Submission to the Senate Community Affairs Committee

Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 prepared by Future Focus Support Coordination

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

This submission has been prepared by Future Focus Support Coordination, drawing on finalised operational and financial data from the 2024–2025 financial year. The analysis and cost modelling presented reflect actual service delivery conditions rather than hypothetical or aspirational assumptions.

Future Focus Support Coordination is a registered Support Coordination provider operating at scale, delivering Level 2 and Level 3 Support Coordination across multiple regions and participant cohorts, including individuals with complex psychosocial, behavioural, justice-involved, and safeguarding-related needs. The organisation employs a multidisciplinary workforce operating under SCHADS-aligned employment conditions and maintains formal clinical governance, supervision, and compliance frameworks consistent with the NDIS Practice Standards.

Future Focus operates within the mainstream Support Coordination market rather than a niche or pilot setting. Its service model is representative of providers that deliver high-volume, participant-facing coordination while absorbing the full cost of workforce employment, supervision, governance, audit, and regulatory compliance. As such, the data and insights contained in this submission are intended to reflect real-world market conditions experienced by providers committed to safe, sustainable, and accountable delivery.

The purpose of providing organisational context is not to advance a single-provider perspective, but to ensure that the evidence presented is understood as grounded in actual market operations, with relevance to the broader Support Coordination sector.

Section 1 - Executive Summary

Future Focus Support Coordination welcomes the opportunity to provide this submission to the Senate Community Affairs Committee regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

Future Focus supports the overarching objectives of the Bill, including strengthening safeguards, improving quality, reducing fraud and ensuring the long-term sustainability of the National Disability Insurance Scheme (NDIS). These objectives are essential to maintaining public confidence in the Scheme and ensuring that future generations of Australians with disability continue to receive the supports they require.

However, while the objectives of the Bill are broadly supported, we are concerned that aspects of the proposed reform agenda may unintentionally undermine participant outcomes if they result in the erosion of one of the Scheme’s most important implementation and safeguarding functions: Support Coordination.

Support Coordination exists because the NDIS is a complex market-based system. Participants are expected to navigate thousands of providers, multiple service systems, workforce shortages, housing challenges, health interfaces, safeguarding concerns and increasingly complex funding arrangements. For many participants, particularly those with psychosocial disability, intellectual disability, acquired brain injury, complex behavioural support needs, justice involvement, homelessness risk, or limited informal supports, choice and control cannot be meaningfully exercised without skilled assistance.

The evidence available to Government does not support the conclusion that Support Coordination should be replaced by a more generalised navigation model. Rather, evidence from the NDIS Review, the Disability Royal Commission, international case management models and the NDIA’s own research consistently demonstrates that people with complex needs achieve better outcomes when they have access to skilled, independent and relationship-based coordination supports.

Future Focus is particularly concerned about the potential impacts of commissioning arrangements and provider panel models that may favour scale,

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

procurement efficiency and administrative simplicity over participant choice, local expertise and provider diversity. While commissioning may improve consistency and oversight, international experience demonstrates that poorly designed procurement systems can also result in market concentration, reduced participant choice, loss of specialist expertise and diminished local knowledge.

The Committee should carefully consider whether reforms designed to improve quality and sustainability may inadvertently recreate challenges already identified within other navigation and commissioned service systems. The experience of Local Area Coordination demonstrates that geographic presence alone does not guarantee participant outcomes. Similarly, lessons from Disability Employment Services and other commissioned disability programs highlight the risks associated with consolidation, standardisation and the displacement of smaller specialist providers.

Future Focus submits that the central policy question is not whether Support Coordination should be regulated. It should be. Nor is the question whether quality standards should be strengthened. They should be. The critical question before Parliament is whether the implementation of these reforms will preserve the features of Support Coordination that currently deliver participant outcomes, including:

• participant choice and control;

• independence from government decision-making;

• local market knowledge and community relationships;

• specialist expertise;

• continuity of trusted relationships;

• safeguarding and risk identification functions; and

• strong governance and professional accountability.

Future Focus submits that the most effective path forward is not the replacement of Support Coordination, but its evolution into a more consistently regulated, professionally governed and evidence-informed service. The Committee should ensure that any future commissioning arrangements, panel structures or navigation reforms preserve provider diversity, participant choice and independent advocacy functions, while strengthening quality and accountability across the sector.

Chapter 1 – The Role of Support Coordination in Achieving the Objectives of the NDIS

Introduction

The National Disability Insurance Scheme was established to provide Australians with disability greater choice and control over the supports they receive. Unlike traditional block-funded disability systems, the NDIS relies upon participants navigating a complex market of providers, supports and service systems in order to achieve their goals.

For many participants, particularly those with significant cognitive, psychosocial, communication, behavioural or social complexity, exercising genuine choice and control is not simply a matter of receiving funding. It requires access to skilled assistance that can translate a plan into practical outcomes.

Support Coordination was introduced to fulfil this function.

While often described as a capacity-building support, Support Coordination performs a far broader role in practice. It operates at the intersection of participant safeguarding, plan implementation, service system navigation, provider market development and risk management. It is one of the primary mechanisms through which the objectives of the NDIS are translated into real-world outcomes.

As Parliament considers reforms intended to secure the future sustainability of the Scheme, it is essential that the role and value of Support Coordination is accurately understood.

Support Coordination Enables Choice and Control

The NDIS is founded upon the principle that people with disability should have choice and control over the supports they receive. However, choice only exists when a person is able to:

• understand their plan;
• understand available service options;
• compare providers;
• identify quality and safeguarding risks;
• navigate funding rules;
• coordinate multiple supports; and
• respond effectively when services fail. For participants with complex support needs, these tasks can be overwhelming without assistance. Support Coordinators support participants to understand and implement their plans, build service networks, exercise informed choice and maintain continuity of supports over time. Without effective implementation support, funding alone does not guarantee outcomes.

Support Coordination as a Safeguarding and Scheme Integrity Function

Support Coordination is frequently described as a service navigation function. While navigation is an important component of the role, this description significantly understates the contribution Support Coordinators make to participant safety, safeguarding and scheme integrity. Unlike many professionals operating within the disability ecosystem, Support Coordinators routinely engage with participants in their homes, communities, workplaces, schools, hospitals and service environments. They often maintain long-term relationships with participants and their support networks and are uniquely positioned to observe the practical realities of a participant’s life rather than relying solely on documentation, assessments or reports. As a result, Support Coordinators are frequently among the first professionals to identify circumstances involving:

• violence, abuse and neglect;
• financial exploitation;
• coercive control;
• provider misconduct;
• restrictive practices being applied inappropriately;
• housing instability and homelessness;

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

• carer breakdown;
• social isolation;
• self-neglect;
• service abandonment;
• emerging mental health crises; and
• escalating behavioural or safeguarding risks.

Support Coordinators do not merely identify these risks. They actively intervene when the people sitting in offices do not have the ability to recognize when there is a problem.

Across Australia, Support Coordinators routinely support participants to leave unsafe living arrangements, exit exploitative service relationships, secure emergency accommodation, access health and mental health services, report incidents to the NDIS Commission, engage police and statutory authorities where required, and coordinate urgent responses during periods of significant risk.

For many participants, particularly those living alone, experiencing psychosocial disability, intellectual disability, acquired brain injury, or complex behavioural support needs, their Support Coordinator may be the only independent professional regularly observing their circumstances across multiple service settings.

This independent oversight function is particularly important because Support Coordinators operate across a participant’s entire support system. Unlike individual service providers, they are able to identify patterns and risks that emerge across multiple services and environments.

