Submission 799 - Supplementary Submission
Committee Secretary
Senate Standing Committees on Community Affairs
Parliament House
Canberra ACT 2600
Re: National Disability Insurance Scheme Amendment Bill 2026 Supplementary Submission
Dear Committee Members,
Lion and Mouse Australia welcomes the opportunity to provide this supplementary submission to the Senate
Community Affairs Legislation Committee in relation to the National Disability Insurance Scheme Amendment
(Securing the NDIS for Future Generations) Bill 2026.
This paper should be read in conjunction with our primary submission to the Committee, lodged on 1 June 2026, and our earlier policy paper, Strengthening NDIS Integrity: A Profession-Led Model to Reduce Fraud and Harm. In those submissions, we expressed support for the objective of ensuring the long-term sustainability of the National Disability Insurance Scheme while also identifying significant implementation risks associated with the proposed reforms, including the sequencing of change, the increasing reliance on standardised assessment models, the redistribution of demand into other systems, and the need to preserve independent review mechanisms such as the Administrative Review Tribunal.
Since lodging those submissions, Lion and Mouse has continued to engage with participants, families, carers, clinicians, support workers, educators and other providers. We have also reviewed additional evidence presented to the Committee, media reporting, sector submissions and emerging policy discussion relating to New Framework Planning, Support Needs Assessments and the proposed future architecture of foundational supports.
Our view remains that reform is necessary.
The NDIS must remain sustainable, transparent and capable of delivering equitable outcomes for future generations. We recognise the challenges faced by government in balancing participant outcomes with stewardship of a Scheme that has grown significantly in both scale and complexity. However, sustainability cannot be understood solely through expenditure management, assessment tools, or administrative consistency.
A sustainable disability system is ultimately one that produces sustainable outcomes for participants, families, carers and communities. Lion and Mouse remains committed to working with Government on helping deliver a sustainable system that improves outcomes for people living with disability.
Yours sincerely,
Anthony Hooper
Chief Executive Officer
Lion and Mouse Australia Ltd
9th July 2026
Submission 799 - Supplementary Submission
National Disability Insurance Scheme Amendment Bill 2026
National Disability Insurance Scheme
Amendment (Securing the NDIS for Future
Generations) Bill 2026
Supplementary Submission to the Senate Community Affairs
Legislation Committee - Carer Capacity, Local Service Reality
and Independent Support Coordination
Submitted by:
Anthony Hooper,
Chief Executive Officer,
Lion and Mouse Australia Ltd
Date: 9 July 2026
Submission: Community Affairs Legislation Committee - Page 1
Submission 799 - Supplementary Submission
Lion and Mouse Australia
Executive Summary
Lion and Mouse Australia supports the long-term sustainability objectives of the proposed reforms and acknowledges the need for greater consistency, transparency and accountability within the National Disability Insurance Scheme (NDIS).
However, based on our experience supporting participants, families and carers across a range of disability cohorts, we believe several critical factors remain insufficiently recognised within the current reform framework.
These include:
- the capacity and sustainability of informal carers;
- the reality of local service availability and workforce constraints;
- the importance of lived experience and longitudinal evidence; and
- the role of independent, professionally accountable Support Coordination. While functional capacity assessments, Support Needs Assessments and structured planning tools can provide valuable information, they should not become substitutes for understanding the real-world circumstances in which participants live.
A participant’s support needs are influenced not only by their functional capacity, but also by the environment around them. Carer health, family sustainability, local service access, transport barriers, workforce shortages, social isolation, school capability and community supports all affect the level of assistance required for a participant to achieve safe and meaningful outcomes.
Two participants with identical assessment scores may require significantly different levels of funded support because their circumstances are fundamentally different. A planning framework that does not adequately recognise these differences risks creating administrative consistency while producing inequitable outcomes.
Lion and Mouse therefore submits that support decisions should incorporate:
- individual functional need;
- carer sustainability and capacity;
- local market and workforce conditions;
- lived experience evidence; and
- observations from those supporting participants in everyday life. These factors should be considered alongside, rather than subordinate to, standardised assessment outcomes.
