Submission 734
Lifespan Therapies: Submission to the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Attention: Committee Secretary, Senate Standing Committee on Community Affairs
Submitted by email: community.affairs.sen@aph.gov.au
Date: 31/05/2026
We welcome the opportunity to make a submission to the Senate Standing Committee on Community Affairs about the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.
About Lifespan Therapies
Lifespan Therapies is a multidisciplinary paediatric allied health provider supporting children and young people with disability and developmental needs across Queensland. Our team includes physiotherapists, occupational therapists, speech pathologists and exercise physiologists working with participants across home, community, educational and clinic-based settings.
Our submission is informed by direct experience supporting NDIS participants and their families through early childhood intervention, capacity building supports, school participation, assistive technology, multidisciplinary care and long-term developmental planning. As clinicians working closely with participants, families and educators, we see firsthand the practical impact that legislative and policy decisions
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have on access to supports, developmental outcomes and participation in everyday
general life.
I want to outline the harm this Amendment Bill will cause if it passes Parliament. This
Bill is too far-reaching to pass as it stands. I believe the Bill requires further scrutiny
and amendment before it proceeds.
Parliamentary Scrutiny and Transparency
The consultation period for the Amendment Bill is two weeks, which is insufficient to
allow for appropriate consultation, considering accessibility and communication
needs. The Australian Government Guide to Policy Impact Analysis says consultation
should occur for a minimum of 30 days where possible.
The short timeline impacts me by restricting the opportunity to provide an accurate
and detailed recount of all the risks posed by these amendments. There is an nextensive list of changes with minimal time to properly read the bill in detail, whilst also continuing to provide vital supports to Australia’s most vulnerable children and families to ensure their health and wellbeing.
Recommendation: Amend the consultation period for a best practice minimum of 30
days.
Key decisions left to ministerial instruments, not law
The issue: The Bill allows Ministers to change who gets NDIS support (Schedule 1 Parts 8 and 9) and how much funding people receive (Schedule 1 Part 4; Schedule 3) by signing an instrument, without going back to Parliament. The rules that will
determine critical eligibility thresholds (Schedule 1 Parts 1, 8 and 9) have not yet been written.
How this affects participants: The decisions that shape the lives of participants, whether they qualify for the NDIS and what supports they can access, could be
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changed without parliamentary debate or public scrutiny. Participants may not know
supports or eligibility rules have changed until their plan is affected.
This decision is extremely dangerous for the lives of all. There is NO consideration of a risk matrix and the potential risk a blanket reduction of supports has to individuals whom rely on these to be kept alive. In past ART Cases, such as KDKJ 2025, it was determined that agency decisions were made without consideration of the risk that decision made to the life of an NDIS recipient. Such decisions create a significant risk of harm where funding reductions occur without consideration of an individual’s support requirements, health risks and protective factors.
Recommendation: Require that all decisions affecting NDIS eligibility and funding levels be made through primary legislation subject to full parliamentary scrutiny, with mandatory advance notice to affected participants before any changes take effect.
Existing participants face narrower criteria and fewer rights to challenge decisions
The issue: The Bill changes the rules for existing NDIS participants and makes it harder to challenge some decisions about supports and funding. It also restricts when you can request a reassessment, removes review rights for automatic plan renewals, and makes funding reductions unreviewable (Schedule 1 Parts 1 and 8).
Combined with restrictions on reassessment requests (Part 2), automatic plan renewals without review rights (Part 5), and unreviewable funding reductions (Part 4), existing participants face narrower criteria with significantly fewer avenues to challenge decisions about their supports.
How this affects participants: This does not protect participants already on the NDIS, who could be reassessed under stricter rules. If someone’s funding is reduced or their plan renewed automatically, they may have limited or no ability to challenge that decision. This could make it harder for people to get extra support when their circumstances or disability change.
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Again, making a blanket funding reduction without first assessing the participant is detrimental and life-threatening actions. Many receive only the bare minimum of life saving supports within their NDIS plans. Combined with the introduction of quarterly funding periods, there is only just enough funding each quarter for the ‘perfect weeks’ which never occurs in life – especially in the life of a disabled person. The current funding does not allow for worse days where increased supports are needed due to illness or other ‘atypical events’ which occur far more regularly than one would extpect in a disabled person’s life.
