Submission 750 - Supplementary Submission
SUBMISSION TO THE SENATE COMMUNITY AFFAIRS
LEGISLATION COMMITTEE
National Disability Insurance Scheme Amendment (Securing the NDIS for
Future Generations) Bill 2026
Senate Community Affairs Legislation Committee
Submission 1 of 5: The Case for Individually Assessed Community Participation
Supports
Submitted by: Independence & Beyond Support Services (IBSS)
ACN: 658 366 360
Contact: ibss.qld@gmail.com
Phone: Not provided
Address: [Address] Date: 1 June 2026 Submission type: NDIS provider — unregistered Confidentiality: Non-confidential — the submitter consents to publication Related submissions: This is one of five complementary submissions made by Independence & Beyond Support Services (IBSS) to this inquiry. Each submission addresses distinct provisions of the Bill. A covering letter introducing the suite has been lodged separately.
- Purpose of this Submission This submission addresses the following provisions of the Bill:
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the provisions enabling the Minister to reduce participant budget allocations for social, civic and community participation supports by up to 50 per cent by legislative instrument, effective from 1 October 2026, resetting average spend to 2023 levels;
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the provisions enabling a 10 per cent reduction to capacity building daily activity allocations; and
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the planning framework changes relating to support eligibility and the definition of reasonable and necessary supports.
Executive Summary
This submission demonstrates that the Bill’s 50 per cent reduction to community participation budget allocations, applied by ministerial instrument without individual assessment, is inconsistent with the NDIA’s own published research, the NHMRC-approved Autism CRC National Guideline, and the individual assessment requirements of the NDIS Act. For autistic participants with ASD Level 2 and Level 3, community participation is not a discretionary support — it is the primary environment in which functional capacity is built, and the evidence base consistently identifies
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community-embedded approaches as producing better outcomes for this cohort than clinic-based intervention. The Bill, as drafted, would accelerate a distortion in the scheme’s funding architecture that the NDIA’s own review has already identified as a problem — while simultaneously contradicting the Government’s own stated commitment, through the Inclusive Communities Fund, to community participation as a valued outcome.
This submission focuses specifically on autistic participants assessed at ASD Level 2 and Level
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It draws exclusively on peer-reviewed research, government-commissioned guidelines, and NDIA-published data.
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ASD Level 2 and Level 3 Cannot Be Addressed by Blanket Policy
Measures
Autism is not a uniform condition and autistic participants are not a uniform population. The diagnostic classification of ASD Level 2 and Level 3 designates participants who require substantial to very substantial support across multiple functional domains. A blanket 50 per cent reduction applied uniformly across all community participation budgets — regardless of diagnosis, functional presentation, support level or individual need — is structurally incapable of reflecting this reality.
The National Guideline for the assessment and diagnosis of autism in Australia (Autism CRC, 2023), approved by the NHMRC and developed with Commonwealth Government funding, explicitly recognises that autistic people present across a wide spectrum of functional need,
that supports must be individually tailored, and that evidence-based practice requiresassessment of the individual rather than application of population-level averages.
The Government's own National Autism Strategy (DSS, 2024), developed followingconsultation with more than 2,000 participants, families and organisations, states as its central vision a society where autistic people can fully take part in all aspects of life. A 50 per cent reduction to community participation funding — applied without individual assessment, resetting average spend to 2023 levels simultaneously across all participants — is directly inconsistent with that stated policy objective for this cohort.
- The Bill Risks Entrenching a Funding Model the Evidence Base Has
Already Rejected
3.1 The NDIS has already pushed practice away from what the evidence supports
Professor Andrew Whitehouse (University of Western Australia and The Kids Research
Institute Australia), Professor David Trembath (Griffith University) and colleagues published peer-reviewed analysis in 2024 identifying that within the NDIS there has been a dramatic increase in the delivery of support in specialised clinical settings, while best practice guidelines consistently call for community-embedded approaches — building capacity within the child’s everyday routines and environments. Within the current NDIS funding model, community embedded supports are either underfunded or unfunded, and therefore not prioritised. The scheme’s architecture has actively pushed practice away from what the evidence says works.
Reducing community participation funding — the primary mechanism through whichcommunity-embedded support is delivered — while leaving clinical therapy billing unchanged does not move the system toward the evidence base. The Bill, as currently drafted, would accelerate the very distortion the NDIA’s own review identified as a problem.
