Submission 647
Committee Secretary
Senate Standing Committees on Community Affairs
PO Box 6100
Parliament House
Canberra ACT 2600
Dear Committee Secretary,
Re: Parliamentary Inquiry - National Disability Insurance Scheme Amendment
(Securing the NDIS for Future Generations) Bill 2026
We are a small organisation providing independent Support Coordination services to approximately 70 participants of all ages across the greater Brisbane area. We welcome the opportunity to provide comments on the Securing the NDIS for Future Generations Bill 2026, referred to throughout this submission as “The Bill.” We are writing this submission, as professionals who work closely with persons with disabilities and their families.
We are writing to oppose the Amendment Bill in its current state, as although we don’t dispute the fact that the scheme needs to be sustainable for future generations, we don’t believe that the answer to the reform is narrowing the eligibility of the scheme, removing participants’ choice and control, or measuring the functional capacity of people in artificial conditions.
Our Key areas of concern include: 1. Commissioned panel of Support Coordination and Connection providers 2. Commissioned panel of Plan Management providers 3. Functional Capacity definition 4. Increased family responsibility and administrative burden 5. Plan reassessments, flexibility and automatic plan renewals 6. Shift to foundational supports 7. Expansion of mandatory registration requirements
1. Commissioned panel of Support Coordination and Connection providers
We oppose the proposed commissioned panel model for support coordination and connection services under The Bill. The proposed changes would remove participant-directed choice by limiting access to providers selected through a government commissioning process, rather than allowing participants to choose a provider that best understands their individual needs, goals, communication style, and circumstances. This undermines the core NDIS principles of choice and control and risks reducing the quality and individualisation of support participants receive.
We are also concerned by the lack of clarity regarding mandatory registration requirements for support coordination providers and how these requirements will interact with the proposed commissioning model. There is significant uncertainty regarding whether smaller or specialist providers will be able to meet future registration and procurement requirements, which may force experienced providers to exit the sector and further reduce participant choice, particularly in regional areas and for participants with complex needs.
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The proposed reforms also create serious risks to continuity of support for participants who rely on long-standing and trusted relationships with their support coordinators. Disrupting these relationships may lead to participant distress, disengagement from services, increased safeguarding risks, and poorer outcomes. Within our organisation we have many participants that we have worked with for over nine years, leading to close and trusted working relationships that help achieve the best outcomes for these participants. We recommend that support coordination remain individually funded and participant-directed, with safeguards to preserve participant choice, provider diversity, and continuity of support.
Recommendations
● Participants retain the right to choose and change their support coordinator ● The Government provides greater transparency and consultation regarding any proposed registration requirements ● Reforms include safeguards to preserve smaller and specialist providers within the market ● Any future changes prioritise continuity of support and minimise disruption to existing participant-provider relationships 2. Commissioned panel of Plan Management providers
We oppose the proposed commissioned panel model for plan management providers under The Bill. The proposed changes would significantly reduce participant choice and control by limiting participants to plan management providers selected through a government commissioning process, rather than allowing participants to freely choose a provider that best meets their individual needs and preferences. Plan management is not simply an administrative function — many participants rely on responsive and personalised relationships with their plan managers to understand their budgets, navigate the NDIS, resolve payment issues, and exercise informed choice over their support.
We are concerned that a commissioned panel model would substantially reduce the size and diversity of the plan management workforce by excluding many small, independent, and specialist providers from the market. This risks reducing competition, limiting service quality, and decreasing the availability of culturally responsive, regionally based, and participant-centred services. Participants may be left with fewer options and less flexibility to choose providers who align with their communication needs, values, and circumstances.
The proposed reforms risk undermining one of the key mechanisms that currently enables participants to exercise flexibility and autonomy within the NDIS. We recommend that plan management remain participant-directed, with participants retaining the right to choose and change their preferred plan management provider. Any future reforms should prioritise preserving participant choice, maintaining a diverse provider market, and ensuring continuity and quality of service for NDIS participants.
Recommendations
● Plan management should remain participant-directed, with participants retaining the right to choose and change their preferred plan management provider at any time.