Supplementary Submission: Community Affairs Legislation Committee - Page 2
Submission 799 - Supplementary Submission
National Disability Insurance Scheme Amendment Bill 2026
This submission also highlights the growing importance of independent Support Coordination within the emerging planning framework.
As assessment processes become more structured and funding models become more standardised, participants will require greater assistance to understand decisions, gather evidence, navigate services, transition between systems, and exercise review rights where appropriate. The need for independent navigation and advocacy therefore increases rather than decreases.
Lion and Mouse does not support models that reduce the independence of Support Coordinators by embedding them within the NDIA or other decision making structures. The answer to quality and consistency concerns is not the removal of independence; it is the professionalisation of the role.
We submit that Support Coordination should remain independent while being strengthened through mandatory qualifications, continuing professional development, professional registration, enforceable ethical standards, independent complaints mechanisms, and oversight through a recognised professional body. This approach would improve quality, accountability and safeguarding while preserving the participant-focused independence that is central to the role.
Ultimately, the success of the proposed reforms will depend not only on the accuracy of assessment tools or the consistency of planning decisions, but on whether the system continues to recognise the realities of everyday life for people with disability, their families and carers. A genuinely sustainable NDIS must be capable of responding to individual circumstances, not simply individual scores.
Submission: Community Affairs Legislation Committee - Page 3
Submission 799 - Supplementary Submission
Lion and Mouse Australia
- Introduction Throughout our work at Lion and Mouse, we see daily examples of participants whose outcomes are shaped not only by their disability, but by the environment around them. We see ageing parents providing round-the-clock care. We see families reducing work hours or leaving employment entirely. We see participants unable to access funded supports because services do not exist locally. We see schools struggling to manage complex behavioural and emotional needs without appropriate therapeutic supports. We see support workers, Support Coordinators and clinicians acting as the bridge between multiple fragmented systems.
These realities are often difficult to capture through standardised assessment processes alone.
Two people with identical functional assessment scores may require fundamentally different levels of support because the circumstances surrounding their lives are different. One participant may have extensive family support, multiple local providers and strong community connections. Another may have an ageing sole carer, limited access to services and significant environmental barriers. Treating these participants as though they have identical support needs simply because they present similarly within an assessment framework risks creating administrative consistency at the expense of practical equity.
Accordingly, Lion and Mouse submits that three issues require greater consideration within the current reform process.
First, the capacity and sustainability of carers must become a formal and meaningful element of planning and support determination. Families are not an unlimited resource. Where formal support is withdrawn, responsibility increasingly shifts to carers, often with significant personal, financial and social consequences.
Second, the planning framework must recognise the reality of local service availability. A support package cannot be considered adequate if the services required to utilise that package are unavailable, inaccessible or subject to extensive waitlists.
Third, as planning arrangements become increasingly structured and assessment-driven, the role of independent Support Coordination becomes more important, not less. Participants require trusted professionals who can assist them to navigate complexity, obtain evidence, access services, challenge decisions where necessary and maintain genuine choice and control. We believe this role should remain independent of the NDIA while being strengthened through formal qualifications, continuing professional development, a professional code of conduct, and oversight through an independent professional
Supplementary Submission: Community Affairs Legislation Committee - Page 4
Submission 799 - Supplementary Submission
National Disability Insurance Scheme Amendment Bill 2026
body. This position is consistent with recommendations made within our earlier integrity reform paper.
The purpose of this supplementary submission is therefore not to revisit the entirety of the proposed reforms. Rather, it is to draw the Committee’s attention to factors that are often underrepresented in discussions about sustainability, yet which have a profound influence on participant outcomes.
In our view, support need cannot be understood solely through functional assessment.
It must also be understood through the lived experience of disability, the capacity of carers, the reality of local service systems, and the availability of independent advocates and professionals who help individuals navigate increasingly complex arrangements.
