Submission 642 - Supplementary Submission
Inquiry into NDIS Amendment (Securing
the NDIS for Future Generations) Bill
2026
Response to consultation extension 10 July 2026
Recipient
Committee Secretary
Senate Standing Committees on Community Affairs - Legislation Committee
community.affairs.sen@aph.gov.au
Dietitians Australia contact
Dr Sabrina Pit, Senior Policy Officer
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Submission 642 - Supplementary Submission
About Dietitians Australia
Dietitians Australia is the national association of the dietetic profession with over 9,000 members, and branches in each state and territory. Dietitians Australia is the leading voice in nutrition and dietetics and advocates for the profession and the people and communities we serve. The Accredited Practising Dietitian (APD) program is the credentialling program of Dietitians Australia. It provides an assurance of safe and quality dietetic practice and is the foundation of self-regulation of the dietetic profession in Australia. This submission was prepared by members of the Dietitians Australia Disability Sector Expert Reference Group following the Conflict-of-Interest processes approved by the Board of Dietitians Australia. Contributors include APDs who are NDIS registered providers, with a full list detailed at the end of this submission including representatives from different States.
Response to Interim Report released 23 June 2026 Dietitians Australia provided an initial response (submission #642)1 and we would welcome the opportunity to present at the upcoming hearings in Canberra (30 and 31 July 2026) and Western Australia (6 August 2026). Given the potential impact on NDIS participants, we believe it would be vital to have Accredited Practising Dietitians, working at the coalface in Western Australia and across other states and territories, provide practical and clinical insights into how the proposed amendments will affect participants’ access to safe, effective and disability-specific nutrition and dietetic therapy supports, particularly for people with complex feeding, hydration, swallowing, enteral nutrition (tube feeding into stomach or bowel), sensory, behavioural and functional capacity needs.
What can an Accredited Practising Dietitian do for people with disability? Accredited Practising Dietitians support one of the most fundamental activities of daily living, eating and drinking, for people whose disability directly impairs their capacity to do so safely, adequately, and independently. The therapeutic support APDs provide enables and equips participants living with disability to engage in therapy, education, employment, family routines, and community participation. Nutrition and dietetic supports are functional, capacity-building, and disability-specific. When removed or reduced, the consequences extend across every domain of a participant’s daily life, negatively impact the success of allied health therapies and will likely increase, not decrease long-term scheme costs. Figure 1 shows the typical therapy of an Accredited Practising Dietitian for people with disability and provides examples of risks associated with the Amendment Bill.
____ 1 DA Submission #642. https://www.aph.gov.au/DocumentStore.ashx?id=9ae04d6d-44d2-4859-a684-1938f539e208&subId=791705 2
Submission 642 - Supplementary Submission
Figure 1 Accredited Practising Dietitians support people with disability
Figure 2 illustrates a case study of a young boy called ‘Rory’2. Rory’s life will be significantly impacted with the introduction of the current Bill due to the narrow interpretation of ‘direct link’ and the exclusion of dietetic therapy to ensure nutrition and hydration adequacy and expanding safe participation in eating. This dietetic support risks being excluded despite arising unambiguously from his disability. The success of Rory’s physiotherapy, speech therapy and occupational therapy interventions is also dependent on Rory’s nutrition and hydration status. There are many more such real-life examples to explain the complexity of dietetic care for people living with disability. This complexity is often ignored or misunderstood.
