Submission 771
Supporting Potential
SUBMISSION TO THE SENATE · COMMUNITY AFFAIRS LEGISLATION COMMITTEE
National Disability Insurance Scheme Amendment (Securing
the NDIS for Future Generations) Bill 2026 Senate Standing Committees on Community Affairs · Submitted 31 May 2026
SUBMITTED BY ORGANISATION
Angela Harvey, Managing Director Supporting Potential Pty Ltd · ABN 99 654 804 216
DATE
31 May 2026
1 Introduction
Supporting Potential is an NDIS quality and safeguarding consulting practice. The practice advises providers on systemic compliance, participant outcomes, and provider-side operational risk. Supporting Potential is also the author of a structural exclusion analysis identifying eleven populations that are excluded from the NDIS by design, and six mechanisms through which that exclusion operates, mapped against the UN Convention on the Rights of Persons with Disabilities.
This submission addresses provisions of the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 across three analytical strands.
The first strand draws on the Treasury modelling released in May 2026 under Senate order to characterise the Bill’s financial architecture and what it means for participants and providers.
The second strand draws on Supporting Potential’s structural exclusion framework and its legislative overlay to identify which specific clauses are hardening existing administrative exclusions into primary legislation, which populations are most affected, and what the compound effect of single clauses operating against multiple populations produces.
The third strand draws on Supporting Potential’s cost modelling of an alternative approach, and argues that the exclusion mechanisms in the Bill are not necessary to achieve the Government’s stated fiscal objectives, and will not achieve them at the whole-of-government level.
The submission makes nineteen specific amendment recommendations at section 11. Supporting analytical documents are listed at section 13 and are available to the Committee on request.
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2 Summary
The NDIS was never intended to be a welfare program. It was designed as an insurance scheme.
The fundamental promise of the insurance model was that investing early in the right supports helps people build skills, confidence, independence, and community connections. Over time, some people require less funded support, others avoid entering more intensive service systems, and overall demand becomes more sustainable.
The goal was not simply to fund disability. The goal was to reduce the long-term impact of disability.
Today, the NDIS supports approximately 739,000 Australians at a cost of almost $50 billion per year. Without reform, projections suggest participant numbers would grow to around 944,000 by 2030-31, with expenditure reaching approximately $66 billion. [Sources: Treasury Modelling, Minister for NDIS Response to Senate Orders, 2026; NDIA Q2 2025-26 Quarterly Report; Health, Disability and Ageing PBS 2026-27, Table 2.1.1, p.374. Expenditure figures for 2030-31 are projections consistent with the Treasury modelling’s 2029-30 figures, extrapolated one year at consistent growth rates.]
What is striking is not the growth in participant numbers. It is the absence of evidence that the insurance mechanism itself is working as intended.
If people were systematically building capacity and reducing reliance on funded supports, we would expect to see the average cost per participant stabilise or decline over time. Instead, costs continue to rise.
The Government’s proposed reforms seek to address this challenge. When the numbers are examined closely, however, we see that whilst there are fewer participants under the reform scenario, the average cost per participant is substantially higher.
That is not because the remaining participants are suddenly receiving better supports. It is because the lower-cost participants are disproportionately removed from the Scheme, leaving a smaller cohort of people with higher support needs and greater complexity.
The projected savings are therefore not primarily generated through a more effective insurance model. They are generated through exclusion. That would be acceptable if Australia had already built the infrastructure to absorb the people leaving the Scheme. Approximately 346,000 participants are projected to leave or be prevented from entering the Scheme by 2030-31. The assessment frameworks, and the lower-needs support mechanisms through states and territories that would receive them, have not been designed, funded, or built.
This is the uncomfortable question sitting beneath the reform agenda.
It should not be about cost savings alone. The question we should be asking is about value for money. If the insurance principles were working as intended, the pathway to sustainability would be clear. People would build capacity. Reliance on funded supports would reduce. Costs per participant would stabilise or fall. Independence would increase.
Instead, the reforms largely achieve savings by reducing participant numbers while leaving the underlying drivers of cost growth largely untouched.
The result is a smaller Scheme supporting a more expensive cohort of participants, with no demonstrated pathway to the outcomes the insurance model requires.
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The Bill pursues two strategies simultaneously. The first changes what the Scheme will pay for, through a series of measures affecting plan budgets, support categories, and reassessment arrangements that will reduce the amount of support available to many participants. The second changes who the Scheme will support. New access requirements, permanence tests, alternative support expectations, suspension powers, and revocation mechanisms are designed to reduce participant numbers over time.
Together these measures are projected to generate savings of approximately $38 billion compared to the no reform baseline. NDIS expenditure still grows. The reforms do not reduce spending in absolute terms. They reduce the rate at which spending grows.
The challenge is that both strategies operate on the same population at the same time. Participants are expected to achieve greater independence while simultaneously receiving reduced access to supports and facing tighter eligibility requirements. Providers are expected to deliver better outcomes under increasing compliance obligations. Families are expected to fill more gaps while broader foundational supports remain under development.
The question is not whether the Scheme needs reform. The question is whether these reforms address the root cause of the problem. If the insurance mechanism is not producing greater independence and lower long-term reliance on funded supports, reducing participant numbers may improve the balance sheet without ever fixing the underlying system. That is the central concern explored in this submission.
This submission identifies six specific concerns arising from that architecture.
Concern 1. The Bill hardens existing administrative exclusions into primary legislation. Three of the six exclusion mechanisms identified in Supporting Potential’s structural analysis have moved from contestable administrative practice into statute. Section 25A(2) alone produces compound exclusion across four distinct populations through a single clause — people on low incomes, people in regional and remote areas, First Nations communities, and people with cyclic and episodic conditions — and the conventional proportionality analysis applied separately to each population does not capture the combined structural effect.
Concern 2. The eligibility framework in sections 24(5), 25A, and 25B creates a structural closed loop for cyclic and episodic disability conditions involving anosognosia that the Bill’s drafting does not resolve and the Explanatory Memorandum does not acknowledge.
Concern 3. The plan suspension and revocation pathway in section 40A will operate predictably against the populations most at risk of contact loss, without the statutory safeguards — inquiry to providers, nominees, and state agencies — that would prevent that outcome.
Concern 4. The ministerial financial powers in sections 34A, 34B, and 45C lack the proportionality and consultation safeguards standard in equivalent Commonwealth frameworks. A power to reduce any support category by up to 99.99 per cent, with no floor, no merits review, and no proportionality test, is not a calibration tool.