Importantly, Support Coordinators also play a significant role in protecting the financial integrity of the NDIS.

Support Coordinators regularly identify:

• services being claimed but not delivered;
• duplicate charging;
• inappropriate service agreements;
• provider over-servicing;
• unsupported recommendations for additional funding;
• conflicts of interest;
• misuse of participant funding;
• participant vulnerability to financial exploitation; and

• practices inconsistent with NDIS pricing arrangements and participant outcomes.

In many cases, Support Coordinators act as the first line of defence against inappropriate expenditure and provider misconduct by helping participants understand how their funding is being used and supporting them to make informed decisions regarding services.

This role is particularly important within a market-based system where participants may engage numerous providers simultaneously and where individual participants may not possess the knowledge, confidence or capacity required to identify inappropriate practices.

The contribution of Support Coordination to safeguarding and scheme integrity is therefore broader than participant support alone. Support Coordinators help protect participants from harm, assist regulators and statutory services to identify and respond to risks, and contribute to the responsible stewardship of public funds.

Any reform that materially reduces the independence, visibility or accessibility of Support Coordinators within participant lives should therefore be considered not only through the lens of service delivery, but also through the potential loss of one of the Scheme’s most significant community-based safeguarding mechanisms.

1.4 Support Coordination as a System Navigation Function

The modern disability system extends far beyond the NDIS. Participants frequently interact with:

• public health systems;
• mental health services;
• housing and homelessness services;
• child protection;
• family violence services;
• aged care;
• education systems;
• employment services;
• justice and corrections systems; and
• mainstream community services.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

Navigating these interfaces is often challenging for participants and families. Support Coordinators play a critical role in helping participants access the right service from the right system at the right time, while reducing duplication, canfusion and service gaps.

This function becomes increasingly important as government policy seeks to strengthen the role of foundational supports and mainstream service systems alongside the NDIS.

Evidence Supporting Support Coordination

The NDIA’s own evidence review identified Support Coordination as an important facilitator of successful plan implementation and found strong support from participants, families and planners for the role it plays in helping participants utilise their plans effectively.

The NDIS Review also identified widespread challenges associated with navigating the Scheme and repeatedly heard from participants and families about the difficulty of understanding funding, finding services, coordinating supports and responding to changing circumstances.

Importantly, the NDIS Review did not conclude that participants require less assistance to navigate complexity. Rather, it proposed new navigation arrangements because complexity within the disability ecosystem remains significant.

The central policy question is therefore not whether participants require assistance to navigate disability supports.

The question is what form that assistance should take, and how it can best preserve participant outcomes, choice, independence and safeguarding.

Support Coordination as an Investment Rather Than a Cost

Support Coordination is often considered solely as an expenditure within participant plans. This perspective overlooks the broader value generated by effective coordination. By helping participants maintain stable housing, avoid service breakdown, access appropriate health and community supports, and respond early to emerging risks, Support Coordination can reduce reliance on significantly more expensive systems including:

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• hospital admissions;
• emergency mental health responses;
• homelessness services;
• crisis accommodation;
• justice interventions; and
• statutory safeguarding responses. The value of Support Coordination should therefore be considered not only through the lens of direct scheme expenditure, but also through its contribution to participant stability, safeguarding and broader system efficiency.

Conclusion

Support Coordination is not merely an administrative support that can be completed in the way that is currently being undertaken in Local Area Coordination. It is a participant safeguarding function, a market navigation function, a plan implementation function and a mechanism through which participants are able to exercise genuine choice and control within the NDIS.

As Parliament considers reforms intended to improve sustainability, integrity and quality across the Scheme, it is essential that the role of Support Coordination is understood in this broader context.

Any reform that weakens the independence, expertise, continuity or accessibility of Support Coordination risks undermining the very participant outcomes that the NDIS was designed to achieve.

Chapter 2 – What the Evidence Tells Us About Local Area Coordination, Navigation Services and the Future of Support Coordination

A central premise underpinning the reforms proposed through the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 is that participants require a more consistent, sustainable and accountable approach to navigation and intermediary supports. Future Focus agrees that reform is required. However, before fundamentally reshaping Support Coordination through commissioning arrangements and panel-based delivery models, it is important to examine the evidence generated through more than a decade of Local Area Coordination and navigation-based supports within the NDIS.

The experience of Local Area Coordination is highly relevant to Parliament’s consideration of this Bill. Local Area Coordination was itself designed to provide participants with local knowledge, navigation assistance, connection to community services and support to exercise choice and control. These are many of the same objectives now being advanced in support of a commissioned Support Coordination model.

The evidence demonstrates that Local Area Coordination performs an important function within the disability ecosystem and should continue to do so. However, the evidence also demonstrates that navigation services alone have not resolved the challenges participants experience implementing plans, coordinating supports and navigating complexity. This distinction is critical because the risk presented by the proposed reforms is not that Support Coordination disappears entirely. The risk is that Support Coordination gradually evolves into a service that increasingly resembles Local Area Coordination while losing the characteristics that have historically made it effective.

The question before Parliament is therefore not whether navigation services are valuable. The evidence clearly demonstrates that they are. The question is whether navigation services can perform the same functions as Support

The Intended Purpose of Local Area Coordination

Local Area Coordination was introduced as a foundational component of the NDIS. Its purpose was to assist people with disability to access information, build community connections, strengthen natural supports, access mainstream services and increase participation in community life. Local Area Coordinators were intended to act as trusted local points of contact capable of assisting people to understand available supports and connect with opportunities within their communities.

These objectives remain important and continue to align with the original vision of the NDIS. Participants benefit from having access to people who understand local communities, local services and local opportunities. Strong community connections remain one of the most effective ways of improving social inclusion and reducing isolation.

However, Local Area Coordination was never intended to perform the same functions as Support Coordination.

As the NDIS matured, it became increasingly apparent that many participants required assistance beyond information, referral and community connection. Participants with complex support needs often required intensive assistance to implement plans, coordinate multiple providers, navigate housing systems, engage with health services, manage behavioural support arrangements, respond to safeguarding concerns and resolve service failures.

Support Coordination emerged because navigation alone was not sufficient for many participants.

This distinction remains important today. Local Area Coordination was designed to help people connect to opportunities and information. Support Coordination was designed to help people navigate complexity and turn funding into outcomes. While there is some overlap between these functions, they are not interchangeable.

What the NDIS Review Heard About Navigation

The NDIS Review provides some of the strongest evidence available regarding the ongoing challenges participants experience navigating the Scheme.

Despite more than a decade of investment in Local Area Coordination and other navigation functions, the Review heard consistent concerns from participants, families and providers regarding the complexity of the NDIS. Participants reported difficulty understanding their plans, locating suitable providers, coordinating multiple services, understanding funding arrangements and responding when providers disengaged or failed to deliver services.

Importantly, the Review also found that the current landscape of intermediaries often created confusion. Participants reported uncertainty regarding the respective roles of Local Area Coordinators, Support Coordinators and other navigation functions. The Review observed that the existing system frequently contains both overlap and gaps, resulting in inconsistent experiences for participants.

What is notable about these findings is that the Review did not conclude that participants required less assistance. Nor did it conclude that navigation functions had become unnecessary. Quite the opposite. The Review proposed a redesigned navigation ecosystem because participants continued to struggle to navigate disability, health, housing and community systems.

This is a critical finding for Parliament. If navigation remains one of the most significant challenges identified by participants after more than ten years of Local Area Coordination, then the evidence does not support the proposition that navigation services alone are sufficient for people with complex support needs.

