incorrect outlays
ART NDIS lodgments, 2024–25 7,935 External review is major accountability mechanism.
Increase in NDIS ART lodgments, 2024–25 95% Review demand rising sharply.
NDIS cases on hand at 30 June 2025 5,839 Significant unresolved dispute load.
Plan-related lodgments, 2024–25 6,141 Majority of disputes concern plans.
Access-related lodgments, 2024–25 1,794 Access also significant.
NDIS cases finalised by consent, 2024–25 71% Review process often corrects or resolves decisionsbefore hearing.
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Appendix C: Key quotations and relevance
Source Short quotation / point Why it matters
Productivity “underfunded, unfair, fragmented, and inefficient” Describes the pre-NDIS system theCommission, 2011 reforms risk recreating.
Office of Impact “The Scheme provides funding for reasonable and necessary States the public purpose at risk.Analysis supports to allow people with disability to be independent, and participate in social and economic life.”
Office of Impact “This more qualitative approach has been taken due to the Shows the Government did not
Analysis nature of the options and the complexity involved.” provide full monetised net-benefitmodelling.
Budget 2026–27 NDIS reforms expected to save $37.8b over four years Confirms scale of fiscal change.
Joint Standing DSS confirmed Government was not undertaking work to Supports the central modelling-gap
Committee on the model the economic benefits of the NDIS argument.NDIS
NDIS Review Foundational supports are “fundamental” and “like Supports foundational supports aspreventative healthcare” additional preventative investment, not a replacement excuse.
Minister Mark Butler “The NDIS is one of Australia’s great human rights Confirms rights-based significance ofachievements.” the Scheme.
Minister Mark Butler “ATM for shonks, grifters, fraudsters and crooks” Demonstrates fraud rhetoric that maycontaminate public attitudes toward disability support.
Disability Royal Violence, abuse, neglect and exploitation occur across Shows choice, exit rights and
Commission settings safeguards are safety mechanisms.
NDIS legislation, s 45 Agency must not pay if requested information is not Creates statutory payment-continuity
payment provision provided in the specified period and cashflow risk.
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Appendix D: Legislative risk analysis matrix and legal tripwire register
This appendix maps the major legislative and administrative mechanisms in the Bill to the practical risks identified throughout this submission. These risks should not be treated as abstract legal concerns. Each mechanism can produce real world consequences when applied across hundreds of thousands of participants, families, providers, workers and service systems.
The central concern is that small legal settings can create large practical effects once translated into assessments, budget methods, automated systems, payment rules, support determinations, provider obligations and participant review rights.
D.1 Legislative risk analysis matrix
Risk area Trigger Primary harm pathway Minimum safeguard
Whole-economy modelling Savings published without Parliament sees the saving but not Table Treasury-level net-public-cost
transparent macroeconomic GDP, jobs, tax, provider and state- modelling before passage.modelling. system costs.
False-economy cost shifting NDIA outlays reduced without Need shifts to hospitals, schools, Assess net public cost, not NDIA
modelling other systems. Centrelink, housing, justice, states outlays alone.and unpaid care.
SCCP reset Category-wide SCCP reduction. Community access, routine, Suspend reset without cohortpsychosocial stability and modelling and individual employment pathways may be safeguards. reduced.
CBDA reset Category-wide CBDA reduction. Therapy implementation, early Exempt children and activeintervention and skill-building may capacity-building participants from be weakened. blunt cuts.
Functional capacity framework Access and budgets rely on Fluctuating, neurodevelopmental, Validate tools across disability type,
assessment tools and definitions. psychosocial and invisible disability culture, age and complexity.may be missed.
Whole-person test Supports linked only directly to Interacting impairments may be Delete or qualify “directly”.access impairment. split and excluded.
Family and informal supports Informal support considered before Unpaid family care becomes a Require voluntary, safe,
funding approval. funding substitute. sustainable, realistic and chosensupport.
24/7 and intimate care Uniform cuts or family substitution Unsafe gaps in personal care, Automatic exemption for complex,
affect high-intensity supports. supervision, communication, continuous and safety-relatedbehaviour or health support. supports.
Treatment-first access Participants may need to exhaust Unavailable or unsuitable Count only accessible, appropriate
treatment before access/support. treatment becomes a barrier to treatment likely to removedisability support. functional need.
