Risk of Artificial Separation of Disability and Mental Health (Provider experience)

Submission 838

Registered Psychologist

SUBMISSION TO THE AUSTRALIAN Gabby Bond Psychology

GOVERNMENT admin@gabbybondpsychology.com May 2026

NDIS Amendment (Securing the NDIS for Future Generations) Bill:

2026 Federal Budget

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Submission 838

Table of Contents

About the Author ………………………………………………………………………………………………………. 2

1. Executive Summary …………………………………………………………………………………………………. 3 1.1 Section 10 – Risk of Artificial Separation of Disability and Mental Health …………………………. 3 1.2 Section 34 – Functional Thresholds and Masking ……………………………………………………….. 3 1.3 Expanded Reassessment and Plan Variation Powers …………………………………………………… 4 1.4 Foreseeable Consequences ………………………………………………………………………………….. 4

1.5 Structural Concerns Requiring Resolution Before Implementation …………………………………. 4

1.6 Required Amendments ……………………………………………………………………………………….. 4 1.7 Preventable Harm and Systemic Cost Escalation in the Absence of Safeguards ………………….. 5

2. Introductory Statement ……………………………………………………………………………………………. 6

3. How the Bill’s Provisions Risk Harm to Autistic Participants ………………………………………………. 7 3a. Section 10 – Definition of “NDIS Supports” and the Risk of Artificial Separation ………………… 7 3b. Section 34 – Revised “Reasonable and Necessary” Criteria and Functional Threshold Risk …… 7 3c. Expanded Reassessment Powers and Disruption Risk ………………………………………………….. 7 3d. Framing of Reform and the Risk to Participants with Invisible or Fluctuating Disabilities ……… 8 3e. Significant Disability Prevalence and the Limits of Scheme Coverage ………………………………. 8 3f. Risk of Participants Being Redirected to Non-Affirming or Unwanted Interventions ……………. 8 Summary …………………………………………………………………………………………………………………. 8

4. Clinical Case Illustrations ………………………………………………………………………………………… 10 4a. Non-Speaking Autistic Adolescent with High Support Needs ……………………………………….. 10 4b. Client B: Primary School-Aged Autistic Child (PDA Profile) with ADHD and Severe Anxiety …. 10 4c. Client C: Late-Diagnosed Autistic Young Adult, Employed Part-Time ……………………………… 10 4d. Client D: Late-Diagnosed Older Autistic Adult ………………………………………………………….. 11 4e. Client E: Late-Adolescent Autistic Person with DID and Complex Co-Occurring Conditions …. 11 4f. Client F: Adult Participant with Complex PTSD and Multi-System Medical Comorbidity ……… 11 4g. Client G: Multiple Autistic Family Members – Interdependent Household ………………………. 11 Cross-Case Systemic Risk: Reduction of Core Support Worker Hours …………………………………….. 12

5. Conclusion ………………………………………………………………………………………………………….. 13 5a. Recommendations ……………………………………………………………………………………………. 14

6. Final Statement ……………………………………………………………………………………………………. 15 Appendix A: Code of Conduct Provisions Supporting ND-Affirming and Trauma-Informed Practice ………………………………………………………………………………………………………………… 16

7. Person-Centred, Respectful, and Culturally Safe Practice …………………………………………….. 16

8. Safe and Effective Care ……………………………………………………………………………………….. 16

9. Informed Consent and Supported Decision-Making ……………………………………………………. 16

10. Professional Competence …………………………………………………………………………………….. 16

11. Non-Discrimination and Equity ……………………………………………………………………………… 16 Appendix B: Annotated Reference List and Evidence Summary …………………………………… 17

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Submission 838

About the Author

This submission is prepared by , a Registered Psychologist and the Principal of Gabby Bond Psychology. My clinical practice is dedicated to providing client affirming in particular, neurodiversity-affirming and trauma-informed psychological support to NDIS participants across the lifespan, from early childhood through to older adulthood.

My professional standing and the evidence provided in this submission are informed by:

• Extensive Clinical Caseload: I work predominantly with autistic participants who meet NDIS access criteria on the basis of permanent and substantial functional impairment. This includes individuals with high support needs, non-speaking profiles, and complex co occurring medical and psychiatric conditions.

