Submission 734 - Supplementary Submission
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: 01/06/2026
I 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 in my role as an employee
(Senior Speech Pathologist and Allied Health Team Leader) at Lifespan therapies.
About Me and my role at Lifespan Therapies
Lifespan Therapies is a multidisciplinary paediatric allied health provider supporting
children and young people with disability and developmental needs in the Morton
Bay areas of Queensland. Our team includes physiotherapists, occupational
therapists, speech pathologists and allied health assistants, working with participants
across home, community, educational and clinic-based settings, with therapies
tailored to where participants needs them most.
My 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
1
Submission 734 - Supplementary Submission
developmental planning. As a clinicians who graduated in 2007, I have nearly 20
years post graduate experience in my field of Speech Pathology, working closely
with participants, families and educators. In the last two years the shift within the
NDIS has been marked and I have seen first hand the practical impact that
legislative and policy decisions have on access to supports, developmental
outcomes and participation in everyday life. Before the introduction of this Bill
participants plans have already begun to be slashed, people are already being
directed off the scheme and so many of the families were work with are being forced to go through the ART for amendments, as their plans are not meeting their needs.
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. It is rushed and I believe the Bill
requires further scrutiny and amendment before it proceeds or it will result in far
reaching harm and have unintended negative consequences for disabled Australians
and their families and caregivers.
Parliamentary Scrutiny and Transparency
The consultation period for the Amendment Bill is two weeks, which is grossly
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 and given the sweeping
changes being proposed and to a population that requires time and accommodations
to engage with and prepare responses to, this is unjust.
The short timeline impacts me as an allied health provider and a parent to a child
accessing the scheme for their disability, by restricting the opportunity to provide an
accurate and detailed recount of all the risks posed by these amendments. There
is an extensive 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 and parents my osn three children,
one of whom has a permanent disability.
2
Submission to the National Disability Insurance Scheme Amendment (Securing the
Submission 734 - Supplementary Submission
Recommendation: I urge that the consultation period be amended, for a best
practice to the 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
- 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
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.
In my own circumstance, my child’s plan had a funded therapy support cut without
consultation in plan review. The planner admitted they had not even read the report
from the psychologist and stated that “psychology was not an NDIS support but
belonged in health”. This was completely unfounded and in-correct and I had to fight
to have this support reinstated, whist in the mean time coping with the financial strain
of paying privately for the support to continue and having to modify my families
finances by stopping sporting activities for my other children so as to pay for the
support and not disrupt my child’s progress and create overwhelm by leaving her
3
Submission to the National Disability Insurance Scheme Amendment (Securing the
Submission 734 - Supplementary Submission
unsupported without any notice. The relational trust and relationship built in this time
for my child was one of their main reasons for capicity to have been build and I know
first hand the improvement achieved. Ultimately the support was reinstated, but not
without significant emotional turmoil and cost both finically and physically to myself
for having to advocate over a protracted period for a needed support. What the bill is
now proposing risks this happening to entire population groups, who currently have
no other means of support. Medicare supports and thriving kids supports are NOT
the same, and thriving kids has not even been built yet.
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
and a longer transition period to ensure that systems and supports are in place
outside of the NDIS.
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. Disability is not static, peoples needs change
4
Submission to the National Disability Insurance Scheme Amendment (Securing the
Submission 734 - Supplementary Submission
over time and disabled children grow into disables adults. What is suitable at age 5 is
not the same as what is suitable at age 15.
Again, making a blanket funding reduction without first assessing the participant is
detrimental and could have life-threatening implications. Many NDIS participants
receive only the bare minimum of 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 real life – especially in the life of
a disabled person. The current funding does not allow for worse days, weeks or
months where increased supports are needed due to illness or other ‘atypical events’
which occur far more regularly than one would expect 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
their 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 resulting in worse outcomes for everyone.
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.
5
Submission to the National Disability Insurance Scheme Amendment (Securing the
Submission 734 - Supplementary Submission
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
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).
6
Submission to the National Disability Insurance Scheme Amendment (Securing the
Submission 734 - Supplementary Submission
How this affects participants: A participant’s community participation, capacity
building or assistive technology funding could be cut without warning and without any
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.
7
Submission to the National Disability Insurance Scheme Amendment (Securing the
Submission 734 - Supplementary Submission
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 and likely to be beneficial to their unique
circumstances.
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
8
Submission to the National Disability Insurance Scheme Amendment (Securing the
Submission 734 - Supplementary Submission
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. The tool has not been assessed
on the populations it is going to now be used on and the train the trainer proposed
9
Submission to the National Disability Insurance Scheme Amendment (Securing the
Submission 734 - Supplementary Submission
method for its implementation also grossly simplifies the experiences of a disabled
person and makes it unsafe.
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. Any
assessment must also be administered by trained clinicians who understand the
clinical populations the tool is being used on. One fit for all tool is simply way too
simplistic to capture the broad needs and nuance of disability experienced by
Australians.
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
10
Submission to the National Disability Insurance Scheme Amendment (Securing the
Submission 734 - Supplementary Submission
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. 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
11
Submission to the National Disability Insurance Scheme Amendment (Securing the
Submission 734 - Supplementary Submission
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.
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.
12
Submission to the National Disability Insurance Scheme Amendment (Securing the
Submission 734 - Supplementary Submission
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.
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
13
Submission to the National Disability Insurance Scheme Amendment (Securing the
Submission 734 - Supplementary Submission
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
loses access to essential supports without appropriate assessment, review rights
and demonstrated alternative pathways of support.
Senior Speech Pathologist and Allied Health Team Leader
Lifespan Therapies
Brendale, Queensland
Email:
14
Submission to the National Disability Insurance Scheme Amendment (Securing the