Submission 806
01/06/2026
Submission Regarding the National Disability Insurance Scheme Amendment Bill
I am a carer for a person with disability who requires NDIS-funded supports, and I work as a Support Coordinator for a NDIS registered provider in regional Victoria.
I wish to raise concerns regarding the proposed NDIS legislative reforms currently being considered by Parliament, particularly their potential impact on participants with the most significant disabilities, complex communication support needs and limited access to informal safeguards.
Many of the NDIS participants myself and my colleagues support previously resided at the former Pleasant Creek Training Centre in Stawell, rural Victoria. Pleasant Creek was a large disability institution that has since closed. Most are now long-term residents of Supported Disability Accommodation (SDA) homes and receive Supported Independent Living (SIL) supports in the community.
A significant number of these individuals experienced custodial institutionalisation from childhood. Many have no known family members, limited social networks, lifelong segregation from community life, unmet communication support needs, intellectual disabilities, autistic traits, high physical support needs and/or complex behaviours of concern. They rely heavily on disability service systems to identify emerging risks and assist them to exercise choice, control and decision-making.
While the proposed reforms appear intended to improve sustainability and administrative efficiency, I am concerned that they may unintentionally create additional barriers for participants who are already least able to engage with NDIS systems independently.
Concerns Regarding Communication, Consent and Engagement
Many participants within this cohort do not have the assistance available to them to:
Independently read or understand NDIA correspondence, including easy English versions.
Access substantial communication support to understand planning and reassessment processes.
Have no family member, guardian or informal advocate available to assist them.
Identify when decisions are not aligned with their preferences.
Are at increased risk of being excluded from decision-making processes despite being among the participants most reliant on the Scheme.
Submission 806
The majority of these participants depend upon support workers, allied health professionals, support coordinators and other service providers to assist them to understand information, communicate preferences and identify emerging concerns. In practice, the concept of participant choice and control often relies upon significant supported decision-making arrangements.
I am concerned that legislative changes may inadvertently assume a level of participant engagement, communication ability and access to informal safeguards that does not exist for many individuals with the most complex disabilities.
Concerns Regarding Plan Reassessment Requests
I am particularly concerned by the Government’s stated intention to tighten access to reassessments and plan variation processes.
Many participants with the most significant disabilities have not been able to access the necessary support to independently identify unmet support needs, gather evidence, communicate changing circumstances, or articulate why their current supports are no longer adequate. For these individuals, requests for reassessment are often initiated, with consent, by family members, nominees, guardians, support coordinators, advocates, allied health professionals or service providers acting as safeguards around the participant.
However, there remains a cohort of participants who have no known family involvement, no active nominee, no guardian, limited access to advocacy services and significantly unmet communication and decision making support needs. Some are unable to reliably communicate complex support needs at all due to not having the assistance available to assist.
For these individuals, it is unclear how unmet needs will be identified and escalated if access to reassessment becomes more restrictive. I ask if guardianship (temporary) is the most appropriate option to support someone to lodge a plan reassessment request, and the Support Coordinator needing to apply to VCAT to have a public guardian reappointed every time there is a need for a plan reassessment?
I am concerned that participants with the highest support needs may be disproportionately disadvantaged by reforms that place greater emphasis on participant-initiated requests, formal evidence requirements or direct engagement with NDIA processes.
A participant who cannot independently communicate their changing support needs should not face a higher barrier to accessing reassessment than a participant who can advocate for themselves.
The participants least able to communicate unmet needs are often the same participants least likely to have family, nominees, guardians or advocates available to identify those unmet needs on their behalf. Any reform that makes reassessment more difficult therefore risks having its greatest impact on those least able to challenge decisions or seek review.
Without specific safeguards, there is a significant risk that some participants will remain in plans that no longer reflect their needs, or not receive new plans, simply because they lack the informal or formal supports necessary to navigate reassessment processes.
Submission 806
It is also important to recognise that many of these participants were able to access the NDIS through grandfathering arrangements between the Victorian Government and the Commonwealth despite the significant communication, decision-making and engagement barriers that continue to exist today.