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● The Government should not implement a commissioned panel model that limits provider access or reduces market diversity, particularly for small, independent, specialist, and regional providers. ● Any reforms to plan management should prioritise participant choice and control, continuity of service, and the preservation of a diverse and sustainable workforce across the sector. 3. Functional Capacity definition
We oppose the proposed changes to the definition and assessment of functional capacity under The Bill. The proposed approach appears to narrow the interpretation of functional capacity and place increased emphasis on standardised assessment processes, which risks failing to capture the real-world and fluctuating impacts of disability on participants’ daily lives. Functional capacity cannot be accurately understood through rigid or overly simplified assessment frameworks alone, particularly for participants with psychosocial disability, neurodevelopmental conditions, episodic conditions, or complex support needs.
We are concerned that the proposed changes may create additional barriers for participants seeking access to the NDIS or appropriate levels of support by placing greater weight on clinical or standardised measures rather than lived experience, environmental factors, and the practical realities of disability. Many participants experience significant functional impairment that fluctuates over time or is not easily measured through traditional assessment tools. A narrower definition of functional capacity may result in participants being deemed ineligible for support or receiving inadequate funding despite experiencing substantial day-to-day challenges.
The proposed reforms also risk increasing inconsistency, confusion, and administrative burden for participants, families, and providers navigating access and planning processes. We recommend that any definition of functional capacity remain broad, person-centred, and reflective of the social model of disability, with recognition of fluctuating conditions, cumulative barriers, and the importance of considering a participant’s individual circumstances, environment, and support needs when determining eligibility and funding.
Recommendations
● The definition of functional capacity should remain person-centred, reflecting the social model of disability and capturing the real-world impact of disability on daily living, and independence. ● Any assessment or framework must explicitly account for fluctuating conditions, psychosocial disability, neurodivergence, and the cumulative impact of multiple impairments, rather than relying on narrow or standardised clinical measures alone. 4. Increased family responsibility and administrative burden
The proposed changes risk shifting a greater proportion of system navigation, evidence gathering, reporting, and coordination tasks onto families and informal carers, rather than maintaining these responsibilities within a well-supported and accessible service system. Many families already undertake significant unpaid administrative and advocacy work to secure and maintain appropriate supports, and further increasing this burden risks exacerbating stress, burnout, and inequitable outcomes across the scheme.
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Increasing administrative complexity and reliance on family-led processes may also create barriers for participants who do not have strong informal supports, including people who are socially isolated, experience family breakdown, or have carers who are themselves elderly, unwell, or unsupported. There is also a heightened risk of inequity for culturally and linguistically diverse families, First Nations participants, and those with limited digital literacy or access. A system that assumes high levels of family capacity to navigate administrative requirements risks undermining equitable access to the NDIS and shifting responsibility away from the Scheme onto unpaid individuals.
Recommendations
● Strengthen and expand funded navigation supports (including support coordination and independent advocacy) so participants are not required to rely on unpaid family members to manage administrative requirements. ● Simplify planning, reporting and review processes to minimise duplication, reduce complexity, and improve accessibility for participants and families. 5. Plan reassessment, flexibility and automatic plan renewals We oppose the proposed changes to plan reassessment, flexibility, and the introduction of automatic plan renewals under The Bill. While we support efforts to reduce unnecessary administrative burden and delays, the proposed model risks shifting towards automated or formula-based plan renewals that reduce meaningful human oversight and limit participant input into planning decisions. This undermines the fundamental NDIS principles of choice and control by reducing opportunities for participants to actively engage in shaping their supports in response to changing needs.
A key concern is the reduction of human judgement in plan decision-making processes. Disability support needs are inherently dynamic and often influenced by fluctuating health conditions, environmental barriers, crises, and life transitions. Automated reassessments or default renewal mechanisms risk failing to capture these changes, potentially resulting in plans that are outdated, inadequate, or misaligned with a participant’s current circumstances. This is particularly concerning for participants with psychosocial disability, episodic conditions, or complex support needs, where timely human review is essential to ensure safety and continuity of supports.
We are also concerned that reduced flexibility in reassessment processes may limit participants’ ability to proactively request plan changes when their needs shift, instead relying on rigid timelines or system-triggered reviews. This may lead to delays in accessing increased or adjusted supports, increasing the risk of service gaps, crises, or hospitalisation.