Concern 5. The automated decision-making framework in sections 59B to 59D authorises AI-driven decisions on access, plan content, and funding without transparency, bias-testing, or human review
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requirements.
Concern 6. The compliance regime creates asymmetric obligations. Providers face hard deadlines and substantial civil penalties. The Agency faces no equivalent statutory exposure.
The submission proposes that the Committee require the Government to commission whole-of-government cost modelling of the five investment levers that are an alternative to exclusion-based cost control, and to release the IHACPA advice that was commissioned and completed but has not been publicly disclosed. Supporting Potential’s back-of-envelope scenario finds that five levers, properly sequenced, produce a cumulative fiscal reduction in the same order of magnitude as the Government’s target, without removing a single eligible participant and without abandoning the insurance premise on which the Scheme’s long-term sustainability depends.
WHAT PARLIAMENT IS ACTUALLY BEING ASKED TO APPROVE
By passing this Bill, Parliament is not refining an existing scheme. It is endorsing a new version of the NDIS whose operative rules have not been established. The critical content that will determine how the scheme actually functions — the functional capacity thresholds under section 9B, the permanence test application to cyclic conditions under section 25A(4), the record retention categories under section 45B, the automated decision-making parameters under sections 59B to 59D — is deferred entirely to NDIS rules that do not yet exist and in most cases are not required to be made within any specified timeframe. Parliament cannot scrutinise a scheme whose rules have not been written. Passing this Bill is an endorsement of a framework whose substantive content will be determined after the vote, by ministerial instrument, without the primary legislation Parliament is approving providing any floor on what those rules must protect. That is a different kind of legislative decision than approving a scheme whose design is known. The Committee should satisfy itself that Parliament understands what it is and is not endorsing.
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3 The Bill’s Financial Architecture
3.1 What the Treasury modelling shows
In May 2026 the Minister tabled Treasury modelling released under Senate order. It contains the actual figures underpinning the Government’s reform decisions.
The modelling reveals a two-strategy architecture that the Bill’s drafting does not make visible.
Strategy 1 operates through plan content. Seven levers reduce the types and amounts of support in individual plans. The largest single lever is a community participation and allied health budget reset, projected to save $13.2 billion. Plan rollover restrictions and reassessment tightening save a further $3.1 billion. Stricter reasonable and necessary rules save $2.9 billion. The remaining four levers account for the balance of the $24.3 billion total.
Strategy 2 operates through participant numbers. Access tightening, the new permanence test, alternative support requirements, and plan suspension and revocation are projected to reduce participant numbers from 739,414 today to approximately 598,000 by 2030–31, against a no-reform baseline of 944,000. The reduction of approximately 346,000 participants relative to baseline is the mechanism through which the second component of savings is achieved.
IMPORTANT CONTEXT
The $38 billion combined saving is the difference between what the Scheme would have cost without reform and what it is now projected to cost with reform. NDIS annual spending still rises in nominal dollar terms; the saving is a slowing of growth, not a cut to actual expenditure. One feature the Memorandum does not address is the divergence between participant funding growth and enforcement apparatus growth. NDIS participant scheme expenditure is projected to grow by 4.3 per cent in 2026-27, from $54.2 billion to $56.5 billion. Over the same period, the NDIS Quality and Safeguards Commission’s total operating expenditure is budgeted to grow by 14.1 per cent, from $197.5 million to $225.3 million, with Commission staffing increasing 21.4 per cent from 892 to 1,083 average staff. The enforcement and oversight apparatus is growing at more than three times the rate of participant funding. [Sources: NDIA Table 2.1.1, Health, Disability and Ageing Portfolio Budget Statements 2026–27, p. 374; NDIS Commission Tables 1.1 and 2.1.1, Health, Disability and Ageing Portfolio Budget Statements 2026–27, pp. 389–393.]
3.2 Section 34A: Ministerial support reduction power
Section 34A gives the Minister power to reduce, by legislative instrument, the funding component amount for a specified group of supports in old framework plans. The reduction can be to any percentage below 100 per cent. A reduction of 99.99 per cent is within the statutory power.
The only substantive limit is the duty in section 34A(3) to have regard to the safety of participants. The Memorandum at page 32 defines safety for this purpose as “neglect, crisis, or loss of essential functioning.” That definition excludes quality of life, dignity, social participation, choice and control, and the broader meaning of safeguarding under the NDIS Quality and Safeguards framework.
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Absent from section 34A are several safeguards that operate in equivalent Commonwealth ministerial powers. There is no proportionality requirement. There is no consultation requirement with participants, providers, states, or the NDIA Board. There is no floor on the residual amount — section 34A(5) explicitly contemplates that residual funding may be insufficient to purchase the support. There is no merits review. There is no sunset clause. Parliamentary disallowance is the sole material check, and has operated patchily for NDIS-affecting instruments historically.
Section 34A(1)(b) permits targeting by participant class, including by characteristics of the supports they receive. A determination targeting, for example, behaviour support for participants in supported independent living is not a class-wide measure. It is a targeted reduction for which no individual review pathway exists.
RECOMMENDATION 1 — SECTION 34A
Amend section 34A(3) to require that the Minister be satisfied that the reduction is proportionate to the financial sustainability objective, that no less restrictive alternative is available, and that any reduction in excess of 25 per cent of a funding component must be subject to positive parliamentary resolution.
3.3 Section 34B: Indexation discretion
Section 34B gives the Minister discretion to set the indexation factor for old framework plan amounts when prices change under section 45C. The Minister must consider whether to index. The Minister is not required to index.
This converts an administrative practice, in which indexation has operated quasi-automatically when maximum prices were adjusted, into a ministerial discretion that can be exercised to manage cost. Combined with section 34A, the Government holds two simultaneous tools on the old framework cohort: explicit reduction through section 34A, and passive real-terms reduction through non-indexation under section 34B. The Scheme transition under section 32B has no statutory end date. Over a five-year window of non-indexation, the combined real-terms effect on plan value can equal a substantial explicit cut with no parliamentary debate.
RECOMMENDATION 2 — SECTION 34B
Amend section 34B to create a presumption of indexation, requiring the Minister to make a corresponding determination unless satisfied that doing so is not necessary to maintain participant purchasing power, and to publish that finding before any pricing change takes effect.
