Submission 799
Committee Secretary
Senate Standing Committees on Community Affairs
Parliament House
Canberra ACT 2600
Re: National Disability Insurance Scheme Amendment Bill 2026
Dear Committee Members,
Lion and Mouse Australia welcomes the opportunity to provide a submission to the Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026, and to contribute to the broader reform agenda, including the development of foundational support initiatives.
We support the Government’s objective of ensuring the long-term sustainability of the NDIS. Reform is necessary to maintain the Scheme for future generations and to improve consistency, transparency, and equity across the system. However, the critical issue is not the intent of reform, but how it is implemented in practice.
Lion and Mouse operates at the intersection of support coordination, workforce delivery, and community-based supports. This provides us with a whole-of-system view across participants, families and service providers, as well as the interaction between the NDIS and mainstream systems such as education and health. The findings within this submission are grounded in that frontline experience, supported by case studies, sector evidence, and national data.
Our key concern is that the proposed reforms do not eliminate demand for supports, they redistribute it. Where formal supports are reduced or access is restricted, underlying need persists and is absorbed by families, schools, the not for-profit sector, and health systems. These systems are already under significant pressure and are not currently designed to meet an increased demand. In practice, this risks shifting pressure rather than resolving it.
While this submission identifies key risks, it is also focused on practical, implementation-oriented solutions. These include the establishment of transitional delivery providers, the integration of real-world functional evidence into assessment processes, and the preservation of legislative safeguards that underpin system integrity, including access to independent review.
Ultimately, the success of these reforms will depend on whether the system responsible for delivering them is properly designed, resourced, and sequenced. Without this, there is a risk that the reforms will increase fragmentation and reduce participant outcomes, rather than improve them.
Lion and Mouse stands ready to work with Government as a practical implementation partner. With careful design and strong collaboration across the sector, it is possible to achieve both sustainability and improved outcomes for people with disability.
Yours sincerely,
Anthony Hooper
Chief Executive Officer
Lion and Mouse Australia Ltd
1st June 2026
Submission 799
National Disability Insurance Scheme Amendment Bill 2026
National Disability Insurance Scheme
Amendment (Securing the NDIS for Future
Generations) Bill 2026
Submission to the Senate Community Affairs Legislation
Committee
Submitted by:
Anthony Hooper,
Chief Executive Officer,
Lion and Mouse Australia Ltd
Date: 1 June 2026
Submission: Community Affairs Legislation Committee - Page 1
Submission 799
Lion and Mouse Australia
Executive Summary
Lion and Mouse Australia supports the direction of reform to strengthen the long-term sustainability of the National Disability Insurance Scheme (NDIS) and to establish a system of foundational supports through initiatives such as Thriving Kids.
Reform is necessary to preserve the Scheme for future generations and to ensure that resources are directed toward those with the highest and most complex needs. The introduction of foundational supports represents a real opportunity to create a more balanced and responsive system, particularly for children and families who do not require lifelong support through the NDIS.
However, based on what we are seeing in practice, the key challenge is not policy intent, but delivery capability. Evidence drawn from lived experience, frontline service delivery, sector submissions and national data indicates that the reforms risk being implemented ahead of system readiness. Without careful sequencing and operational design, there is a real risk that demand will be shifted into families, schools, and health systems rather than reduced.
Data from the Australian Institute of Health and Welfare reinforces this context, showing that people with disability already experience poorer health outcomes, higher levels of psychological distress, and greater difficulty accessing services than the general population. This is important. Reform is being introduced into a system that is already under strain, and that baseline needs to be acknowledged if unintended consequences are to be avoided.
Submission: Community Affairs Legislation Committee - Page 2
Submission 799
National Disability Insurance Scheme Amendment Bill 2026
- Introduction Lion and Mouse operates across key components of the disability service ecosystem, including support coordination, workforce delivery, community access supports, employment support, and allied health coordination. In practice, this means we are working across the full spectrum of participant experience from early engagement and planning, through to day-to-day support delivery and long-term outcomes.