The Review’s findings suggest that participants require different levels of assistance depending on their circumstances. While some participants may only require information and community connection, others require intensive support to implement plans, coordinate multiple systems, manage risk and respond to crises. These are fundamentally different functions requiring different levels of expertise and intervention.

Local Presence Alone Does Not Produce Better Outcomes

A common argument in favour of navigation-based service models is that locally based services are inherently better positioned to support participants. While local knowledge is undoubtedly valuable, the experience of the NDIS demonstrates that local presence alone does not guarantee participant outcomes.

Local Area Coordinators have operated within communities across Australia for more than a decade. They are, by design, embedded within local regions and possess local knowledge and community connections. Yet despite this substantial investment in a locally based navigation workforce, participants continue to report significant challenges implementing plans, accessing services and navigating complexity.

This should not be interpreted as a criticism of Local Area Coordinators. Rather, it reflects the reality that many participant challenges extend beyond information and referral.

A participant may know that a housing provider exists. They may know that a mental health service is available. They may know that a behavioural support practitioner operates in their region. However, achieving a successful outcome frequently requires much more than awareness. It may require negotiation between providers, crisis intervention, safeguarding responses, advocacy, multidisciplinary coordination and ongoing oversight of complex support arrangements.

These activities require expertise, continuity and capacity that extend beyond community navigation alone.

The evidence therefore suggests that locality is only one component of effective support. Participants achieve the best outcomes when local knowledge is combined with specialist expertise, continuity of relationships, safeguarding capability and sufficient time to respond when circumstances become complex.

This lesson becomes particularly important when considering future commissioning arrangements. If reforms prioritise geographic coverage, procurement efficiency and standardisation without adequately protecting capability, there is a risk that local presence becomes a substitute for expertise rather than a complement to it.

The Difference Between Community Connection and Complex Coordination

The distinction between Local Area Coordination and Support Coordination becomes clearer when examining the outcomes each service is intended to achieve. The NDIA’s own evidence review identifies Local Area Coordination as contributing to outcomes such as community participation, social inclusion, wellbeing and reduced social isolation. These are important outcomes that should continue to be supported through a strong navigation ecosystem.

Support Coordinators, however, operate in a different domain. Support Coordinators are frequently engaged where participants are unable to effectively implement their plans without assistance. They may be coordinating multiple providers, transitioning from hospital, entering Specialist Disability Accommodation, engaging with justice systems, experiencing homelessness, managing behavioural risks or responding to safeguarding concerns.

Support Coordinators routinely participate in hospital discharge planning, multidisciplinary case conferences, behavioural support reviews, safeguarding investigations, housing meetings and crisis response processes. They work across disability, health, housing, justice and community systems simultaneously.

They are often required to identify service failures, challenge poor provider practices, coordinate urgent responses and assist participants to navigate situations involving significant risk.

These functions differ substantially from the traditional role of community navigation and community connection. The evidence therefore suggests that Local Area Coordination and Support Coordination should be viewed as complementary functions within the disability ecosystem rather than interchangeable services.

The Proposed Commissioned Model and the Risk of Convergence with Local Area Coordination

The distinction between navigation and coordination becomes particularly important when examining the reforms proposed through the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

The Explanatory Memorandum outlines the Government’s intention to establish commissioned intermediary functions and panel-based delivery models as part of a broader effort to improve quality, consistency, integrity and sustainability within the Scheme. These objectives are understandable and broadly supported. However, they raise an important question: what characteristics of Support Coordination will remain if the service becomes increasingly shaped by procurement, commissioning and standardisation?

Historically, Support Coordination has been distinguished from Local Area Coordination through its intensive participant engagement, safeguarding functions, multidisciplinary coordination, crisis response capability and independence from funding and planning decisions.

By contrast, navigation services such as Local Area Coordination have traditionally focused on information, advice, community connection, referral pathways and access to mainstream services.

Many of the features currently described within the reform agenda—including greater consistency, standardisation, market stewardship, commissioning and panel-based delivery—are characteristics historically associated with navigation models rather than intensive coordination models.

What is notably less visible within the proposed framework is explicit recognition of the functions that distinguish Support Coordination from navigation services. There is limited discussion regarding participant advocacy, safeguarding oversight, crisis intervention, provider accountability, multidisciplinary coordination and the intensive implementation support required by participants with significant complexity.

The concern raised by Future Focus is not that commissioned providers will cease being local. Many may remain physically located within the communities they serve.

The concern is that local presence may become the primary defining feature of the service while the specialist functions that distinguish Support Coordination from Local Area Coordination gradually diminish through procurement settings, capped funding arrangements, standardised service expectations and increasing administrative obligations.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

If this occurs, participants may continue to have access to a locally based navigator while losing access to the intensive coordination and safeguarding functions that Support Coordination was originally designed to provide.

In practical terms, the Committee should consider whether the commissioned model proposed by Government risks creating a service that increasingly resembles Local Area Coordination in function, even if it continues to be described as Support Coordination in name.

Lessons for Future Reform

The experience of Local Area Coordination provides several important lessons for Parliament to consider in accepting this bill and implementing future reforms as they relate to Support Coordination.

First, navigation services remain necessary and valuable. Participants continue to require assistance understanding and navigating disability and mainstream systems.

Second, local presence alone is insufficient. Participant outcomes depend on a combination of local knowledge, expertise, continuity, independence and capability.

Third, complexity matters. Participants with significant safeguarding risks, housing instability, psychosocial disability, justice involvement or complex support arrangements require a level of intervention that extends beyond navigation alone.

Finally, the evidence demonstrates that navigation and Support Coordination perform different functions. One assists participants to connect with opportunities and information. The other assists participants to implement plans, coordinate systems, manage risk and achieve outcomes. The success of future reforms will depend on recognising and preserving this distinction.

Conclusion

More than a decade of experience with Local Area Coordination demonstrates that navigation services are an essential component of the disability ecosystem. However, the evidence does not support the proposition that navigation services

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

alone are sufficient for participants experiencing complexity, vulnerability or safeguarding risks.

The experience of Local Area Coordination demonstrates that participant outcomes are achieved not simply through local presence, but through the combination of local knowledge, specialist expertise, continuity of relationships, safeguarding capability and effective implementation support.

As Parliament considers the future design of Support Coordination, it should ensure that reforms preserve the characteristics that distinguish Support Coordination from navigation services. Failure to do so risks creating a model that increasingly resembles Local Area Coordination in practice while losing the intensive coordination functions that many participants continue to rely upon to achieve meaningful outcomes.

Chapter 3 – The Risk of Replacing

Support Coordination with a Commissioned Navigation Model

Future Focus supports the Government’s objectives of improving quality, reducing fraud, strengthening safeguards and ensuring the long-term sustainability of the National Disability Insurance Scheme. These objectives are both necessary and appropriate. The NDIS is one of Australia’s most significant social policy investments and governments have a responsibility to ensure that public funds are spent effectively and that participants are protected from harm.

The question before Parliament is therefore not whether reform should occur. Reform is necessary. The question is whether the reforms proposed through the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 will strengthen the existing strengths of Support Coordination, or whether they risk fundamentally changing the nature of the service itself.

Throughout the explanatory materials accompanying the Bill, there is a strong emphasis on consistency, sustainability, integrity, commissioning, market stewardship and improved oversight. These are all legitimate policy objectives. However, they are also characteristics commonly associated with commissioned navigation systems and government-managed service models. What is less apparent throughout the reform framework is how the characteristics that have historically distinguished Support Coordination from navigation services will be preserved.