3.4 Section 45C: Ministerial pricing
Section 45C gives the Minister power to set maximum prices by legislative instrument. The shift from an Agency process informed by the independent Pricing Authority to a ministerial instrument removes a procedural separation between cost-management objectives and pricing outcomes. The Pricing Authority is retained in an advisory capacity. The Minister is not required to accept, or to publish reasoning for departing from, that advice. Where maximum prices do not keep pace with provider costs, providers face the choice of absorbing losses or withdrawing service. For participants in supported independent living, provider withdrawal can mean the loss of accommodation.
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RECOMMENDATION 3 — SECTION 45C
Amend section 45C to require the Minister to table reasons for any pricing determination that departs from the Pricing Authority’s advice before the determination takes effect.
3.5 Section 45A: The asymmetric claim window
Schedule 2, Part 5 reduces the provider claim window from two years to 90 days from the date the support was provided. The Agency’s obligation to process claims remains governed by internal service standards, with no corresponding statutory deadline. A claim submitted on day one depends on the Agency’s processing timetable. If the Agency returns a claim for correction, the provider’s window continues running while the Agency faces no statutory consequence for delay. For smaller and rural providers with limited working capital, this asymmetry creates genuine cash flow risk on properly delivered supports.
RECOMMENDATION 4 — SECTION 45A
Insert a provision requiring the Agency to pay or notify of a deficiency within 28 days of a properly submitted claim, with interest accruing on unpaid amounts after that period.
3.6 The unreleased IHACPA advice on NDIS pricing reform
In the 2024-25 Budget, the Government provided $5.3 million for IHACPA — the Independent Health and Aged Care Pricing Authority — to undertake preliminary work identifying opportunities to reform how NDIS pricing currently works. IHACPA is a statutory body established under the National Health Reform Act 2011 whose pricing and cost advisory functions operate independently of Treasury and the responsible line department. This was a separately commissioned piece of work, outside IHACPA’s usual hospital and aged care remit, commissioned precisely because the Government required independent expert analysis of NDIS pricing that its own agencies could not provide.
IHACPA ran a public consultation process, closed November 2024, titled “A fresh approach to NDIS pricing.” It published a snapshot of what it heard from that consultation in September 2025. The actual advice IHACPA provided to Government has not been publicly released.
This matters directly for the Committee’s examination of section 45C. Section 45C gives the Minister power to set maximum prices by legislative instrument, replacing the existing Agency-published pricing arrangements. It is exactly the provision that IHACPA’s independent pricing advice was designed to inform. The Government holds an independent expert analysis of NDIS pricing reform options. That analysis has not been provided to the Parliament, to the sector, or to submitters to this inquiry.
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THE TRANSPARENCY PROBLEM
The public record shows that IHACPA completed its work, provided advice to Government, and published only a stakeholder consultation summary. The advice itself — the independent expert view on how NDIS pricing should be reformed, and what options would and would not serve participants and providers — is the document the Parliament most needs to assess whether section 45C’s ministerial pricing power is the right mechanism. Without IHACPA’s advice, the Committee is assessing a significant pricing reform on the basis of the Government’s own fiscal modelling. That is precisely the gap the IHACPA commission was meant to fill. The Committee is well placed to require that it be produced.
RECOMMENDATION 5 — IHACPA ADVICE ON NDIS PRICING
The Committee seek production of the IHACPA advice on NDIS pricing reform opportunities provided to Government following the 2024-25 commission, including any scenario analysis, options assessment, and recommendations, and make those materials available to submitters for response before the reporting date. [Source: IHACPA, NDIS pricing reform, ihacpa.gov.au; NDIS pricing reform opportunities — what we’ve heard, 15 September 2025; Budget Paper No. 2, 2024-25,
p. 183.]
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4 The Eligibility Framework
4.1 What the structural exclusion analysis shows
Supporting Potential’s structural exclusion framework identifies eleven populations that are excluded from the NDIS by design, and six mechanisms through which exclusion operates, mapped against the CRPD. The analysis was developed prior to this Bill.
The Bill changes the nature of that exclusion fundamentally. Three of the six mechanisms have moved from administrative practice into primary legislation. Exclusion that was previously contestable through individual appeal, complaint, and policy advocacy now requires parliamentary amendment, constitutional challenge, or international human rights complaint to address.
A further structural feature of the Bill is that single clauses operate simultaneously against multiple populations. Section 25A(2) was drafted to address one legal issue. Its operation excludes four structurally distinct populations through a single instrument. The proportionality of each exclusion, assessed separately, understates the compound harm.
4.2 Sections 24(5) and 25A: The permanence test and the cyclic disability closed loop
Section 24(5) introduces a new permanence test. An impairment is not permanent unless the person has undertaken all appropriate treatment, and remaining treatment options are unlikely to materially improve or alleviate the impairment. Section 25A(1) defines appropriate treatment as treatment that is evidence-based, reliably alleviates the impact of the impairment, and is regularly performed in Australia.
Together, these provisions create a structural closed loop for cyclic and episodic conditions involving anosognosia. Schizophrenia is the clearest example. Antipsychotic medication satisfies all three limbs of section 25A(1). The Bill therefore treats antipsychotic medication as appropriate treatment that a person with schizophrenia must have undertaken to establish permanence.
THE CLOSED LOOP
Anosognosia is the neurological absence of insight into one’s own illness. It affects approximately 50 to 60 per cent of people with schizophrenia and around 40 per cent of people with bipolar disorder during acute phases. The condition prevents the person from recognising the need for treatment. Adherence to antipsychotic medication requires the NDIS-funded supports the tightened access criteria will withhold. Supports are withheld because medication exists and is clinically available. The person cannot resolve the loop without external support, and the external support is unavailable until the loop is resolved.
Side effect profiles compound the problem. Antipsychotic medications commonly produce tardive dyskinesia, metabolic syndrome, sedation, and akathisia. Stopping medication because the side effects are clinically intolerable is a rational decision about a real burden. The Bill’s test does not accommodate this. The kindling effect of repeated relapse means each untreated episode produces cumulative deterioration in cognitive function, social functioning, and treatment responsiveness.
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The same pattern applies to bipolar disorder, recurrent major depression, borderline personality disorder, and complex post-traumatic stress disorder. It also appears in relapsing-remitting multiple sclerosis, Crohn’s disease, ulcerative colitis, epilepsy, severe migraine, and endometriosis.