Recommendations
● All plan renewals and reassessments retain meaningful human oversight and decision-making, ensuring that automated processes do not replace individualised assessment ● Participants retain clear and accessible pathways to request plan reviews or reassessments at any time when their circumstances change ● Plan flexibility is preserved as a core principle of the NDIS, with reassessment processes designed to respond promptly and appropriately to fluctuating and complex support needs.
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6. Shift to foundational supports
The Bill outlines that responsibility for a range of supports is intended to transition from individualised NDIS funding to broader foundational support systems. While we support the intent of strengthening mainstream and community-based support, the current approach risks introducing significant gaps in service delivery due to the absence of a clearly defined, adequately funded, and operationalised foundational support system.
A key concern is that foundational supports have not yet been fully designed, implemented, or tested at scale before being relied upon as a replacement for existing NDIS-funded supports. Without clear service definitions, eligibility criteria, geographic coverage guarantees, and accountability mechanisms, there is a substantial risk that participants will experience reduced access to essential supports or inconsistent service availability depending on location or service system maturity. This creates uncertainty for participants and providers alike, and risks fragmenting rather than strengthening the broader disability support system.
There is also a risk that shifting supports prematurely may result in service gaps, with participants falling between systems where responsibilities are unclear between the NDIS, state and territory governments, and mainstream services. This may disproportionately impact people with complex needs, those in regional and remote areas, and participants who rely on consistent, specialised supports that are not readily replicated in generalist service systems.
Recommendations
● No transition to foundational supports occur until they are fully designed, co-developed with the disability community, and demonstrably operational across all jurisdictions with clear accountability arrangements. ● Foundational supports must be clearly defined, consistently funded, and guaranteed in availability before any reduction or transfer of NDIS-funded supports occurs. ● Strong safeguards are established to ensure no participant experiences a reduction or gap in supports during any transition between the NDIS and foundational support systems. 7. Expansion of mandatory registration requirements
We oppose the proposed expansion of mandatory registration requirements under The Bill. While we support the importance of safeguarding participants and improving quality across the sector, expanding mandatory registration alone is not the solution to preventing fraud, abuse, neglect, or participant injury. Increased registration requirements may create significant administrative and financial burdens for providers without improving the quality of frontline supports delivered to participants.
We are concerned that the proposed reforms place a strong emphasis on regulatory compliance while failing to adequately address workforce capability, training, and professional standards across the disability sector. Improving participant safety requires investment in a skilled and competent workforce, not simply increased registration obligations. Greater focus should instead be placed on strengthening minimum worker qualifications and ongoing professional development requirements, including nationally
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recognised training relevant to disability support work, mandatory first aid certification, and continuing professional development (CPD) expectations. These measures would more directly improve participant safety, service quality, and worker capability across the sector.
We are also concerned that expanding mandatory registration may reduce workforce availability and provider diversity, particularly for small providers, sole traders, and regional services that may struggle to meet increased compliance costs and administrative requirements. This risks reducing participant choice and access to supports without clear evidence that broader registration requirements alone will achieve improved participant outcomes or reduce fraud.
Recommendations
● The Government prioritises workforce capability and training reforms, including consideration of minimum qualification requirements such as a Certificate III or IV in Individual Support or Disability, mandatory first aid certification, and ongoing CPD requirements for disability support workers. ● Any expansion of mandatory registration be evidence-based, proportionate to risk, and developed in genuine consultation with participants, providers, and the disability sector. ● Reforms focus on targeted safeguarding, stronger compliance enforcement against poor practice and fraud, and workforce development initiatives rather than broad regulatory expansion that may unintentionally reduce provider diversity and participant choice.
Closing Statement
We make this submission on behalf of the people we support who require their support to have stability, and consistency to be able to participate meaningfully in daily life. The changes that have been proposed in this Bill have very real-world implications for the people that rely on the support from NDIS providers to meaningfully participate in everyday life.
The risks associated with this Bill being passed as legislation in its present form, are documented in this submission, including significant risks of increasing social isolation, and increasing burden on other mainstream services such as the health department.
Sincerely,
The Heather Support Coordination Pty Ltd
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