This distinction is critically important because the effectiveness of Support Coordination has never been derived solely from its ability to connect participants with services. Rather, its value has emerged from its ability to operate as an independent, participant-focused, safeguarding and implementation function within an increasingly complex disability ecosystem. The concern raised by Future Focus is that the proposed reforms may unintentionally preserve the appearance of Support Coordination while gradually replacing many of the functions that make it effective.

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Commissioning, Market Concentration and the Loss of Local Expertise

One of the most significant risks associated with any commissioned service model is the gradual concentration of service delivery within a smaller number of providers. This outcome is not unique to disability services. It has occurred repeatedly across government-funded sectors including employment services, aged care, vocational education and community services.

Commissioning frameworks are generally designed to achieve consistency, accountability and administrative efficiency. In doing so, they inevitably reward certain organisational characteristics. Providers that possess dedicated tender-writing teams, sophisticated compliance systems, substantial financial reserves and large administrative infrastructures are naturally better positioned to compete within procurement environments than smaller providers. While these characteristics may indicate organisational capacity, they do not necessarily indicate better participant outcomes.

This distinction is particularly important within Support Coordination because some of the sector’s greatest strengths are found within small and medium-sized providers operating within specific communities, regions or specialist practice areas. These organisations frequently possess deep local knowledge, established relationships with community services, extensive understanding of local provider markets and longstanding relationships with participants and families. Their effectiveness is often derived from community embeddedness rather than organisational scale.

The NDIS was deliberately designed around the concept of market diversity. Choice and control were not intended to be exercised between a small number of large government-selected providers. Rather, participants were expected to benefit from access to a diverse marketplace capable of responding to different needs, cultural backgrounds, geographic locations and levels of complexity. The success of Support Coordination has been heavily influenced by this diversity. Across Australia, participants have been able to engage providers with expertise in psychosocial disability, justice involvement, housing pathways, acquired brain

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

injury, culturally and linguistically diverse communities, First Nations communities and numerous other specialist practice areas.

A commissioning framework that unintentionally favours organisational scale over local expertise risks undermining these strengths. The Committee should be particularly mindful that market diversity, once lost, is often difficult to rebuild. Smaller providers that exit the market as a consequence of procurement outcomes may not have the financial capacity to return. The long-term result can be a market that is administratively simpler but less responsive to participant needs.

This concern is particularly relevant in regional and remote communities. Many of the most effective Support Coordinators operating in these communities have spent years building relationships with local hospitals, housing providers, behavioural practitioners, justice agencies, community organisations and informal support networks. These relationships cannot be replicated through a procurement process. A provider may successfully win a contract to operate within a region while possessing little of the local intelligence and trust that currently supports participant outcomes.

The Committee should therefore consider whether commissioning arrangements are being designed to preserve diversity, local expertise and specialist capability, or whether they may unintentionally create incentives for market consolidation. While the latter may improve administrative simplicity, there is limited evidence that it will improve participant outcomes.

The Risk of Transforming Support Coordination into a Navigation Function

The greatest concern arising from the proposed reforms is not market concentration alone. It is the possibility that the fundamental nature of Support Coordination may change.

As discussed in Chapter 2, the evidence generated through Local Area Coordination demonstrates that navigation services perform an important role within the disability ecosystem. They assist participants to access information, connect with services and engage with their communities. However, navigation services were never intended to perform the same role as Support Coordination.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

Support Coordination evolved because participants required assistance beyond information and referral. Participants with complex circumstances often require intensive support to implement plans, coordinate multiple systems, manage risk and respond to crises. They require assistance when providers fail, when housing arrangements collapse, when hospital discharges break down, when safeguarding concerns emerge or when multiple systems are unable to work together effectively. These functions are fundamentally different from navigation.

Yet many of the characteristics emphasised within the reform agenda—consistency, standardisation, commissioning, panel management and market stewardship—align more closely with navigation models than with intensive coordination models. This is not necessarily problematic in itself. However, it raises an important question that the Committee should carefully consider:

“What will distinguish the future commissioned Support Coordination model from Local Area Coordination?”

This question becomes increasingly important when examining the findings of the NDIS Review. Despite more than a decade of Local Area Coordination, participants continue to report difficulties navigating the Scheme, implementing plans and coordinating services. Navigation remains one of the most significant challenges identified throughout the Review process. The evidence therefore suggests that navigation alone has not resolved these challenges.

If the response to these findings is to reshape Support Coordination into a service that increasingly resembles navigation, there is a risk that the system simply recreates the same limitations under a different name.

The distinction between the two functions can be observed in everyday practice. A Local Area Coordinator may help a participant identify a service. A Support Coordinator may spend months coordinating housing providers, behavioural practitioners, support workers, hospital clinicians, guardians and justice agencies to ensure that a participant can safely access that service. A Local Area Coordinator may provide information about available supports. A Support Coordinator may intervene when those supports collapse, identify safeguarding risks, report provider misconduct and coordinate an urgent response to prevent homelessness or hospitalisation. These functions are absolutely not interchangeable.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

The concern is that the characteristics that make Support Coordination effective independence, flexibility, safeguarding capability, participant advocacy and intensive implementation support are difficult to standardise within commissioned service models. They are relational functions rather than transactional functions. They depend upon professional judgement, local knowledge and the ability to respond to complexity in ways that cannot always be prescribed through service specifications or procurement frameworks.

If these functions are not explicitly protected through the reform process, there is a genuine risk that they gradually diminish over time. The service may continue to be called Support Coordination, but its practical role may increasingly resemble navigation rather than coordination.

Why Regulation, Not Replacement, Better Achieves the Objectives of the Bill

The Government has identified genuine challenges within the Support Coordination sector. Concerns regarding quality, governance, conflicts of interest and inconsistent practice are legitimate and should not be dismissed. Future Focus agrees that stronger safeguards are required.

However, the existence of these challenges does not necessarily support the conclusion that Support Coordination should be fundamentally redesigned through commissioning arrangements. Many of the concerns identified by Government are more directly addressed through stronger regulation than through market restructuring.

For example, concerns regarding inconsistent quality can be addressed through registration, workforce standards, supervision requirements and outcome measurement. Concerns regarding conflicts of interest can be addressed through stronger governance requirements, disclosure obligations and enforcement mechanisms. Concerns regarding safeguarding can be addressed through mandatory reporting obligations, quality standards and stronger oversight by the NDIS Commission.

Importantly, these reforms preserve the characteristics that currently contribute to participant outcomes while addressing legitimate concerns regarding quality and accountability.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

This approach is also more consistent with the findings of the Disability Royal Commission, which repeatedly emphasised the importance of strengthening safeguards, improving accountability and increasing oversight of disability services. The Royal Commission did not conclude that participant safety would be improved through reducing independence, reducing participant choice or concentrating service delivery among fewer providers. Rather, it consistently focused on improving the quality and accountability of existing supports.

Similarly, the NDIS Review identified the need for a stronger and more coherent navigation ecosystem, but did not conclude that intensive coordination functions were no longer required. Indeed, many of the challenges identified throughout the Review reinforce the continuing need for skilled professionals capable of assisting participants to navigate complexity.

The Committee should therefore carefully consider whether the objectives of the Bill are best achieved through replacing key characteristics of the current Support Coordination model, or whether they can be achieved through stronger regulation of those characteristics. Future Focus submits that the available evidence strongly supports the latter.

Conclusion

The Committee is not being asked to choose between reform and the status quo. The Committee is being asked to determine what form of reform is most likely to improve participant outcomes while supporting the long-term sustainability of the NDIS. Future Focus supports stronger regulation, stronger governance, stronger safeguards and greater accountability. These reforms are necessary and should be implemented.