Alternative systems NDIS support refused because Participants are referred into Require actual, timely, funded,
another system theoretically exists. services that cannot meet need. accessible, enforceable andsufficient support.
Thriving Kids / foundational Children redirected into capped Individualised early intervention No transition without per-child,
supports supports. may be replaced by capped or demand, workforce and state-group services. capacity models.
Hidden caps and formulas Caps, formulas and weights sit in Practical funding rules move Make all caps, formulas and cohort
tools or incorporated documents. outside parliamentary scrutiny. definitions transparent anddisallowable.
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Risk area Trigger Primary harm pathway Minimum safeguard
Capital continuity Plan renewal or non-carry-over Approved AT, home or vehicle Carry forward quoted, ordered,
affects one-off items. modifications may lose funding. approved or underway capitalsupports.
Emergency reassessment Tighter unscheduled reassessment Deterioration, provider failure, Create a 14-day emergency
rules. carer breakdown or housing risk reassessment pathway.may wait too long.
Suspension and revocation Plans may be suspended/revoked Communication, housing, cognitive Define contact steps and require
after contact failure. or psychosocial barriers may trigger accessible human review.loss of support.
Claim and record rules Short claim windows, information Good-faith error or disability- Longer windows, exceptions and
requests and debt powers. related administration barriers may good-faith protections.become non-payment or debt.
Digital payments Electronic claiming and pre- Legitimate supports may be Require urgent-support exceptions,
payment evidence requests. delayed, blocked or suspended. human review and cashflowsafeguards.
Automation / robo-assessment Administrative actions, claims or Scaled error may affect plans, Require transparency, audit,
budgets may be automated. payments, claims, suspension or accessibility testing and humanreview. review before adverse effect.
Appeal rights Tribunal may lack power to vary or Review exists in form but not in Preserve full merits review and ART
substitute funding decisions. remedy. power to correct funding decisions.
Provider registration and panels Registration, civil penalties, panels Small providers may exit and Use risk-proportionate compliance
and commissioning. participant choice may narrow. and thin-market protections.
Harm reporting Evaluation occurs after Harm may be measured after Require quarterly harm reporting
implementation. supports, markets or carers have and remedial triggers.collapsed.
D.2 Consolidated legal tripwire register
No. Legal tripwire Risk Minimum safeguard
1 Category-wide cuts Participants may lose funding Retain merits review where thethrough broad support reduction creates harm or unsafe determinations without an loss of support. individually reviewable merits decision.
2 Complex 24/7 supports Uniform percentage cuts may Automatic exemption for complex,create unsafe gaps in supervision, continuous, intensive or safety behaviour support, related support needs. communication, personal care or health support.
3 Hidden caps Cap numbers may sit in external Require cap values, budgetincorporated documents rather formulas and cohort definitions to than directly in disallowable rules. be disallowable.
4 Whole-of-person test The word "directly" may split Delete or qualify "directly" sointeracting impairments and whole-person functional impact exclude real functional need. remains recognised.
5 Capital funding continuity Quoted, ordered, approved or Carry forward one-off fundingunderway equipment and already actioned.
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No. Legal tripwire Risk Minimum safeguardmodifications may lose funding on plan renewal.
6 Emergency reassessment Support collapse, housing risk, Create a 14-day emergencyhealth risk or safety risk may wait reassessment pathway. too long.
7 Suspension and revocation Undefined contact attempts may Define contact steps and requireharm people in crisis or with accessible human review. communication barriers.
8 Treatment-first access Unavailable, unaffordable, Only count treatment that isinappropriate or traumatising accessible, appropriate and likely treatment may be treated as to remove eligibility-level appropriate. impairment.
9 Alternative schemes Theoretical access to health, Require actual, funded, timely,education, housing, compensation accessible, enforceable and or state systems may substitute sufficient alternative support. for real support.
10 Self-management and nominee Short claim windows and civil Longer claim windows, exceptions
risk penalties may punish disability- and good-faith protections.related administration barriers or good-faith family nominees.
11 Replacement supports Rigid rules may block cheaper Assess by functional outcome andmainstream alternatives that total public cost. achieve the same or better functional result.
