Submission 775
Submission to the Senate Community Affairs Legislation
Committee
Inquiry into the NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026
Zac Demopoulos
Behaviour Support Lead, Step 2 Allied Health
Behaviour Support Practitioner (Advanced)
AASW-Accredited Social Worker
Email: Date: 29 May 2026
Introduction
I am a Behaviour Support Practitioner (Advanced) and AASW-Accredited Social Worker.
I lead the behaviour support team at Step 2 Allied Health in Geelong, Victoria.
Our team works with NDIS participants who have complex behavioural support needs, and with their families and support teams.
I oppose the Bill in its current form.
The case studies that follow are drawn from current and recent work across my team. They have been de-identified to protect participant privacy.
Case studies
Each case study is structured the same way: background, what happened, and what is at risk under the Bill.
Case Study 1
Background.
A young person living at home with their mother and siblings.
Complex behavioural support needs, including significant dysregulation, perseverative behaviour loops, and self-harming behaviours when their needs aren’t met in expected ways.
The family relies on consistent, well-implemented supports to function.
What happened.
Submission 775
● By late 2025 the family was at a point of crisis. ● The participant was in sustained distress across home and community settings. ● They and their mother were waking every two hours from midnight through to 5am. ● Their mother reported, on some nights, being physically unable to get out of bed to respond. ● Relinquishment of care was considered, alongside the possibility that the family would lose their housing. ● A subsequent provider used a 2:1 staffing model but placed inexperienced workers who could not implement the PBS approach in practice. ● Behaviours of concern escalated. ● A staged introduction of a new, experienced support worker, beginning with shadow shifts alongside a long-standing worker and progressing to 1:1 ● The participant now accepts community-based OT intervention, uses a communication board at school to self-advocate, manages their own toileting independently at school, returns home regulated, and engages appropriately with their siblings and mother. ● Their sleep has improved.
What is at risk.
This outcome depended on consistent, well-funded, specialist-led support.
Reduced funding, ministerial-directed cuts to community participation or capacity building, or automated decisions that treat this participant as an average case would have made the staged worker introduction unworkable.
Relinquishment was the likely alternative.
Case Study 2
Background.
A young person transitioning from school to a day program. The program could not safely support him without 2:1 staffing.
What happened.
● Without the staffing ratio they required, they were effectively confined to one room with limited stimulation and minimal community access. ● Distress escalated. ● Behaviours included absconding, physical aggression toward himself and others, and a decline in self-care. ● The family reported feeling disempowered and overwhelmed.
Submission 775
● After they withdrew from the program and were supported 2:1 at home and in the community, behaviours of concern reduced. ● They have responded to visual routines, have engaged in short supported outings with their parents, and are preparing to re-engage with a new day program.
What is at risk.
An across-the-board cut to social and community participation funding would not have allowed the 2:1 home and community support model that produced this change. The likely alternative would have been a return to a poorly matched program, with associated escalation in behaviours and family distress.
Case Study 3
Background.
A young person with severe intellectual disability.
The family’s expectation was that the child would remain at home and attend day programs after completing high school.
What happened.
● When behaviour support began, the young person presented with multiple behaviours of concern, including behaviours that posed risk to other household members. ● By 2026, with consistent intensive support, behaviours of concern have reduced to a single low-level behaviour. ● As the team was no longer in constant reactive mode, the focus was able to shift to skill development that supports their independence. ● Their OT now identifies him as a candidate for disability supported employment on completion of school.
What is at risk.
Their trajectory depends on the intensity of supports currently in place.
A blanket reduction in capacity building funding would undermine the work driving their skill development.
An automated decision benchmarking him against an average participant would not recognise that the current funding level is the reason for their progress, not evidence that funding can be reduced.
Submission 775
Case Study 4
Background.
A teenager with limited informal supports, whose primary NDIS-recognised diagnosis is autism.
The young person also developed an FND diagnosis (not formally recognised by the NDIS), which progressively took away their ability to walk, talk, and complete activities of daily living.
What happened.