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3.2 Skills learned in clinical settings do not reliably transfer to real-world environments The peer-reviewed literature consistently identifies the failure to transfer skills learned in clinical settings into real-world environments as a significant risk for autistic individuals with higher support needs. Skills acquired in a structured clinical environment do not reliably transfer to the kitchen, the shopping centre, the bus, or the workplace without repeated supported practice in those settings.
Community-embedded intervention approaches have a growing body of randomised controlled trial evidence supporting their efficacy. A 2025 systematic review and network meta-analysis
identified these approaches as producing meaningful improvements across social
communication, language and adaptive behaviour domains for autistic children, withcommunity-based delivery specifically identified as a facilitating factor. The Autism CRC’s
Interventions for Children on the Autism Spectrum evidence synthesis — the mostcomprehensive review of autism intervention evidence compiled in Australia — similarly identified community-embedded approaches as consistent with best practice for this cohort.
The proposed 50 per cent reduction directly reduces access to the real-world environments in which evidence-based approaches are delivered — while clinical therapy billing, which
produces skills that research confirms often do not transfer to real settings, continuesunchanged.
3.3 More therapy hours do not produce better outcomes — individualised planning does A recent meta-analysis found no evidence that outcomes improve with increasing amounts of therapy, and concluded that the right amount of intervention should be individually determined and vary across a participant’s life as their needs change. A participant with ASD Level 2 or Level 3 who receives fortnightly therapy accumulates approximately 24 clinical contact hours per year. A participant receiving three hours of skilled community access support per week accumulates 156 hours of real-world developmental contact in the same period. The evidence base does not support the conclusion that 24 hours of clinic-based contact produces better
outcomes than 156 hours of skilled community-based support. Halving communityparticipation budgets while leaving therapy billing unchanged reflects a funding priority the research literature does not support.
- Evidential Basis for Group-Based Community Delivery IBSS delivers community access support to participants with ASD Level 2 and Level 3 through a group-based model in which groups of up to eight participants, each accompanied by their own trained support worker, participate together in real community environments. This model is directly consistent with the evidence base for group-delivered community intervention for autistic participants.
A significant and often underdocumented benefit of this model is incidental learning — the acquisition of skills, social understanding and adaptive behaviour that occurs as a natural by product of shared real-world activity rather than direct instruction. Research consistently identifies incidental learning in community settings as a meaningful contributor to social and communicative development for autistic individuals, particularly when supported by structured peer interaction. Within IBSS’s group delivery model, participants observe and respond to each other’s communication, regulation strategies and social navigation in real time — learning from genuine peer interaction in the environments where those skills are needed. This form of learning cannot be programmed into a therapy session. It emerges from being present,
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supported and active in ordinary community life alongside others navigating the same environments. A 50 per cent reduction to community participation funding eliminates the conditions under which incidental learning occurs — not by reducing a therapy input, but by removing the participant from the environment entirely.
Research published in the Journal of Speech, Language, and Hearing Research (2024) examined the effects of inclusive group-based community intervention on active engagement in autistic children and found meaningful improvements in engagement and related outcomes, with the group delivery format identified as supporting social learning, peer modelling and generalisation across environments.
A 50 per cent reduction to community participation funding does not reduce this model by 50 per cent. It makes it non-viable. The cost structure of skilled 1:1 support within a group delivery model does not allow for a 50 per cent budget reduction without a proportional reduction in service hours — which, for participants already at the minimum required for meaningful developmental progress, means elimination rather than reduction.
- The Bill’s Blanket Mechanism Is Inconsistent with the NDIS Act’s
Individual Assessment Requirements
The NDIS Act requires that supports funded under a participant’s plan be reasonable and necessary having regard to that participant’s specific circumstances, functional needs and goals.
The Bill's mechanism — a Minister-determined percentage reduction applied across all
participant plans without individual assessment — is structurally inconsistent with thisframework. For participants with ASD Level 2 and Level 3, whose community participation requirements are already individually assessed as reasonable and necessary, a blanket 50 per cent reduction applied without revisiting that individual assessment does not constitute a lawful determination that the reduced amount remains reasonable and necessary.
The NHMRC-approved Autism CRC National Guideline (2023) explicitly states that supports for autistic people must be individually tailored and that practitioners should engage in individualised assessment and planning. A funding mechanism that bypasses individual assessment is inconsistent with the Government’s own NHMRC-approved clinical guideline. The Government has not explained what evidence was considered in determining that a blanket reduction is consistent with this guideline, or why the individual assessment framework it requires has been set aside.