The system is already overburdened and not consistently using the same rules and processes for plan reviews or renewals and the communication to participants and thier representatives is significantly reduced. This proposed bill provides no warning or preparation for families to allow them to be prepared with adequate evidence to prove their needs. Beyond what they should have to fight for when already fighting daily to care for their loved ones.
As a paediatric provider, I regularly work with children whose support needs fluctuate over time due to developmental progression, changes in educational environments, family circumstances, medical needs and life transitions. Restricting reassessment opportunities and review rights may prevent participants from accessing supports at The time they are most needed and may delay intervention during critical developmental periods.
Recommendation: Require a “no harm” safeguard ensuring no current participant loses access to supports unless equivalent supports are in place, with independent review rights before any exit decision and access to unscheduled reassessments preserved.
Increased evidence burden on participants and families
The issue: The proposed amendments increase reliance on reassessments, functional capacity assessments and evidence requirements to establish eligibility
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and support needs. At the same time, some review and reassessment rights are
reduced, creating additional complexity for participants seeking to maintain access to
supports.
How this affects participants: Participants and families may face increased
pressure to repeatedly demonstrate eligibility and justify support needs while
navigating complex disability, health and education systems. Gathering evidence
often requires specialist reports, assessments and professional input, which can be
costly, time-consuming and difficult to access due to workforce shortages and
waitlists.
Families of children with disability already spend significant time coordinating
therapies, medical appointments, educational supports and advocacy activities.
Additional administrative and evidentiary requirements may disproportionately impact
those with the least capacity to navigate complex systems, creating barriers to
accessing the supports they require.
Recommendations: Ensure evidence requirements remain proportionate, accessible and participant-centred, with clear review pathways and funded access to assessments where additional evidence is required to establish eligibility or support needs.
Unreviewable ministerial power to cut funding across all support categories
The Minister can reduce funding for any support or group of supports by a specified percentage through an instrument that cannot be challenged (Schedule 1 Part 4). This applies across all budget categories. Unspent funds will no longer carry over at plan renewal (Schedule 1 Part 5).
How this affects participants: A participant’s community participation, capacity building or assistive technology funding could be cut without warning and without any
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Lifespan Therapies: Submission to the National Disability Insurance Scheme
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right to appeal. Participants who save unspent funds across plan periods for high-
cost items will lose that ability entirely.
Funding is already managed with finite precision to ensure the ability to have essential
ongoing supports that participants need daily, weekly and monthly. Families schedule
this to ensure it is timed appropriately and in accordance with the legislation to ensure
they are accessing the right supports at the right time for their child or participant.
Assistive technology funding is used to purchase equipment items when someone is
at the right size and need. Repairs and maintenance is not done at the start of a plan
as it is dependent on the annual maintenance cycle just like a car. It must be serviced
at set times to ensure the longevity of items. Removing the funding because the NDIA
decides it should have been spent is detrimental and will lead to further requests for
assistive technology, or lack of equipment for people by not having the access to these
essentials when needed. Likewise, funding for capacity building supports is spent
according to the professional recommendations of highly qualified and experienced
health professionals whom have extensive post graduate knowledge.
In my experience, NDIS funding is rarely allocated in excess of participant need.
Families and clinicians already make difficult decisions about how finite funding can
be used to achieve the greatest functional outcomes. Capacity building supports,
assistive technology, school collaboration and parent coaching are carefully prioritised
based on clinical evidence and participant goals.
Unspent funding should not automatically be interpreted as unnecessary funding. In
paediatric practice, funding is often intentionally reserved for planned equipment
purchases, equipment maintenance, periods of increased support need, intensive
therapy blocks, school transitions or specialist assessments. Preventing carryover or
applying blanket reductions may create circumstances where participants are unable
to access supports at the time they are required.
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Lifespan Therapies: Submission to the National Disability Insurance Scheme
Recommendation: Require that unspent funds carry over at plan renewal for
participants saving for high-cost items and require independent review rights before
any funding reduction takes effect.