This position provides us with a broad and grounded view of how the system is functioning in the real world. We see how participants engage with their plans, how families manage gaps when supports are insufficient, and how providers navigate increasing complexity in delivery. Importantly, we also see how the NDIS support frameworks interacts with mainstream systems such as education and health, where pressures often become most visible when supports are not aligned or are reduced.
This submission draws together that lived and operational experience with broader sector evidence and national data. It is intended to move beyond a purely policy-based perspective and present a practical view of how reform will operate in real-world conditions.
While the reforms are well-intentioned, their success will ultimately depend on how they are implemented within this complex environment. From our perspective, the key risk is not whether the policy settings are conceptually sound, but whether the system that is expected to deliver them is ready, resourced, and coordinated enough to do so effectively.
Accordingly, this submission seeks to support Government by translating policy intent into operational reality. It identifies where risks are likely to emerge if implementation is not carefully staged, and outlines practical considerations that could strengthen delivery, protect outcomes, and reduce unintended pressure on participants, families and the broader system.
Submission: Community Affairs Legislation Committee - Page 3
Submission 799
Lion and Mouse Australia
- Lived Experience and System Reality 2.1 Adult – The consequences of missed early intervention A 42-year-old individual, recently diagnosed with Autism Spectrum Disorder Level 3, presents with extremely low adaptive functioning and a lifetime of unsupported need.
Their conceptual, social, and practical skills are all in the “Extremely Low” range. They struggle with communication, self-direction, social interaction, leisure activities, self - care, and community use. For example, when engaged in special interests or video games, they forget to eat, drink, or attend to personal hygiene. They avoid social interaction due to exhaustion and anxiety and finds small talk and reciprocal conversation difficult. They have a lifelong preference for routines and predictability, and experiences distress when these are disrupted.
Despite clear indicators in childhood, no formal diagnosis or structured support was provided. This resulted in long-term social isolation, mental health challenges and economic exclusion. This case illustrates that when systems fail to identify and support individuals early, the impacts are not temporary. They extend across the lifespan and create significantly higher social and economic cost over time.
2.2 Child – Under-supported within current NDIS and other systems A ten-year-old child with Autism Level 3, ADHD and speech apraxia requires intensive, coordinated support across home, school and community settings. Clinical evidence clearly identifies high levels of functional impairment and risk.
The child exhibits clinically significant maladaptive behaviours, including internalising symptoms (e.g., anxiety, withdrawal, suicidal ideation) and externalising behaviours (e.g., aggression, running away, self-harm). They have spoken about wanting to harm themself and physically harmed themself by biting, pinching, and banging their head. They have also run away from home and school, placing themself in dangerous situations, such as wandering into traffic.
However, funding levels within the current system have fallen significantly below recommended intervention thresholds. This has resulted in increased safety risks, reduced developmental progress and significant stress on the family. The only income earner is now incapable of working unless the role has significant ‘work from home’ options. This case demonstrates that being within the NDIS does not guarantee that support levels align with functional need.
Submission: Community Affairs Legislation Committee - Page 4
Submission 799
National Disability Insurance Scheme Amendment Bill 2026
2.3 School – System failure and lack of functional care model An eleven-year-old student with autism, ADHD and anxiety has experienced escalating distress within the school environment, including repeated self-harm incidents. Bullying disclosures were dismissed or inadequately investigated, and behaviour‑related safety plans were either incomplete or inconsistently applied.
Repeated meetings promised additional supports, including Education Support (ES) allocation, classroom adjustments, and behavioural planning. However, these commitments were not actioned appropriately. As the child’s distress increased, so did the severity of their behaviours: absconding from class, physical aggression, and self‑harm.
This school‑level inexperience had significant downstream consequences. Without formal documentation of incidents, behavioural escalation, or safety risks, the family struggled to secure appropriate NDIS funding for essential therapies and in‑home supports-demonstrating how school administrative failures can inadvertently block access to critical disability services.