____ 2 ‘Rory’ is a real life NDIS participant, however the case was de-identified for privacy purposes. 3
Submission 642 - Supplementary Submission
Figure 2 How Rory’s life is impacted by his disability from a nutrition and dietetic perspective
Participant and provider safety: Dietitians Australia continues to hold serious concerns about the Bill and does not support it in its current form. The proposed changes create unacceptable risks for NDIS participants, particularly in relation to safety, access to allied health supports, and the availability of capacity-building supports (See Figure 1 above) Further evidence provided by a variety of stakeholders during the Inquiry reinforced these concerns. The proposed reforms are likely to have wide-reaching harmful consequences for participants, allied health providers, families and communities. In particular, they will limit participants’ ability to develop skills, increase independence, improve daily functioning, and participate more fully in family, education, work and community life. Beyond this, Accredited Practising Dietitians hold deep concerns about the misunderstood functional benefits and risk protections that nutrition and dietetic therapy enable. The absence or significant reduction of nutrition and dietetic supports will reduce the functional capacity of a participant, their ability to function independently and confidently and participate in daily activities. The success of other allied health interventions is dependent on an NDIS participant’s nutrition and hydration status and their physical ability to effectively participate in therapy interventions. For individuals who rely on enteral feeding (via a tube to stomach or bowel) or a combination of oral feeding (with texture modification and enteral tube feeding) it also means their feeding schedules and modifications need to be carefully planned and scheduled to ensure therapy interventions such as Physiotherapy or Occupational Therapy can effectively occur. More specifically, a person with disability who is undernourished or dehydrated will lack the energy and cognition to respond to therapeutic intervention, activity or instruction. These safety concerns are not theoretical. DA’s de-identified case studies describe participants whose reduced or absent dietetic support can increase risks of choking, reflux-related deterioration, gastrointestinal bleeding, wound infection, delayed healing, unintentional weight loss, kidney failure, falls, behavioural escalation, restrictive practices, metabolic instability and avoidable hospitalisation. Providers are concerned because, without appropriate dietetic assessment, planning and support-worker training, participants may be left relying on informal or non-clinical feeding, hydration and nutrition decisions in situations where small errors can lead to serious deterioration, acute care escalation, or increased reliance on high-intensity supports. 4
Submission 642 - Supplementary Submission
With a reduction in dietetic therapy supports, APDs have already observed NDIS participants experiencing significant deteriorations in their physical condition and functional capacity. Workforce exodus – keeping existing expertise is more cost-efficient: A workforce exodus is already occurring. There is significant risk that the Bill will weaken an already fragile allied health market. Many providers are already reporting pressures that may force them to reduce services, close their books, withdraw from NDIS work, or cease operating altogether. This would further reduce access for participants who already face long wait times and limited service options. The ongoing sustainability of dietetic workforce supply within the disability sector is causing deep concern. With access to dietetic therapy being restricted and inappropriately priced, the viability of practices has become untenable. Many dietitians are now forced to leave the sector and redirect their work to other sectors. This will result in a significant reduction in NDIS service delivery capacity and will leave participants with fewer safe and qualified providers. Dietitians Australia has over the last 2 years conducted surveys amongst Accredited Practising Dietitians (the majority are sole practitioners and small business owners) to understand the sentiment. It provided staggering findings. These are presented in the highlighted section below.
June 2024 – Price freeze. 25% of APDs in the disability sector considering stopping some or all services to NDIS participants due to the ongoing pricing restrictions since 2019 (note pricing was frozen for 5 years prior and not indexed despite rising costs). June 2025 - Price reduction effective 1 July 2025. 64% of APDs working in disability sector indicated that they were considering ceasing or reducing NDIS services. Dietitians reported business losses. June 2026 - Price reduction effective 1 July 2026. APDs have now informed Dietitians Australia that their businesses are no longer viable and they will cease to accept new NDIS clients. Furthermore, they indicated their intention is to leave the sector completely given that business losses are projected to triple due to ongoing rise in business operating costs. A loss of skilled dietetic workforce within the sector will place participants at risk and diminish the efficiency and goals of the scheme.
The assumption that reductions in capacity-building funding will be offset by improved plan utilisation is overly simplistic. It does not reflect the real-world barriers affecting therapy access, including provider shortages, service viability, travel demands and thin markets. These issues are especially pronounced in rural and remote areas, where participants often have fewer providers to choose from and face additional barriers to receiving timely and appropriate allied health support.
Recommendations
If the Bill proceeds: Dietitians Australia urges Parliament to include stronger protections before any reforms are implemented. This includes clear parliamentary scrutiny, protected review rights, and safeguards for participants. Any amendments must also protect the clinical expertise of allied health professionals, including Accredited Practising Dietitians. Decisions about participants’ nutrition, hydration and dietetic needs should be informed by qualified dietitians and must not be displaced by generic tools, automated decision-making, standardised algorithms, or staff without appropriate clinical training. We also request that the order in which reforms are being pursued is adjusted. Major changes to NDIS access, eligibility or funded supports should not occur until alternative and complementary supports outside the NDIS are fully established, accessible, properly funded, and proven to meet participant needs.