However, the available evidence does not demonstrate that participant outcomes will improve if Support Coordination becomes increasingly standardised, procurement-driven and focused on navigation rather than coordination. Nor does the evidence demonstrate that market concentration, reduced provider diversity or diminished independence will improve outcomes for participants with complex support needs.

The greatest strengths of Support Coordination are its independence, flexibility, safeguarding capability, local expertise and ability to respond to complexity. These characteristics should be viewed as assets to be strengthened rather than

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

obstacles to reform. As Parliament considers the future of Support Coordination, the central objective should be to improve quality without losing the features that make the service effective. The future of the NDIS will not be secured by creating a larger version of Local Area Coordination. It will be secured by ensuring that participants continue to have access to skilled, independent and locally connected professionals capable of translating plans into meaningful outcomes.

Chapter 4 – Why Provider Diversity Matters

One of the defining features of the National Disability Insurance Scheme is that it was deliberately designed around participant choice and control. Unlike previous block-funded disability systems, participants were intended to have the ability to choose who supports them, how supports are delivered and which providers best align with their individual circumstances.

This principle was not simply a philosophical preference. It reflected an understanding that disability is not a uniform experience and that no single provider model can effectively meet the needs of every participant.

As Parliament considers reforms that may reshape the Support Coordination market through commissioning arrangements and panel-based delivery models, it is important to recognise that provider diversity is not merely a market characteristic. It is a fundamental mechanism through which participants exercise choice and control.

The future success of Support Coordination should not be measured by how many providers remain in the market, but by whether participants continue to have access to providers that possess the expertise, relationships and local knowledge required to meet their individual needs.

The NDIS Was Designed Around Diversity

The NDIS was established on the premise that participants achieve better outcomes when they are able to make informed decisions regarding the supports they receive. Embedded within this principle is the recognition that participants have different goals, different support needs, different cultural backgrounds and different definitions of what constitutes a good outcome. For this reason, the NDIS market has evolved into a diverse ecosystem of providers operating at different scales and with different areas of expertise. Some providers specialise in psychosocial disability. Others focus on acquired brain injury, forensic disability, complex behavioural support, housing pathways, First Nations communities or culturally and linguistically diverse participants. Some operate nationally while others operate within a single town or region. This diversity is not evidence of market inefficiency. It is evidence that providers have developed expertise in response to the differing needs of participants. The Committee should therefore be cautious about reforms that unintentionally reduce provider diversity in pursuit of administrative simplicity. A simpler market is not necessarily a better market if participants lose access to providers that understand their circumstances.

Diversity Improves Participant Outcomes

Participants with disability are not a homogenous group. A participant living with psychosocial disability in regional Victoria may require a very different Support Coordinator from a participant exiting hospital into Specialist Disability Accommodation in metropolitan Brisbane. Similarly, a participant involved with child protection, family violence services or the justice system may require specialist expertise that is not available through a generalist provider model.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

The strength of the current Support Coordination market is that participants can often access providers who possess expertise relevant to their specific circumstances.

In practice, this means participants are able to engage Support Coordinators who understand:

• psychosocial disability;
• acquired brain injury;
• forensic disability;
• housing and homelessness pathways;
• child protection systems;
• family violence systems;
• mental health systems;
• culturally specific service systems;
• First Nations communities; and
• local provider markets.

These forms of expertise are difficult to replicate through standardised service models. The Committee should recognise that provider diversity is often the mechanism through which specialist expertise is delivered. Reducing diversity may therefore reduce participant access to specialised knowledge and support.

Diversity Strengthens Safeguarding

Provider diversity is also an important safeguarding mechanism for the Scheme and its participants. A diverse market allows participants to change providers when relationships break down, when safeguarding concerns arise or when services fail to meet expectations. This ability to leave one provider and engage another is one of the most important protections available within a market-based system.

Where markets become concentrated, participants often have fewer alternatives available to them. This is particularly problematic in regional and remote communities where service options may already be limited. Support Coordinators themselves frequently assist participants to leave unsuitable service arrangements, identify alternative providers and rebuild support networks following service breakdown. This function becomes substantially more difficult when participants have fewer options available.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

The Committee should therefore consider market diversity not only through the lens of competition, but also through the lens of participant safety and safeguarding. A participant’s ability to choose an alternative provider is often one of the most effective protections against poor service quality and provider misconduct.

The Importance of Local and Community-Based Providers

One of the greatest strengths of the current Support Coordination market is the presence of providers that are deeply embedded within their local communities. These organisations frequently possess extensive knowledge of local service systems, community resources and informal networks. They often maintain long-standing relationships with housing providers, hospitals, mental health services, behavioural practitioners, schools, justice agencies and community organisations.

This knowledge cannot easily be documented within a tender response or transferred through a procurement process. It is developed through years of engagement within a community. Importantly, local providers often continue supporting participants through periods of significant instability because they possess relationships that extend beyond individual service transactions.

The Committee should recognise that local expertise is not simply a function of geographic presence. It is the product of long-term community engagement, trust and relationship-building. Any future commissioning model should therefore be designed to preserve these strengths rather than assuming they will automatically survive market restructuring.

Why Governance Matters More Than Provider Size

Discussions regarding market reform often create a false distinction between large providers and small providers. In practice, organisational size is a poor indicator of service quality. Large providers can deliver excellent outcomes. Small providers can deliver excellent outcomes. Equally, both large and small providers can perform poorly. The characteristic most closely associated with quality is not organisational size but governance.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

Participants benefit when providers operate within systems that include:

• clinical supervision;
• quality assurance;
• incident reporting;
• safeguarding frameworks;
• workforce development;
• professional accountability;
• risk management processes; and
• transparent governance structures. The Committee should therefore focus on how reforms can strengthen governance across the sector rather than how they can reduce the number of providers operating within it. If the objective is quality improvement, governance is the appropriate target for reform. If the objective is participant outcomes, provider diversity should be preserved wherever possible.

Preserving Diversity Within Any Future Commissioning Model

Future Focus acknowledges that Government may ultimately determine that some form of commissioning arrangement is required. If this occurs, the Committee should ensure that provider diversity is explicitly protected within the design of the model. This should include consideration of mechanisms that preserve:

• regional providers;
• specialist providers;
• First Nations providers;
• culturally specific providers;
• medium-sized providers;
• community-based providers; and
• providers with demonstrated expertise supporting participants with complexity. Without deliberate safeguards, procurement systems naturally favour larger organisations capable of absorbing administrative burden and commercial risk.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

The Committee should ensure that any future model preserves participant access to diverse provider options rather than unintentionally creating barriers to participation for smaller specialist organisations.

Conclusion

Provider diversity is not simply a feature of the Support Coordination market. It is one of the mechanisms through which participant choice and control is exercised. The current market contains providers of different sizes, operating within different communities and possessing different forms of expertise. This diversity allows participants to access support that is tailored to their individual circumstances and provides an important safeguard against service failure and provider misconduct.

As Parliament considers reforms to Support Coordination, it should recognise that market diversity and participant outcomes are closely connected. Reforms that unintentionally reduce diversity may also reduce participant choice, specialist expertise and safeguarding capacity.

The objective of reform should therefore not be to create a smaller market. The objective should be to create a stronger market—one that combines robust governance and accountability with the diversity and local expertise that participants continue to rely upon to achieve meaningful outcomes.