● Their wheelchair request was refused. ● Community access with a support worker was almost entirely defunded, with parental responsibility cited as the reason. ● Their mother sustained injury attempting to manage transfers alone, and was injured again attempting to support him through behaviours of concern. ● The young person became isolated within the home. ● Behaviours of concern escalated to high-risk levels, including physical aggression and property damage. ● By the time behaviour support engaged, their mother was considering relinquishment. ● Despite a full multidisciplinary team being involved (behaviour support, support coordination, OT, speech, dietitian, exercise physiology, physiotherapy, and a specialist paediatric mental health service), the NDIS would not increase funding on the basis that the requested supports did not align with the autism diagnosis. ● Support coordination funding was reduced instead, leaving their mother to continue advocating largely alone.
What is at risk.
This case demonstrates the practical effect of the proposed parental responsibility clause, prior to its enactment.
A parent sustained injury performing work that would otherwise be undertaken by a trained worker.
A young person became isolated and unsafe. Formalising this clause in legislation is likely to produce more cases of this kind.
Case Study 5
Background.
A single mother with multiple children, all with autism, ADHD and intellectual disability.
Submission 775
The family has a significant history of family violence.
What happened.
● Support worker funding was reduced. ● Parent A reported a level of burnout such that they were making care decisions that placed the family in conflict with existing legal and child protection arrangements, in order to manage. ● The children were frequently subjected to physical restraint at home as a consequence of Parent A’s exhaustion. ● Parent A had also sustained physical injury themself. ● After behaviour support engaged and (with support from a CSO and DFFH) successfully advocated for additional support worker hours (which occurred), physical restraint ceased. The home environment became safer. Parent A no longer felt forced to breach the family court arrangement, an outcome welcomed by child protection.
What is at risk.
This family is one funding decision away from a return to physical restraint at home, breach of family court orders, and likely child protection intervention.
Ministerial-directed cuts to support worker funding are likely to produce that outcome.
Case Study 6
Background.
A child with autism, one of several children in a household. Their father is the sole income earner. Two of their siblings had NDIS-funded core support. The participant did not.
What happened.
● Without core support funding, he could not safely access learning, the community, or social opportunities with peers. ● Behaviours of concern were significant, including absconding with risk of injury or death. ● The position taken on their plan was that building their community access capacity was a matter of parental responsibility. ● Because it was not safe to leave him at home, their father was regularly required to manage the participant during his own working hours, with associated risks and frequent work interruptions. ● The family was at risk of being pushed further into poverty and at increased risk of child protection involvement.
Submission 775
● Following an ART review, core support funding was granted. ● Since then, no incidents of absconding or other behaviours of concern have been recorded during supported shifts. ● Their father has been able to return to work consistently. ● Family quality of life and stress levels have improved. ● A reduction in chemical restraint is now being trialled.
What is at risk.
This case illustrates the parental responsibility clause in operation.
A working parent was expected to absorb the implementation of behaviour support while running a business and providing for a very busy household with many children.
The clause currently before the Committee would entrench that position in law.
Case Study 7
Background.
A child with high-intensity support needs.
The whole care team (support workers, behaviour support, OT, school, and support coordination) had identified that 24/7 support was required.
What happened.
● The NDIS reduced her support worker funding to < 8 hours per day, below the level the care team had identified as necessary. ● Her mother could not sustain the gap. ● The participant has since been relinquished into the child protection system. ● She is now in a full-time out-of-home care arrangement with 24/7 support.
What is at risk.
Relinquishment is occurring under the current arrangements.
The Bill is likely to accelerate this trend by legislating parental responsibility to include the implementation of behaviour support, and by enabling category-wide cuts without reference to individual need.
The cost to the scheme of a child protection arrangement of this kind is significantly higher than the support worker hours that were cut.
Case Study 8
Submission 775
Background.
An adult living with their elderly parent, who is their primary carer.
Long history of behaviours of concern, including verbal threats posing serious risk to the safety of others in the home such as serious death threats.
What happened.