12 Evidence hierarchy Peer-reviewed evidence Recognise lived experience,requirements may exclude rare, clinical judgement and functional individualised, emerging or lived- evidence. experience supports.
13 Informal care and bodily Personal and intimate care may be Protect dignity, privacy and
autonomy forced back onto families. choice; fund formal support whereneeded.
14 Automated decision-making Automation may affect plans, Human review before adverseclaims, payments, suspension or effect and statutory automated review without enforceable decision reporting. safeguards.
15 Harm reporting Harm may be discovered only Quarterly public harm reportingafter implementation. and independent review with remedial trigger.
D.3 Core legal finding
The Bill does not only change individual decisions. It changes the rules, tools, assumptions and administrative machinery through which future decisions will be made.
If caps, formulas, assessment weights, support determinations, automated payment rules and review limits are not transparent, disallowable and independently reviewable, the practical funding decision may move out of Parliament and into administrative machinery.
The minimum standard is clear: transparency, disallowance, accessibility, human review, full merits review, actual-service testing, cohort-specific modelling and real-time harm monitoring.
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Appendix E: Cohort impact matrix
This matrix consolidates the cohort-impact analysis and shows how the same reform mechanism can create different functional, economic and safeguarding consequences across disability groups.
Cohort Main reform exposure Functional and economic Required evidence andimpact safeguard
Autism and neurodevelopmental Thriving Kids, CBDA/SCCP cuts, Misclassification, school refusal, Autism-specific assessment
disability assessment tools, group supports. communication delay, validation; use home, school andsensory/executive dysfunction, family evidence; no unsuitable family burnout; costs shift to group substitution. families, schools and mental health.
Developmental delay / early Thriving Kids, CBDA cuts, state- Lost developmental window, No child loses support until funded,
childhood system substitution. reduced parent coaching, delayed local, accessible and enforceablespeech, motor, self-care and alternatives operate. regulation skills; costs shift to parents, childcare, schools and future NDIS.
Intellectual disability SCCP cuts, automation, appeal Skill regression, exploitation risk, Easy Read, supported decision-
barriers, provider consolidation. isolation and reduced supported making, advocacy, continuitydecision-making; costs shift to safeguards and human review. families and safeguarding systems.
Psychosocial disability SCCP cuts, treatment-first rules, Relapse, hospitalisation, No blanket SCCP reset without
reassessment limits. homelessness, police contact, carer recovery-oriented individualdistress; community participation is assessment and actual-service recovery infrastructure. testing.
Visual impairment SCCP cuts, transport/interface Unsafe community access, Protect orientation, mobility,
rules, provider restrictions. isolation, reduced independence transport and community accessand family transport burden. supports.
Down syndrome SCCP/CBDA cuts and employment Reduced communication Cohort-specific modelling and
pathway risk. opportunities, supported protection for communication andemployment readiness, social employment supports. participation and family respite.
Complex physical disability / CP / Personal care, AT, transport, Reduced mobility, pressure injury Assess through health-prevention
SCI therapy and SCCP reductions. risk, carer injury, isolation, health and participation lens; protectdecline and loss of work/study personal care, AT, transport and access. therapy implementation.
Acquired brain injury Reassessment limits, executive- Missed deterioration, behavioural ABI-informed assessment,
function barriers, automation. escalation, family breakdown, debt executive-functionor support loss. accommodations and rapid reassessment pathway.
Progressive neurological conditions Rigid planning and reassessment Delayed response to decline, falls, Guaranteed rapid plan variation for
limits. hospitalisation and carer collapse. deterioration and episodic decline.
Hearing / communication disability Inaccessible notices, automation, Missed deadlines, exclusion, debt, Accessible communication before
appeal barriers. support loss and inability to adverse action: Auslan, captioning,challenge decisions. interpreters, Easy Read, alternative contact and human review.
First Nations participants Evidence burden, geography, Underutilisation, distrust, service Co-designed culturally safe
cultural safety and thin markets. gaps and cost shifting to pathways, local service mappingfamilies/community-controlled and no substitution without actual services. access.
CALD participants Language barriers, evidence Misassessment, under-claiming, Interpreting, translated materials,
burden, navigation. reduced culturally safe support and advocacy and culturally appropriateinability to challenge decisions. assessment.
