Submission 740
Senate Community Affairs Legislation Committee Inquiry
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill
2026
Introduction
Red Frog for Families welcomes the opportunity to provide a submission regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.
Red Frog for Families is a multidisciplinary allied health and disability support provider with more than 15 years’ experience supporting children, young people and families across NSW. Our organisation delivers speech pathology, occupational therapy, psychology, behaviour support and disability support services across metropolitan, regional and semi-rural communities. We support several hundred families each year.
A significant proportion of the individuals and families supported by our organisation live with autism, intellectual disability, neurodevelopmental disability, psychosocial complexity and behaviours of concern. We regularly work alongside families experiencing significant care burden, system complexity and safeguarding risk.
Our submission is informed by direct operational experience supporting participants and families navigating the realities of the NDIS, education, health, child protection and community systems. We see firsthand the impact that stable and appropriate supports can have on safety, participation, independence, communication, family sustainability and long-term outcomes. We also see the consequences when supports are reduced, delayed, fragmented or inaccessible. This is already occurring at an alarming rate.
Red Frog for Families acknowledges the importance of ensuring the long-term sustainability and integrity of the NDIS. We support efforts to reduce fraud, improve consistency, and strengthen public confidence in the Scheme. We are dismayed that the public narrative has become so incredibly toxic following what seems to have been a coordinated campaign by the government to destroy public trust in the NDIS.
However, we are deeply concerned that the proposed Bill fundamentally shifts the balance of the NDIS away from participant rights, safeguards, and evidence-informed individualised support, and toward administrative control, fiscal management, and centralised decision-making powers.
In our view, the proposed reforms create substantial foreseeable risks for participants, families, carers, providers and broader community systems.
Key Concerns
Loss of Participant Rights and Safeguards
Red Frog for Families is concerned that the Bill reduces participant protections and limits meaningful pathways for review and reassessment.
www.rf4f.com.au 02 4039 8555 reception@rf4f.com.au Unit 1, 10 Denney Street, Broadmeadow NSW 2292
Submission 740
People with disability are not static. Children develop, family circumstances change, health fluctuates, carers age, housing arrangements break down and support needs evolve over time. In our experience, reassessment pathways within the NDIS are already extremely difficult for participants and families to navigate. Many of the plans our organisation sees are poorly constructed from the outset, despite extensive expert evidence being provided. It is not uncommon for detailed clinical reports to appear unread, misunderstood, or dismissed entirely during planning processes. The result is often a plan that is impractical, unsafe or unable to meet the participant’s actual support needs, forcing families into lengthy and stressful review processes simply to access functional supports. Rather than improving this situation, the proposed changes risk making meaningful reassessment and review pathways almost inaccessible, even where there have been substantial changes to a participant’s safety, functioning, or family circumstances.
We are particularly concerned about increased reassessment timeframes, narrowing review access, suspension powers linked to participant contact, automatic continuation arrangements that may fail to reflect changing need, and reduced procedural fairness for participants attempting to challenge decisions.
For many participants and families, the NDIS represents something that sits well beyond a funding mechanism. It is a critical safeguard supporting safety, stability, participation, and sustainability within the community.
Red Frog for Families is concerned that aspects of the proposed legislation are inconsistent with the broader intent of the Convention on the Rights of Persons with Disabilities, particularly principles relating to inclusion, participation, autonomy, equality, and access to supports required for full community participation. We are also concerned that the proposed reforms appear difficult to reconcile with many of the findings and recommendations of the Disability Royal Commission, which repeatedly highlighted the importance of safeguarding, accessible supports, supported decision-making, social inclusion, and the prevention of neglect, abuse, isolation, and institutionalisation.
In our view, reforms that reduce access to meaningful review, narrow understandings of disability, and increase barriers to support risk moving Australia backwards from the lessons identified through decades of disability advocacy, reform, and inquiry.
Expansion of Government and Ministerial Powers
Red Frog for Families is concerned by the concentration of broad discretionary powers within government and Ministerial instruments.
The proposed legislation appears to significantly expand the capacity for broad funding reductions, rule changes, and planning limitations to occur with limited scrutiny and limited participant recourse.