● Significant behaviours of concern resulted in the practitioner recommending vastly increased community access funding as the risk in the home was too great for participant’s elderly parent to manage on their own ● The participant was funded to attend a structured community participation program four times per week, alongside taxi funding that enabled independent movement in the community. ● Over two years, behaviours of concern resolved as the participant’s social participation and skills increased. ● Behaviour support involvement reduced over time, and the case was closed. ● The community participation and transport funding produced the change.
What is at risk.
A 50% reduction in social and community participation funding would not have allowed for the level of community participation that produced this outcome.
The supports that resolved their behaviours of concern are the supports the Bill proposes to halve.
Their parent’s safety in her own home depended on them.
Case Study 9
Background.
A child with high-intensity, high-risk behaviours of concern.
The child’s parent is their primary carer and was in their own mental health crisis at the time of engagement, unable to access support for themself because of the demands of the child’s care.
What happened.
● Behaviours of concern have included incidents posing serious risk of injury to support workers and others, and an incident involving significant property damage within the family home.
Submission 775
● Following sustained advocacy, intensive data collection, a ministerial review process, and collaboration with the treating medical team, the child was restreamed to Complex Support Needs and their plan increased, including funding for active overnight support. ● The child’s parent subsequently reported sleeping uninterrupted for multiple weeks for the first time in years. ● The parent’s mental health has improved. ● Environmental restraints have been implemented to reduce access to knives and matches. ● The child is now using a car harness, which has opened up community access. ● Prior to the plan increase, the child’s parent had expressed homicidal and suicidal ideation in relation to themself and the child, identifying this as the most humane option for both of them. ● The parent has since reported a change in that position.
What is at risk.
If this plan were reduced to anything resembling the previous level, the safety margin in this household would be lost.
The behaviour support work that produced this outcome required individualised clinical reasoning, evidence collection over months, and access to a ministerial review process.
None of that is compatible with automated plan decisions, comparison to other participants, or denial of funding on financial sustainability grounds.
Case Study 10
Background.
A teenager with autism and an emerging ADHD presentation.
The child lives with their mother who works to support the family while providing the bulk of the child’s disability-related care.
What happened.
● The participant’s plan commenced with significant behaviour support and OT funding, but minimal core support funding, placing the balance of disability-related care on their mother. ● The participant’s mother was expected to deliver the balance of disability-related support. ● Carer burnout was significant, and relinquishment was seriously contemplated.
Submission 775
● During a two-year ART process, the participant regressed: they were operating at the level of a young child in their mid-teens, and were refusing school. ● After behaviour support engaged and provided evidence to the ART, core funding was increased to 8 hours per week. ● The family has since stabilised. ● School attendance has improved through an online program. ● Friendships are forming. ● Incidents have reduced significantly over the past month. ● The care team is now in a position to investigate broader contributing factors and start addressing these as well as building skills.
What is at risk.
Fourteen hours of core funding per year was an inadequate starting point.
Automated decision making, comparative benchmarking, and ministerial-directed category cuts would entrench similar positions and remove the review pathway that allowed this family to reach a workable plan.
Case Study 11
Background.
An adult participant in their 30s with autism, ADHD and an anxiety disorder.
Long history of complex behaviours of concern, including self-injury, attempts to exit moving vehicles, ingestion of non-food items, and sexually disinhibited behaviour.
They live at home with their parents.
What happened.
● With multiple nights of respite per week and a daily community participation program, and consistent advice and support from the practitioner, behaviours of concern reduced significantly. ● Routine chemical restraint was reduced to a minimal level. ● PRN chemical restraint has not been used for many years. ● The need for buckle guards reduced to nil over the same timeframe. ● Their parents have sustained their caring role into their adulthood. ● Now, a recent plan reduction has undone those arrangements and resulted in parental burnout, significant risk of harm, actual harm, and ● Significant care team resources were then required to demonstrate, again, what the existing evidence already established: that removing the supports would result in
Submission 775
greater harm, higher cost, and a likely move into full-time supported accommodation (now being planned for).
What is at risk.
Their progress was not evidence that needs were reducing and therefore that funding could be reduced.
It was evidence that consistent, well-funded supports work.
Automated and comparative decision making cannot read that distinction.