Section 5 – Good Governance Should Be Strengthened, Not Replaced

A recurring theme throughout the reform agenda is the desire to improve quality, consistency and accountability across the Support Coordination sector. Future Focus strongly supports these objectives. The current market contains examples of excellent practice as well as examples of poor practice. There are providers that operate within robust governance frameworks and there are providers that operate with minimal oversight. There are organisations investing heavily in workforce development, supervision and safeguarding, and there are organisations that do not.

These inconsistencies are a legitimate concern and should be addressed. However, there is an important distinction between addressing weaknesses in governance and restructuring an entire market. The evidence suggests that participant outcomes are primarily influenced by the quality of governance surrounding service delivery rather than the size of the organisation delivering the service. The central question for Parliament is therefore whether the objectives of quality improvement, fraud reduction and safeguarding are best achieved through stronger governance requirements or through the replacement of

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission 812

The Quality Problem is a Governance Problem

Concerns regarding Support Coordination have often focused on inconsistent service quality, conflicts of interest, poor documentation, inadequate participant engagement and variable workforce capability. These concerns should not be dismissed. However, it is important to recognise that these issues are not unique to Support Coordination. Similar concerns have existed across disability services, aged care, health care, child protection, employment services and numerous other human service systems.

The common factor across these sectors is that poor outcomes are rarely caused by organisational size. They are usually caused by weak governance. When serious failures occur, investigations commonly identify:

• inadequate supervision;
• poor escalation pathways;
• insufficient training;
• weak incident management;
• lack of quality assurance;
• poor record keeping;
• inadequate risk management; or
• ineffective organisational oversight.

Importantly, they can occur within both large and small organisations. The implication for policymakers is significant. If the problem is governance, then governance should be the focus of reform. Replacing providers does not automatically improve governance but strengthening governance requirements does.

What Good Governance Looks Like in Support Coordination

Support Coordination has evolved considerably since the early years of the NDIS. Many providers now operate within governance frameworks that closely resemble those found in other professional human service sectors. These frameworks commonly include structured supervision, clinical consultation

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

pathways, incident reporting systems, safeguarding frameworks, and internal auditing.

These systems exist because Support Coordination increasingly involves participants experiencing significant complexity and risk. Support Coordinators regularly encounter circumstances involving homelessness, abuse, neglect, mental health crises, restrictive practices, behavioural risks, justice involvement and provider misconduct. Effective management of these situations requires organisational support structures that extend far beyond the actions of an individual practitioner.

Good governance provides participants with protections that are often invisible when services are functioning well. It ensures that concerns are escalated appropriately, risks are identified early and staff have access to support when managing complex situations. These are precisely the types of safeguards that reforms should seek to strengthen.

Governance is a Participant Safeguard

Governance is frequently discussed as an organisational responsibility. However, its primary purpose is participant protection. Participants are often unaware of the systems operating behind the scenes when they engage a Support Coordinator. They may not see supervision sessions, audit processes, incident reviews or risk meetings. Nevertheless, these processes frequently determine whether emerging concerns are identified and addressed before harm occurs.

Strong governance creates multiple layers of protection around participants. For example, where a participant is experiencing provider misconduct, financial exploitation or escalating safeguarding risks, a well-governed organisation provides avenues for escalation, consultation and independent review. The issue is not left solely to the judgement of an individual worker. Similarly, where participants are involved with multiple systems including health, housing, justice and disability services, governance structures help ensure that risks are documented, monitored and acted upon consistently.

These protections become particularly important for participants who may lack the capacity, confidence or support networks required to advocate for themselves. The Committee should therefore recognise governance not merely as a compliance issue but as a participant safeguarding mechanism.

Lessons from the Disability Royal Commission

The findings of the Disability Royal Commission provide important guidance regarding the future direction of reform. Throughout the Royal Commission, failures were repeatedly linked to inadequate oversight, weak safeguarding systems, poor accountability and ineffective responses to participant risk. The Commission consistently emphasised the need for stronger quality systems, stronger safeguards and greater accountability across disability services.

Importantly, the Commission’s recommendations did not suggest that participant safety would be achieved through reducing provider diversity or concentrating service delivery within fewer organisations. Instead, the focus was on improving quality across the sector. The lessons arising from the Royal Commission are therefore highly relevant to Support Coordination. If the objective is to reduce abuse, neglect, exploitation and service failure, the evidence suggests that stronger governance arrangements are likely to be more effective than market consolidation alone. This distinction is important because governance improvements can be implemented while preserving participant choice, local expertise and provider diversity.

Strengthening Governance Without Losing What Works

One of the strengths of the current reform agenda is its recognition that quality and accountability must improve. Future Focus supports reforms that strengthen:

• registration requirements;
• workforce capability;
• safeguarding obligations;
• supervision standards;
• conflict of interest management;
• outcome measurement;
• incident reporting; and
• regulatory oversight. These reforms directly address many of the concerns identified by Government, the NDIS Review and the Disability Royal Commission. Importantly, they can be implemented without fundamentally changing the participant-facing features of Support Coordination that currently contribute to positive outcomes. Participants do not benefit from governance in isolation. They benefit when governance exists

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

alongside trusted relationships, local expertise, participant choice and independent advocacy.

The challenge for policymakers is therefore not simply to increase accountability. It is to increase accountability without diminishing the qualities that participants value most. A regulatory framework that strengthens governance while preserving participant choice is likely to achieve better outcomes than one that improves consistency at the expense of diversity and independence.

Conclusion

The evidence suggests that many of the challenges identified within the Support Coordination sector are governance challenges rather than market structure challenges. Concerns regarding quality, safeguarding, fraud and accountability should be addressed. However, the most effective response is likely to be stronger governance requirements rather than the replacement of existing market characteristics.

The Committee should be cautious about treating organisational size, commissioning arrangements or market concentration as proxies for quality. There is limited evidence that these factors alone improve participant outcomes. By contrast, there is strong evidence that supervision, safeguarding systems, professional accountability, risk management and organisational oversight contribute to safer and more effective service delivery.

The future of Support Coordination should therefore be built upon stronger governance, not fewer providers. Reform should focus on strengthening the systems that protect participants while preserving the diversity, independence and local expertise that remain central to participant choice and control.

Chapter 6 Support Coordination as an Investment in Participant Outcomes and Scheme Sustainability

Much of the discussion surrounding Support Coordination has focused on its cost to the National Disability Insurance Scheme. This focus is understandable. As governments seek to improve the long-term sustainability of the Scheme, all funded supports should be subject to scrutiny and there is a legitimate public interest in ensuring that taxpayer funds are used effectively.

However, there is a significant risk in assessing Support Coordination solely through the lens of direct expenditure. Unlike many funded supports, Support Coordination is not intended merely to deliver a service to a participant. Its primary function is to ensure that the broader network of supports surrounding a participant functions effectively. The value generated by Support Coordination therefore extends beyond the hours directly delivered to a participant and is often reflected in outcomes that are difficult to measure through traditional funding metrics.

The central policy question is not whether Support Coordination costs money. Clearly it does. The more important question is whether the outcomes generated by effective Support Coordination outweigh the cost of providing it. Future Focus submits that this is the more appropriate framework through which the Committee should assess the future role of Support Coordination within the NDIS.

The Cost of Complexity

The NDIS increasingly supports participants with highly complex circumstances. Many participants engage not only with disability services but also with housing systems, mental health services, hospitals, justice agencies, family violence services, child protection systems, mainstream community organisations and informal support networks.

