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 3 of 5: The Inclusive Communities Fund — Why the Model Cannot Serve ASD Level 2 and Level 3 Participants
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 establishing the Inclusive Communities Fund, providing $200 million over three years to rebuild capability among community organisations to host participation activities for NDIS participants; and
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the provisions reducing participant budget allocations for social, civic and community participation supports by up to 50 per cent by legislative instrument from 1 October 2026, on the stated basis that the Inclusive Communities Fund will provide an alternative pathway to community participation.
Executive Summary
The Bill proposes to reduce individual community participation budgets by 50 per cent from 1 October 2026 on the basis that the $200 million Inclusive Communities Fund will provide an alternative participation pathway. This submission identifies a fundamental problem with that premise: the Fund is currently held in the Commonwealth Contingency Reserve, its design has not been finalised, no application process has been announced, and consultation on how it will operate does not commence until July 2026 — while individual budgets begin to be cut from October 2026,
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before consultation has concluded and well before any funding reaches any communityorganisation. The realistic timeline from consultation to operational programs is a minimum of twelve to eighteen months, meaning participants will absorb the full impact of the cut for over a year before any alternative exists. For autistic participants with ASD Level 2 and Level 3, the Fund cannot in any case replace individualised support — the evidence base, the Disability Royal Commission’s findings, and a decade of operational experience with this cohort all confirm that generic group-based community programs cannot safely or meaningfully serve participants with complex presentations. The Bill cuts the funding that works before the alternative exists, and proposes an alternative that will not work for this cohort regardless of when it arrives.
This organisation does not oppose the principle of community inclusion for people with disability. It submits that the Inclusive Communities Fund, as currently framed, cannot serve autistic participants assessed at ASD Level 2 and Level 3, and that no 50 per cent reduction to individual community participation budgets should proceed until an alternative that actually works for this cohort is operational.
The observations in this submission are drawn from more than a decade of direct service experience supporting participants with ASD Level 2 and Level 3 in community environments, supported by the Disability Royal Commission’s published findings and peer-reviewed evidence.
- The Fund Does Not Yet Exist — But the Cuts Begin Before It Will The Committee’s attention is directed immediately to the sequencing of the Bill’s provisions, because it is the most specific and incontrovertible problem this submission raises.
The $200 million Inclusive Communities Fund is currently held in the Commonwealth Contingency Reserve. No application process has been announced. No distribution timeline has been published. No capability requirements for funded organisations have been released. According to the Government’s own published information, consultation on how the Fund will operate is not scheduled to commence until July 2026.
Individual community participation budgets begin to be reduced from 1 October 2026 — while the Fund’s consultation process is still underway.
Participants with ASD Level 2 and Level 3 will experience a 50 per cent reduction to their community participation budgets before the Fund’s consultation has concluded, before any application process has opened, before any funding has reached a single community organisation, and before any organisation has built any capability. The realistic timeline from consultation commencement to funding reaching organisations, capability being developed, and programs becoming operational is a minimum of twelve to eighteen months — meaning participants will be absorbing the full impact of the cut for well over a year before any alternative exists. The alternative the Bill offers in exchange for the cut is not yet designed. It is a future promise. The cut is a present certainty.
Medical Journal of Australia analysis published in April 2026 identified this directly: reducing individual funding for social and community participation before the Inclusive Communities Fund has been able to develop alternatives leaves an obvious gap for participants — a gap that requires urgent attention. This submission respectfully submits that the Committee should not
allow the reduction provisions to commence before the Fund is operational and hasdemonstrated capability to serve this cohort.
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- Even When Operational, the Fund Cannot Replace Individualised
Support for This Cohort
3.1 What supporting ASD Level 2 and Level 3 participants actually requires Participants with ASD Level 2 and Level 3 frequently present with non-verbal or severely limited verbal communication, severe emotional dysregulation with rapid unpredictable onset,
self-injurious behaviour, elopement risk, extreme sensory sensitivity, and co-occurring
intellectual disability or epilepsy. Supporting these participants safely in communityenvironments requires skilled, trained, experienced 1:1 support workers who know the individual participant’s specific triggers, communication patterns, behavioural history and regulatory strategies. This knowledge is built through months of consistent relationship. It cannot be substituted by a community organisation that has received a capacity-building grant.
The peer-reviewed evidence base confirms that meaningful community participation for this cohort requires individualised supports in ordinary community environments and trusted support relationships — findings confirmed by the NDIA’s own 2022 research. A community organisation hosting a group activity does not provide individualised support. It provides a setting. For participants with ASD Level 2 and Level 3, the setting without the skilled support is not participation. It is placement.