This creates uncertainty not only for participants and families, but also for providers attempting to maintain workforce stability, continuity of support, and long-term service planning. These pressures are not limited to private providers and have and will affect NGOs and community organisations across the sector.
Running sustainable disability services is already operationally complex. Registered providers are currently navigating short funding periods, inconsistent plan structures, delayed reviews, pricing uncertainty, workforce shortages, and significant administrative burden associated with supporting March 2026 Page 2 of 7 This document is private and confidential and is solely for the use of the identified recipient. If you are not the identified recipient or the person responsible for delivering to the identified recipient, be advised that you have received this document in error and that any use of it is strictly prohibited. This document is Copyright © and remains the property of Red Frog for Families. Use of this information beyond personal reference by the recipient is
Submission 740
participants to understand and manage their funding. Our organisation, like many others across the sector, is already carrying financial risk where participant funding has been exhausted despite ongoing support need.
The prospect of broad Ministerial powers allowing support categories or funding levels to be reduced through administrative mechanisms creates further instability and makes responsible workforce, infrastructure, and service planning increasingly difficult.
We are particularly concerned by the potential for situations where a participant’s plan may state an approved level of funding, while separate Ministerial determinations or funding restrictions effectively override what can actually be accessed within support categories. This creates substantial confusion for participants, families, and providers and significantly undermines the ability to safely budget, plan, and coordinate supports. Participants already experience considerable difficulty understanding and managing NDIS funding arrangements. Introducing further layers of administrative complexity and unpredictability risks increasing plan exhaustion, service disruption, debt exposure, and safeguarding concerns.
In practice, this uncertainty risks destabilising the very service systems participants rely upon to remain safe, included, and supported within the community.
We are concerned that the Bill centralises significant decision-making power while simultaneously reducing participant capacity to seek review or reconsideration of decisions affecting their daily lives, independence and safety.
Reductionist Approaches to Disability and Functional Capacity
Our organisation is deeply concerned by proposals that narrow the interpretation of functional capacity and reduce consideration of environmental and contextual factors.
Disability does not occur in isolation from environment, relationships, trauma, communication, regulation, housing, education, social inclusion, and support systems.
This is particularly relevant for autistic people, people with intellectual disability, and individuals with psychosocial or behavioural complexity, whose functioning can vary significantly depending on the safety, predictability, and supportiveness of their environment.
Our clinicians regularly observe children and young people functioning successfully in one environment and experiencing significant distress or functional impairment in another.
A reductionist approach to functional capacity risks oversimplifying disability and may result in inaccurate funding decisions, underestimation of support need, and increased safeguarding risks.
We are also concerned about increasing reliance on unqualified workers using specialist standardised tools and potentially automated approaches to decision-making in areas requiring nuanced clinical judgement and contextual understanding.
Many participants already experience significant barriers navigating the complexity of the NDIS. This includes difficulties understanding funding categories, managing budgets, responding to NDIA communication, gathering evidence, interpreting changing rules, and advocating during review March 2026 Page 3 of 7 This document is private and confidential and is solely for the use of the identified recipient. If you are not the identified recipient or the person responsible for delivering to the identified recipient, be advised that you have received this document in error and that any use of it is strictly prohibited. This document is Copyright © and remains the property of Red Frog for Families. Use of this information beyond personal reference by the recipient is
Submission 740
processes. For many people with disability, these challenges arise directly from disability-related impacts affecting communication, executive functioning, organisation, emotional regulation, and system navigation. The increasing administrative complexity created through these reforms risks disproportionately disadvantaging the very people the Scheme is intended to support.
Increased Reliance on Unpaid Carers
Red Frog for Families is concerned that the practical effect of many proposed reforms will be increased reliance on unpaid family care.
Families are already carrying substantial emotional, financial, and practical care burdens. Many carers, particularly women, have reduced workforce participation, financial insecurity, and long-term impacts on their own health and wellbeing as a result of caring responsibilities. These impacts often overflow to other government-funded services including reduced taxation income and increased spending in health, aged care, and justice systems.