Critically, the issue is not only the absence of adequate supports, but the absence of a coherent care model addressing her functional development, emotional regulation and safety. School responses have been inconsistent, with limited documentation of incidents and no sustained, structured wellbeing framework.
This absence of a coordinated care model has direct implications for NDIS access and planning. Without clear documentation and structured support pathways, the child’s needs are not fully recognised within formal systems. This demonstrates that outcomes within the NDIS are heavily influenced by the capability and practices of adjacent systems, particularly education.
Submission: Community Affairs Legislation Committee - Page 5
Submission 799
Lion and Mouse Australia
- Systemic Risks Across the Reform Across lived experience, sector submissions and broader data, several consistent systemic risks emerge that are critical to the successful implementation of reform.
3.1 Sequencing of reform The most significant risk is the sequencing of reform. Current settings indicate that reductions in NDIS supports may occur before foundational supports are fully operational. In practice, this creates a gap where individuals lose access to structured supports without a viable alternative system in place. The likely outcome is a transfer of responsibility to families, schools and health systems, many of which are already operating at capacity.
3.2 Functional capacity assessment The proposed functional capacity model places significant reliance on standardised and point-in-time assessments. However, disability is not static. Functional capacity is often context-dependent, influenced by environment, supports and fluctuating conditions. A system that does not incorporate real world observation risks systematically underestimating need, particularly for neurodivergent and psychosocial cohorts.
3.3 Community participation Community participation should not be viewed as a discretionary support. It is fundamental to development, social inclusion and safety. Reductions in community participation supports are likely to increase isolation, reduce independence and contribute to higher long-term demand for crisis and health services.
3.4 Provider market capacity Reforms are being introduced at a time when the provider market is already under pressure. Workforce shortages, compliance requirements and pricing constraints are affecting service availability. Without careful planning, reform may accelerate provider exit or contraction, reducing the system’s ability to deliver the very services it depends on.
Submission: Community Affairs Legislation Committee - Page 6
Submission 799
National Disability Insurance Scheme Amendment Bill 2026
- Legislative and Safeguarding Risks In addition to operational risks, the Bill includes several legislative provisions that introduce potential safeguarding concerns.
The expansion of ministerial powers to adjust funding categories through instruments creates a mechanism by which supports may be reduced without individual reassessment or independent review. This introduces uncertainty for participants and providers and risks disconnecting funding decisions from individual need.
Changes to reassessment and review processes may limit participants’ ability to challenge decisions or respond to changes in their circumstances. This is particularly significant for participants with fluctuating conditions or those experiencing life transitions.
The reliance on standardised functional assessment tools, including those not fully validated across all disability types, creates a risk of under-identification. Where assessments do not capture complexity, participants may receive insufficient support or be excluded from access entirely.
Submission: Community Affairs Legislation Committee - Page 7
Submission 799
Lion and Mouse Australia
- Core System Insight: Demand is Being Redistributed The central insight emerging from this analysis is that the reforms do not remove demand from the system. Instead, they redistribute it. Where formal supports are reduced, the demand does not disappear. It is absorbed by families, schools and broader community systems. Without adequate support, this redistribution leads to poorer outcomes and higher long-term costs.
The central insight from this analysis is that the proposed reforms do not eliminate demand for supports within the disability system. Rather, they fundamentally redistribute that demand across different parts of the service ecosystem.
When formal supports are reduced or eligibility criteria are tightened, the underlying needs of participants do not diminish. Functional impairments, developmental challenges, behavioural risks and support requirements remain unchanged. In practice, those needs are absorbed by other parts of the system, often in a less structured, less effective, and more costly way over time.
This dynamic is already observable in existing data and service patterns.
Data from the Australian Institute of Health and Welfare (AIHW) confirms that people with disability experience significantly poorer health outcomes and higher levels of unmet need than the general population. Only 31% of people with disability report very good or excellent health, compared to 68% of those without disability, while 33% experience high or very high psychological distress-almost three times the rate of the general population. These disparities indicate that demand for support is already high and, in many cases, already insufficiently met.