3.2 Practical exclusion already occurs in every mainstream setting this cohort attempts This organisation submits, from more than a decade of direct service experience, that the practical outcome for ASD Level 2 and Level 3 participants in community group settings funded through the Inclusive Communities Fund is foreseeable — because it already occurs consistently in every mainstream setting these participants attempt to access.
Schools, childcare centres, after-school care programs, sporting clubs, arts organisations and community activity groups across Australia regularly communicate to families of ASD Level 2 and Level 3 participants that they cannot safely manage the participant’s behaviours, do not have staff with appropriate training, cannot provide the required support ratio, or do not have the environmental controls required to support the participant safely. This is not formal refusal. It is the practical communication that the setting is not equipped for this cohort — and it occurs regardless of the goodwill of the organisation involved.
Children and Young People with Disability Australia’s report published in August 2025 found that 73 per cent of disabled students were bullied in 2024 and three in five parents reported their child had been physically, verbally or socially excluded from school settings. These are mainstream, regulated, professionally staffed educational environments with decades of inclusion policy behind them. A community organisation receiving a capacity-building grant from the Inclusive Communities Fund will not produce a different result.
- The Evidence Base Does Not Support Congregate Group Programs for
This Cohort
The Inclusive Communities Fund proposes to fund community organisations to host group participation activities for NDIS participants. For participants with ASD Level 2 and Level 3, this is a variation of the congregate disability service model — group activities designed for disabled people as a distinct population, separate from the broader community. The evidence on outcomes for this model is not encouraging, and the Disability Royal Commission examined it directly.
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The Royal Commission’s research report — Outcomes associated with ‘inclusive’, ‘segregated’ and ‘integrated’ settings for people with disability (McVilly et al., University of Melbourne,
- — reviewed evidence from 35,888 sources. It found that genuine inclusion requires more than physical presence in a group setting. It requires social connectedness, relationship, and active membership of a community. The report found that segregated and group-based settings consistently fail to produce these outcomes and called for reform toward individualised, community-embedded approaches.
The Disability Royal Commission’s Final Report (2023) found that congregate settings can severely limit opportunities to connect with others and participate in the community. All Commissioners strongly supported the need for more inclusive, individualised models. The evidence the Commission received was, in its own words, overwhelming — demonstrating how segregated systems have consistently failed to produce the participation outcomes they promise.
The proposed Inclusive Communities Fund does not represent a new model. It represents a return to an older one — group programs for disabled people as a category — that the Royal Commission’s own evidence base has found wanting. For participants with ASD Level 2 and Level 3, it will produce the same practical exclusion those models have always produced for this cohort.
- What a $200 Million Fund Distributed to Community Organisations
Cannot Provide
The Committee’s assessment of the Fund should be grounded in a clear understanding of what $200 million distributed across community organisations across Australia can and cannot achieve for ASD Level 2 and Level 3 participants specifically.
The Fund can provide: capital grants for physical modifications to community spaces, training resources for community organisation staff, subsidies for activity costs, and operational funding for new or expanded programs.
The Fund cannot provide: the years of relationship-building required for a worker to know an individual ASD Level 2 or Level 3 participant’s specific triggers and communication patterns; the specialist behavioural training required to safely support a participant experiencing acute dysregulation in public; the staffing ratios required to ensure a participant cannot elope or injure themselves in an uncontrolled environment; or the individual tailoring of activity, timing, sensory environment and social demand that makes participation genuinely accessible rather than nominally available.
National Disability Services’ State of the Disability Sector Report (2023) identified that 34 per cent of non-government disability providers made a loss in financial year 2022–23 and 18 per cent broke even, with more than eight large disability organisations reducing or exiting NDIS service delivery over the following period — with impacts falling disproportionately on participants with complex support needs. These are organisations with years of sector experience, specialist workforces and disability-specific infrastructure. If they cannot sustain quality support for this cohort at current NDIS pricing, a community organisation with a time limited capacity-building grant cannot do so either.
- The Fund Reallocates Away from Participant Choice Toward
Organisational Control
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The NDIS was designed as a participant-directed scheme. Individual funding allowsparticipants to choose who supports them, how, where, and when. The Inclusive Communities Fund represents a structural departure from this principle for the community participation category — rather than funding the participant to choose their support, it funds organisations to design programs that participants are then expected to attend.
Medical Journal of Australia analysis published in April 2026 identified this directly: the Fund represents a reallocation of funding away from people with disability and towards organisations that will decide which services are offered — and is inconsistent with the scheme’s philosophy of personalisation and participant choice. For participants with ASD Level 2 and Level 3, whose safety and participation depend on individualised, responsive, relationship-based support, this reallocation removes the funding mechanism through which genuine community participation is currently achieved and replaces it with a program-based model from which this cohort will, in practice, be excluded.