• Specialist Clinical Focus: My practice specialises in complex neurodevelopmental presentations, including the Pathological Demand Avoidance (PDA) profile, Dissociative Identity Disorder (DID), and the intersection of neurodivergence with Complex PTSD (C PTSD).

• Integrated Care Oversight: I regularly coordinate care for participants with multi-system medical comorbidities (including EDS, POTS, and metabolic disorders), providing me with a unique perspective on the functional inseparability of physical health, mental health, and disability.

• Frontline Crisis Prevention: A significant portion of my work involves developing psychological scaffolding that prevents hospitalisations, behavioural crises, and family unit breakdown. I have direct experience in the “preventative” value of NDIS supports in reducing long-term costs to the state health and welfare systems.

• Professional Advocacy: In accordance with the Psychology Board of Australia: Code of Conduct for Psychologists (2025), I have a professional obligation to advocate for the welfare of my clients and to highlight where systemic or legislative changes pose a foreseeable risk to participant safety and functional stability.

I hold no financial or personal conflicts of interest regarding this bill. This submission is provided as an independent clinical contribution to the inquiry, intended to ensure that the legislative reform process is informed by the lived realities of participants with complex, invisible, and fluctuating disabilities.

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1. Executive Summary This submission is provided by a registered psychologist specialising in neurodevelopmental conditions and working predominantly with autistic NDIS participants across the lifespan. It draws on direct clinical experience with participants who meet NDIS access criteria on the basis of permanent and substantial functional impairment.

This submission identifies three elements of the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 that present significant clinical and systemic risk when applied to autistic participants:

• Section 10 – Restrictive Definition of NDIS Supports
• Section 34 – Revised “Reasonable and Necessary” Criteria
• Expanded Reassessment and Plan Variation Powers 1.1 Section 10 – Risk of Artificial Separation of Disability and Mental Health

The narrowed definition of NDIS supports creates a significant risk that autism-informed psychological supports will be reclassified as “mainstream mental health treatment” where participants present with anxiety, trauma-related symptoms, emotional dysregulation, dissociation, or depression.

For autistic participants, these presentations are frequently inseparable from their neurodevelopmental disability. Anxiety may arise from sensory processing differences; trauma may result from lifelong social exclusion or repeated service failures; emotional dysregulation may reflect neurodevelopmental differences in stress response systems. Treating these as discrete “mental health conditions” rather than integrated aspects of disability creates an artificial distinction that is clinically unsound.

Reclassification to mainstream mental health care does not produce equivalent substitution. Under the Medicare Better Access framework, Mental Health Care Plans (MHCPs) are typically capped at 10 sessions per calendar year. For participants with complex neurodevelopmental disability and high support needs, 10 sessions is clinically insufficient to provide stabilisation, capacity building, and relapse prevention. Further:

• MHCP access requires a diagnosable mental health condition; not all disability-related distress meets those criteria.

• Gap fees for private psychology under Medicare frequently render services financially inaccessible for disability-affected households.

• MHCP-funded therapy is structured as time-limited symptom treatment, not long-term disability-related capacity building.

1.2 Section 34 – Functional Thresholds and Masking

The revised “reasonable and necessary” criteria place increased emphasis on observable functional capacity. This approach risks disadvantaging autistic individuals who mask impairments or maintain employment at significant internal cost. Clinical experience demonstrates that masking is associated with increased anxiety, depression, autistic burnout, and suicide risk. Removal of psychological capacity-building supports based on surface-level presentation alone would predictably increase psychiatric destabilisation, employment loss, and crisis service utilisation.

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1.3 Expanded Reassessment and Plan Variation Powers

For participants with permanent neurodevelopmental disabilities, repeated reassessment processes introduce instability. Continuity of therapeutic relationships is clinically protective. Disruption to established behavioural and regulatory supports is associated with escalation of self-injury, behavioural crises, carer burnout, and emergency presentations. Frequent reassessment without clear evidence of material change in permanent conditions risks creating administrative churn rather than improved outcomes.