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Cohort Main reform exposure Functional and economic Required evidence andimpact safeguard
SIL/SDA and congregate settings SCCP cuts and provider Housing becomes containment; Protect community access,
consolidation. reduced community visibility and independent advocacy, providerabuse-exit options. exit pathways and incident monitoring.
Executive-function disability Claim windows, records, digital Missed deadlines, payment failure, Reasonable adjustments,
payments, suspension. debt and support loss caused by reminders, nominee contact, longerdisability-related administration timeframes and supported human barriers. follow-up.
24/7 and intimate-care participants Personal care funding, family Loss of hygiene, privacy, bodily Exempt high-risk and continuous
substitution and provider autonomy, safety and dignity; supports; count informal care only
restrictions. unpaid family care and hospital risk if voluntary, safe, trained,increase. proximate and chosen.
Regional, rural and thin-market Provider exit, registration burden, A pathway on paper becomes no Thin-market continuity plans,
participants payment delays, state substitution. service in town; travel, family provider-exit modelling and ruralburden and provider closure service guarantees. increase.
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Appendix F: Scenario failure analysis
This matrix consolidates the foreseeable implementation failure scenarios and the evidence the Senate should require before the Bill proceeds.
Scenario What happens if the assumption fails Likely displaced cost Evidence the Senate should require
1. State and Participants lose NDIS supports before Families, schools, community State-by-state readiness model,
foundational replacement services exist. The result is health, hospitals, Centrelink, waitlist data, workforce capacity,
supports are delayed not transition; it is withdrawal. crisis services and future NDIS re- service guarantees and rapid NDIS re-entry. entry pathway.
2. Thin markets A regional or specialist provider loses Loss of service access, higher Provider-exit modelling by region,
collapse enough participant income to close. travel costs, unmet need, family thin-market continuity plans,
Participants cannot simply choose care, provider exit and local job workforce mapping and service-gap
another provider because no equivalent loss. reporting.provider exists locally.
3. Carers absorb the Families initially cover reduced paid Lost wages, lost tax receipts, Unpaid-care substitution model,
shortfall supports. The policy appears to save reduced superannuation, carer gendered workforce modelling, carer
money, but carer employment falls, burnout, mental health costs and health modelling and household
health declines and crisis risk grows. family breakdown. income impact.
4. Workers become Support workers are told there is Lower income tax, Centrelink Local labour-market modelling,
underemployed demand elsewhere in care, but local exposure, reduced household underemployment data,
funded hours disappear faster than spending, business closures and redeployment feasibility and regional
alternative work emerges. workforce attrition. workforce impact.
5. Automation A claim, payment, notice, assessment or Support interruption, unpaid Automation impact assessment,
creates exclusion suspension is processed automatically. providers, debt, complaints, accessibility testing, human review
The participant does not understand the reviews, advocacy demand and rights, error-rate reporting and
decision or cannot respond in time. crisis escalation. adverse-action safeguards.
6. Fraud measures Participants avoid using supports, or Underutilisation, provider Fraud-control impact model,
create participant providers avoid complex participants, withdrawal, unmet need, distinction between fraud and
and provider fear because records, penalties, payment participant distress and reduced administrative incapacity, provider
delays and debts feel too risky. service continuity. cashflow safeguards and participantprotections.
7. Group supports Participants are moved into group Functional decline, family Suitability criteria, individual
replace individual options because individual budgets are burden, behaviour escalation, exception pathways, outcome data,
supports reduced. This may look efficient but can dropout, exclusion and future dropout data and safeguards for
reduce dignity, safety and functional higher support needs. people unable to tolerate groups.outcomes.
8. Appeal systems People seek review after reductions, or Administrative churn, legal costs, Review-volume modelling, ART
flood or remedies lose effective review rights. distress, delayed correction, crisis powers, consent-outcome data,
narrow Administrative savings are offset by escalation and unresolved unmet funding-remedy protections and
internal reviews, ART matters, advocacy need. appeal-timeframe reporting.demand and stress-related harm.
9. Early childhood Children moved out of individualised Delayed development, school Per-child funding model, service
supports fragment pathways enter capped state systems pressure, childcare exclusion, intensity, provider capacity, workforce
with waiting lists, group-based models parent workforce withdrawal and modelling, geographic access and
and inconsistent service quality. later higher support intensity. NDIS re-entry rules.
