Submission 750
INDEPENDENCE & BEYOND SUPPORT SERVICES (IBSS)
ACN: 658 366 360 | ibss.qld@gmail.com1 June 2026
The Chair
Senate Community Affairs Legislation Committee
Parliament of Australia
Canberra ACT 2600
By electronic lodgement — ibss.qld@gmail.com
Re: Suite of Submissions — National Disability Insurance Scheme Amendment (Securing
the NDIS for Future Generations) Bill 2026
Dear Chair and Committee Members,
Independence & Beyond Support Services (IBSS) is a Queensland-based NDIS provider specialising in individualised 1:1 community access support for autistic participants with ASD Level 2 and Level 3. IBSS lodges five supplementary submissions to this inquiry, each addressing distinct provisions of the Bill. This covering letter introduces those submissions and provides context for the organisational background from which they are made.
Organisational Background
The directors of IBSS were formed within an integrated therapeutic, residential and educational community that has operated for more than fifty years, built on a model developed over a century of international practice specifically for people with developmental disabilities and complex needs. That model — sometimes described as an ‘all of life’ approach — structures daily life, work, relationships, community participation and vocational learning as a unified whole rather than as isolated clinical interventions. It is, in the language of the current evidence base, a naturalistic developmental framework delivered across the full span of a person’s life.
What makes this formation unusual, and directly relevant to this inquiry, is not its longevity but its scope. The directors did not train in a clinical office or a university placement. They trained inside a living model — working alongside allied health therapists daily, operating within school environments, supporting adults through community and vocational life, and absorbing over many years the accumulated knowledge of long-term practitioners who had themselves worked within this framework across decades. The depth of understanding of what genuine community participation means for people with developmental disabilities and complex needs — what it requires, what it builds, and what is lost when it is withdrawn — came from sustained immersion in a model that treated participation not as an outcome to be measured but as the fabric of daily life itself.
Submission 750
One director holds a Graduate Certificate in Autism. Both directors have worked full-time in the disability support sector for more than ten years. IBSS was established on the foundation of that formation, applying its principles specifically to the community access support needs of autistic participants with ASD Level 2 and Level 3 within the NDIS framework.
The evidence base has arrived, through decades of research, at conclusions that this model reached through practice: that skills develop in the environments where they are needed; that relationships are the medium through which learning and regulation become possible; that independence is built gradually through supported participation in ordinary life, not through clinical approximations of it. The directors of IBSS do not cite this convergence as a credential. They cite it because it means the arguments in these submissions are grounded in both evidence and experience — and that the committee can have confidence that the operational observations made are not opinion, but the product of sustained, serious engagement with this cohort.
The Suite of Submissions
IBSS lodges five supplementary submissions. Each addresses a distinct set of Bill provisions and makes arguments not repeated in the others. The Committee is directed to whichever submission is most relevant to the area of inquiry under consideration:
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Submission 1 — The Case for Individually Assessed, Naturalistic Community Participation Supports. Addresses the blanket 50 per cent reduction mechanism and its inconsistency with the NHMRC-approved Autism CRC National Guideline, the NDIA’s own 2022 research, and the individual assessment requirements of the NDIS Act. Draws on peer-reviewed evidence that naturalistic community-based supports produce better outcomes for this cohort than clinic-based intervention.
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Submission 2 — Workforce Integrity, Competency-Based Pricing, and Verified Service Delivery. Addresses the Bill’s worker registration provisions and submits that registration alone is insufficient. Proposes a tiered competency register connecting verified specialist experience to billing rate eligibility, and a technology-based verified service delivery system linked to the invoicing process.
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Submission 3 — The Inclusive Communities Fund: Why a Congregate Model Cannot Serve ASD Level 2 and Level 3 Participants. Addresses the $200 million Inclusive Communities Fund and submits that the fund cannot replace individualised support for this cohort, that its design has not been finalised, and that its cuts precede its alternatives by a structural margin that participants will bear directly.
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Submission 4 — ASD Level 2 and Level 3: Functional Complexity, Co-occurring Conditions, and the Team-Based Support Model. Addresses the planning framework provisions restricting funding to primary disability, the simultaneous cuts to Core and Capacity Building supports, and the case for a team-based individualised approach as the only operationally viable model for this cohort.
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Submission 5 — Supported Independent Living: Skill Development, Support Worker
Continuity, and Long-Term Fiscal Consequences. Addresses the Bill’s SIL
commissioning provisions and the community participation reduction provisions, with particular focus on the developmental purpose of SIL, the structural conflict of interest in bundled SIL arrangements, and the fiscal costs transferred to other government systems when community participation supports are reduced.
Submission 750
All five submissions are lodged as non-confidential. IBSS consents to publication of all submissions.
A Note on Scope These submissions address exclusively the provisions of the Bill as they affect autistic participants assessed at ASD Level 2 and Level 3. IBSS does not make broader claims about the NDIS or its reform beyond the specific provisions addressed. The arguments are narrow, evidence-based, and directed at the Bill’s text.
IBSS does not oppose the principle of scheme sustainability. It opposes specific mechanisms within the Bill that, as drafted, will produce outcomes for participants with the highest support needs that are directly contrary to the scheme’s own evidence base, its founding insurance principles, and the Government’s own stated policy commitments to autistic Australians.
IBSS thanks the Committee for the opportunity to contribute to this inquiry and for the extension of the submission period to 1 June 2026, which has enabled a more thorough engagement with the provisions of the Bill than the original deadline permitted.
Yours sincerely,
The Directors
Independence & Beyond Support Services (IBSS)
ACN: 658 366 360
ibss.qld@gmail.com Date: 1 June 2026
Enclosures: Five supplementary submissions (lodged separately)