Submission 692
Senate Community Affairs Legislation Committee
Inquiry into the National Disability Insurance Scheme Amendment
(Securing the NDIS for Future Generations) Bill 2026
Submitted: 26 May 2026
About this submission I am a person with lived experience of disability, residing in Westcourt in Far North Queensland, submitting in a personal capacity. I have neurological conditions that are not reliably captured in standardised assessments and I navigate the health and disability systems both for myself and in support of a family member with Down syndrome. I am a paramedic by background.
I do not oppose reform. I support a sustainable NDIS. My concerns are with four structural implementation risks in this Bill that have not received substantive public responses: the validation status of the assessment tool; the untested absorption assumption underlying the community participation budget reduction; the safeguarding consequences of reducing community participation for people at risk of violence and abuse; and the absence of legislated transition guarantees.
I write from Far North Queensland, where geographic distance, provider thin markets, and significant First Nations populations make the implementation risks in this Bill more acute than in metropolitan settings. Where I raise regional issues, I do so not as a local complaint but as a structural argument: if the policy assumptions in this Bill do not hold in FNQ, they have not been adequately tested before being legislated.
The scale of what is proposed This Bill delivers $37.8 billion in direct cuts to participant payments over four years. Sixty percent of the budget’s savings are drawn from people with disability, who represent twenty-five percent of the population. That is not a balanced approach to fiscal sustainability. It is a targeted reduction in support for some of the most disadvantaged Australians.
The cost of removing support does not disappear. It moves — to emergency departments, mental health crisis services, the justice system, and unpaid family carers. The government’s own $37.8 billion savings figure does not account for what Treasury, Medicare, state mental health systems, and Centrelink will spend absorbing what the NDIS drops. This is cost transfer, not fiscal sustainability. The committee should ask for whole-of-government cost accounting before the Bill proceeds.
Submission 692
- Assessment tool validation (Schedule 1, Part 1) Schedule 1 introduces a legislative definition of ‘substantially reduced functional capacity’ and embeds it in access determinations, replacing diagnosis-list eligibility with a standardised assessment. The intent is sound. The implementation risk is significant.
The Australian Psychological Society formally raised in its submission to the consultation on new planning framework rules that the proposed assessment tool has not been adequately validated across the populations it will assess — specifically people with psychosocial disability, autism, acquired brain injury, and fluctuating conditions. These are not edge cases. They represent a substantial proportion of current participants and the cohort most likely to be affected by tighter access criteria.
Fluctuating conditions are poorly captured by point-in-time standardised assessment by definition. ABI presents heterogeneously and is frequently missed in assessment contexts, particularly for First Nations people and people in remote areas where the diagnostic pathway is longer and less consistent. In FNQ, the journey from symptom to diagnosis to documented functional impact is not comparable to a metropolitan trajectory — yet the assessment tool will be applied uniformly.
The Bill does not require the tool to be validated before use. Schedule 4 gives the Minister broad power to specify the assessment tool and budget method by legislative instrument, with limited parliamentary scrutiny. Crucially, neither the I-CAN tool nor the budget method has published cultural validation for First Nations populations — a foreseeable design gap with foreseeable consequences for the 63,000 First Nations people currently on the NDIS, over one in three of whom in remote communities are already not accessing the supports in their plans.
Comparisons to Robodebt are not rhetorical. Both involve automated or algorithm assisted determination of entitlements, applied at scale before methodological concerns are resolved. The government has not publicly responded to the APS validation concern. The Committee should recommend that:
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The assessment tool be independently validated across all populations to which it will be applied — including First Nations populations — before it is used for access determinations.
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Validation results be publicly released before the tool is specified by legislative instrument.
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An accessible and adequately resourced review pathway be operational before access decisions using the tool take effect.
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Community participation budget reduction and the absorption assumption (Schedule 1, Part 4; Schedule 4)
Submission 692
From 1 October 2026, participant budgets for social, civic and community participation and capacity building daily activities will be reduced — an average drop from approximately $31,000 to $26,000 per participant. The $200 million Inclusive Communities Fund is the partial replacement. This fund is paid to organisations, not participants, and is not individualised.
The policy assumption underpinning this design is that community infrastructure exists to absorb the reduction — that organisations can deliver genuine participation opportunities at sufficient scale that removing direct funded support from individual plans does not reduce participation in practice. This assumption has not been publicly evidenced. It has been legislated.
In metropolitan areas, the assumption may hold in some cases. In Far North Queensland it frequently does not. NDIS Market Insights data shows provider availability in FNQ is significantly lower than urban Queensland, transport costs are higher, and community organisations operate with reduced capacity. In this context, participation requires direct funded support — to access venues, navigate transport, and maintain engagement. Redirecting that funding to organisational grants does not restore participation; it transfers the shortfall to families and individuals.