The Bill is likely to make the kind of misreading that produced their recent plan reduction the norm rather than the exception.
Case Study 12
Background.
A teen approaching adulthood.
When behaviour support engaged, the participant was living in an informal care arrangement, after their parents had reached the point of burnout.
Their parents had expressed both homicidal and suicidal ideation and intent, identifying these as genuine risks with a high likelihood of acting them out if the participant were to return home when the informal carer’s months-long period of support ended.
What happened.
● At the point of engagement, the participant was presenting with behaviours of concern multiple times daily, including head-banging, other self-injurious behaviour, physical aggression, and property damage. ● With behaviour support engagement and movement into a formal out-of-home care pathway, supported by a dedicated team of support workers, behaviours of concern have reduced to less than weekly, and often less than monthly. ● The participant is now in a skill-building phase, and is preparing to transition into adult programs, which has become a viable option as a result of the reduction in behaviours of concern. ● The parents are no longer suicidal and are hopeful for their future.
What is at risk.
Behaviour support combined with a formal care pathway addressed a situation in which serious harm to the participant and their parents had been identified as a likely outcome.
Submission 775
That response would not have been viable if parental responsibility had been legislatively expanded to include the implementation of behaviour support, or if automated decisions had benchmarked their needs against an average participant.
The Bill, as drafted, increases the likelihood that situations of this kind end differently.
Analysis: how the Bill affects the work above
- Redefining parental responsibility to include behavioural support The Bill amends the reasonable and necessary criteria so that parents are treated as responsible for providing substantial support for their children, and lists the categories this covers.
Behavioural support is named explicitly in that list, alongside supervision, personal care, transport, emotional support, and assistance with daily living [1].
The Bill also provides that the NDIA cannot fund a support whose primary purpose is to reduce the carer burden on parents below what is typical for a child of the same age [1], [2].
Down Syndrome Australia has noted that this broadened definition could see intensive, highly specialised, or round-the-clock supports deemed a matter of parental responsibility [3].
“Behavioural support”, in this case is assumed to refer to the day-to-day implementation of behaviour management and support to the person; that is, the delivery of proactive strategies, skill development, and response strategies, sometimes including the use of restrictive practices.
The NDIS Pricing Arrangements and Price Limits define this as Intensive and Complex Behaviour Support, and require the provider delivering it to be registered and assessed under Module 2A (Implementing Behaviour Support Plans), and to deliver it in accordance with the participant’s behaviour support plan [4].
The scheme’s pricing framework treats the implementation of behaviour support as high-risk work requiring provider registration, module assessment, and adherence to a behaviour support plan.
The Bill treats the same activity as a matter of ordinary parenting.
Case Studies 4, 5, 6, 7 and 12 indicate the practical consequences: physical injury to a carer, breach of family court orders, relinquishment to child protection, and family members expressing homicidal and suicidal ideation.
Submission 775
- Across-the-board funding cuts The Bill enables the Minister to adjust support budgets across whole categories without reference to individual participant need.
Current proposals include reductions to social and community participation funding and capacity building funding across all plans [2].
Case Studies 2, 3, 8 and 11 indicate what these supports produce when adequate: resolution of behaviours of concern, reduction in restrictive practices, and trajectories toward supported employment.
The NDIS Act requires supports to represent value for money relative to both benefits achieved and the cost of alternative supports.
Blanket percentage reductions applied without reference to individual circumstances cannot satisfy that test; the cost will come up later in increased incidents, carer burnout, crisis presentations, long-term moves into SIL and SDA as well as hospitals and jails.
- Automated decisions and comparative benchmarking The Bill allows the NDIA to automate specific administrative actions, and requires the NDIA to consider scheme sustainability and equity across participants with similar needs and circumstances [2].
In practice, this enables decisions based on what other participants have received and on the financial sustainability of the scheme.
Participants with complex behavioural needs do not present as average.
Quality behaviour support is effective only because of its specificity to the individual: early warning signs, triggers, functional analysis, environment, and family system.
Case Studies 9 and 10 indicate what individualised clinical reasoning can produce, and what automation cannot.