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Submission 642 - Supplementary Submission
The Dietitians Australia Disability Sector Expert Reference Group proposes the following amendments to Schedule 1 of the Bill that carry significant risks for participants whose disability directly impairs their ability to eat (nourish), drink (hydrate), prepare food, and sustain the nutrition required for daily function and participation.
Provision from Our concerns Our recommendationsSchedule 1
Part 1: Defining Functional capacity assessed without Align with the WHO definition3 that
Functional Capacity environmental context may environment-dependent and caregiver-underestimate disability-related feeding dependent functional feeding
Item 4 / s.9B and hydration impairments that are impairments remain valid expressions ofcontext-dependent or support- disability-related functional capacity and dependent. are not excluded from assessment due to contextual variation.
Part 3: Strengthen link A narrow interpretation of “directly Clarify that functional feeding
between impairment arising” may exclude feeding impairments impairments arising through cognitive,
and need for support arising through cognitive, sensory, sensory, behavioural, or motor pathwaysbehavioural, or motor pathways. are considered to arise directly from the Item 28 / s.32K(3A) participant’s disability and remain eligible for support.
6—Reasonable and Uniform maximum therapy caps may Consultation with peak allied health
necessary supports restrict clinically necessary dietetic input bodies; ensure exemptions for ongoingwithout disability-specific evidence. clinical risk and complex care needs; and Item 68 / s.33(2EA) allow clinician-led variation or override where functional need is demonstrated.
6—Reasonable and Referring NDIS participants to Medicare Consider the unique limitations faced by
necessary supports for allied health services disregards the NDIS participants when deciding if referralNDIS Bill and overlooks the limitations to ‘health services’ is accessible and
Item 70 / insertion faced by hospital outpatient clinics and practical for the NDIS participant.after 34 (1)(f) Medicare Chronic Disease Management Plans.
6—Reasonable and The limited evidence base may Call for more research and consultation to
necessary supports disadvantage people with a disability; the address evidence gaps where population-migration of care to Medicare Chronic level evidence is limited. Item 73 / s.34(1E) Disease Care plans is not fit-for-purpose for people with a disability.
6—Reasonable and Include all three components of Evidence After 1E(a) add new (b):
necessary supports Based Practice to determine whether a “(b) The clinical expertise and professionalsupport is effective or beneficial for the judgement of an appropriately qualified
Item 73 / s.34(1E) participant: best available evidence; health practitioner, including evidenceclinical expertise; and patient values and about the participant’s individual preferences.4 functional capacity, risks, support needs, disability-related circumstances and likely outcomes.”
We further recommend that the evidence framework be adjusted to ensure it is appropriate for disability specific practice where population-level research may be limited but clinical need and functional outcomes are well established in practice. The evidence framework could be strengthened by:
Recognising that the absence of generalisable research for a specific disability population does not indicate that an intervention is ineffective or inappropriate.
____ 3 World Health Organization. ICF. https://www.who.int/standards/classifications/international-classification-of-functioning-disability-and-health 4 Sackett, D. L., Rosenberg, W. M. C., Gray, J. A. M., Haynes, R. B., & Richardson, W. S. (1996). Evidence based medicine: What it is and what it isn’t. BMJ, 312(7023), 71–72. https://doi.org/10.1136/bmj.312.7023.71 6
Submission 642 - Supplementary Submission
Equally ranking demonstrated functional outcomes for individual participants (consistent with subsection 34(1E) (c)) with generalisable research where population-level evidence is limited. Requiring the NDIA to maintain clear guidance on disability-specific populations where the evidence base is acknowledged to be limited, but where there is strong clinical consensus and established practice supporting intervention. Require mandatory consultation with Dietitians Australia and relevant peak allied health bodies prior to commencement to avoid unintended consequences. Ensuring review and oversight by the Evidence Advisory Committee. Removing reliance on an open-ended discretion such as “any other matters the CEO considers appropriate,” to ensure transparency, consistency, and clinical accountability in decision-making frameworks.
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