In addition, people with disability face measurable barriers to accessing healthcare and support services. A proportion delay or avoid care due to cost, and many require engagement with multiple professionals to manage their needs. This reflects a system where support needs are complex, persistent, and often fragmented across services.
Within this context, reducing structured supports does not reduce need, it removes one of the primary mechanisms by which that need is managed.
Submission: Community Affairs Legislation Committee - Page 8
Submission 799
National Disability Insurance Scheme Amendment Bill 2026
5.1 Demand shifts to families and informal care systems The most immediate impact of reduced supports is a shift toward families and caregivers. Where formal services are withdrawn or reduced:
- parents increase direct care hours
- workforce participation decreases or ceases
- financial strain increases
- informal care replaces structured intervention The case evidence above highlights this clearly. In the case of a high-needs child (section 2.2), a parent was required to leave employment to manage care requirements due to insufficient funded supports. This is not an isolated scenario; it reflects a broader pattern across the disability system.
Over time, this leads to:
- caregiver burnout
- reduced household income
- increased long-term reliance on income support systems In policy terms, this represents a transfer of cost from the NDIS to the social security system and broader economy, rather than a net saving.
5.2 Demand shifts into education systems In the absence of adequate disability supports, needs frequently manifest within the education system. As demonstrated in Section 2.3, the ten-year-old student is not receiving a structured care model to support their functional development, emotional regulation, or safety. In this environment, behavioural and mental health needs escalate, not because they have increased in severity, but because they are unmanaged.
Schools, which are not designed or resourced to provide therapeutic or behavioural intervention at scale, become the default support system. This leads to:
- increased behavioural incidents
- disengagement from education
- escalation to exclusionary practices (suspension, expulsion)
- long-term educational disadvantage Research consistently shows that students with disability are disproportionately impacted by exclusionary discipline practices, further compounding disadvantage and disengagement.
Submission: Community Affairs Legislation Committee - Page 9
Submission 799
Lion and Mouse Australia
5.3 Demand shifts into the health and crisis systems A critical consequence of reduced early and preventative supports is increased demand on health systems. Community participation, behavioural supports, and early intervention services function as:
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stabilising mechanisms
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developmental supports
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preventative interventions When these are reduced, the system increasingly responds to:
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crisis presentations
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acute mental health needs
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hospital admissions
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emergency service contact AIHW data reinforces that people with disability already experience higher psychological distress and complex health needs. Reducing preventative supports in this context increases the likelihood of escalation, resulting in higher-cost interventions across hospital and mental health systems.
5.4 Demand shifts into higher-cost service environments At a system level, insufficient early and community-based support leads to downstream demand in more intensive and expensive service environments, including:
- out-of-home care
- justice system interfaces
- inpatient health services
- crisis accommodation These systems operate at significantly higher cost per individual than community-based or early intervention supports. As such, reductions in lower cost supports often lead to increased expenditure elsewhere within the system.
This creates what can be described as a false economy, where short-term reductions in NDIS expenditure result in higher long-term costs across government systems.
Submission: Community Affairs Legislation Committee - Page 10
Submission 799
National Disability Insurance Scheme Amendment Bill 2026
5.5 System fragmentation amplifies the impact A key reason this redistribution occurs is the fragmented nature of the service system.
Disability support, education, health, and social services operate across different jurisdictions, funding models, and accountability frameworks. When supports are reduced in one system without coordinated expansion in another, gaps emerge.
Participants do not experience these systems separately. They experience them as a single, interconnected environment.
Where coordination fails:
- needs are duplicated or missed entirely
- families must navigate multiple systems without support
- outcomes deteriorate 5.6 Policy implication The implication for reform is clear:
Sustainability cannot be achieved by reducing supports in isolation. It must be achieved through coordinated system design.