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Recommendations This submission respectfully recommends that the Committee:
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Recognise that the proposed 50 per cent reduction, applied by ministerial instrument without individual assessment and resetting average spend to 2023 levels, is inconsistent with the NDIS Act’s individual assessment requirements and the NHMRC-approved Autism CRC National Guideline.
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Recommend that the Bill be amended to require individual functional assessment before any reduction to a community participation budget allocation takes effect for participants with ASD Level 2 or Level 3.
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Recognise that the Bill risks entrenching a clinic-based funding model that the peer- reviewed evidence base and the NDIA’s own review have identified as inconsistent
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Submission 750 - Supplementary Submission
with best practice, by reducing community-based support while leaving clinical therapy billing unchanged.
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Recommend that the Committee seek Government advice on what evidence was considered in determining that a blanket 50 per cent reduction is consistent with the Autism CRC National Guideline, the NDIA’s own 2022 research, and the National Autism Strategy.
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Recommend that any reduction to community participation support be accompanied by published individual-level outcome modelling specifically addressing ASD Level 2 and Level 3 participants.
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Conclusion The proposed 50 per cent reduction is a blanket measure applied without reference to diagnosis, functional level, individual need, or the evidence base for what produces outcomes for autistic participants with high and complex support needs. The Government’s own NHMRC-approved Autism CRC Guideline requires individual assessment. The Government’s own National Autism Strategy commits to full community participation. The Government’s own Inclusive Communities Fund presupposes that community participation is a valued outcome worth investing in. The Government’s own NDIA published research in 2022 confirming that community participation is essential to belonging, confidence, independence and functional capacity for autistic participants.
The Bill, as currently drafted, is inconsistent with all of these. This submission respectfully urges the Committee to recommend amendments that restore the individual assessment requirement and protect the community-based supports through which autistic participants with the highest support needs build the functional capacity to participate in Australian life.
Thank you for considering this submission.
Authorised by:
The Directors
Independence & Beyond Support Services (IBSS)
Date: 1 June 2026
References
Autism CRC (2023). National Guideline for supporting the learning, participation and wellbeing of autistic children and their families in Australia (2nd ed.). NHMRC-approved. Available at: https://www.autismcrc.com.au/best-practice
Autism CRC (2023). National Guideline for the assessment and diagnosis of autism in Australia (2nd
ed.). NHMRC-approved. Available at: https://www.autismcrc.com.au/best-practice/assessment-and-diagnosis
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Department of Social Services (2024). Draft National Autism Strategy. Australian Government.
Available at: https://engage.dss.gov.au/wp-content/uploads/2024/04/draft-national-autism-strategy.pdf
NDIA Research and Evaluation Branch (2022). “Getting out into the world”: pathways to community participation and connectedness for NDIS participants with intellectual disability, on the autism spectrum and/or with psychosocial disability. Policy, Advice and Research Division, NDIA. Available at: https://www.ndis.gov.au/research-and-data/research-and-evaluation-reports
Whitehouse, A.J.O., Trembath, D., & Pillar, S. (2024). First an autism diagnosis then a clinician’s office — how the evidence supports a different approach for families. University of Western Australia
/ The Kids Research Institute Australia. Available at:https://www.uwa.edu.au/news/article/2024/july/first-an-autism-diagnosis-then-a-clinicians office-how-the-evidence-supports-a-different-approach-for-families
Liu, Y. et al. (2025). The effects of community-embedded developmental behavioural interventions in young children with autism spectrum disorder: A systematic review and network meta-analysis. ScienceDirect. [Confirm DOI at ScienceDirect prior to lodging]
Barrett, A.C. et al. (2024). Effects of an inclusive group-based community developmental intervention on active engagement in young autistic children. Journal of Speech, Language, and Hearing Research. https://pubs.asha.org/doi/abs/10.1044/2024_JSLHR-24-00322
Guthrie, W. et al. (2023). The earlier the better: An RCT of treatment timing effects for toddlers on the
autism spectrum. Journal of Autism and Developmental Disorders.https://journals.sagepub.com/doi/10.1177/13623613231159153
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill
2026 (Cth), introduced 14 May 2026. Available at:https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Community_Affairs/ND ISFutureGenBill
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