The rule-making power under section 25A(4) is the available resolution. NDIS rules made under that subsection could treat conditions producing anosognosia, or that impair decision-making during relapse phases, as situations where the person has undertaken all appropriate treatment. The Bill leaves this entirely to subsequent rule making. It does not require those rules to be made, does not set a timeframe, and does not direct what protection must be provided.
RECOMMENDATION 6 — SECTIONS 24(5) AND 25A(1)
Make commencement of sections 24(5) and 25A(1) conditional on NDIS rules being in force under section 25A(4) that address the application of the permanence test to cyclic and episodic conditions involving anosognosia and impaired treatment decision-making capacity.
4.3 Section 25A(2): The Davis reversal and compound exclusion
Section 25A(2) provides that treatment may be appropriate treatment regardless of whether a person’s individual circumstances restrict access to it. The note to the subsection explicitly identifies financial circumstances and geographical location as individual circumstances within the meaning of the provision. This reverses the reasoning of the Federal Court in National Disability Insurance Agency v Davis [2022] FCA 1002, which held that affordability and geographical accessibility are relevant to whether treatment is available to the person.
The provision operates simultaneously against four structurally distinct populations: people on low incomes who cannot sustain access to intensive treatment programs; people in regional and remote areas where treatments are not delivered locally; First Nations communities where geographic and financial barriers are compounded by cultural and linguistic inaccessibility; and people with cyclic and episodic conditions whose adherence barriers are internal to the condition itself.
These are not four small overlapping groups at the margins. These are four substantial populations the Scheme was designed for. A single legislative clause produces compound exclusion across all four simultaneously. The conventional proportionality analysis applied separately to each population does not capture the combined structural effect.
RECOMMENDATION 7 — SECTION 25A(2)
Amend section 25A(2) to require consideration of whether the treatment is practically accessible to the person having regard to their financial and geographical circumstances, and whether the person has the cognitive and motivational capacity to undertake the treatment without external support.
4.4 Section 25B: Alternative support requirements
Section 25B allows the CEO to redirect participant needs to alternative support systems outside the NDIS. The risk is not primarily at the access stage. It is at the plan development stage, where a participant who is eligible may have support needs redirected to alternatives that are theoretically available but practically inaccessible. State mental health services have contracted. School-based disability supports have weakened. Aged care pathways
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have narrowed. The mainstream systems that section 25B references as alternatives have shed the load that produced NDIS cost growth in the first place. A participant whose support needs are redirected to an alternative that does not operationally exist is not supported; they are categorised.
RECOMMENDATION 8 — COMMENCEMENT OF ELIGIBILITY TIGHTENING
Make commencement of Schedule 1 Parts 8 and 9 conditional on Foundational Supports being operationally available for the cohorts affected by those parts.
RECOMMENDATION 9 — SECTION 25B
Insert into section 25B a requirement that, before redirecting needs to an alternative system, the CEO must be satisfied that the alternative support is operationally available and practically accessible to the participant.
4.5 Section 9B: Statutory functional capacity
Section 9B introduces a statutory definition of functional capacity with thresholds set in NDIS rules. This converts an assessment process that has been individually contextualised and clinically informed into one with a standardised threshold structure. The rules have not been made. The Bill provides no statutory direction on calibration against the existing participant population or what review mechanism applies if thresholds exclude previously eligible categories of impairment.
RECOMMENDATION 10 — SECTION 9B
Insert into section 9B a requirement that functional capacity thresholds be calibrated against the functional profiles of existing eligible participants, reviewed within three years, and designed not to exclude categories of impairment that have previously met the disability requirements.
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5 Plan Continuity
5.1 Section 40A: The contact suspension power
Section 40A gives the CEO power to suspend a participant’s plan where the CEO is satisfied that reasonable attempts to contact the participant have been made and the participant is not contactable. Section 30(1A) provides that participant status may be revoked if the plan has been suspended for 90 days.
“Reasonable attempts” is not defined in the Bill. There is no rule-making power in Part 7 to define it. The Bill imposes no obligation to contact the participant’s existing service providers, plan nominees, or correspondence nominees. It imposes no obligation to check with state and territory health, mental health, corrective services, or child protection departments — though those agencies typically know exactly where a missing participant is. The 90-day revocation clock runs from suspension regardless of further Agency action.
PREDICTABLE OPERATIONAL SCENARIO
A SIL resident is admitted to a state-run psychiatric inpatient unit during a relapse. Written correspondence goes to the SIL house. The resident does not receive it. On day 91 the plan is suspended. On day 181 the plan is revoked. When the resident is discharged, they return without a plan, without accommodation security, and without support coordination. The state hospital knew exactly where they were throughout. The Agency had no obligation to ask.
The populations most likely to experience contact loss are the populations for whom loss of plan is most dangerous: people with cognitive disability, people with psychosocial disability in relapse, people in crisis, people experiencing homelessness, and people in institutional settings where correspondence does not reach them. These are not marginal cases. For the SIL sector, these are the core resident cohort.
Transitional item 87 for Part 7 provides that the CEO may have regard to “reasonable attempts” made before commencement. Pre-commencement contact failures can be retrospectively counted toward the suspension threshold. Participants currently subject to long-running Agency contact attempts could find their plans suspended on day one of commencement.
RECOMMENDATION 11 — SECTION 40A
Amend section 40A to define “reasonable attempts” to include written inquiry to any registered NDIS provider currently delivering supports, any plan or correspondence nominee, and relevant state and territory health and corrective services agencies, and to require documentation of each inquiry in the participant’s record before suspension.
5.2 Sections 48 and 48A: Reassessment restrictions
The amendments to section 48 remove support coordinators and plan managers as parties who can request reassessment. The Memorandum at page 19 is explicit that this is the provision’s purpose. This removes a practical pathway on behalf of participants who lack capacity to initiate reassessment themselves. Many SIL residents have
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cognitive or psychosocial disability that makes self-initiated requests difficult or impossible. Plan nominees are not universally appointed for this cohort.
New section 48A requires a finding of significant change arising from a discrete event — an alteration in functional capacity or a change in personal or environmental circumstances. Gradual acuity escalation within an existing impairment profile, without a discrete triggering event, will commonly fail the test. The Memorandum’s own worked examples confirm this. The extended CEO response time of 90 days means providers carry the staffing and safety burden during the assessment window.
RECOMMENDATION 12 — SECTION 48(2)
Amend section 48(2) to include as a requester category a registered NDIS provider delivering supports to a participant who lacks capacity to self-initiate and has no plan nominee in place, subject to documented evidence of the participant’s awareness of the request.