1.4 Foreseeable Consequences

Across high, moderate, and lower apparent support needs, the foreseeable consequences of these provisions include:

• Increased behavioural and psychiatric crises.
• Greater reliance on emergency departments and inpatient units.
• School breakdown and family destabilisation.
• Elevated suicide risk in late-diagnosed and high-masking autistic adults.
• Cost shifting to already overburdened state-funded health and crisis systems.

1.5 Structural Concerns Requiring Resolution Before Implementation

Significant structural issues must be addressed before these provisions are operationalised:

• Medicare-funded MHCPs are capped and do not provide ongoing disability capacity-building support.

• Public mental health services are threshold-based and focused on acute risk, not long-term functional capacity.

• There is no evidence that mainstream services have been resourced or trained to deliver ND- affirming, trauma-informed, disability-integrated care at scale.

1.6 Required Amendments

In my professional opinion, the provisions examined in this submission should not proceed in their current form. At minimum, the following amendments are required:

• Amend Section 10 to explicitly protect neurodevelopmentally informed psychological capacity-building supports from reclassification solely because co-occurring mental health symptoms are present.

• Revise Section 34 to require that determinations explicitly account for masking, internalised distress, burnout, and documented suicide risk, rather than relying on observable presentation.

• Preserve funding flexibility for episodic and transition-based needs.

• Introduce safeguards limiting unnecessary reassessment for participants with permanent conditions unlikely to change.

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• Require demonstrated service equivalence prior to redirection to mainstream systems.
• Protect continuity of established therapeutic relationships as a clinical safety requirement. 1.7 Preventable Harm and Systemic Cost Escalation in the Absence of Safeguards

Failure to address these concerns will result in foreseeable and preventable harm to autistic NDIS participants. It will also generate increased long-term costs across health, housing, and welfare systems. Reform under the Securing the NDIS for Future Generations Bill 2026 should not proceed until integrated service capacity, funding adequacy, and continuity safeguards are demonstrably in place.

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2. Introductory Statement I am a registered psychologist in private practice, specialising in neurodevelopmental conditions. My clinical work is predominantly with autistic NDIS participants across the lifespan, including children, adolescents, adults, and older adults with complex and permanent impairments affecting multiple functional domains.

I practise in accordance with the Psychology Board of Australia Code of Conduct (2025), which requires evidence-based, culturally responsive, neurodiversity-affirming, and trauma-informed care. The Code also requires psychologists to take reasonable steps to advocate for client welfare where policy or systemic change creates foreseeable risk of harm. All NDIS participants I support meet access criteria on the basis of permanent and substantial functional impairment.

This submission raises serious concerns regarding three provisions of the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 (the Bill):

• The revised and restrictive definition of “NDIS supports” (s. 10);
• The amended “reasonable and necessary” criteria (s. 34);
• The expanded powers relating to reassessment of eligibility and supports. In their practical application to autistic participants, these provisions risk creating artificial separation between disability and mental health, destabilising established supports, and redirecting participants to mainstream systems that are not resourced, structured, or funded to provide equivalent neurodevelopmentally informed capacity-building intervention. The foreseeable harms include service discontinuity, escalation of behavioural and psychiatric crises, increased hospital utilisation, and elevated suicide risk. These outcomes do not represent reduced need; they represent displacement of cost and risk to already overstretched state-funded systems.

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3. How the Bill’s Provisions Risk Harm to Autistic Participants 3a. Section 10 – Definition of “NDIS Supports” and the Risk of Artificial Separation

Section 10 of the NDIS Amendment Bill 2026 introduces a revised and more prescriptive definition of “NDIS supports,” supported by lists specifying what may and may not be funded. The stated intention is to confine NDIS funding to supports directly attributable to the primary impairment and to redirect other needs to mainstream systems.

In application to autistic participants, this creates risk where psychological supports address anxiety, trauma-related symptoms, emotional dysregulation, burnout, or depression. For many autistic individuals, these presentations are not incidental or independent “mental health conditions.” They are functionally intertwined with sensory processing differences, communication impairments, executive functioning limitations, cumulative trauma, and chronic environmental mismatch. Peer reviewed literature (e.g., Lai et al., 2019; Michelini et al., 2024) demonstrates high rates of psychiatric co-occurrence and shared mechanisms across neurodevelopmental and psychiatric presentations. Psychological interventions for autistic participants target functional capacity across NDIS domains: emotional regulation, adaptive coping, and social communication. These are disability-related capacity-building supports.

