National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 731
Submission for Inquiry into National Disability Insurance Scheme Amendment
(Securing the NDIS for Future Generations) Bill 2026
Executive Summary:
Prelude Australia welcomes the opportunity to provide feedback on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. Prelude Australia, as a quality Early Childhood Intervention & Therapy Supports provider, recognises the importance of the National Disability Insurance Scheme (NDIS) to fund best practice supports to children with permanent & significant disability and their families, while ensuring long term sustainability of the NDIS.
Prelude Australia is requesting that the Community Affairs Legislation Committee (“the Committee”) and federal government consider the following impacts on children & families, in relation to:
• Definition of Functional Capacity • Application of Parental Responsibility • Treatment Requirements • Powers of the Minister o Funding Periods o Stated Supports • Impact on Workforce & Providers
Children & Families
Functional Capacity:
The Bill: the definition of functional capacity (s9B) “excludes the impact of the persons environmental and personal circumstances.”
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 731
The Risk: environmental factors and personal circumstances that can impact on a child’s developmental trajectory are not considered within the context of children & families during functional capacity assessments.
The Ask: We ask that the definition is reviewed to ensure that the environmental and personal circumstances that increase the risk of developmental vulnerability in children are included during the assessment of functional capacity and support needs for children. These include but are not limited to:
• Children and families who identify as First Nations • Children from CALD Communities • Children living in regional, rural and remote communities • Families where there are multiple children with developmental concerns and/or
disability • Families where there is a caregiver with a disability • Families experiencing domestic & family violence • Children who have experienced trauma including intergenerational trauma • Socioeconomic disadvantages including poverty, risk of homelessness and/or
food insecurity. • Children who have been abused or neglected • Children in out-of-home care, kinship or foster care arrangements • Families with low literacy, digital literacy or limited health/system literacy
We understand that these risk factors do not have a causation effect on functional capacity, however the different impact of environmental and personal circumstances for children compared to adults, and the increased risk on functional capacity for children must be considered in the legislation.
Expanded Parental Responsibility
The Bill: The Bill may act to expand parental responsibility in (s34(1G)–(1H)) which
outlines that support must not be provided to:
(a) Reduce burdens on parental time below what is reasonably expected of a parent
(c) As a preference for support to be provided otherwise than by parental care
The Risk: That the interpretation and application of parental responsibility will reduce, limit and/or preclude parents of children with disability from receiving needed support that will further risk:
• Financial hardship
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 731
• Lower rates of workforce participation • Parental stress & burnout • Disproportionate impact on women • Risk of child, domestic & family violence • Relinquishment of care
The Ask: We ask that the clause is reviewed to ensure appropriate recognition of what is a reasonable expectation of a caregiver in relation to a child with disability and higher support needs that is fundamentally different and requires additional support from parents of typically developing children.
We understand that caregivers hold inherent parental responsibility however, parental responsibility needs to be considered in line with the supports needed to keep children, women & families safe and deliver outcomes in the long term.
Treatment Requirements:
The Bill: introduces in 24(4) that an impairment is not permanent, or likely to be permanent unless the person has undertaken all appropriate treatment.
The Risk: that there will be an ongoing and increase impact on children and families related to:
• That the ‘appropriate treatment’ is NDIS supports • Delay in receiving early intervention and therapy • ‘Appropriate Treatment’ is determined by a workforce that does not have the qualifications or skills to identify evidence-based treatment options • Families are disempowered to make decision about ‘appropriate treatment’ for their child and no longer have choice & control on treatment for their child • Ongoing need and cost to obtain a diagnosis to determine ‘appropriate treatment’ • Inappropriate use of alternative funding (ie Medicare) for diagnosis • Need to utilise all alternative funding (e.g. Medicare) despite not being evidence based where the funding does not meet the support needs of the child & family • Ongoing and increased financial hardship where families are expected to utilise alternative treatments prior to funded supports (including but limited to Medicare funded treatments).
The Ask: Children and families are supported with an appropriate assessment of functional capacity & support needs and then have the opportunity to access their support team to identify & action any relevant ‘treatments.’
