Submission 784
Attention: Committee Secretary, Senate Standing Committee on Community Affairs
Submitted by email: community.affairs.sen@aph.gov.au
Date: 1/06/2026
Loom Arts and Management welcomes the opportunity to make a submission to the Senate
Standing Committee on Community Affairs about the National Disability Insurance Scheme
Amendment (Securing the NDIS for Future Generations) Bill 2026.
Loom Arts and Management is a disability-led, registered charity which exists to increase
representation, respect and access to opportunities for d/Deaf and disabled people within
the arts industry.
Since Loom began its operations in 2021, we have supported d/Deaf and disabled
artists to complete 300 paid creative engagements and 200 consulting jobs. Loom
has now worked with over 100 arts organisations across the country.
I want to outline the harm this Amendment Bill will cause if it passes Parliament. This Bill is
too far-reaching to pass as it stands. I believe the Bill requires further scrutiny and
amendment before it proceeds.
Parliamentary Scrutiny and Transparency
The consultation period for the Amendment Bill is two weeks, which is insufficient to allow
for appropriate consultation, considering accessibility and communication needs. The
Australian Government Guide to Policy Impact Analysis says consultation should occur for a
minimum of 30 days where possible.
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Submission 784
There also must be a deployment of free and accessible supports for d/Deaf and disabled
people to have their voices heard on this issue. Proper consultation involves the government
actively engaging with the community on its own terms. The avenues for making a
submission have not only been inaccessible in terms of timeline but in format and in the lack
of support available for d/Disabled people to engage.
Recommendation: Amend the consultation period for a best practice minimum of 30 days
and provide free, community determined supports as needed.
The threat of regimenting and/or restricting supports to NDIA approved providers.
Threatened cuts to Core: assistance with social and community participation.
Loom offers highly bespoke Artist Support Services for artists with disability. Loom is
categorically different from other disability support services in that we work specifically with
artists pursuing professional, creative careers. We are not a day service provider, we do not
run group programs, and we do not operate in the realm of art as recreation, therapy or
enrichment alone.
Loom’s Co-Founders/Executive Directors worked in disability day service settings for many
years and created the organisation specifically as a point of difference from the group
programming model. Loom’s Artist Support Services extend far beyond the realms of other
offerings within the disability sector and into our very established networks within the
professional arts industry.
Our Artist Support Services are individually built around each artist’s strengths, passions,
self-identified goals and career objectives. For example, 1:1 sessions may involve support
with grant writing, project management, producing, self-publishing, securing paid work and
negotiating with mainstream arts organisations for accessible working conditions, equitable
pay and proper recognition.
Loom Arts and Management, ABN 696 406 221 53
Submission 784
Such personalised support simply cannot be delivered at any other ratio than 1:1. This type
of specialised support can only be delivered by support workers with professional arts
industry experience of their own. We have trained many professional artists as highly
effective support workers who enable their clients to upskill and function as independently
as possible within mainstream arts contexts.
The siloing of eligible support services to registered NDIS providers only would not only be
the end of our organisation, it would be an enormous step backwards in terms of the rights
of disabled people to exist and participate in broader social and economic society.
Through our Artist Support Services, we provide highly individualised supports for d/Deaf
and disabled artists within the mainstream arts sector. This includes but is not limited to:
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Mentorship and professional work experience
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Skills and career development
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Self-producing of art works, performances, books, albums
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Arts business development, management and promotion
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Planning, administration and executive function
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Building strategies for sustainable work to prevent burnout
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Financial management and budgeting (projects, business, personal, NDIS)
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Negotiating fair terms and working conditions with employers
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Submitting for arts grants, prizes and funding applications
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Finding and engaging supports outside of Loom
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Attending and effectively communicating during networking and business opportunities
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Understanding personal rights and advocating for autonomy
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Emotional regulation and safety within the arts community Most of the artists we support utilise core funding to engage with us – assistance with social
and community participation being the most frequently used category. We understand this
Loom Arts and Management, ABN 696 406 221 53
Submission 784
category in particular is under the threat of funding cuts. Without access to these funds, it
will simply not be possible to access our services.
Key decisions left to ministerial instruments, not law
The issue: The Bill allows Ministers to change who gets NDIS support (Schedule 1 Parts 8 and
- and how much funding people receive (Schedule 1 Part 4; Schedule 3) by signing an instrument, without going back to Parliament. The rules that will determine critical eligibility
thresholds (Schedule 1 Parts 1, 8 and 9) have not yet been written.
How this affects participants: The decisions that shape the lives of participants, whether
they qualify for the NDIS and what supports they can access, could be changed without
parliamentary debate or public scrutiny. Participants may not know supports or eligibility
rules have changed until their plan is affected.
Recommendation: Require that all decisions affecting NDIS eligibility and funding levels be
made through primary legislation subject to full parliamentary scrutiny, with mandatory
advance notice to affected participants before any changes take effect.