Reclassification of such supports as “mainstream mental health treatment” under Section 10 would not create equivalent substitution. Medicare-funded Mental Health Care Plans are capped (generally 10 sessions annually), diagnosis-dependent, and structured for short-term symptom treatment rather than long-term disability capacity building. Furthermore, Section 10’s move toward fixed funding structures and prescribed support lists reduces flexibility. Autistic support needs commonly fluctuate due to burnout cycles, sensory load, and developmental transitions. Rigid funding parameters limit the ability to increase support intensity at predictable high-risk periods.

The National Autism Strategy 2025–2031 explicitly recognises that autism frequently presents alongside a broad range of additional conditions, including anxiety, ADHD, and connective tissue disorders. This reflects the clinical reality that autism is rarely experienced in isolation. For many, the disabling impact arises from the interaction between autism and these co-occurring conditions (e.g., EDS/hypermobility). This reinforces that disability-related need cannot be narrowly confined to a singular “primary impairment” as proposed by the Bill.

3b. Section 34 – Revised “Reasonable and Necessary” Criteria and Functional Threshold Risk

The amended Section 34 introduces revised criteria requiring that supports be necessary to address needs arising from the impairment and not duplicate mainstream systems. In practice, emphasis on observable functioning creates risk for autistic participants who mask impairments or maintain employment despite significant internal distress.

Masking—the effortful suppression of autistic traits—is associated with increased depression, anxiety, suicidality, and autistic burnout (Hull et al., 2021; Higgins et al., 2021). Women, girls, and gender-diverse individuals are particularly affected due to diagnostic bias. A “reasonable and necessary” assessment that relies predominantly on surface-level functioning under Section 34 risks systematically underestimating impairment. If supports are withdrawn on this basis, individuals at heightened suicide and hospitalisation risk may lose protective intervention.

3c. Expanded Reassessment Powers and Disruption Risk

The Bill expands powers relating to information requests, eligibility reassessment, and plan variation. Continuity of therapeutic relationships is clinically protective for autistic individuals, particularly those with trauma histories. Reassessment processes that result in disruption to established

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supports can trigger anxiety escalation, burnout, and behavioural deterioration. For participants who have experienced prior systemic invalidation, the prospect of losing supports may itself precipitate psychological destabilisation. Absent demonstrated equivalence of service provision, expanded reassessment and redirection risk shifting participants into systems not designed to meet their needs.

3d. Framing of Reform and the Risk to Participants with Invisible or Fluctuating Disabilities

The title of the Bill, “Securing the NDIS for Future Generations,” carries implications that warrant consideration. While the stated intent is fiscal sustainability, the framing risks reinforcing a narrative that current participant needs represent a “system deviation” rather than legitimate support requirements. There is a significant clinical concern that this framing, combined with the restrictive language in sections 10 and 34, encourages a hierarchy of disability, entrenching the belief that unless a disability is “physically obvious,” it is somehow less worthy of support.

This framing risks marginalising participants based on:

• The “Invisibility” of Impairment: prioritising observable impairments while de-legitimising neurodevelopmental, psychosocial, or fluctuating medical conditions (e.g., MS, FND, EDS, POTS).

• The Narrative of Worthiness: inadvertently signalling that individuals with complex or non- linear support needs are the cause of systemic instability.

• Validation of Diagnostic Bias: disproportionately impacting high-masking phenotypes at risk of being deemed “not disabled enough” despite documented risks of burnout and suicidality.

3e. Significant Disability Prevalence and the Limits of Scheme Coverage

Contextualising reform within population data shows that the majority of Australians with significant disability are not NDIS participants. According to the ABS (2022), approximately 2.2 million people have severe or profound disability, yet the NDIS supports approximately 760,000 (NDIA, 2024). This indicates that access criteria already operate as a substantial filter. If sections 10 and 34 narrow interpretation further, additional participants will lose access, shifting their needs to informal carers, state-funded health systems, and emergency services. Sustainable reform must account for demographic reality; reducing access does not reduce the underlying prevalence of disability.