My family situation is concrete, not illustrative. I support a sibling with Down syndrome. The informal burden that falls on family carers when funded support is reduced is immediate, uncompensated, and cumulative. Family carers are not a buffer with infinite capacity. The NDIA is also losing 669 staff in the next financial year — during the most complex implementation period in the scheme’s history. The combination of reduced individual funding, organisational-level replacement, and reduced agency staffing creates foreseeable gaps that do not appear in the government’s savings projections.
The Committee should recommend that:
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The government publicly release the evidence base for the infrastructure absorption assumption, disaggregated by region, before the participation budget reset takes effect.
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The Inclusive Communities Fund allocation and eligibility criteria explicitly account for thin-market and remote regions where direct funded support is a prerequisite for participation, not an alternative to it.
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Implementation of the participation budget reset be deferred until the absorption assumption is verified across all regions.
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Community participation as safeguarding Community participation is not only a quality-of-life support. For many people with disability — particularly those in group homes, segregated settings, or situations of domestic and family violence — it is a safeguarding mechanism. Regular participation in community life is how workers, community members, and services notice when something is wrong. It is the contact point that catches abuse, deterioration, and crisis before they become emergencies.
Submission 692
The Disability Royal Commission heard extensively what happens when people with disability are isolated from community, denied choice, and left without adequate safety measures. The government has accepted those findings. Cutting community participation funding is in direct tension with acting on them.
Women with disability are disproportionately affected. Women make up only 38% of NDIS participants, are exiting the scheme at greater rates than men, and are twice as likely as women without disability to experience violence — including in disability settings where they are supposed to be safe. The Women with Disabilities Australia budget response noted that cuts to social and community participation supports will be especially damaging for women and girls in group homes and segregated settings, where isolation already increases risk of violence, abuse and neglect.
For women using the NDIS to leave violent situations, community participation funding is not supplementary — it is the funded support that makes connection to services, safe relationships, and exit possible. The $200 million Inclusive Communities Fund, paid to organisations and not individualised, cannot substitute for this. The government has committed to preventing and responding to gender based violence. That commitment is directly contradicted by reducing the individual funded support that makes safety and community connection possible for women with disability.
The Committee should recommend that:
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A formal safeguarding impact assessment be conducted and published before community participation budgets are reduced, with specific analysis of impacts on women with disability and people in group home or segregated settings.
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Individual funded support for community participation be retained for people assessed as at risk of violence, abuse or neglect, and not replaced by organisational grant funding.
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Transition sequencing (Schedule 5) The community participation budget reduction starts October 2026. Full foundational support implementation is not expected until 2028. That gap is not a detail. It is the policy.
This Bill was introduced on 14 May 2026 with a Senate inquiry closing 15 days later. Some provisions commence shortly after Royal Assent. Transition arrangements are to be specified by ministerial rule under Schedule 5, not legislated — subject to a 12 month window and 12-month expiry, with no requirement that they be in place before scheme changes take effect. Australia’s Disability Representative Organisations have called explicitly for effective transition systems to be confirmed before people are moved off the scheme. That commitment has not been made.
For people with fluctuating conditions, ABI, or psychosocial disability, disruption to funded support is not a manageable inconvenience. It can destabilise functioning and precipitate crisis. In Far North Queensland, where re-entry to support can take months and alternative services are limited, there is no safety net during a transition gap. The absence of a legislated transition guarantee is not a procedural concern.
Submission 692
For some people, it is the difference between stability and crisis contact with emergency services or the justice system.
The Committee should recommend that:
- Transition arrangements be legislated, not left to ministerial rule. 10.No participant be removed from the scheme or have funding materially reduced until an individual transition pathway is confirmed and operational. 11.The Committee extend the inquiry timeframe or recommend the Bill not proceed until adequate community and clinical scrutiny has occurred.
Summary of recommendations Before the Bill proceeds, the Committee should seek: 12.Whole-of-government cost accounting for projected savings, including costs transferred to Medicare, state health systems, Centrelink, housing, justice, and unpaid carers. 13.Independent validation of the assessment tool across all assessed populations, including First Nations populations, with results publicly released before the tool is specified by legislative instrument. 14.Public release of the evidence base for the community infrastructure absorption assumption, disaggregated by region, before the participation budget reset takes effect. 15.A safeguarding impact assessment — including gendered analysis — before community participation budgets are reduced, with individual funded support retained for people at risk of violence, abuse or neglect. 16.Legislated transition arrangements, with individual pathways confirmed before any participant loses funding or scheme access.
Sources referenced Australian Psychological Society submission to the consultation on new NDIS planning framework rules (2026): https://psychology.org.au/psychology/advocacy/submissions/2026/aps-submission to-the-consultation-on-new-planning Joint statement, Australia’s Disability Representative Organisations: https://dana.org.au/joint-statement-disability-advocates-call-on-government-to ensure-critical-supports-remain-while-ndis-changes-are-made/ Women with Disabilities Australia budget response (2026): https://wwda.org.au First Peoples Disability Network budget response (2026): https://fpdn.org.au
Submission 692
I am willing to provide further information or give evidence to the Committee if that would be useful.
26 May 2026