Where formal supports are reduced or harder to access, these pressures do not disappear. They are transferred to families who are often already operating at or beyond sustainable capacity. We are particularly concerned by emerging narratives suggesting that families should absorb increasing levels of disability-related support responsibility where a participant’s needs are considered to fall outside what government views as requiring formal support. Participants who require support beyond what is considered typical should not be denied access to appropriate assistance simply because families are expected to carry more.
Our sector has already witnessed tragic cases where families experiencing overwhelming care burden, isolation, and inadequate support have reached crisis point with devastating consequences. Whole families have already died, and more are at risk. While these events are complex and multifactorial, they are stark reminders that family sustainability and safeguarding cannot be treated as secondary considerations within disability policy and funding decisions.
Increased reliance on unpaid carers risks carer burnout, family breakdown, reduced workforce participation, increased poverty, safeguarding concerns, and poorer outcomes for both participants and carers.
Likely Human Impact
Red Frog for Families is concerned that the cumulative effect of the proposed reforms may contribute to deterioration in functional skills, increased behavioural distress and crisis presentations, loss of communication and participation gains, increased social isolation, reduced community inclusion, greater use of restrictive practices, increased family stress and breakdown, and increased safeguarding risks.
We are particularly concerned that where participants experience functional decline as a result of reduced or interrupted supports, the accompanying reduction in funding may then make it extremely difficult to adequately rebuild or regain those lost skills. In practice, this creates a risk of participants entering a cycle of deterioration where reduced supports contribute to declining function, while increasingly restricted funding limits the ability to provide the intensity of intervention required to restore capacity, participation, and stability. The ultimate outcome of this is an increase in future government spending to address the increased level of disability.
March 2026 Page 4 of 7 This document is private and confidential and is solely for the use of the identified recipient. If you are not the identified recipient or the person responsible for delivering to the identified recipient, be advised that you have received this document in error and that any use of it is strictly prohibited. This document is Copyright © and remains the property of Red Frog for Families. Use of this information beyond personal reference by the recipient is
Submission 740
We are further concerned about the impact on children and young people who rely on early, consistent, and capacity-building supports to maintain developmental progress and participation within their communities. Childhood development does not pause while systems become more restrictive or administratively complex. Delays, interruptions, or reductions in support during critical developmental periods may have lifelong consequences for communication, emotional regulation, independence, participation, and educational engagement. Again, the ultimate outcome of this is an increase in future government spending to address an increased level of disability.
We are also concerned that the proposed reforms appear increasingly inconsistent with the evidence base underpinning early intervention, capacity building, and community inclusion. While public policy continues to emphasise prevention, participation, and reducing long-term support dependence, many of the proposed mechanisms risk making it harder for participants to access the very supports most likely to improve long-term outcomes and reduce future system costs.
Australia has spent decades attempting to move away from segregated and institutional responses to disability. Reductions in flexible community-based supports risk undermining this progress and increasing reliance on more restrictive, crisis-driven, and system-based responses.
Our organisation is also concerned that reduced access to appropriate supports may contribute to increased use of restrictive practices within homes, schools, and service environments as families and systems struggle to safely manage escalating distress and behavioural complexity without adequate support.
Across the families we support, predictability and consistency are critical protective factors. Stable supports allow families to maintain routines, sustain employment, attend school, regulate behaviour, and avoid crisis. Increasing administrative instability, uncertainty, and unpredictability within the NDIS risks becoming disabling in itself for many participants and families already managing significant complexity.
Asymmetrical Impact on Women
Red Frog for Families is particularly concerned that the proposed reforms are likely to disproportionately impact women.
Across the disability sector, women continue to undertake the majority of both paid and unpaid caring responsibilities for children, young people, and adults with disability. In our experience, mothers are frequently reducing work hours, leaving employment altogether, managing appointments and systems coordination, providing behavioural and personal care support, and carrying the emotional burden associated with navigating increasingly complex and adversarial systems.
Where formal supports are reduced or become harder to access, this labour does not disappear. It is absorbed by families, most often by women. The likely consequences include reduced workforce participation, financial insecurity, social isolation, declining mental health, and increased long-term economic disadvantage.
We are also concerned about the impact on the predominantly female disability and allied health workforce. Ongoing instability, funding uncertainty, and increasing administrative burden risk driving experienced clinicians and support workers out of the sector at a time when workforce shortages already exist across many regions and disciplines.