3f. Risk of Participants Being Redirected to Non-Affirming or Unwanted Interventions

The combined operation of section 10 and section 34 risks redirecting participants away from neurodiversity-affirming psychological supports toward interventions more readily classified as “behavioural.” If autism-informed psychological supports are removed, participants with behaviours of concern may be left with limited options under compliance-based methodologies derived from Applied Behaviour Analysis (ABA).

Lived experience and academic critique (e.g., Kupferstein, 2018; Bottema-Beutel et al., 2021) indicate that compliance-focused approaches can be distressing or traumatising. If the Bill results in the removal of affirming psychological supports while retaining behaviour support funding, participants may feel compelled to accept interventions not aligned with their values. This creates ethical tension regarding informed consent and participant choice and control.

Summary

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The combined operation of section 10, section 34, and expanded reassessment powers creates structural risks for autistic participants. These provisions risk:

• Artificially separating neurodevelopmental disability from its psychiatric and physical consequences;

• Over-weighting observable presentation while under-recognising masking and internalised distress;

• Disrupting continuity of therapeutic relationships; and

• Redirecting participants to mainstream systems that are not currently resourced to provide equivalent care.

Absent explicit safeguards, these changes are likely to increase crisis presentations and long-term cross-system costs, rather than achieving sustainable and clinically sound reform.

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4. Clinical Case Illustrations The following de-identified case illustrations are drawn from my current clinical caseload. Each example demonstrates a specific mechanism by which the proposed amendments to the NDIS Act under the Securing the NDIS for Future Generations Bill 2026 would create foreseeable clinical harm and undermine the objectives of the Scheme.

4a. Non-Speaking Autistic Adolescent with High Support Needs

Functional Context: This cohort requires near-continuous support for activities of daily living and often has a history of significant self-injury. Stability is contingent upon NDIS-funded psychology maintaining an individualised behavioural and environmental support framework implemented by trained staff.

Risk Under the Bill: While eligibility may be preserved, Section 10 and Section 34 create risk that specialist neurodiversity-informed behavioural psychology could be reclassified as “mainstream” health intervention. Mainstream health services do not provide integrated, disability-specific behavioural oversight. Furthermore, expanded reassessment powers risk disrupting the continuity of care that is clinically protective for this group.

Foreseeable Consequences: Increased frequency of self-injury, greater use of restrictive interventions, and escalation to emergency department presentations.

4b. Client B: Primary School-Aged Autistic Child (PDA Profile) with ADHD and Severe Anxiety

Functional Context: Client B experiences demand-sensitive distress and episodic crises, requiring family-centred, neurodevelopmentally informed intervention. Traditional behavioural approaches are contraindicated.

Risk Under the Bill: The narrowing of Section 10 risks reclassifying anxiety and emotional regulation work as “mainstream mental health treatment,” despite these features being inseparable from the PDA profile. Fixed funding structures under the Bill fail to reflect the episodic nature of this child’s support needs, which spike during developmental transitions.

Foreseeable Consequences: Breakdown of home-education arrangements, increased carer burnout, and reliance on crisis mental health services.

4c. Client C: Late-Diagnosed Autistic Young Adult, Employed Part-Time

Functional Context: Client C is verbally articulate but has a history of prolonged masking, autistic burnout, and recurrent suicidal ideation. Stability is maintained through ongoing trauma-informed psychological intervention.

Risk Under the Bill: Under a presentation-based interpretation of Section 34, observable employment may obscure internal distress. This participant risks being deemed “not disabled enough” for support. Reclassification under Section 10 further threatens access to the disability-specific capacity building that prevents functional regression.

Foreseeable Consequences: Rapid recurrence of autistic burnout, loss of employment, and increased psychiatric admission risk.

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4d. Client D: Late-Diagnosed Older Autistic Adult

Functional Context: Client D was diagnosed in their fifties after decades of failed mainstream depression treatments. Autism-informed therapy has resulted in the first measurable reduction in depressive episodes in their adult life.

Risk Under the Bill: Section 10 risks reclassifying this effective therapy as “mainstream care,” despite mainstream services having been previously ineffective and retraumatising. Section 34 may undervalue this disability-specific adaptation in favour of generic service availability.

Foreseeable Consequences: Depressive relapses, social isolation, and loss of therapeutic engagement.