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Recommendations This submission respectfully recommends that the Committee:
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Recommend that the provisions reducing community participation budget allocations not take effect until the Inclusive Communities Fund has been fully designed, its consultation process completed, funding distributed to operational organisations, and capability to serve participants with ASD Level 2 and Level 3 demonstrated — on the basis that the current sequencing creates a structural gap that participants will bear directly from 1 October 2026.
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Recommend that the Inclusive Communities Fund provisions be amended to require that programs funded through the Fund demonstrate, as a condition of funding, the operational capability to safely and meaningfully support participants with complex autism presentations — including non-verbal participants, those with self-injurious behaviour, elopement risk, sensory processing needs, and co-occurring intellectual disability.
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Recognise that the Fund represents a reallocation of funding away from individualised participant choice toward organisational program delivery — inconsistent with the NDIS’s foundational principles of choice and control — and recommend that individual community participation funding be preserved for participants whose functional presentations require individualised 1:1 support.
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Recognise that the evidence base reviewed by the Disability Royal Commission does not support congregate or group-based disability-specific participation models as producing genuine community inclusion outcomes for participants with complex support needs, and recommend that the Committee seek advice on how the Fund’s design will avoid replicating those outcomes.
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Recommend that the Government publish, prior to enactment of the community participation reduction provisions, an independent assessment of the proportion of current community participation funding recipients with ASD Level 2 and Level 3 who could safely access Inclusive Communities Fund programs without individualised 1:1 support.
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Conclusion IBSS Submission 3 of 5 — The Inclusive Communities Fund | Page 5
Submission 750 - Supplementary Submission
The Inclusive Communities Fund is not yet designed. It has no application process, no distribution timeline, and no published capability requirements. The 50 per cent reduction to individual community participation budgets begins while Fund consultation is still underway — and will be fully felt by participants for well over a year before any alternative is operational. For participants with ASD Level 2 and Level 3 — who cannot access generic community programs without skilled 1:1 support — the Fund does not offer an alternative pathway. It offers a future promise that does not yet exist, in exchange for a present reduction that takes effect immediately.
The Disability Royal Commission, the NDIA’s own research, and the operational experience of providers supporting this cohort all point to the same conclusion: genuine community
participation for autistic participants with high and complex support needs requiresindividualised, skilled, relationship-based support. A capacity-building grant to a community organisation does not provide that. The evidence of decades of congregate and group-based disability service delivery in Australia confirms it.
This submission respectfully urges the Committee to recommend that the communityparticipation reduction provisions not proceed until the Inclusive Communities Fund has demonstrated the capability to serve this cohort — and that individualised funding for participants whose presentations require it be explicitly protected regardless of the Fund’s development.
Thank you for considering this submission.
Authorised by:
The Directors
Independence & Beyond Support Services (IBSS)
Date: 1 June 2026
References
McVilly, K.R., Genat, A., & Zirnsak, T. (2022/2023). Outcomes associated with ‘inclusive’, ‘segregated’ and ‘integrated’ settings: Accommodation and community living, employment and education. Research report commissioned by the Royal Commission into Violence, Abuse, Neglect and
Exploitation of People with Disability. University of Melbourne. Available at:https://disability.royalcommission.gov.au/publications/outcomes-associated-inclusive segregated-and-integrated-settings-people-disability
Disability Royal Commission (2023). Final Report — Volume 7: Inclusive education, employment and
housing. Commonwealth of Australia. Available at:https://disability.royalcommission.gov.au/publications/final-report-volume-7-inclusive education-employment-and-housing
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Disability Royal Commission (2023). Final Report — Volume 3: Nature and extent of violence, abuse,
neglect and exploitation. Commonwealth of Australia. Available at:https://disability.royalcommission.gov.au/publications/final-report-volume-3
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
Children and Young People with Disability Australia (CYDA) (August 2025). Nothing has changed: report on disability inclusion in Australian schools 2025. Available at: https://cyda.org.au
National Disability Services (2023). State of the Disability Sector Report 2023. Available at: https://nds.org.au/news/new-data-reveals-worst-year-ever-for-disability-providers-more expected-to-close
Dedman, T. & Wen, C.K. (April 2026). Tightened eligibility and cuts to plans: what the NDIS changes
mean for participants. Medical Journal of Australia Insight. Available at:https://insightplus.mja.com.au/2026/16/tightened-eligibility-and-cuts-to-plans-what-the-ndis changes-mean-for-participants
Department of Health, Disability and Ageing (May 2026). About the changes to the NDIS — Securing the NDIS for Future Generations. Available at: https://www.health.gov.au/our-work/ndis legislation-changes/amendments/ndis-amendment-securing-the-ndis-for-future-generations bill-2026/about-the-changes-to-the-ndis
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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