This requires recognition that:
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demand will persist regardless of funding model
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early and preventative supports reduce long-term cost
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system capacity must exist before responsibilities are shifted Without this, reforms risk:
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increasing hidden costs
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reducing outcomes
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placing unsustainable pressure on families and mainstream systems Accordingly, the core insight of this submission is not simply that demand is being redistributed. It is that: The effectiveness of reform will depend on whether the system receiving that demand is designed, resourced, and operational at the point the shift occurs.
At present, evidence suggests this condition has not yet been met.
Submission: Community Affairs Legislation Committee - Page 11
Submission 799
Lion and Mouse Australia
- Recommendations To support effective implementation, Lion and Mouse proposes a set of practical and achievable reforms focused on strengthening delivery capability and safeguarding participant outcomes:
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First, establish a class of Transitional Delivery Providers capable of supporting participants as they move between NDIS and foundational supports. These providers would maintain continuity of care and reduce system disruption.
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Second, embed real-world functional evidence into assessment processes. This includes longitudinal observation and input from providers who support participants in daily life.
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Third, prioritise commissioning of integrated providers capable of coordinating, delivering and measuring outcomes across multiple support types.
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Fourth, formally recognise community participation as an essential support linked to functional development and long-term independence.
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Fifth, ensure reforms are sequenced appropriately, with foundational supports fully operational before any tightening of eligibility or reduction of supports.
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Sixth, strengthen legislative safeguards by preserving review rights (including the ART), ensuring transparency in decision-making and maintaining alignment between funding and individual need.
Submission: Community Affairs Legislation Committee - Page 12
Submission 799
National Disability Insurance Scheme Amendment Bill 2026
- The Role of the Administrative Review Tribunal (ART) The role of the Administrative Review Tribunal (ART) is a critical safeguard within the National Disability Insurance Scheme and must be preserved and strengthened under the proposed reforms.
The ART provides an essential mechanism for independent review of decisions made by the National Disability Insurance Agency (NDIA). Importantly, it enables decisions to be assessed not only through administrative process, but through the application of law, evidence, and procedural fairness. This distinction is fundamental. While the NDIA operates within policy and operational constraints, the ART provides a mechanism to ensure that decisions align with legislative intent and the principles of reasonable and necessary supports.
In practice, the ART plays a vital role in correcting systemic issues within the Scheme. It allows participants to present comprehensive clinical evidence, including multidisciplinary reports and longitudinal functional data, which may not be fully captured or considered within standardised assessment processes. Through this process, the ART is able to support the development of bespoke plans that more accurately reflect a participant’s functional needs, rather than relying solely on generalised frameworks or assessment tools.
This function is particularly important in the context of the proposed reforms. As the system moves towards:
- more standardised assessment models
- tighter definitions of support eligibility
- increased reliance on functional capacity tools the risk of under-identification and under-support increases. In this environment, the ART serves as a necessary counterbalance.
Without a strong and accessible independent review mechanism:
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participants may have limited ability to challenge incorrect or incomplete assessments
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funding decisions may become increasingly disconnected from individual need
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systemic errors may remain uncorrected, compounding over time
Submission: Community Affairs Legislation Committee - Page 13
Submission 799
Lion and Mouse Australia
There is also a broader system benefit. ART decisions contribute to the development of case law and interpretation of the NDIS Act, providing guidance to the NDIA, providers and participants. This helps improve consistency, transparency and accountability across the Scheme.
Concerns raised within this Bill regarding:
- reduced reassessment pathways
- automatic plan renewals without review
- and limitations on appeal rights present a material risk to the integrity of this safeguard. If participants are unable to access independent review in a timely and effective manner, the Scheme risks shifting from a rights-based model to one that is administratively determined without sufficient legal oversight.
Accordingly, Lion and Mouse submits that:
The role of the ART must be preserved as a core component of the NDIS architecture.
