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SIL skill development is essential for autistic participants with ASD Level 2 and Level 3 (Individual advocacy)

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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 5 of 5: Supported Independent Living — Skill Development, Support

Worker Continuity, and the True Cost of Reduced Community Participation

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.

  1. Purpose of this Submission This submission addresses the following provisions of the Bill:

  • the provisions reducing community participation Core support budget allocations by 50 per cent and capacity building daily activity allocations by 10 per cent, effective 1 October 2026;

  • the provisions proposing a new commissioning approach for Supported Independent Living (SIL) for participants requiring 24/7 support, with consultation commencing July 2026; and

  • the provisions and associated policy directions relating to long-term participant outcomes, carer support, and scheme sustainability.

Executive Summary

For autistic participants with ASD Level 2 and Level 3, Supported Independent Living is only as effective as the daily living skills the participant brings to it and develops within it — and those skills are built through community participation supports the Bill proposes to halve. This submission makes three arguments the Bill’s costings do not address: that SIL without structured

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skill development produces containment rather than independence; that the current SIL model systematically severs the established support worker relationships on which participants with complex autism presentations depend, and that the Bill’s SIL commissioning provisions should address this structural failure directly; and that the fiscal savings claimed in the Bill do not account for the costs transferred to carers, the health system, and other government services when community participation supports are reduced.

This submission focuses on three interconnected arguments not addressed in the organisation’s

other submissions  to  this  inquiry.  It draws on peer-reviewed  research and published

government and sector data throughout.

  1. Daily Living Skill Development Is the Foundation of SIL Outcomes 2.1 The evidence base For autistic participants with ASD Level 2 and Level 3, Supported Independent Living is only as effective as the daily living skills the participant brings to it and develops within it. A 2024 systematic literature review published in the Journal of Intellectual and Developmental Disability (Taconet et al.) examined independent living skills interventions for youth with ASD

    and intellectual disability and found that only 5 per cent of youth with ASD could

independently complete all five core activities of daily living — including meal preparation, laundry, cleaning, shopping and independent travel. The review identified that stronger independent living skills are a consistent predictor of positive post-school outcomes including employment, post-secondary education and residential independence.

Research published in the Journal of Autism and Developmental Disorders (Duncan et al.,

2022) confirmed through a randomised controlled  trial that targeted daily living  skills

interventions for autistic adolescents produce measurable improvements in independence — but critically, these improvements require practice in real-world environments. The skills must be learned and rehearsed in the environments where they will be applied: the kitchen, the supermarket, the laundromat, the bus. A clinic cannot substitute for this. Neither can a SIL arrangement that provides personal care and overnight support but does not incorporate structured community access.

2.2 SIL without structured skill development produces containment, not independence The NDIS Act’s insurance principle is that early investment in support produces long-term

reductions in need. That principle only holds  if SIL  is actively developmental. A SIL

arrangement that provides personal care, meals and overnight supervision — but does not incorporate structured daily living skill development, community navigation and vocational preparation — does not reduce future need. It maintains the participant at their current level of dependence indefinitely, at ongoing cost to the scheme.

Community participation supports — funded under the Core supports budget the Bill proposes to halve — are the primary environment in which daily living skills are developed, practised and generalised for participants with ASD Level 2 and Level 3. Cutting the community participation funding that builds those skills while SIL funding continues is not a sustainability measure. It is a structural investment in long-term dependence. The scheme pays to house the participant. It removes the mechanism through which the participant learns to function in their own life. The SIL cost continues. The independence outcome does not materialise.

This submission recommends that the Bill’s proposed SIL commissioning framework require, as a condition of funding, that SIL arrangements for participants with ASD Level 2 and Level

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3 incorporate a  structured  daily  living  skill development framework with measurable

independence outcomes reviewed  at defined  intervals. A SIL arrangement  that cannot

demonstrate participant progress toward greater independence over a defined period should trigger a plan review — not automatic renewal of funding.

  1. The Support Worker Relationship: What the SIL Model Systematically

Destroys

Of all the arguments in this submission, this one is the most directly connected to the daily experience of the participants and families IBSS supports. It is also the one least visible in policy documents — because the people it affects most are those least able to describe what they have lost.

3.1 Why relationship continuity is not a preference — it is a clinical necessity Peer-reviewed research published in Social Sciences (McGhee Hassrick et al., 2021) found that trust among support team members is significantly associated with successful transitions for autistic children, and that high turnover of key support personnel — when workers who know the participant exit and new workers begin — disrupts continuity of care and negatively impacts developmental outcomes.