Requirement to exhaust treatment options before eligibility
The issue:
A person with disability will need to exhaust treatment options before they can be eligible for the Scheme (Schedule 1 Part 8). There will also be a removal of whole-of-person assessment, replaced by single eligible impairment consideration (Schedule 1 Part 3). The note that previously acknowledged environmental factors and other ineligible impairments could affect support needs will be removed (Schedule 1 Part 3).
How this affects participants:
People with disability will need to prove their impairment cannot be treated before they access the NDIS. Once in the scheme, their supports will only be assessed against a single eligible impairment rather than their whole experience. A person’s individual circumstances will not be considered, including ability to pay for treatment, where they live or whether treatment is actually available to them.
As an early childhood provider, I am concerned that a requirement to exhaust treatment options before eligibility may delay access to supports during critical developmental windows. Children do not have unlimited time for intervention. Delayed access to support while families pursue multiple treatment pathways may result in poorer long-term outcomes, increased support needs and greater costs to the Scheme over time.
Diagnostic pathways alone can take years to complete. In many cases, families spend significant periods waiting for specialist appointments, genetic testing, investigations and final diagnostic confirmation before treatment options can even be explored. Genetic testing alone may take more than two years from referral to final results. For many rare and complex disabilities, there may ultimately be no available
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treatment options, however this cannot be determined until the diagnostic process is complete.
Access to treatment options is also not equal. Availability varies significantly based on geography, workforce shortages, waitlists and a family’s financial circumstances.
Eligibility decisions should recognise these practical barriers rather than assuming treatment pathways are equally accessible to all Australians.
Recommendation: Do not proceed with a requirement to exhaust “appropriate” treatment options – there are no safeguarding measures around participant harm due to side effects or complications, a participant’s financial ability to pay, or their geographic capacity to access treatments.
Unvalidated functional capacity assessment tool risks misidentifying need
The issue: The Bill shifts assessment from whole-of-person consideration to a single eligible impairment (Schedule 1 Part 3). Read together with the eligibility thresholds in Parts 8 and 9, the tool used to conduct functional capacity assessments must be capable of sufficiently identifying whether a person meets the threshold for that single impairment.
The named assessment tool is the Instrument for Classification and Assessment of Support Needs (I-CAN). I-CAN requires validation to ensure it will sufficiently identify the needs of all people with disability, including those whose needs may be fluctuating or episodic and may not be captured through a point-in-time assessment, and to ensure it is culturally appropriate for First Peoples with disability.
How this affects participants: If the assessment tool does not accurately capture the full extent of a person’s disability, including needs that fluctuate or vary over time, a participant may be found ineligible or have their supports undercounted, with no guarantee the result reflects their actual experience.
Functional Capacity in Children
Functional capacity in children cannot always be accurately captured through a single point-in-time assessment. Many children demonstrate different levels of function across home, school, community and clinical environments. Children may also perform significantly differently when supported by familiar caregivers, when fatigued, during periods of illness or during times of transition.
Any assessment framework must incorporate multidisciplinary clinical evidence, reports from families and educational settings, and consideration of developmental trajectories rather than relying solely on a standardised assessment outcome.
Recommendation:
Do not proceed with I-CAN as the functional capacity assessment tool unless it has been demonstrably validated to identify the needs of all people with disability, including those with episodic or fluctuating disability, and demonstrated to be culturally appropriate for First Peoples with disability.
Developmental Trajectories Cannot Be Assessed Through Current Function Alone
The Issue:
The proposed amendments place greater emphasis on functional capacity assessments and eligibility thresholds based on current presentation. This approach risks failing to adequately consider developmental trajectories and future participation requirements, particularly for children and young people.
How this Affects Participants:
Children may not currently demonstrate significant functional limitations but may have clear indicators of future disability-related support needs. Early intervention is effective because supports are provided before functional limitations become entrenched. Assessing children solely on their current level of function may delay access to supports until difficulties become more severe, reducing the effectiveness of intervention and potentially increasing long-term support requirements.
Children develop within changing environments and face increasing participation demands as they move through early childhood, school and community settings.