4e. Client E: Late-Adolescent Autistic Person with DID and Complex Co-Occurring Conditions

Functional Context: Client E has high support needs, DID, C-PTSD, and multiple chronic medical issues. Psychological intervention is the primary stabilising modality due to medication sensitivities. They live in an interdependent household with a parent who is also a participant.

Risk Under the Bill: Section 10 risks reclassifying trauma-stabilisation work as mainstream health, yet mainstream systems are not structured to provide long-term, high-frequency, dissociation-informed care within a disability framework. Furthermore, the Bill does not account for interdependent households where a reduction in one plan directly destabilises the other.

Foreseeable Consequences: Increased dissociative instability, self-harm, and heightened risk of housing instability or homelessness.

4f. Client F: Adult Participant with Complex PTSD and Multi-System Medical Comorbidity

Functional Context: Client F has significant multisystem medical conditions (metabolic, cardiovascular, neurological). Their neurodevelopmental profile and C-PTSD amplify their medical burden. NDIS psychology coordinates their engagement with the broader health system.

Risk Under the Bill: Section 10 reclassification may view psychological components as “health-related,” failing to recognise them as the coordinating mechanism that allows safe management of life-limiting medical conditions. Section 34 risks underestimating need based on Client F’s ability to communicate verbally in structured settings.

Foreseeable Consequences: Decline in essential medical appointment attendance, medication non-adherence, and increased risk of acute admissions related to poorly managed chronic disease.

4g. Client G: Multiple Autistic Family Members – Interdependent Household

Functional Context: This household contains multiple participants whose functional stability is mutually contingent.

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Risk Under the Bill: Simultaneous exposure to Section 10 reclassification and Section 34 threshold tightening creates cumulative vulnerability. A reduction in support for one member increases pressure on the others, particularly where masking is misinterpreted as reduced need.

Foreseeable Consequences: Multiplicative regression across the family unit, loss of employment for adult members, and potential total household collapse.

Cross-Case Systemic Risk: Reduction of Core Support Worker Hours

Across these cases, a consistent pattern emerges: observable stability is the product of structured psychological and practical scaffolding. Core support worker hours are the mechanism through which therapeutic strategies are implemented.

Risk Under the Bill: The interaction of Section 10 (reclassification), Section 34 (observable functioning), and prescribed support lists creates a structural pathway to reduce practical supports. Removing core supports based on surface-level presentation risks creating regression across multiple domains simultaneously.

System-Level Implications: Sustainable reform requires recognition that practical support hours are preventative infrastructure. Reducing them shifts costs to:

• Acute Hospitals: For self-harm and medical crises.
• Child Protection: Due to family breakdown.
• Welfare Systems: Due to lost employment and housing instability. The Securing the NDIS for Future Generations Bill 2026 risks trading long-term functional independence for short-term fiscal savings that will inevitably be eclipsed by the cost of crisis management.

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5. Conclusion Across the clinical cases and research outlined in this submission, spanning high, moderate, and lower apparent support needs across the lifespan, a consistent pattern of risk is evident. The provisions relating to section 10, section 34, expanded reassessment powers, and funding rigidity within the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 fail to account for the clinical reality of neurodevelopmental disability.

The proposed reclassification of disability-specific psychological supports as “mainstream” mental health treatment does not produce equivalent substitution. Instead, it creates profound gaps in access, affordability, and continuity. Mainstream mental health systems are not configured to absorb this demand; Mental Health Care Plans are capped, time limited, and designed for short-term symptom management rather than the long-term, disability-related capacity building required for functional stability.

Furthermore, the Bill fails to acknowledge the multidimensional and often invisible nature of neurodevelopmental and neurological disability. As recognised in the National Autism Strategy 2025–2031, autism frequently presents as a multisystem condition where “primary” disability cannot be cleanly separated from co-occurring physical and psychiatric consequences. Assessing support needs based predominantly on observable presentation systematically disadvantages those with invisible or fluctuating conditions, including high masking autistic individuals and those with conditions such as MS or FND, whose stability is contingent upon intensive, non-visible scaffolding.