RECOMMENDATION 13 — SECTION 48A
Amend section 48A to include a limb for gradual acuity escalation within an existing impairment profile, where the participant has experienced sustained or repeated increases in support intensity without a discrete qualifying event.
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6 Automated Decision-Making
Section 59B authorises the use of computer programs to take administrative action under the Act, including action involving discretion, evaluative judgement, and states of mind. This is the appropriate post-Robodebt legislative architecture: authorise automation explicitly, require written CEO arrangement, and maintain merits review. The structural framework is sound.
It does not go far enough in three respects. There is no statutory requirement for human review of adverse automated decisions before they take effect. A participant whose access is refused, plan is reduced, or status is suspended by an automated decision is told after the fact. There is no statutory transparency requirement. Standard operating procedure instruments under section 59D are required, but the Bill does not require publication of the parameters, algorithm, or decision logic. There is no statutory bias-testing requirement. Automated systems trained on historical NDIS data will inherit the historical patterns of administrative exclusion the structural analysis identifies. Without systematic testing, the Bill risks encoding existing structural exclusions at scale.
The Royal Commission into the Robodebt Scheme recommended transparency, human review of adverse decisions, and audit mechanisms as baseline requirements for automated administrative decision-making. All three are absent from sections 59B to 59D.
Section 59B(4) is broad enough to authorise an automated system to form the satisfaction required for plan suspension under section 40A(1). Combined with the contact suspension concern above, a plan could be suspended by an automated trigger without any human assessment of why the participant is uncontactable.
RECOMMENDATION 14 — SECTION 59B
Amend section 59B to require human review of adverse automated decisions affecting access, plan content, or payment before the decision takes effect, or alternatively require notification of the automated nature of the decision and provision of a fast-track internal review pathway.
RECOMMENDATION 15 — SECTION 59D
Amend section 59D to require that standard operating procedure instruments be published in a form accessible to participants, providers, and advocates.
RECOMMENDATION 16 — SECTION 59B
Insert into section 59B a requirement that the Agency conduct and publish bias testing for any automated decision system affecting access, plan content, or payment, with reference to disability type, geographical location, income, First Nations status, and cultural and linguistic background.
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7 The Compliance Regime
7.1 Section 45B: Record retention obligations
Section 45B creates a civil penalty of 120 penalty units for failure to retain records of a kind prescribed by NDIS rules — equalling $37,560 per breach for individuals and $187,800 for corporations under the five-times corporate multiplier. The substantive content of the obligation is entirely deferred to Category D rules requiring state and territory consultation. Those rules cannot be in place before commencement. The Bill provides no minimum record categories, no timeframe for making rules, and no public consultation requirement. Providers must default to retaining everything rather than comply with a defined standard, at non-trivial storage and privacy cost.
RECOMMENDATION 17 — SECTION 45B
Amend section 45B to include a non-exhaustive statutory list of minimum record categories, and require that NDIS rules prescribing additional categories be made within 12 months of commencement and be subject to provider consultation.
7.2 Section 53: Coercive information gathering from participants
Section 53 gives the CEO power to require a participant to provide information or documents relevant to the Agency’s functions, with a civil penalty of 60 penalty units for non-compliance. The power extends to health information including psychiatric records, treatment plans, and medication history. A participant whose permanence is being reassessed under sections 24(5) and 25A can be required to produce the documents the Agency will use to remove their access, without statutory limits on how that information is subsequently used, and without a requirement to consider whether the participant has decision-making support in place.
RECOMMENDATION 18 — SECTION 53
Amend section 53 to require the CEO to consider whether the participant has decision-making support in place before issuing a notice, and to prohibit use of health information collected under the notice to support a plan reduction or revocation without separate notice and an opportunity to respond.
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8 Why Exclusion-Based Cost Control Fails
The Committee is examining a Bill whose stated objective is the long-term sustainability of the Scheme. That objective is legitimate. The structural question is not whether fiscal stabilisation is necessary, but whether the instruments the Bill uses to pursue it will work at the whole-of-government level and over the decade.
Supporting Potential’s analysis identifies five structural reasons to expect that exclusion-based cost control will not deliver sustained fiscal stabilisation.
Appeals and review load. Tighter access tests produce more refused applications and more contested decisions. In the 12 months to June 2025, 73 per cent of Administrative Review Tribunal matters were resolved by pre-hearing agreement — meaning the NDIA changed its position before the case was heard. Of matters that proceeded to substantive hearing, 45 per cent resulted in the NDIA decision being set aside or varied. A system where the Agency concedes in nearly three quarters of contested cases before they reach a hearing is a system with systematic front-line decision failure, not a system where the access test is being applied correctly. The Bill’s access tightening will produce more decisions at higher volume, with no evidence that the front-line quality problem has been resolved. Each pre-hearing concession costs more than the original approval would have, in Agency time, participant stress, and legal representation. [Source: NDIA, Quarterly Report Q4 2024-25.]
Hidden cohorts and re-entry. People removed from the NDIS re-enter at higher cost through state mental health inpatient units, forensic disability accommodation, the corrections system, aged care misplacement, and homelessness services. Each is more expensive per person per year than the NDIS supports it displaces. The NDIS-line saving is partly illusory at the Commonwealth balance sheet level.
Compound exclusion against intended populations. The Bill’s exclusion mechanisms operate hardest against the populations the NDIS was designed for: people with cyclic and episodic conditions, First Nations people, people in regional and remote areas, people on low incomes, and people with co-occurring impairments. Sustained cost reduction by squeezing these populations will not survive political contact over a decade.
Regulatory arbitrage. Where access tests are tightened, sophisticated actors find pathways around them. The administrative cost of each cycle of tightening and adaptation accumulates. The blanket compliance load on compliant providers is itself a version of this: it increases costs across the sector to address a problem concentrated in a minority of actors.
Erosion of public legitimacy. A Scheme that suspends plans for people in psychiatric units, removes participants with cyclic disability, and shifts cost to state systems loses the political support it depends on for long-term funding. Sustained funding requires sustained legitimacy.