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Submission 740
This disproportionate impact sits counter to other government efforts to recognise and correct previous gender-based imbalances including the recent Fair Work Commission review of Gender-based undervaluation.
Systemic and Economic Consequences
Red Frog for Families is concerned that the proposed reforms may reduce visible NDIS expenditure while shifting costs into other already pressured systems.
When disability supports become inadequate or inaccessible, the consequences are often experienced elsewhere, including within emergency departments, hospitals, mental health systems, child protection, housing and homelessness services, education systems, family violence services, justice systems, and aged care.
We are also concerned about broader workforce and economic impacts, including contraction of the disability and allied health workforce, loss of experienced clinicians and support workers, increased thin market instability, reduced regional service availability, provider closures, and reduced continuity of care for participants.
The current uncertainty surrounding the proposed reforms is already affecting workforce confidence across the sector. Disability and allied health workforces require long-term investment, supervision, and capability development, particularly within paediatric practice, behaviour support, and complex disability. Once experienced clinicians and support workers leave the sector, rebuilding this expertise may take many years.
Regional and thin market communities are particularly vulnerable. Many services in these areas already operate within extremely narrow margins due to workforce shortages, travel demands, and difficulties recruiting experienced clinicians. Even modest reductions in viability or increases in administrative burden may result in services withdrawing from communities altogether, with rebuilding access likely to be extremely difficult.
Our organisation is already observing escalating anxiety, confusion, and distress amongst participants and families attempting to understand how these reforms may affect their future safety, stability, and access to support.
The proposed reforms also risk increasing economic disadvantage for carers, particularly women, through reduced workforce participation and increased unpaid care responsibilities.
What the NDIS can be
During the past decade, the NDIS has achieved many wonderful milestones. We have seen first-hand the development of participants from significant levels of disability preventing engagement within school and community environments, having received appropriate levels of early intervention and therapeutic support resulting in those same participants able to engage in typical adult occupations including entering the workforce, living independently, and accessing higher education with only minimal supports.
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Submission 740
Similarly, many examples exist where NDIS funding has transformed the lives of participants and families where participants still need significant levels of support. Where appropriate supports have been provided, participants are able to access and contribute to their communities including volunteer work, and parents that were previously providing full-time informal care have re-entered the workforce.
These incredible outcomes should be front of mind when considering changes that reduce supports provided through the NDIS. The NDIS is recognised to contribute more than two times its cost back into the Australian economy, cuts to this essential program should carefully consider the broader economic ramifications. The NDIS has been and should continue to be a system that contributes positively to Australian culture and that Australians are proud to say leads the world in promoting disability rights and inclusion.
Recommendations
Red Frog for Families recommends that the Committee consider:
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Delaying implementation pending broader consultation and impact assessment.
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Preserving meaningful participant review and reassessment rights.
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Retaining environmental and contextual factors within functional capacity assessment processes.
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Limiting broad Ministerial powers relating to funding reductions and planning determinations.
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Strengthening independent oversight and safeguarding mechanisms.
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Protecting participant access to early intervention, therapy, and capacity-building supports.
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Prohibiting fully-automated eligibility and funding decisions.
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Ensuring foundational supports or other alternate supports are fully established and adequately funded prior to transitioning any access from the NDIS to these support systems.
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Conducting comprehensive human rights, safeguarding, and socioeconomic impact assessments before implementation.
Conclusion
Red Frog for Families acknowledges the need for a sustainable and effective NDIS. However, sustainability cannot be achieved through reforms that reduce safeguards, weaken participant rights, and transfer risk onto disabled Australians, their families, and other service systems.
We urge the Committee to carefully consider the long-term human, social, and economic consequences of the proposed legislation and to ensure that future reforms strengthen, rather than weaken, the principles of dignity, participation, safety, and inclusion that underpin the NDIS.
March 2026 Page 7 of 7 This document is private and confidential and is solely for the use of the identified recipient. If you are not the identified recipient or the person responsible for delivering to the identified recipient, be advised that you have received this document in error and that any use of it is strictly prohibited. This document is Copyright © and remains the property of Red Frog for Families. Use of this information beyond personal reference by the recipient is