The long-term success of these reforms will depend not only on the accuracy of assessment tools or the consistency of planning decisions, but on whether the system remains responsive to the realities of everyday life for people with disability and those who support them.
Submission: Community Affairs Legislation Committee - Page 5
Submission 799 - Supplementary Submission
Lion and Mouse Australia
- Real World Planning Cannot Be Reduced to Functional
Scores Alone
One of the central assumptions underpinning the proposed reforms is that support need can be determined through increasingly standardised assessment processes.
While structured assessments and support needs tools have an important role to play, Lion and Mouse submits that they cannot be the sole or primary determinant of support levels.
A participant’s life is not experienced through an assessment tool.
It is experienced through:
- the capacity of family members to provide care
- the availability of local services
- housing and transport circumstances
- community participation opportunities
- school and employment supports
- the cumulative effect of disability over time Two participants with identical assessment scores may require very different levels of funded support because their circumstances are fundamentally different.
Accordingly, Lion and Mouse submits that support planning should continue to recognise three critical forms of evidence:
- functional need
- individual lived experience
- environmental reality Failure to recognise these factors risks creating a system that is administratively consistent but practically inequitable.
2.1 Carer Capacity Is Not Infinite
The proposed reforms place significant emphasis on participant functioning.
However, they place far less emphasis on the capacity of carers and families who often provide the majority of support.
In practice, many support plans are only workable because carers already provide substantial unpaid labour.
This reality is often invisible within assessment processes.
Supplementary Submission: Community Affairs Legislation Committee - Page 6
Submission 799 - Supplementary Submission
National Disability Insurance Scheme Amendment Bill 2026
Across our own participant base we routinely encounter:
- parents who have reduced work hours
- carers managing their own disabilities
- grandparents providing significant support
- single-parent households
- families experiencing financial hardship These circumstances directly affect what level of formal funded support is required.
A support package which appears adequate on paper may become entirely inadequate if the informal support system collapses.
Example: Workforce withdrawal
The Committee should consider the publicly reported case of Karen McKenzie, whose adult son Jarrod has autism and severe intellectual disability.
Following major reductions to NDIS-funded supports, Ms McKenzie reported she was forced to leave employment and provide full-time care herself. She described significant emotional distress and concern about the family’s future after supports were reduced by more than half.
Reference : https://www.abc.net.au/news/2022-02-11/ndis-funding-slashed autism-intellectual-disability/100809854
This example illustrates an important policy reality:
- The support did not disappear. It was transferred.
- The cost moved from the NDIS to a family already under considerable pressure.
Recommendation
Carer sustainability should become a mandatory planning consideration.
Legislation or Rules should require consideration of:
- carer age
- carer health
- carer workforce participation
- cumulative caring responsibilities
- risk of carer burnout when determining support levels.
Submission: Community Affairs Legislation Committee - Page 7
Submission 799 - Supplementary Submission
Lion and Mouse Australia
2.2 Local Service Availability Directly Influences Need
Support needs cannot be separated from service availability.
The experience of a participant living in metropolitan Melbourne differs significantly from the experience of someone living in regional Victoria or outer metropolitan growth corridors.
Services may technically exist on paper but remain inaccessible because of:
- waitlists
- workforce shortages
- travel barriers
- provider withdrawal from thin markets Yet current reform discussions focus heavily on the participant and comparatively little on the environment in which they live.
There are practical considerations on Foundational Supports and other services, in the services absence. “Who is expected to provide support when local foundational supports do not exist?“
For example: If a child loses NDIS funding because foundational supports should meet their needs:
- what if those supports do not exist?
- what if there is a waitlist?
- what if families cannot travel? Example: Early intervention unavailable despite clinical advice
ABC News reported the case of Delilah Miller, a child with Level 3 autism who experienced significant gains through early intervention services.
According to her family, requests for funding that would allow continued access to clinically recommended services were declined, despite substantial evidence of developmental benefit and professional recommendation. The family reported being told that much lower levels of therapy were sufficient.