We understand that there is a mutual benefit of children, families, providers and the government to ensure that children are receiving evidence based supports however, we
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 731
must ensure that we continue to design a system that is informed by the social model of disability and the rights of the child.
Powers of the Minister to Reduce Funding:
The Bill: introduces in 34(A) powers to the Minister to reduce a percentage (lower than 100%) by which a funding component amount for a specified group of supports is reduced for the purpose of financial sustainability of the NDIS.
The Risk: Unilateral decisions aimed at financial sustainability for the NDIS will have an unintentional impact on children and families that includes but is not limited to:
• Decisions in which all children regardless of support needs will have a percentage of funding removed from their plans or reduced in their next plan (e.g. 10% capacity building supports) • Reducing access to evidence based early intervention and therapy supports in everyday settings • Reducing access to collaborative & specialised multidisciplinary supports • Increasing long-term costs and duration of early intervention if access to funding needs to be utilised over a longer time period or number of plans • Additional risks if and when the determination occurs at times of greater support needs (e.g transition to school)
The Ask: The greater risk to children under 9 years is recognised and this cohort is excluded from any determination in which there is a reduction of funding across a support category with the purpose of NDIS sustainability.
For the avoidance of doubt, Prelude Australia does not support any determination whereby people with disability have their funding reduced by a percentage based on the sustainability of the NDIS that is not aligned with their support needs or personal circumstances.
A Note on Funding Periods and Stated Supports:
In addition, Prelude Australia in the context of this Bill, recommends that the Committee review Funding Periods and Stated Supports that impact children and families in the following ways:
• Reduces the ability to complete authentic assessments and functional assessments with the support of a collaborative transdisciplinary team. We have not observed funding periods to be front loaded for children. • Reduces ability for early childhood intervention to align with timing of support needs and availability of the workforce required for support • Limits recognition of the unique timing of children’s lives that may require flexibility due to: o Family capacity
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 731
o Family availability o Medical intervention o Education needs, transition to school and school holidays o Transitions and change (e.g. moving house, parent divorce) o Child protection factors o Cultural factors (e.g. Sorry Business) • Increases the cost of support when and where inappropriate or inadequate support is provided.
The application of funding periods and stated supports for children unequivocally does not align with best practice and is not endorsed by Prelude Australia.
Impact on Workforce and Providers
Prelude Australia suggests that all and any legislative impacts on children and families will have a secondary impact on our workforce and organisation. As a Not for Profit registered provider, the NDIS continues to be an unviable and unsustainable funding body in which to deliver services long term without significant reform.
As a provider we urge the Committee to review the Bill to create a funding environment that is both sustainable for the community, government and providers and prioritises:
• Early access to early childhood intervention delivered by Early Childhood Teachers and Allied Health Professionals • A functional ecosystem of Foundational Supports prior to any children being revoked from the NDIS • Bilateral commitment to the ongoing implementation of General Supports, Targeted Supports and NDIS in which all children with support needs can receive best practice support that is sufficiently funded to achieve a meaningful impact on the child’s development and family’s well being,, delivered in everyday settings • Alignment with the National Best Practice Framework • Recognition of Early Childhood Intervention as a high-risk support category requiring mandatory NDIS registration • Recognition of the increased costs for quality registered providers and the Not for Profit sector in the development of a tiered pricing system • A pricing system that is viable, sustainable and ensures the long-term future of quality providers as partners with children & families in local communities.
Recommendation Summary:
Prelude Australia recommends that the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 is revised to consider:
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 731
- A definition that recognises the risk and impact of environmental factors and personal circumstances on children’s functional capacity.
- The unique and nuanced difference on parental responsibility expectations and the support needs of parents of children with disability.
- The risk and impact of treatment requirements on early childhood intervention and therapy.
- Exemption of children under 8 years old from Funding Periods and Stated Supports
- Exemption of children reduced funding based on support category
- Legislative protection for the alignment of funding for children with the National Best Practice Framework
Thank you for the opportunity to provide a submission, consultation and feedback.
Kimberly Lewis
Chief Executive Officer
Prelude Australia