Submission 771
Failure of the insurance premise. The NDIS was designed as an insurance scheme on the actuarial assumption that capacity-building supports would reduce long-term dependency, generate exits, and moderate cost growth over time. The figures do not show this happening. Without reform, the no-reform baseline projects per-participant cost rising modestly from approximately $67,350 today to approximately $70,340 by 2030–31 — 4.4 per cent over five years, broadly tracking inflation. Under the Bill’s reform scenario, per-participant cost rises to approximately $90,300 — a 34 per cent increase from today. The reform does not reduce per-participant cost; it raises it sharply. The implied average cost of each of the 346,000 participants removed is approximately $35,800 — roughly half the current scheme average — confirming the reform removes lower-cost participants first and concentrates the highest-complexity cohort in a smaller scheme. An insurance scheme achieving its purpose would show stable or declining per-participant cost as people build independence and reduce their support needs. The reform scenario produces the opposite. The structural problem — why individual cost trajectories are not reducing over time — is left entirely unaddressed.
Submission 771
9 An Alternative Path: Five Investment Levers
The Committee may wish to consider whether the Bill should be amended to require the Government to commission whole-of-government modelling of the following five investment levers as an alternative to exclusion based cost reduction.
Supporting Potential has prepared a back-of-envelope scenario modelling the combined effect of these levers. The scenario is directional, not a fiscal model. All figures use ranges and are stated with explicit assumptions. They are published here for illustrative purposes. The Committee should note that Treasury or Parliamentary Budget Office modelling would be required to test the proposition rigorously — and that commissioning such modelling is itself a recommendation of this submission.
LEVER 1 Build Foundational Supports before tightening Tier 1 eligibility
The 2011 Productivity Commission design assumed Tier 2 — a population-level supports system for people with moderate needs — would exist alongside the NDIS. It was never built. The cost growth in Tier 1 is a direct consequence: people whose needs Tier 2 would have met entered Tier 1 because there was nowhere else to go. The NDIS Review named this explicitly in 2023.
Building Foundational Supports operationally would absorb 100,000 to 150,000 current plan-equivalents at fit-for-purpose cost. The Bill’s eligibility tightening commences before Foundational Supports is operational — producing a window of compound exclusion. The amendment that addresses this is conditional commencement: eligibility tightening should not commence until Foundational Supports is operationally available for the affected cohorts.
$7–11bn $14–24bn $7–13bn
Year-4 annual saving 4-year gross saving 4-year net effect
LEVER 2 Enforce mainstream system interfaces before redirecting participants
NDIS cost growth has been amplified by mainstream system failure. State mental health services have contracted. Aged care pathways have narrowed. Child protection and justice systems route people with disability through the NDIS for supports those systems should be funding directly. Section 25B of the Bill redirects participants to alternatives that have shed the load that drove NDIS cost growth. A genuine boundary management strategy would invest in those systems and ensure the alternatives exist before redirecting anyone.
$1.5–3bn $4–8bn $2.5–5bn
Year-4 annual saving 4-year gross saving 4-year net effectSubmission 771
LEVER 3 Shift from fee-for-service to outcomes-based pricing
The Bill centralises pricing in the Minister without changing the underlying fee-for-service structure. Fee for-service rewards volume, not outcomes. A 5 to 10 per cent efficiency gain on projected scheme expenditure, achievable by shifting to outcomes-based and capability-calibrated pricing, is the largest demand-side lever available — because it operates on every dollar in the Scheme, not on a sub-cohort. The Productivity Commission, the Grattan Institute, and the 2023 NDIS Review have all identified this as the principal unrealised lever. The Bill’s pricing centralisation creates the statutory architecture that outcomes pricing requires. The lever is available without further legislation.
$3–5bn $7–14bn $6–13bn
Year-4 annual saving 4-year gross saving 4-year net effect
LEVER 4 Integrity by design, not blanket compliance load
The Bill’s own modelling assigns approximately 8.2 to 8.3 per cent of payments to leakage, approximately $3.5 to $5 billion per year. The current realised capture rate is approximately 5 to 10 per cent of that leakage. Investing in real-time anomaly detection, cross-agency data sharing through the existing Fraud Fusion Taskforce, and targeted enforcement against the actors producing the patterns can increase capture to 30 to 50 per cent. This produces substantially greater integrity return at a fraction of the compliance load that Schedule 2’s blanket approach imposes on the 90 per cent of providers who are compliant.
$1.5–3bn $3–7bn $2.5–6bn
Year-4 annual saving 4-year gross saving 4-year net effect
LEVER 5 Fund the NDIA properly to enable good planning
In the 12 months to June 2025, 73 per cent of Administrative Review Tribunal matters were resolved by pre-hearing agreement — the NDIA changing its position before the case was heard — with a further 45 per cent overturn rate among the minority of cases that proceeded to substantive hearing. This is the clearest available evidence that front-line planning quality is systematically poor. Plans set too low produce acuity crises and emergency increases. Plans set too high produce avoidable cost without capability gain. The appeals process consumes resources at both NDIA and Tribunal level. Investment in planner capability, caseload reduction, decision-support tools, and quality assurance reduces avoidable variation and appeal volume. A 4 to 6 per cent reduction in avoidable plan variation produces $2 to $3 billion per year in saving. The Bill’s automated decision-making framework moves in the opposite direction, risking the scaling of current quality problems.
$2–3bn $4–7bn $2–4.5bn
Year-4 annual saving 4-year gross saving 4-year net effectSubmission 771
The combined scenario
Year-4 annual 4-year gross 4-year 4-year net
Lever
saving saving investment effect
1. Foundational Supports $7–11bn $14–24bn $7–11bn $7–13bn
/ Tier 2
2. Mainstream interfaces $1.5–3bn $4–8bn $1.5–3bn $2.5–5bn
3. Outcomes-based $3–5bn $7–14bn $0.5–1bn $6–13bn
pricing
4. Integrity by design $1.5–3bn $3–7bn $0.4–0.7bn $2.5–6bn
5. NDIA planning $2–3bn $4–7bn $1.5–2.5bn $2–4.5bn
capability
Total $15–25bn $32–60bn $11–18bn $20–42bn
THE HONEST FRAMING
The five-lever scenario produces a cumulative NDIS-line gross saving of $32 to $60 billion over four years, against a Government target of $60 to $70 billion. The upper bound of the investment scenario sits within the Government’s target range on a like-for-like NDIS-line comparison. The whole-of-government comparison is more favourable to the investment approach, because the exclusion strategy shifts cost to state mental health, homelessness, aged care, and justice systems at rates that are higher per person than the NDIS supports removed. These are directional figures, not a fiscal model. The Productivity Commission, Australian Government Actuary, or Parliamentary Budget Office have the capacity to test the proposition rigorously.