This includes:
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maintaining full access to independent review of NDIA decisions
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ensuring participants can present comprehensive clinical and functional evidence
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preserving the ability of the Tribunal to make determinations based on individual circumstances
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and ensuring that legislative or procedural changes do not limit access to fair and independent review
Ultimately, the ART is not simply a dispute resolution mechanism. It is a foundational component of system integrity, ensuring that participants have access to a fair hearing and that decisions affecting their lives are subject to independent scrutiny.
Submission: Community Affairs Legislation Committee - Page 14
Submission 799
National Disability Insurance Scheme Amendment Bill 2026
- Conclusion Across lived experience, sector submissions, frontline service delivery, and national data, a consistent pattern emerges: the current system is already operating under significant pressure. People with disability experience poorer health outcomes, higher psychological distress, and increased barriers to accessing services. Families and caregivers are absorbing substantial unmet need, often at considerable personal and financial cost. At the same time, the provider market is managing workforce shortages, pricing constraints, and growing complexity in service delivery.
If implemented without appropriate sequencing, safeguards, and operational design, there is a material risk that the reforms will not reduce demand, but rather redistribute it. Supports removed from the NDIS will not disappear; instead, they will shift into families, schools, health systems, and the broader community. These systems are not currently configured or resourced to absorb that demand. The likely outcome is increased pressure across multiple domains, resulting in poorer participant outcomes and higher long-term cost.
Proposed changes to functional capacity assessment, funding controls, and eligibility criteria further compound this risk. Standardised and point-in-time assessments, while efficient, do not adequately reflect the lived reality of disability, which is often dynamic, context-dependent, and influenced by environmental and support factors. Without the integration of real-world functional evidence, there is a danger that participant needs will be systematically underestimated.
At the same time, proposed limitations on reassessment pathways and independent review mechanisms raise concerns regarding procedural fairness and system integrity. The role of the Administrative Review Tribunal is particularly critical in this regard. The ART provides an essential safeguard, ensuring that decisions can be independently reviewed against law and evidence, and that participants retain access to a process capable of recognising the complexity of individual circumstances. Maintaining this function is fundamental to ensuring that the Scheme remains grounded in principles of fairness, accountability, and rights-based decision-making.
Taken together, these risks point to a single conclusion: The success of the reforms will be determined not by policy design alone, but by the strength of the system that delivers them.
Submission: Community Affairs Legislation Committee - Page 15
Submission 799
Lion and Mouse Australia
To achieve this, reform must be supported by:
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clear sequencing, ensuring foundational supports are fully operational before any reduction in NDIS supports occurs
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robust assessment frameworks integrating longitudinal, real-world evidence
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legislative safeguards that preserve transparency, accountability, and access to independent review
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and a stable, capable provider market able to deliver integrated, outcome- focused supports
Most critically, there is a need to recognise and formalise the operational layer that sits between policy and participant outcomes. This layer-comprising coordination, workforce delivery, real-time support management, and system navigation-is essential to translating policy into practice. Without it, even well designed reforms will struggle to achieve their intended outcomes.
Lion and Mouse operates within this layer. Through our work across coordination, workforce delivery, and integrated support environments, we see firsthand how policy decisions translate into daily experience for participants and families. We already perform many of the functions the reformed system will increasingly rely upon, including managing complexity, coordinating services, and supporting individuals across multiple systems (inside and outside the NDIS).
Accordingly, we do not position ourselves in opposition to reform. Lion and Mouse stands ready to contribute as a practical delivery partner in successful reform implementation, supporting the design and implementation of a system that is not only financially sustainable, but also operationally effective, evidence informed, and grounded in the lived reality of people with disability.
A sustainable system is not one that simply reduces expenditure. It is one that delivers the right support, at the right time, in the right way-ensuring that individuals are supported to participate, develop, and live with dignity, while preventing the escalation of need into more complex and costly systems.
The opportunity before Government is significant. With careful design, proper sequencing, and strong partnership with providers and communities, the reforms can achieve both sustainability and improved outcomes.
Without this, there is a risk that the system will become more constrained, less responsive, and ultimately less effective.