Reference: https://www.abc.net.au/news/2024-09-10/ndis-funding-cuts children-with-autism-families-impacted/104303492
This demonstrates a broader lesson:
-
Local service availability and the practical reality of obtaining supports matter.
-
A support plan is only effective if the participant can actually access the supports it funds.
Supplementary Submission: Community Affairs Legislation Committee - Page 8
Submission 799 - Supplementary Submission
National Disability Insurance Scheme Amendment Bill 2026
Recommendation
Support planning should explicitly consider:
- service availability
- provider wait times
- workforce shortages
- transport barriers
- regional and rural disadvantage when determining support levels.
2.3 Lived Experience Is Evidence
The proposed reforms place increasing emphasis on structured assessments and support needs tools.
Lion and Mouse supports the use of structured assessments.
However:
Assessments should inform decisions, not replace human judgement.
A participant may appear capable within an assessment environment while experiencing substantial difficulties in daily life.
A participant’s ability to complete a task during an assessment is not necessarily evidence that they can complete that task safely, consistently, independently or repeatedly in everyday life.
Similarly, many participants minimise their needs because:
- they have adapted
- they mask difficulties
- they fear stigma
- they do not recognise their coping strategies as supports Family members often possess a depth of knowledge that cannot be replicated through a single assessment.
Support workers, coordinators and clinicians frequently observe:
- behavioural escalation
- fatigue cycles
- burnout
- safety concerns
- support intensity
Submission: Community Affairs Legislation Committee - Page 9
Submission 799 - Supplementary Submission
Lion and Mouse Australia
over months or years.
This evidence should continue to be recognised as legitimate planning evidence.
Example: Families already reporting significant support reductions
Advocacy for Inclusion recently collected participant stories describing reductions in:
- therapy
- support coordination
- psychology
- meal supports
- respite with participants reporting significant impacts on independence and daily functioning.
Reference: https://www.advocacyforinclusion.org/a-cut-is-a-cut-ndis participants-speak-out/
Whether every individual case is ultimately upheld is less important than the emerging pattern:
Participants consistently report that their lived experience differs from what is being recognised within decision-making processes.
Recommendation
The legislation should require explicit consideration of:
- participant evidence
- family evidence
- multidisciplinary evidence
- longitudinal provider observations alongside any standardised assessment process.
Supplementary Submission: Community Affairs Legislation Committee - Page 10
Submission 799 - Supplementary Submission
National Disability Insurance Scheme Amendment Bill 2026
- Why Independent Support Coordination Matters
More Under New Framework Planning
One of the assumptions embedded within current reform discussions is that a more standardised planning framework will reduce complexity within the NDIS and therefore reduce the need for intensive Support Coordination.
Lion and Mouse submits that the opposite is likely to occur.
The movement towards New Framework Planning, Support Needs Assessments,
standardised budget methodologies, impairment-linked funding decisions and foundational supports will fundamentally alter how participants access and navigate the Scheme. While these reforms may create greater consistency from an administrative perspective, they will also create new layers of complexity for participants and families who are expected to understand changing eligibility requirements, navigate multiple systems, engage with new assessment processes and challenge decisions when they believe their circumstances have not been adequately recognised.
For many participants, particularly those with intellectual disability, psychosocial disability, acquired brain injuries, autism and complex support needs, these changes will not simplify their lives. They will create additional navigation challenges at precisely the time when the support landscape is becoming more fragmented.
Participants will increasingly require assistance to:
- understand assessment outcomes;
- interpret planning decisions;
- obtain clinical and functional evidence;
- connect with appropriate services;
- transition between the NDIS and foundational supports;
- navigate internal reviews;
- understand their appeal rights; and
- participate effectively in Administrative Review Tribunal proceedings where necessary.
In this environment, Support Coordination becomes more important, not less.