For participants with ASD Level 2 and Level 3, this finding is not a marginal consideration. Many participants in this cohort are non-verbal or have severely limited verbal communication. Their ability to indicate distress, communicate needs, signal discomfort or demonstrate emerging skills depends entirely on the capacity of the people around them to read their communication — built through months or years of consistent, trusting relationship. A new support worker arriving in a SIL environment without prior knowledge of a participant’s triggers, communication patterns, behavioural history and regulatory strategies is not a neutral event. For many participants, it is acutely destabilising. Dysregulation increases. Community participation decreases. Progress regresses. The SIL cost continues.

This is not a preference for familiar faces. It is a clinical reality documented in the peer reviewed literature and observed daily by every provider and family supporting this cohort. The support worker relationship, for many ASD Level 2 and Level 3 participants, is the medium through which every other support goal becomes possible.

3.2 The current SIL model systematically severs these relationships The current SIL model contains a structural mechanism that routinely destroys what takes months or years to build: the requirement that participants entering SIL accept the provider’s own support workers as the primary or sole delivery workforce. Participants who have developed trusted, longstanding relationships with community access support workers are frequently required to relinquish those relationships — not because the existing workers are

unsuitable, but because the SIL provider employs  its own workforce and structures  its

commercial arrangement accordingly.

The NDIA’s own guidance identifies as a conflict of interest any arrangement in which an accommodation provider limits a participant’s choice of support provider to benefit its own commercial interests. The Disability Royal Commission (2023), in Recommendation 10.2, recommended that the NDIS create a rule that it is not appropriate for a supplier of support coordination to also provide other funded supports — recognising that the bundling of services under a single provider creates structural conditions for conflicts of interest that operate against participants.

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InLife Independent Living’s submission to the NDIS Review documented cases where participants with highly complex support needs found that the vast majority of available SDA properties required the use of a bundled support provider — with only a handful permitting the participant to bring their existing support team. This is not an isolated arrangement. It reflects a market structure in which accommodation and support have become commercially entangled in ways that systematically remove participant choice at precisely the point when a participant’s life is changing most significantly.

For participants with ASD Level 2 and Level 3, the human cost of this is not abstract. The transition into SIL — already a major disruption to routine, environment and daily structure — is compounded by the simultaneous loss of every support worker relationship the participant has developed. The process of rebuilding those relationships takes months. During that period, community participation stalls, skill development regresses, and behavioural escalation is common. The SIL cost continues throughout. The independence trajectory does not.

3.3 What the Bill’s SIL commissioning framework must address The Bill proposes a new commissioning approach for SIL, with consultation commencing July

2026. This submission submits  that  the commissioning framework must  address  the

relationship continuity problem directly. Specifically it should:

  • require that SIL providers accommodate a participant’s existing support workers within the SIL arrangement where those workers hold appropriate qualifications and screening clearances, rather than requiring displacement as a condition of entry;

  • prohibit SIL providers from structuring arrangements in ways that make the use of the provider’s own workforce a practical or commercial condition of the participant’s tenancy or accommodation;

  • require that SIL support workers delivering supports to participants with ASD Level 2 and Level 3 hold verified specialist autism competency as a condition of the provider’s registration; and

  • require full commercial separation between SIL and SDA providers, consistent with the Disability Royal Commission’s Recommendation 10.2, to eliminate the structural conflict of interest that arises when accommodation providers control the participant’s support workforce.

  1. The Bill’s Savings Figure Does Not Account for What the Cuts Actually

Cost

4.1 The insurance logic requires community participation investment The NDIS was designed as a social insurance scheme on the principle that investment in support during the years when independence can be built reduces lifelong dependence and therefore total lifetime cost. Research confirms that community participation rates among autistic individuals decline significantly during the transition to adulthood (Myers et al., 2015), and that structured adolescent support is the primary factor associated with sustained adult

participation  outcomes.  Cutting  community  participation  support  during  the  critical

developmental window does not save money over a participant’s lifetime. It shifts cost forward to a period when it will be substantially higher, substantially less amenable to intervention, and substantially less visible in the NDIS budget.

4.2 The costs transferred to carers and other systems

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For families of participants with ASD Level 2 and Level 3, funded community participation supports are frequently the only period in which parents can sustain paid employment, attend to medical needs, and manage household functioning. This is not a secondary consideration. It is the structural condition that makes continuous caregiving sustainable over years and decades.

Deloitte Access Economics modelling commissioned by Carers Australia (2020) found that

approximately  160,900  primary  carers  are  not  in  paid  employment  due  to  caring

responsibilities, with substantial documented impacts on lifetime income and retirement savings. The Australian Institute of Family Studies has identified strong evidence linking caregiving for individuals with more severe functional impairment with reduced workforce participation, particularly among mothers. When formal supports are reduced, informal caring demand rises directly and immediately. The fiscal consequence is not eliminated from the public accounts. It is redistributed across reduced income tax revenue, increased Carer Payment and Carer Allowance expenditure, increased Medicare demand, and long-term welfare reliance.