The challenge for these participants is rarely the absence of services alone. More often, it is the difficulty of ensuring that multiple services operate effectively together.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

When systems fail to coordinate, the consequences can be significant. Participants may experience avoidable hospital admissions, housing instability, homelessness, mental health crises, service breakdown, safeguarding concerns or involvement with emergency and statutory services. These outcomes are not only harmful for participants but are often substantially more expensive than preventative intervention.

One of the defining characteristics of Support Coordination is that it operates across these systems rather than within a single service. Support Coordinators are frequently responsible for bringing together providers, families, clinicians, government agencies and community supports to ensure that participants receive coordinated and effective assistance. While this work can be difficult to quantify, it is often the difference between a participant maintaining stability and a participant entering crisis.

This distinction is important because the cost of complexity does not disappear if Support Coordination is reduced. Rather, the burden is frequently transferred elsewhere. The question is not whether these needs will continue to exist, but which part of the broader service system will ultimately absorb them.

The Value of Prevention

One of the challenges in evaluating Support Coordination is that many of its most significant contributions are preventative. The success of a Support Coordinator is often measured by events that do not occur. A participant who remains safely housed does not require emergency accommodation. A participant whose support network remains stable may avoid hospitalisation. A participant who receives assistance resolving service issues early may avoid crisis intervention, safeguarding investigations or prolonged periods without support.

These outcomes rarely appear in expenditure reports because they are costs that have been avoided rather than costs that have been incurred. Yet from a public policy perspective, preventative outcomes are often among the most valuable outcomes a system can generate. This issue is not unique to disability services. Health systems invest in preventative care because preventing illness is often more effective and less expensive than treating illness after it occurs. Child protection systems invest in early intervention because preventing family

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

breakdown is generally preferable to responding after harm has occurred. The same principle applies within disability services.

Support Coordination is one of the few supports within the NDIS specifically positioned to identify emerging risks before they escalate. Through ongoing engagement with participants, families and service providers, Support Coordinators are often able to recognise early indicators of service failure, housing instability, carer fatigue, provider misconduct or safeguarding concerns. Addressing these issues early can prevent significantly more complex and costly interventions later.

Support Coordination and Scheme Integrity

The sustainability objectives underpinning this Bill are frequently discussed in financial terms. However, financial sustainability is influenced not only by the amount of money spent, but also by how effectively that money is used.

In practice, Support Coordinators play a significant and largely unrecognised role in protecting the integrity of participant funding. Because they work across multiple providers and maintain oversight of a participant’s broader support arrangements, Support Coordinators are often among the first professionals to identify circumstances where services are not delivering intended outcomes. They frequently assist participants to understand service agreements, review provider arrangements, question unnecessary expenditure and identify situations where services may be inconsistent with participant goals or funding intentions.

Support Coordinators also regularly encounter situations involving provider conflicts of interest, duplicate service arrangements, inappropriate charging practices or services that are being delivered in ways that do not reflect participant needs. In many cases, they assist participants to transition to alternative providers, renegotiate service arrangements or escalate concerns to appropriate authorities.

This contribution to scheme integrity is rarely acknowledged within discussions regarding the cost of Support Coordination. Yet it directly supports many of the objectives that underpin the current reform agenda. A participant who is supported to make informed decisions regarding providers is less vulnerable to exploitation and more likely to achieve value from their plan funding.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

The Committee should therefore consider whether Support Coordination contributes not only to participant outcomes, but also to the effective stewardship of public resources.

Lessons from International Evidence

Australia is not unique in confronting the challenges associated with coordinating complex disability and human service systems. Internationally, governments have invested heavily in various forms of case management, care coordination, navigation and key worker models in recognition of the fact that participants with complex needs often require assistance that extends beyond direct service delivery.

While these models differ considerably in design, a consistent theme emerges from the literature. Participants experiencing complexity generally achieve better outcomes when a skilled professional assists them to coordinate supports across multiple systems.

The benefits identified through international research extend beyond participant satisfaction. Studies have reported improvements in housing stability, increased engagement with services, reduced crisis presentations and better coordination between agencies. Importantly, governments have generally responded to increasing complexity by strengthening coordination functions rather than reducing them.

The international debate is therefore not whether coordination should exist. The debate is how coordination should be governed, regulated and funded. This distinction is particularly relevant to the Committee’s consideration of the Bill. The evidence suggests that the challenge facing Australia is not whether Support Coordination remains necessary, but how to ensure that it operates effectively and consistently into the future.

Sustainability Requires More Than Cost Reduction

Throughout discussions regarding NDIS reform, sustainability is often framed as a question of expenditure control. While expenditure management is undoubtedly important, sustainability is ultimately about ensuring that the Scheme continues to achieve its intended outcomes over the long term.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

A system that reduces expenditure in one area while generating greater costs elsewhere cannot necessarily be described as sustainable.

The Committee should therefore consider the broader consequences of reducing the effectiveness of Support Coordination. If participants are less able to navigate services, identify risks, coordinate providers and maintain stable support arrangements, the resulting pressures are unlikely to disappear. Instead, they may emerge within hospitals, homelessness services, mental health systems, safeguarding agencies, justice systems and informal family support networks.

Similarly, if participants are less able to identify poor-quality providers or inappropriate expenditure, efforts to strengthen scheme integrity may be undermined rather than enhanced. A sustainable NDIS requires more than efficient administration. It requires participants to have access to the supports necessary to achieve stable, safe and effective outcomes. Support Coordination contributes directly to these objectives. The Committee should therefore be cautious about viewing Support Coordination solely as a cost centre. Its contribution to sustainability extends beyond expenditure and includes prevention, safeguarding, coordination and scheme integrity.

Conclusion

The future sustainability of the NDIS is a legitimate and important policy objective. However, sustainability should not be measured solely by reductions in individual budget categories.

Support Coordination exists because the disability ecosystem is complex. Its role is to help participants navigate that complexity, coordinate multiple systems and achieve outcomes that would often be difficult to achieve independently.

Much of the value generated by Support Coordination is preventative in nature. It is reflected in crises avoided, risks identified, service failures resolved and participant outcomes achieved. It is also reflected in the contribution Support Coordinators make to safeguarding participants and supporting the responsible use of public funds.

The evidence suggests that effective coordination should be viewed not merely as an expenditure, but as an investment in participant outcomes, scheme integrity and long-term sustainability. As Parliament considers reforms to the NDIS,

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

it should ensure that efforts to improve sustainability do not inadvertently weaken one of the very mechanisms that helps participants achieve stable and effective outcomes within the Scheme.

Chapter 7 – Recommendations to the Committee

Future Focus acknowledges the need for reform within the National Disability Insurance Scheme and supports measures intended to improve quality, safeguarding, integrity and long-term sustainability. The recommendations below are intended to assist Parliament in achieving these objectives while preserving participant choice, local expertise and the safeguarding functions currently performed by Support Coordination.

Recommendation 1: Preserve Participant Choice of Support Coordinator

The Committee should recommend that participants retain genuine choice regarding who provides Support Coordination services, regardless of any future commissioning or panel arrangements.

The principles of choice and control underpin the NDIS. Participants should not be restricted to a narrow range of government-selected providers where alternative providers are available and capable of meeting participant needs.

Any future commissioning model should be designed to expand participant access to quality services rather than limiting provider choice.

Recommendation 2: Recognise Support Coordination as a Safeguarding Function

The Committee should recommend that Support Coordination be formally recognised as a participant safeguarding function within future reform design.

Support Coordinators routinely identify abuse, neglect, exploitation, provider misconduct, housing instability, service breakdown and emerging participant risks. These functions extend well beyond navigation and should be explicitly recognised within future policy frameworks.