Reference: https://www.abc.net.au/news/2025-06-06/ndis-plan-reviews leaving-participants-families-stressed/105359526
Submission: Community Affairs Legislation Committee - Page 11
Submission 799 - Supplementary Submission
Lion and Mouse Australia
3.1 Support Coordinators Are More Than Service Navigators
Support Coordinators are often described as service navigators. While navigation is an important part of the role, this description significantly understates their value within the broader disability ecosystem.
Independent Support Coordinators frequently perform functions that are critical to participant safety, planning integrity and system accountability.
In practice, they operate as:
- safeguarding mechanisms;
- conflict identification mechanisms;
- evidence coordinators;
- system translators;
- problem solvers;
- family supports; and
- independent advocates. Unlike planners, assessors, providers or government agencies, Support Coordinators often have visibility across the participant’s entire support ecosystem.
They understand:
- how supports interact;
- where service gaps exist;
- the practical impact of funding decisions;
- and the cumulative pressures being experienced by participants and families.
This broader perspective is rarely available through assessments conducted at a single point in time.
Support Coordinators are often the first people to identify:
- provider misconduct;
- inappropriate service delivery;
- participant safeguarding concerns;
- escalating family stress;
- carer burnout;
- school breakdown;
- housing risk; and
- emerging mental health concerns.
Supplementary Submission: Community Affairs Legislation Committee - Page 12
Submission 799 - Supplementary Submission
National Disability Insurance Scheme Amendment Bill 2026
Removing independence from this role risks removing one of the few functions within the NDIS that maintains visibility across all aspects of a participant’s life.
3.2 Independent Support Coordination as a Safeguard As planning systems become increasingly standardised, there is a risk that participants become progressively disconnected from decision-making processes.
A participant may receive an assessment outcome, planning decision or budget allocation without fully understanding:
- how the decision was made;
- what evidence was considered;
- whether the decision accurately reflects their circumstances; or
- what options are available if they disagree. Independent Support Coordinators help bridge this gap.
They assist participants to understand:
- their rights;
- their options;
- available evidence pathways;
- review processes; and
- appeal mechanisms. They also help ensure participants are active participants in decisions affecting their lives rather than passive recipients of administrative outcomes.
This role becomes even more important under a planning framework increasingly informed by standardised tools and budget methodologies.
A system that relies heavily on assessments but provides insufficient support to understand and respond to those assessments risks creating procedural fairness concerns for participants.
Independent Support Coordinators represent one of the few practical mechanisms available to address this risk.
Lion and Mouse is concerned that the proposed commissioning approach may unintentionally weaken the independence of Support Coordination by creating a perception that coordinators are accountable primarily to budget management objectives rather than participant outcomes. For Support Coordination to remain effective, participants must have confidence that their coordinator’s primary obligation is to the participant, their goals, and their rights under the Scheme. Independence is not an administrative feature of Support Coordination; it is central to its purpose.
Submission: Community Affairs Legislation Committee - Page 13
Submission 799 - Supplementary Submission
Lion and Mouse Australia
3.3 The Connection Between Support Coordination and the ART
Lion and Mouse’s previous submission highlighted the importance of preserving the Administrative Review Tribunal (ART) as a safeguard within the NDIS system.
Support Coordination and independent review mechanisms are closely connected.
Many participants and families first become aware of their review rights through their Support Coordinator.
Support Coordinators frequently assist participants to:
- collect evidence;
- obtain reports;
- identify gaps in decision-making;
- understand review pathways;
- prepare supporting documentation; and
- engage appropriately with legal and advocacy services. Importantly, they do this while remaining separate from the decision-maker.
As public reporting has demonstrated, many successful challenges to NDIS decisions rely upon the existence of strong evidence and independent support networks. Families have increasingly sought reviews and appeals where they believe participant needs have not been appropriately recognised.
Reference: https://www.theguardian.com/australia-news/2026/apr/27/ndis changes-cuts-state-government-support-autism
If Support Coordination loses its independence, there is a risk that participants lose access to one of the most important supports available to them when exercising their rights under the Scheme.