10. Mental health Evaluation occurs after supports are Psychological distress, crisis Real-time harm monitor, distress
worsens before removed. Harm is documented only contacts, carer collapse, indicators, complaints data, crisis
evaluation after families and participants have disengagement, hospitalisation referral pathways and remedial
already absorbed it. and loss of public trust. triggers.
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Appendix G: Questions for the Committee to put to Government witnesses
G.1 Macroeconomic modelling
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Has Treasury modelled the effect of the $37.8b saving on GDP, employment, tax receipts and household consumption?
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If not, why is Parliament being asked to consider the Bill without this analysis?
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What multiplier assumptions has Government accepted or rejected?
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Has Government modelled provider exits, underemployment and reduced local spending?
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Has Government modelled increased Centrelink exposure if disability-sector workers lose hours? G.2 Participant harm and cohort impact
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How many participants are expected to lose actual support hours?
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Which cohorts are expected to be most affected by SCCP and CBDA reductions?
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What harm indicators will trigger a pause or reversal?
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Has Government modelled functional decline, hospitalisation, school exclusion, carer collapse and future NDIS re- entry?
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What disability cohort impact assessments have been completed? G.3 SCCP and CBDA reductions
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Why is SCCP being treated as reducible where it maintains routine, employment readiness, psychosocial stability and community access?
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Why is CBDA being reduced where it funds therapy implementation and early childhood capacity building?
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How will Government distinguish low utilisation caused by low need from low utilisation caused by provider shortages, waitlists or access barriers?
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Which cohorts will be exempted from blanket reductions? G.4 Thriving Kids and foundational supports
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What per-child funding model applies to Thriving Kids?
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What service intensity will children receive?
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What happens when a child cannot tolerate group-based support?
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Who provides in-home and community implementation support?
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Which level of government is legally responsible if the service is unavailable?
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What rapid NDIS entry or re-entry pathway will apply? G.5 Treatment-first and mainstream substitution
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How will Government define “all appropriate treatment”?
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Will treatment be counted if it is unaffordable, unavailable, culturally unsafe, traumatising, waitlisted or unlikely to remove functional impairment?
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Can NDIS support be refused because another system exists only in theory?
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What actual-service test will apply before a person is redirected to health, education, housing, compensation or state services?
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G.6 Digital payments, automation and appeals
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What claim-blocking rules will apply under the digital payment system?
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What human review timeframe will apply before essential supports are disrupted?
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How many claims are expected to be suspended or rejected?
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Will participants retain full merits review of the total funding amount?
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Will the ART have power to substitute or vary funding decisions?
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What assessment tools, formulas and weightings will be published and disallowable? G.7 Providers and market consolidation
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How many providers are expected to exit because of registration, panels, payment systems or funding reductions?
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How will Government protect sole traders, microproviders and thin markets?
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How will plan-management panels affect existing plan managers?
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How will commissioned support coordination preserve participant independence?
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How will participants leave unsafe providers if market choice narrows? G.8 Mental health and public trust
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What assessment has Government made of participant distress caused by reform uncertainty?
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How will public communication separate provider fraud from participant legitimacy?
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What independent advocacy funding will be provided before reforms commence?
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What crisis referral pathways will be offered during transition?
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Appendix H: Proposed safeguards / conditions before passage
Proposed safeguard Purpose
Condition precedent: Reforms cannot commence until independent modelling of GDP, jobs, tax receipts and macroeconomic impact displaced costs is tabled. statement
Condition precedent: No participant may be moved to non-NDIS supports unless the alternative is funded, foundational supports readiness operational, accessible and enforceable.
Participant no-worse-off No participant loses supports where evidence shows reduction may reduce safety, safeguard independence, communication, work, study, community access or carer sustainability.
SCCP protection clause SCCP cannot be reduced where it maintains employment, psychosocial stability, safety, supported decision-making or community visibility.
CBDA protection clause CBDA cannot be reduced for children, early intervention, transition, therapy implementation or capacity-building goals without individual review.
Intimate-care dignity safeguard Personal care and intimate supports cannot be shifted to family unless voluntary, safe, sustainable and chosen by the participant.