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A child’s support needs cannot always be accurately determined through a point-in-
time assessment without consideration of developmental progression and future
participation expectations.
Recommendation: Require assessment processes to consider developmental trajectories, anticipated participation demands and future support needs, rather than relying solely on current functional presentation.
Mainstream systems assumed to provide replacement supports
The issue: The Bill places increased emphasis on determining whether supports should be provided through other service systems rather than the NDIS. However, many mainstream systems, including health, education and community services, are already experiencing significant workforce shortages, waitlists and funding constraints. The Bill provides no guarantee that equivalent supports will be available before NDIS supports are reduced or removed.
How this affects participants: Participants may lose access to supports based on an assumption that another system will provide them, when in reality those supports may not be available, accessible or adequately funded. Families frequently experience lengthy wait times for public allied health, specialist medical services and educational supports. This may leave participants without access to essential services for extended periods, resulting in deterioration of function, reduced participation and increased reliance on informal supports and carers.
As a paediatric provider, I regularly support families who have already exhausted available mainstream services before accessing the NDIS. In many cases, public services are unable to provide the frequency, intensity or specialised support required to meet a child’s needs. Without demonstrated capacity within these systems, participants may lose access to supports without a viable alternative being available.
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Lifespan Therapies: Submission to the National Disability Insurance Scheme
Recommendation: Require evidence that equivalent supports are available,
accessible and operational within alternative service systems before NDIS-funded supports can be reduced or removed.
Supports cut before replacement system is ready
The issue:
From 1 October 2026, the government has announced funding for social, civic and community participation supports will be cut by 50 per cent and capacity building daily activities by 10 per cent for all participants, reductions that will be implemented through the ministerial instrument power in Schedule 1 Part 4. The Foundational Supports system intended to fill that gap has no confirmed implementation date and is not yet operational.
How this affects participants:
Supports that help participants connect with their community, build skills and maintain independence may be cut before anything exists to replace them, leaving carers and families with greater responsibilities and no additional support. These supports are often what help people stay visible, connected and safe.
Capacity building and community participation supports are often incorrectly viewed as discretionary supports. In reality, these supports frequently prevent escalation of needs by building participant independence, supporting caregiver capacity and promoting meaningful participation in everyday life.
For many children, capacity building supports delivered through allied health services improve communication, mobility, emotional regulation, participation in education and social inclusion. Reducing these supports before replacement systems are operational risks creating service gaps that may take years to recover from.
Any reduction should occur only after replacement systems have demonstrated accessibility, capacity and effectiveness.
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Recommendation:
Require that no reductions to community participation or capacity building supports take effect until Foundational Supports are fully operational, adequately funded and demonstrably able to meet the needs of those who will lose NDIS supports.
The proposed shift away from whole-of-person consideration is of particular concern. Children rarely present with a single isolated impairment. Functional outcomes are influenced by the interaction between physical, communication, cognitive, sensory, behavioural, environmental and social factors.
Effective support planning requires consideration of the whole child and their participation within family, educational and community contexts. A system that focuses narrowly on a single eligible impairment risks underestimating support needs and reducing the effectiveness of interventions.
Conclusion
Lifespan Therapies supports efforts to strengthen the sustainability, integrity and consistency of the NDIS. We recognise the importance of ensuring Scheme funding is directed appropriately and that safeguards exist to protect both participants and public confidence in the NDIS.
However, we are concerned that several proposed amendments may unintentionally reduce individualisation, limit participant safeguards and create barriers to timely access to supports, particularly for children and young people with disability. We encourage the Committee to carefully consider the cumulative impact of these changes, particularly where reduced review rights, increased evidence requirements, reliance on unvalidated assessment processes and assumptions regarding alternative support systems may combine to create unintended harm for participants.
We respectfully recommend that the Bill be amended to strengthen participant safeguards, preserve individualised decision-making and ensure that no participant
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loses access to essential supports without appropriate assessment, review rights
and demonstrated alternative pathways of support.
Elizabeth Donnellan
Director & Paediatric Physiotherapist
Lifespan Therapies
Brendale, Queensland
Email:
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Lifespan Therapies: Submission to the National Disability Insurance Scheme