Recommendation
Support Coordination needs to be preserved independent of the NDIA.
3.4 Why Independence Matters
Lion and Mouse acknowledges concerns raised by Government regarding quality, consistency and accountability within the Support Coordination sector.
These concerns are legitimate.
Supplementary Submission: Community Affairs Legislation Committee - Page 14
Submission 799 - Supplementary Submission
National Disability Insurance Scheme Amendment Bill 2026
However, we do not believe the solution is to reduce the independence of the role.
A Support Coordinator embedded within the NDIA, or operating under arrangements that create real or perceived obligations to government objectives, may face competing responsibilities.
Participants must have confidence that their coordinator’s primary obligation is to:
- the participant;
- their goals;
- their wellbeing; and
- their rights under the NDIS. Not funding targets.
Not provider interests.
Not administrative efficiency.
Participants.
Independence is not an administrative feature of Support Coordination.
It is the foundation upon which participant trust is built.
Without that trust, the effectiveness of the role is substantially diminished.
3.5 The Solution Is Professionalisation, Not Reduced Independence
Lion and Mouse believes the solution to concerns regarding quality and consistency is not the removal of independence.
The answer to quality and consistency concerns is not the removal of independence; it is the professionalisation of the role.
In our earlier integrity reform submission, we proposed the creation of a recognised professional framework for Support Coordination.
Under this model, Support Coordinators would remain independent while being subject to:
- minimum qualification requirements;
- mandatory professional development;
- enforceable ethical standards;
- professional registration requirements;
- external complaints processes;
- disciplinary mechanisms; and
- oversight through an independent professional body.
Submission: Community Affairs Legislation Committee - Page 15
Submission 799 - Supplementary Submission
Lion and Mouse Australia
This approach would improve:
- participant protection;
- consistency of practice;
- workforce capability;
- accountability; and
- confidence in the profession. Most importantly, it preserves the independence that makes Support Coordination effective in the first place.
Recommendation
The Commonwealth should establish a recognised professional framework for Support Coordinators including:
- minimum qualifications
- mandatory professional development
- professional registration
- enforceable ethical standards
- independent quality assurance consistent with recommendations previously made by Lion and Mouse Australia to professionalise the Support Coordination workforce through mandatory qualifications, continuing professional development requirements, an enforceable code of conduct, independent complaints and disciplinary processes, and oversight through a recognised professional body.
Supplementary Submission: Community Affairs Legislation Committee - Page 16
Submission 799 - Supplementary Submission
National Disability Insurance Scheme Amendment Bill 2026
- Recommendations Drawing on the evidence, examples and issues discussed throughout this supplementary submission, Lion and Mouse Australia makes the following additional recommendations to complement those contained in our previous submissions:
- 7: Formal recognition of carer sustainability.
- 8: Mandatory consideration of local service availability..
- 9: Recognition of lived experience evidence.
- 10: Preserve independent Support Coordination.
- 11: Establish a professional framework for Support Coordination.
Submission: Community Affairs Legislation Committee - Page 17
Submission 799 - Supplementary Submission
Lion and Mouse Australia
- Conclusion The proposed reforms seek to create a more consistent and sustainable NDIS.
However, sustainability cannot be achieved through assessment tools and administrative processes alone.
Support needs are shaped by:
- functional capacity
- family capacity
- local service reality
- lived experience A planning system that does not adequately recognise these factors risks appearing consistent while producing inequitable outcomes.
Similarly, Support Coordination should not lose its independence in pursuit of consistency.
The better path is professionalisation, accountability, and quality assurance through an independent professional framework.
Lion and Mouse therefore encourages the Committee to ensure that future legislation, rules and planning frameworks recognise not only functional need, but the real-world circumstances in which people with disability and their families live.
This supplementary submission complements our original submission to the Committee and our earlier Integrity Reform submission by focusing on the practical realities that ultimately determine whether reform succeeds or fails.