Section 31 of the NDIS Act requires plans to advance the inclusion and participation of the participant.
Automated, comparative and budget-driven decision making isn’t compatible with that obligation.
Submission 775
Rights
The case studies indicate two things about participant rights.
When adequate, individualised supports are in place, participants exercise rights the UNCRPD and the NDIS Act commit Australia to upholding:
● living at home rather than in segregated settings (Article 19); ● accessing supports that build independence (Article 26); ● experiencing reductions in restrictive practices (Articles 5 and 17); and ● being supported by families whose caring role is sustained (NDIS Act s 4(12), 4(12A), 31(d)).
When supports are inadequate or removed, the same rights are diminished.
Conclusion and recommendations
The case studies above aren’t edge cases… They are just examples of work our team does on a daily basis.
The Bill, in its current form, will cause harm to participants, to families and carers, and to the workforce.
In the medium to long term, it is also likely to harm the financial sustainability of the scheme it claims to protect, by pushing participants into more expensive forms of care while reducing the supports that keep them out of those settings.
I urge the Committee to recommend that the Bill not be passed in its current form. Specifically, I urge the Committee to recommend:
● Removal of the proposed redefinition of parental responsibility, in particular the inclusion of behavioural support in the list of supports parents are expected to provide, given that the implementation of behaviour support is treated as specialist, registration-gated work under the scheme’s own pricing framework.
● Removal of ministerial powers to adjust funding across whole categories without reference to individual participant need.
● Removal of automated and comparative plan decision-making, and of the proposed power to deny funding on the basis of the financial sustainability of the scheme.
I am happy to be contacted if further detail would assist the Committee.
Submission 775
Yours sincerely,
Zac Demopoulos
Behaviour Support Lead, Step 2 Allied Health
Behaviour Support Practitioner (Advanced)
AASW-Accredited Social Worker
Submission 775
Preparation and contributors
This submission was prepared by Zac Demopoulos, Behaviour Support Lead, Step 2 Allied Health.
The case studies are a combination of de-identified examples contributed by members of the Step 2 Allied Health behaviour support team. Contributors:
● Nat Colosimo, Behaviour Support Practitioner, Step 2 Allied Health
● Beth Lowe, Behaviour Support Practitioner, Step 2 Allied Health
● Jen Phillips, Behaviour Support Practitioner, Step 2 Allied Health
● Meg Maples, Behaviour Support Practitioner, Step 2 Allied Health
● Jessica Chakir, Behaviour Support Practitioner, Step 2 Allied Health
● Holly Martin, Behaviour Support Practitioner, Step 2 Allied Health
Identifying details have been altered or removed to protect participant and family privacy. Each case study is drawn from real work.
Submission 775
References
1. National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026, introduced to the House of Representatives 14 May 2026; parental responsibility provisions (Part 6) amending the reasonable and necessary criteria. Bill text and explanatory memorandum available via the Parliament of Australia bill page: https://www.aph.gov.au/Parliamentary_Business/Bills_Legislation/Bills_Search_Resul ts/Result?bId=r7487
2. NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 fact sheet, Australian Government Department of Health, Disability and Ageing: https://www.health.gov.au/resources/publications/ndis-amendment-securing-the-ndis for-future-generations-bill-2026-fact-sheet
3. Down Syndrome Australia, “NDIS Bill: our initial thoughts and how to have your say” (22 May 2026): https://www.downsyndrome.org.au/blog/2026/05/22/ndis-bill-our-initial-thoughts-and how-to-have-your-say/
4. NDIS Pricing Arrangements and Price Limits 2025-26 (v1.1, published 14/10/2025), “Implementing Intensive and Complex Behaviour Supports,” p. 41. Defines the support and the requirement that providers be registered and assessed for Module 2A (Implementing Behaviour Support Plans) and deliver in accordance with the participant’s behaviour support plan.
5. NDIS Act 2013, including section 34 (reasonable and necessary supports), section 75 (parental responsibility), and section 31 (principles relating to plans): https://www.legislation.gov.au/C2013A00020/latest/text