Existing participants face narrower criteria and fewer rights to challenge decisions
The issue: The Bill changes the rules for existing NDIS participants and makes it harder to
challenge some decisions about supports and funding. It also restricts when you can request
a reassessment, removes review rights for automatic plan renewals, and makes funding
reductions unreviewable (Schedule 1 Parts 1 and 8). Combined with restrictions on
reassessment requests (Part 2), automatic plan renewals without review rights (Part 5), and
unreviewable funding reductions (Part 4), existing participants face narrower criteria with
significantly fewer avenues to challenge decisions about their supports.
How this affects participants: This does not protect participants already on the NDIS, who
could be reassessed under stricter rules. If someone’s funding is reduced or their plan
renewed automatically, they may have limited or no ability to challenge that decision. This
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Submission 784
could make it harder for people to get extra support when their circumstances or disability
change.
Recommendation: Require a “no harm” safeguard ensuring no current participant loses
access to supports unless equivalent supports are in place, with independent review rights
before any exit decision and access to unscheduled reassessments preserved.
Unreviewable ministerial power to cut funding across all support categories
The Minister can reduce funding for any support or group of supports by a specified
percentage through an instrument that cannot be challenged (Schedule 1 Part 4). This
applies across all budget categories. Unspent funds will no longer carry over at plan renewal
(Schedule 1 Part 5).
How this affects participants: A participant’s community participation, capacity building or
assistive technology funding could be cut without warning and without any right to appeal.
Participants who save unspent funds across plan periods for high-cost items will lose that
ability entirely.
Recommendation: Require that unspent funds carry over at plan renewal for participants
saving for high-cost items and require independent review rights before any funding
reduction takes effect.
Requirement to exhaust treatment options before eligibility
The issue: A person with disability will need to exhaust treatment options before they can
be eligible for the Scheme (Schedule 1 Part 8). There will also be a removal of
whole-of-person assessment, replaced by single eligible impairment consideration (Schedule
1 Part 3). The note that previously acknowledged environmental factors and other ineligible
impairments could affect support needs will be removed (Schedule 1 Part 3).
How this affects participants: People with disability will need to prove their impairment
cannot be treated before they access the NDIS. Once in the scheme, their supports will only
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be assessed against a single eligible impairment rather than their whole experience. A
person’s individual circumstances will not be considered, including ability to pay for
treatment, where they live or whether treatment is actually available to them.
Recommendation: Do not proceed with a requirement to exhaust “appropriate treatment”
options – there are no safeguarding measures around participant harm due to side effects or
complications, a participant’s financial ability to pay, or their geographic capacity to access
treatments.
Unvalidated functional capacity assessment tool risks misidentifying need
The issue: The Bill shifts assessment from whole-of-person consideration to a single eligible
impairment (Schedule 1 Part 3). Read together with the eligibility thresholds in Parts 8 and 9,
the tool used to conduct functional capacity assessments must be capable of sufficiently
identifying whether a person meets the threshold for that single impairment.
The named assessment tool is the Instrument for Classification and Assessment of Support
Needs (I-CAN). I-CAN requires validation to ensure it will sufficiently identify the needs of all
people with disability, including those whose needs may be fluctuating or episodic and may
not be captured through a point-in-time assessment, and to ensure it is culturally
appropriate for First Peoples with disability.
How this affects participants: If the assessment tool does not accurately capture the full
extent of a person’s disability, including needs that fluctuate or vary over time, a participant
may be found ineligible or have their supports undercounted, with no guarantee the result
reflects their actual experience.
Recommendation: Do not proceed with I-CAN as the functional capacity assessment tool
unless it has been demonstrably validated to identify the needs of all people with disability,
including those with episodic or fluctuating disability, and demonstrated to be culturally
appropriate for First Peoples with disability.
Supports cut before replacement system is ready
Loom Arts and Management, ABN 696 406 221 53
Submission 784
The issue: From 1 October 2026, the government has announced funding for social, civic and
community participation supports will be cut by 50 per cent and capacity building daily
activities by 10 per cent for all participants, reductions that will be implemented through the
ministerial instrument power in Schedule 1 Part 4. The Foundational Supports system
intended to fill that gap has no confirmed implementation date and is not yet operational.
How this affects participants: Supports that help participants connect with their community,
build skills and maintain independence may be cut before anything exists to replace them,
leaving carers and families with greater responsibilities and no additional support. These
supports are often what help people stay visible, connected and safe.
Recommendation: Require that no reductions to community participation or capacity
building supports take effect until Foundational Supports are fully operational, adequately
funded and demonstrably able to meet the needs of those who will lose NDIS supports.
Please do not hesitate to contact me for further information/consultation.
Zoe Boesen
Co-Executive Director
Loom Arts and Management
Loom Arts and Management, ABN 696 406 221 53