The Disability Royal Commission and the NDIS Review both found that participants receiving SIL sometimes experienced poor-quality care and inadequate safeguards. The downstream cost of those poor outcomes — through hospital presentations, mental health system demand, crisis accommodation and family breakdown — does not appear in the NDIS budget. A reduction in NDIS community participation expenditure that simultaneously increases carer burnout,

reduces  carer  workforce  participation, and  entrenches  participant dependency  cannot

accurately be described as a net fiscal saving. It is a cost transfer, not a saving — and it is a cost transfer onto the people least equipped to absorb it.

  1. Recommendations This submission respectfully recommends that the Committee:

  2. Recognise that community participation supports are not ancillary to SIL outcomes for participants with ASD Level 2 and Level 3 — they are the developmental mechanism through which SIL achieves its independence purpose — and recommend that the SIL commissioning framework require structured daily living skill development with measurable independence outcomes as a condition of funding.

  3. Recommend that the SIL commissioning framework require SIL providers to accommodate a participant’s existing support workers where those workers hold appropriate qualifications and screening clearances, and prohibit commercial arrangements that make the use of the provider’s own workforce a condition of the participant’s tenancy or accommodation.

  4. Recommend that SIL support workers delivering supports to participants with ASD Level 2 and Level 3 be required to hold verified specialist autism competency, distinct from generic disability support qualifications, as a condition of the provider’s registration.

  5. Recommend full commercial separation between SIL and SDA providers, consistent with the Disability Royal Commission’s Recommendation 10.2.

  6. Recommend that the Government publish whole-of-government impact modelling — covering carer workforce exit, Medicare and mental health system demand, state housing and crisis service costs, and lost income tax revenue — before the community participation reduction provisions take effect, on the basis that the Bill’s savings projections do not account for these transfers.

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  1. Conclusion Supported Independent Living for participants with ASD Level 2 and Level 3 is only as effective as the daily living skills, community confidence and support worker relationships the

    participant brings to it and develops within it. Community participation supports are the

primary mechanism through which those foundations are built. Halving them while SIL funding continues converts a developmental investment into a containment cost — indefinitely.

The current SIL model’s structural failure — the routine severance of established support relationships when participants enter SIL — causes demonstrable harm to participants for whom those relationships are not a preference but a clinical necessity. The Bill’s SIL commissioning framework is an opportunity to address this directly. The Bill’s savings projections are built on a figure that does not include what the cuts will cost everywhere else. The Committee has the opportunity to require that accounting before the legislation passes.

This submission respectfully urges the Committee to recommend amendments that preserve the community participation supports through which SIL achieves its purpose, protect the support worker relationships through which this cohort develops and maintains functional capacity, and require the Government to account honestly for what the proposed savings actually cost.

Thank you for considering this submission.

Authorised by:

The Directors

Independence & Beyond Support Services (IBSS)

Date: 1 June 2026

References

Taconet, A.V.  et  al. (2024). Interventions focused on independent living  skills for youth with

intellectual disability or autism spectrum disorder. Journal of Intellectual and Developmental Disability. https://doi.org/10.1177/21651434231152200 [Only 5% of youth with ASD could independently complete all five core daily living activities]

Duncan, A. et al. (2022). A pilot randomized controlled trial of a daily living skills intervention for adolescents with autism. Journal of Autism and Developmental Disorders, 52(2), 938–949. https://doi.org/10.1007/s10803-021-04993-y

McGhee Hassrick, E. et al. (2021). Disrupted care continuity: Testing associations between social networks and transition success for children with autism. Social Sciences, 10(7), 247. https://doi.org/10.3390/socsci10070247 [Trust among support team members significantly associated with transition success for autistic children]

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Myers, B.J. et al. (2015). Community and social participation among individuals with autism spectrum disorder transitioning to adulthood. Journal of Autism and Developmental Disorders, 45(8), 2373–2381.

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 [Recommendation 10.2 — separation of support coordination from other funded supports]

InLife Independent Living (2023). Three quality independent supports are key to NDIS success. Submission to the NDIS Review. Available at: https://www.inlife.org.au/news/three-quality independent-supports-are-key-to-ndis-success

NDIA (2024). Conflicts of interest in the NDIS provider market. National Disability Insurance Agency. Available at: https://www.ndis.gov.au/providers/provider-compliance/conflicts-interest-ndis provider-market

Deloitte Access Economics (2020). The value of informal care in 2020. Prepared for Carers Australia. Available at: https://www.carersaustralia.com.au/wp-content/uploads/2020/07/FINAL-Value of-Informal-Care-22-July_No-Restriction.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.   NDIA.    Available      at:

https://www.ndis.gov.au/research-and-data/research-and-evaluation-reports

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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