The fact that these barriers were acknowledged at the point of Scheme entry does not mean they have since been resolved. For many participants, the same challenges that necessitated alternative pathways into the NDIS continue to impact their ability to understand NDIA communications, participate in planning processes, communicate unmet needs, or seek reviews of decisions.
Equal consideration should therefore be given to establishing clear and accessible planning and reassessment pathways that ensure participants with profound communication and decision-making barriers can continue to access necessary supports and have emerging needs recognised and responded to.
I am concerned that, without specific safeguards, many participants may effectively be required to obtain increasingly formal substitute decision-making arrangements, such as temporary guardianship, in order to navigate NDIS processes that they cannot realistically engage with independently without capacity building support first provided. Reforms should seek to strengthen supported decision-making wherever possible and ensure that participants are not disadvantaged simply because they lack family members, nominees or guardians to advocate on their behalf.
Concerns Regarding Proposed Reductions to Social, Civic and Community
Participation Funding
I am also concerned by the Government’s stated intention to reduce funding allocated to social, civic and community participation supports.
While reductions may have limited impact on some participants, there is a cohort of individuals with profound disability, high physical support needs and/or significant intellectual disability who already receive what could reasonably be considered the minimum level of support necessary to safely access their community.
Many participants residing in Supported Independent Living settings that my service support require 24-hour support and cannot safely access community activities independently. Community participation frequently requires dedicated support staff, specialised transport, behavioural supports, communication supports and extensive planning.
Many of these individuals are unable to safely remain at home without support and are unable to safely access the community independently. They require assistance with essential daily activities such as personal care, meal preparation, medication management, communication, decision-making, mobility and maintaining their own personal safety – at home and in the community. Without support being available, many would be unable to meet their basic daily needs to survive.
Submission 806
For these participants, funded support is not simply about accessing recreational activities. It is often the mechanism through which they are able to leave their home, engage with other people, maintain relationships and participate in society. Reductions to social and community participation funding may therefore have a disproportionate impact on individuals with the highest support needs, particularly where existing support arrangements are already operating at the minimum level considered safe and appropriate.
For these participants, reductions to social and community participation funding may not result in greater efficiency. Instead, they may simply result in fewer opportunities to leave their homes, engage with their communities, maintain relationships and participate in ordinary aspects of Australian life. Individuals will not have the available funded support available to them at home instead.
I am particularly concerned that participants with the highest support needs may be disproportionately affected because there is often little or no capacity to reduce support ratios further without compromising safety, dignity or meaningful participation.
Many of the individuals I support have already experienced lifelong segregation through institutional care and continue to face significant barriers to community inclusion. Services are typically not appropriately funded to meet additional complex health related needs, such as dysphagia and complex bowel care management. Reductions to social and community participation funding risk reinforcing these patterns of isolation rather than advancing the objectives of the NDIS.
For some participants, social and community participation supports are the primary mechanism through which they access community life outside of their supported accommodation environment. Reducing these supports risks further isolating individuals who have already spent much of their lives segregated from broader society.
Recommendations
I respectfully request that the Committee consider additional safeguards for participants who have significant communication impairments, intellectual disability, institutional histories and limited informal supports.
These safeguards may include:
Alternative reassessment pathways for participants unable to independently engage with NDIA processes.
Proactive NDIA outreach and monitoring for participants identified as having limited informal safeguards.
Stronger supported decision-making mechanisms.
Improved access to independent advocacy.
Submission 806
Clear pathways for concerns regarding unmet needs to be raised by independent professionals with direct knowledge of a participant’s circumstances.
Additional consideration of the impact of social and community participation funding reductions on participants requiring intensive support to access their communities.
Explicit recognition of the unique circumstances of participants who entered the NDIS through state-based institutional transition and grandfathering arrangements.
The NDIS was established to promote choice, control and inclusion. Any reforms should ensure that participants who face the greatest barriers to exercising those rights are not inadvertently left behind.
Thank you for considering this submission.