Any commissioned model should demonstrate how safeguarding functions will be preserved and strengthened.

Recommendation 3: Protect Provider Diversity Within Any Commissioned Model

The Committee should recommend that any future panel or commissioning arrangements include explicit mechanisms to preserve provider diversity. This should include protections for:

• regional providers;
• specialist providers;
• community-based providers;
• First Nations providers;
• culturally specific providers; and
• providers supporting participants with complex needs. The Committee should recognise that participant outcomes are strengthened when participants have access to providers with differing expertise, perspectives and local knowledge.

Recommendation 4: Prioritise Governance Standards Over Organisational Size

The Committee should recommend that future quality frameworks focus on governance capability rather than organisational scale. Quality should be assessed through demonstrated governance systems, supervision structures, safeguarding frameworks, workforce capability and accountability mechanisms rather than assumptions regarding provider size. There is limited evidence that larger organisations consistently produce better participant outcomes. There is strong evidence that stronger governance improves service quality.

Recommendation 5: Maintain Independent Coordination Functions

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

The Committee should recommend that future reforms preserve the independence of Support Coordination from funding decisions, service delivery conflicts and government decision-making processes.

Participants often rely upon Support Coordinators to challenge poor service delivery, identify risks and advocate when systems fail.

These functions depend upon participant trust and perceived independence.

The effectiveness of Support Coordination may be reduced if participants no longer view coordinators as independent advocates operating in their interests.

Recommendation 6: Preserve Intensive Coordination for Participants with Complexity

The Committee should recommend that participants with significant complexity, safeguarding risks or multi-system involvement retain access to intensive coordination supports.

The evidence presented to the NDIS Review, Disability Royal Commission and international literature consistently demonstrates that participants experiencing complexity require more than navigation alone.

Any future model should clearly distinguish between navigation functions and intensive coordination functions.

Recommendation 7: Undertake Independent Evaluation Before Significant Market Restructuring

The Committee should recommend that any substantial commissioning or panel-based reforms be subject to independent evaluation prior to national implementation.

This evaluation should examine:

• participant outcomes;
• participant satisfaction;
• safeguarding outcomes;

• provider diversity;
• regional impacts;
• market concentration;
• workforce impacts; and
• long-term scheme sustainability. Reforms should be guided by evidence of participant outcomes rather than assumptions regarding administrative efficiency.

Recommendation 8: Strengthen Regulation Rather Than Replace Effective Market Features The Committee should recommend continued development of stronger regulatory frameworks for Support Coordination, including registration requirements, workforce standards, supervision expectations, safeguarding obligations and conflict of interest management.

The evidence suggests that many of the challenges identified within the sector are governance issues rather than evidence that the Support Coordination model itself is ineffective.

The objective of reform should therefore be to strengthen quality and accountability while preserving the participant-focused features that currently contribute to positive outcomes.

Recommendation 9: Require Outcome-Based Evaluation of Support Coordination The Committee should recommend the development of nationally consistent outcome measures for Support Coordination.

Future policy decisions should be informed by evidence regarding participant outcomes, safeguarding outcomes, housing stability, service engagement and participant wellbeing rather than focusing solely on expenditure measures.

A stronger evidence base will support future policy development and provide greater confidence regarding the value generated by Support Coordination.

Recommendation 10: Ensure Reform Preserves the Distinction Between Navigation and Coordination

The Committee should recommend that future reforms explicitly preserve the distinction between navigation services and Support Coordination.

The evidence reviewed throughout this submission demonstrates that these functions perform different roles within the disability ecosystem.

Navigation services assist participants to access information, community connection and mainstream supports.

Support Coordination assists participants to implement plans, coordinate services, manage risk and achieve outcomes.

Future reforms should strengthen both functions while avoiding the unintended consequence of transforming Support Coordination into a standardised navigation service.

Closing Recommendation

Future Focus respectfully submits that the most effective path forward is not the replacement of Support Coordination, but its evolution into a more consistently regulated, professionally governed and evidence-informed service.

The Committee should ensure that reforms preserve participant choice, provider diversity, local expertise, safeguarding capability and independent advocacy while strengthening accountability and quality across the sector.

In doing so, Parliament can improve the sustainability of the NDIS without sacrificing the participant outcomes that the Scheme was designed to achieve.

Submission 812

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Chapter 8 – Conclusion

The National Disability Insurance Scheme has transformed the lives of hundreds of thousands of Australians with disability by providing greater choice, control and access to supports. The objectives underpinning the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 are therefore both understandable and necessary. Future Focus supports the Government’s commitment to strengthening safeguards, improving quality, reducing fraud and ensuring the long-term sustainability of the Scheme.

The evidence presented throughout this submission demonstrates, however, that sustainability should not be pursued at the expense of participant outcomes. The long-term success of the NDIS depends not only on controlling expenditure, but on ensuring that participants can effectively access, implement and benefit from the supports available to them.

Support Coordination exists because the disability ecosystem is inherently complex. For many participants, particularly those experiencing psychosocial disability, housing instability, justice involvement, safeguarding risks, behavioural complexity or limited informal supports, choice and control cannot be meaningfully exercised without assistance. Funding alone does not produce outcomes. Outcomes are achieved when participants are able to navigate systems, coordinate supports, manage risk and translate plans into practical improvements in their lives.

The evidence from the NDIS Review, the Disability Royal Commission, international case management literature and the experience of the NDIS itself consistently demonstrates that participants with complexity require more than information and referral. They require skilled, independent and relationship-based support capable of coordinating multiple systems, identifying risks and responding when services fail.

This submission has highlighted a central concern regarding the proposed reform agenda. While the Bill seeks to strengthen quality and sustainability, there is a risk that the implementation of commissioning arrangements and panel-based delivery models could gradually reshape Support Coordination into a more standardised navigation service. In doing so, Parliament may inadvertently weaken many of the characteristics that currently make Support Coordination

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 812

The experience of Local Area Coordination demonstrates that local presence alone is insufficient to achieve participant outcomes. Similarly, the experience of other commissioned human service systems demonstrates that procurement efficiency and market consolidation do not automatically translate into better outcomes for the people those systems exist to serve. The Committee should therefore approach any future restructuring of Support Coordination with caution and ensure that reforms are guided by evidence of participant outcomes rather than assumptions regarding administrative efficiency.

Future Focus does not submit that Support Coordination should remain unchanged. The sector should continue to evolve. Stronger governance, registration requirements, workforce standards, safeguarding obligations and accountability mechanisms are both necessary and appropriate. Indeed, many of the concerns identified by Government, the NDIS Review and the Disability Royal Commission are most effectively addressed through stronger regulation rather than the replacement of the core characteristics of the current model.

The Committee has an opportunity to ensure that future reforms strengthen what already works. A sustainable and effective Support Coordination sector should be one that combines robust governance and accountability with provider diversity, participant choice, local knowledge and specialist expertise. These characteristics should not be viewed as obstacles to reform. They are among the sector’s greatest strengths and are central to the outcomes achieved by participants every day.

Ultimately, the future of the NDIS will not be secured simply by reducing expenditure or standardising service delivery. It will be secured by ensuring that participants continue to have access to the skilled, independent and locally connected professionals who help them navigate complexity, exercise genuine choice and control, remain safe, and achieve meaningful outcomes in their lives.

Future Focus respectfully urges the Committee to ensure that any future reforms preserve these functions and strengthen them through better regulation, stronger governance and evidence-based policy. In doing so, Parliament can improve the sustainability of the NDIS while remaining faithful to the principles upon which the Scheme was founded.