Actual-service test Treatment or mainstream services only replace NDIS support where actual, timely, funded, accessible, appropriate, enforceable and sufficient.
Accessible administration clause No suspension, debt, claim rejection or adverse action without accessible communication and advocacy or nominee support.
Automation safeguard Automated administrative action must be transparent, reviewable, non discriminatory and subject to human intervention before adverse effect.
Appeal-right safeguard Participants retain full merits review, including power for the ART to vary or substitute funding decisions.
Provider continuity clause NDIA must assess thin-market service continuity and publish mitigation plans before provider restrictions or budget cuts.
Small-provider transition support Legitimate sole traders, microproviders and small allied health practices should receive proportionate compliance pathways.
Digital payment safeguard Payment controls must include urgent-support exceptions, provider cashflow protections and human review.
Independent harm monitor Independent body led by people with disability and economists reports every six months on functional, economic, provider, carer and rights impacts.
Sunset and disallowance Ministerial support determinations, assessment formulas, caps and incorporated budget rules should sunset unless renewed by Parliament after impact reporting.
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Appendix I: One-page evidence propositions for Senators
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A Budget saving is not a net national saving. The Government has modelled the saving but not the displaced cost.
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Social participation is disability support. SCCP maintains routine, community visibility, psychosocial stability, employment readiness and carer sustainability.
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Capacity building is prevention. CBDA is where therapy recommendations become daily-life skills.
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Fraud control must not become support control. Fraud should be prosecuted without reducing legitimate supports or stigmatising participants.
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Foundational supports must be built first. The NDIS was created because the previous state-based model was fragmented and rationed.
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Thin markets do not behave like normal markets. Where there is no alternative provider, market exit means service disappearance.
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Unpaid care is not free. Cutting funded supports shifts labour to families, especially women, with effects on work, income, health and superannuation.
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Population growth is not disability demand. Disability prevalence, functional need, ageing carers, unmet need and service failure are not captured by population growth alone.
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Automation needs disability safeguards. Automated claims, payments, notices and assessment tools can create real-world harm.
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Appeal rights are not symbolic. External merits review corrects decisions; weakening it makes errors harder to fix.
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Choice and control are safety mechanisms. Participants need the ability to leave unsafe, unsuitable or culturally unsafe providers.
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Evaluation after harm is not a safeguard. Monitoring must occur before and during implementation, with remedial triggers.
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Appendix J: Core bibliography
Australian Government Budget 2026–27. Strengthening care and broadening opportunity.
Australian Government Department of Health, Disability and Ageing. NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 – fact sheet.
Australian Government Office of Impact Analysis. National Disability Insurance Scheme Reforms – Impact
Analysis.
Department of Health, Disability and Ageing. 2026–27 Health Portfolio Budget Statements.
National Disability Insurance Agency. Quarterly Reports.
NDIS Data and Insights. Participant datasets.
Australian Bureau of Statistics. Disability, Ageing and Carers, Australia: Summary of Findings, 2022.
Australian Bureau of Statistics. Labour Force, Australia, April 2026.
Australian Institute of Health and Welfare. People with disability in Australia.
Productivity Commission. Disability Care and Support, 2011.
NDIS Review. Working together to deliver the NDIS – Final Report.
Parliament of Australia, Joint Standing Committee on the NDIS. Implementation, Forecasting and Sustainability.
Per Capita / National Disability Services. False Economy: The economic benefits of the NDIS and the consequences of government cost-cutting.
Administrative Review Tribunal. Annual Report 2024–25.
Australian National Audit Office. NDIA management of claimant compliance with NDIS claim requirements.
Parliamentary Joint Committee of Public Accounts and Audit. Procurement of the PACE platform by NDIA.
Parliamentary Budget Office. 2026–27 Budget Snapshot.
Disability Royal Commission. Final Report.
Minister Mark Butler. National Press Club speech, 22 April 2026.
Disability Advocacy Network Australia. DANA message, April 2026.
People with Disability Australia. Public comments on the 2026–27 Budget and NDIS reform package.
Paior, Sam / The Growing Space. Submission to the Senate Community Affairs Legislation Committee: NDIS
Amendment Bill 2026.
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