RECOMMENDATION 19
The Committee recommend the Government commission the Productivity Commission, Australian Government Actuary, or Parliamentary Budget Office to model the whole-of-government fiscal effect of the five investment levers identified in this section, and to compare that effect with the whole-of-government fiscal effect of the exclusion strategy, including cost-shift to state and territory systems.
Submission 771
10 Specific Drafting Concerns
Beyond the structural concerns above, the Committee may wish to examine the following specific drafting features.
Section 34A(5) explicitly contemplates that a support determination may leave funding below the cost of the support. There is no floor on the residual amount and no mechanism for the participant to seek supplementary funding. The Committee may wish to seek the Minister’s explanation for this design choice.
Section 40A contains no requirement to contact state and territory agencies before plan suspension. The Memorandum at page 58 implies the Agency should not suspend where the participant was in hospital, but provides no statutory mechanism to ascertain that. The protection the Memorandum describes is contingent on Agency practice, not legislative requirement.
Section 48(2)(b)(iii) is sometimes read as a children-focused provision. The substantive feature is the lockout of intermediaries. The children’s paragraph is a procedural accommodation mirroring similar provisions throughout the Act. The material operational impact is on adult SIL residents.
Section 59B(4) authorises automation of decisions involving “a state of mind being formed.” This is broad enough to authorise an automated system to form the satisfaction required for plan suspension under section 40A(1) — compounding the contact suspension concern at section 5.1 above.
Transitional item 87 for Part 7 provides that the CEO may have regard to “reasonable attempts” made before commencement. Pre-commencement contact failures can be retrospectively counted toward the suspension threshold. Participants currently subject to long-running Agency contact attempts could find their plans suspended on day one of Part 7’s commencement.
Submission 771
11 Recommendations
This submission proposes nineteen specific matters for the Committee’s consideration.
RECOMMENDATION 1
Amend section 34A(3) to require that the Minister be satisfied that the reduction is proportionate to the financial sustainability objective, that no less restrictive alternative is available, and that any reduction in excess of 25 per cent of a funding component must be subject to positive parliamentary resolution. Section 34A — ministerial support reduction power
RECOMMENDATION 2
Amend section 34B to create a presumption of indexation, requiring the Minister to make a corresponding indexation determination unless satisfied that doing so is not necessary to maintain participant purchasing power, and to publish that finding before any pricing change takes effect.
Section 34B — indexation discretion
RECOMMENDATION 3
Amend section 45C to require the Minister to table reasons for any pricing determination that departs from the Pricing Authority’s advice before the determination takes effect. Section 45C — ministerial pricing
RECOMMENDATION 4
Insert a provision requiring the Agency to pay or notify of a deficiency within 28 days of a properly submitted claim, with interest accruing on unpaid amounts after that period. Section 45A — asymmetric claim window
RECOMMENDATION 5
The Committee seek production of the IHACPA cost study commissioned in relation to NDIS reform, including any scenario analysis, sensitivity analysis, and comparison with Treasury projections, and make those materials available to submitters for response before the reporting date. IHACPA cost study — transparency and parliamentary scrutiny
RECOMMENDATION 6
Make commencement of sections 24(5) and 25A(1) conditional on NDIS rules being in force under section 25A(4) that address the application of the permanence test to cyclic and episodic conditions involving anosognosia and impaired treatment decision-making capacity. Sections 24(5), 25A(1) — conditional commencement on protective rules
Submission 771
RECOMMENDATION 7
Amend section 25A(2) to require consideration of whether the treatment is practically accessible to the person having regard to their financial and geographical circumstances, and whether the person has the cognitive and motivational capacity to undertake the treatment without external support. Section 25A(2) — the Davis reversal
RECOMMENDATION 8
Make commencement of Schedule 1 Parts 8 and 9 conditional on Foundational Supports being operationally available for the cohorts affected by those parts.
Schedule 1 Parts 8 and 9 — commencement sequencing
RECOMMENDATION 9
Insert into section 25B a requirement that, before redirecting needs to an alternative system, the CEO must be satisfied that the alternative support is operationally available and practically accessible to the participant. Section 25B — alternative support requirements
RECOMMENDATION 10
Insert into section 9B a requirement that functional capacity thresholds be calibrated against the functional profiles of existing eligible participants, reviewed within three years, and designed not to exclude categories of impairment that have previously met the disability requirements. Section 9B — statutory functional capacity
RECOMMENDATION 11
Amend section 40A to define “reasonable attempts” to include written inquiry to any registered NDIS provider currently delivering supports, any plan or correspondence nominee, and relevant state and territory health and corrective services agencies, and to require documentation of each inquiry in the participant’s record before suspension. Section 40A — plan suspension
RECOMMENDATION 12
Amend section 48(2) to include as a requester category a registered NDIS provider delivering supports to a participant who lacks capacity to self-initiate and has no plan nominee in place, subject to documented evidence of the participant’s awareness of the request. Section 48(2) — reassessment requesters
RECOMMENDATION 13
Amend section 48A to include a limb for gradual acuity escalation within an existing impairment profile, where the participant has experienced sustained or repeated increases in support intensity without a discrete qualifying event. Section 48A — reassessment conditions
Submission 771
RECOMMENDATION 14
Amend section 59B to require human review of adverse automated decisions affecting access, plan content, or payment before the decision takes effect, or alternatively require notification of the automated nature of the decision and provision of a fast-track internal review pathway. Section 59B — automated decision-making
RECOMMENDATION 15
Amend section 59D to require that standard operating procedure instruments be published in a form accessible to participants, providers, and advocates.
Section 59D — standard operating procedures
RECOMMENDATION 16
Insert into section 59B a requirement that the Agency conduct and publish bias testing for any automated decision system affecting access, plan content, or payment, with reference to disability type, geographical location, income, First Nations status, and cultural and linguistic background. Section 59B — automated decision-making
RECOMMENDATION 17
Amend section 45B to include a non-exhaustive statutory list of minimum record categories, and require that NDIS rules prescribing additional categories be made within 12 months of commencement and be subject to provider consultation. Section 45B — record retention obligations
RECOMMENDATION 18
Amend section 53 to require the CEO to consider whether the participant has decision-making support in place before issuing a notice, and to prohibit use of health information collected under the notice to support a plan reduction or revocation without separate notice and an opportunity to respond. Section 53 — coercive information gathering
RECOMMENDATION 19
The Committee recommend the Government commission the Productivity Commission, Australian Government Actuary, or Parliamentary Budget Office to model the whole-of-government fiscal effect of the five investment levers identified in section 9, and to compare that effect with the whole-of government fiscal effect of the exclusion strategy, including cost-shift to state and territory systems. Whole-of-government cost modelling
Submission 771
12 Conclusion
The Bill’s objectives are legitimate. Fiscal sustainability is a precondition for the Scheme’s existence. Integrity protections are necessary. The structural problems the Bill responds to are real.
The key issue now is whether the instruments the Bill uses to pursue those objectives are calibrated to deliver them, or whether they will produce the structural failures that exclusion-based cost control has historically produced in comparable schemes.
This submission has identified specific provisions that can be improved within the Bill’s own framework. It has proposed an alternative fiscal path that the Parliament is well positioned to require the Government to test. And it has identified the structural exclusion features that, if left unchanged, will produce the compound outcomes that make schemes like this unsustainable politically over the long term.
None of the recommendations in this submission oppose the reform. Each identifies an amendment that would make the provisions more precisely targeted, more consistent with existing Commonwealth governance standards, or more likely to achieve the objectives they are designed to serve.
Supporting Potential would be pleased to provide further information, supplementary analysis, or oral evidence at any hearing the Committee conducts.
Angela Harvey
Managing Director, Supporting Potential Pty Ltd
ABN 99 654 804 216 ·
AI disclosure. Artificial intelligence tools were used in the drafting and development of this submission. All analysis, positions, arguments, figures, and recommendations have been directed, verified, and are owned by Angela Harvey. The content reflects her professional judgment and she accepts full responsibility for it.
Submission 771
13 Supporting Analysis
The following documents prepared by Supporting Potential are available to the Committee on request.
Attachment A: What the Bill means in practice — two case studies in invisible harm Two real individuals (anonymised with written permission) — Sierra, an autistic woman on the NDIS, and Ashlee, subject of the Lifestyle Solutions Federal Court proceedings — with clause-by-clause analysis of how sections 40A, 48(2), 25A(2), 25B, 59B, and 45B would have applied to their lives. Available at research/legislation/attachment-case-studies-bill-2026.html.
NDIS Disability Inequality: Structural Exclusion Framework with Legislative Overlay (v2, Bill 2026)
Visual research tool identifying eleven structurally excluded NDIS populations, six exclusion mechanisms, and the specific clauses of this Bill that harden administrative exclusions into primary legislation. Available at research/ndis-disability-inequality-systems-v2-legislation-overlay.html.
NDIS Reform: What the Treasury Modelling Actually Shows
Analysis of Treasury modelling released under Senate order in May 2026, including the two-strategy architecture, participant trajectory figures, per-participant cost analysis, and enforcement cost comparisons. Available at research/ndis-reform-financial-model-explainer.html.
Cost Control Without Exclusion: How to Stabilise the NDIS While Honouring the Reasonable and
Necessary Test
Analytical argument for the five investment levers and an explanation of why exclusion-based cost control fails at the structural level. Available at research/legislation/cost-control-without-exclusion.md.
Back-of-Envelope Counter-Scenario: Five Investment Levers Instead of Exclusion
Directional fiscal scenario of the five levers against the Government’s stated target, with per-lever assumptions, ranges, and source references. Available at research/legislation/cost-piece-gap6 counter-scenario.md.
Bill 2026 Question Log
Detailed analysis of ten specific provisions including direct citation of bill text, Memorandum commentary, SIL provider operational implications, and amendment recommendations. Available at research/legislation/bill-2026-question-log.md.
Submission to the Parliamentary Joint Committee on Human Rights
Human rights compatibility analysis addressing CRPD articles 4(2), 4(3), 5, 12, 13, and 19 with specific attention to the cyclic disability closed loop and compound exclusion. Available at
Submission 771
research/legislation/pjchr-submission-securing-ndis-bill-2026.md.
References
– National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026, first reading text.
– National Disability Insurance Agency v Davis [2022] FCA 1002.
– Treasury Modelling, Minister for the National Disability Insurance Scheme Response to Senate Orders Nos 504,
506, 508 (and 503, 505, 507 directed to the Treasurer), tabled May 2026. Ref No: MC26-010216. Covers participant trajectory projections and per-lever fiscal impact.
– National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026,
Explanatory Memorandum, Statement of Compatibility with Human Rights and Regulatory Impact Analysis
(Department of Health, Disability and Ageing, 2026). – National Disability Insurance Agency, Quarterly Report Q2 2025-26 (December 2025 quarter).
– National Disability Insurance Agency, Quarterly Report Q4 2024-25 (June 2025 quarter). Source for Administrative Review Tribunal pre-hearing agreement rates.
– Health, Disability and Ageing Portfolio Budget Statements 2026-27 (May 2026). NDIA Table 2.1.1, p.374; NDIS Commission Tables 1.1 and 2.1.1, pp.389-393.
– Department of Social Services Portfolio Budget Statements 2025-26 (March 2025). NDIS Commission resource statement, pp.177-181; NDIA resource statement, pp.153-154.
– Independent Review into the National Disability Insurance Scheme (2023), final report Working Together to Deliver the NDIS.
– Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability (2023), final report.
– Royal Commission into the Robodebt Scheme (2023), final report.
– Productivity Commission (2011), Disability Care and Support, Inquiry Report Nos 54 and 55.
– Productivity Commission (2017), National Disability Insurance Scheme (NDIS) Costs, Study Report. – Australian National Audit Office, Report 48 of 2024-25, NDIA Fraud and Non-Compliance Management.
– Australian National Audit Office, Report 41 of 2024-25, NDIA Board Governance.
– Taylor Fry (2023), Cost-Benefit Analysis of the NDIS, commissioned by the NDIS Review.
– Per Capita (2021), The Economic Contribution of the NDIS.
– CRPD Committee, General Comment No. 1 (2014) on Article 12; General Comment No. 5 (2017) on Article 19; General Comment No. 7 (2018) on participation. – UN Convention on the Rights of Persons with Disabilities, entered into force 3 May 2008, ratified by Australia 17 July 2008.
Supporting Potential Pty Ltd · ABN 99 654 804 216 angela@supportingpotential.com.au · 0409 799 381 Submission to the Senate Community Affairs Legislation Committee · 31 May 2026