The expanded reassessment powers and rigid funding structures further introduce instability. For participants with permanent disabilities, continuity of care is clinically protective, and disruption to established therapeutic relationships is a documented risk factor for crisis. By narrowing access to neurodiversity-affirming psychological supports, the Bill also risks coercing participants into compliance-based or non-affirming interventions that do not align with their clinical needs or personal preferences, undermining the fundamental NDIS principle of choice and control.

The foreseeable consequences of these provisions include:

• Increased behavioural and psychiatric crises and elevated suicide risk.
• Greater reliance on emergency departments and acute inpatient units.
• Breakdown in school, employment, and community participation.
• Long-term cost shifting to overstretched state-funded health, housing, and welfare systems.

Ultimately, narrowing access through the provisions of Sections 10 and 34 will not reduce underlying need; it will simply shift the clinical risk to informal carers and crisis services. For these reasons, these provisions should not proceed in their current form.

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5a. Recommendations

I respectfully ask the Committee to recommend that:

• Section 10 is amended to explicitly protect neurodevelopmentally informed psychological capacity-building supports as NDIS-funded disability supports, not transferrable to mainstream systems solely because co-occurring mental health symptoms are present.

• Section 34 is revised to require that “reasonable and necessary” determinations incorporate masking, internalised distress, burnout, female and gender-diverse autism phenotypes, cumulative trauma exposure, and context-dependent functioning, not observable presentation alone.

• Any redirection of autistic participants to mainstream mental health systems be contingent upon demonstrated availability, accessibility, affordability, and neurodiversity-affirming equivalence of service.

• Recognition be formalised that MHCP-limited therapy (typically 10 sessions annually) does not constitute equivalent substitution for disability-related capacity building intervention.

• Explicit safeguards be introduced to protect continuity of established therapeutic relationships during reassessment processes.

• Funding models allow flexibility for episodic, fluctuating, and transition-based need across developmental stages.

• Interdependent participant households are explicitly considered in planning and reassessment frameworks to avoid family unit destabilisation.

• Independent, transparent modelling of the projected impact of sections 10 and 34 on suicide rates, hospital utilisation, and workforce participation be completed prior to further implementation.

• Genuine co-design with autistic self-advocates, families, and clinicians with demonstrated neurodevelopmental expertise be embedded in all subordinate rules and operational guidelines.

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6. Final Statement The provisions examined in this submission—the revised section 10 definition of supports, the amended section 34 criteria, and the expanded reassessment powers—risk creating structural separation between disability and mental health in a manner that is clinically unsound and functionally destabilising for autistic participants.

These reforms risk:

• Severing integrated psychological capacity-building from the disability framework that makes it accessible and effective;

• Applying functional thresholds that systematically exclude high-masking and internally distressed individuals;

• Forcing reliance on capped, time-limited, and cost-prohibitive mainstream mental health systems;

• Destabilising therapeutic continuity that is protective against crisis and suicide. The mainstream system is not currently resourced to absorb displaced demand. Without significant reform and resourcing, these changes will shift cost and risk rather than reduce them. I urge the Committee to require robust modelling, structural safeguards, and demonstrated service equivalence before further implementation, and to ensure that reform does not proceed at the expense of participant safety, continuity of care, and long term system sustainability.

I am available to provide further clinical evidence, data, or testimony if required.

Respectfully submitted,

Registered Psychologist

Gabby Bond Psychology

admin@gabbybondpsychology.com

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Appendix A: Code of Conduct Provisions Supporting ND-Affirming and

Trauma-Informed Practice

The Psychology Board of Australia’s Code of Conduct (2025) does not use the exact phrases “neurodiversity-affirming” or “trauma-informed”; however, equivalent obligations are clearly embedded across several provisions. The following sections of the Code provide the regulatory foundation for ND-affirming and trauma-informed practice.

1. Person-Centred, Respectful, and Culturally Safe Practice Psychologists must treat people with respect, dignity, and courtesy; recognise and respect diversity including disability and neurodivergence; provide culturally safe and responsive practice; and avoid discrimination and stigma. These requirements underpin neurodiversity affirming practice by mandating respect for difference and rejection of deficit-based or pathologising approaches.

Relevant section: Part 2 – Working with Clients (Respectful, Culturally Safe and Person

Centred Practice)

2. Safe and Effective Care Psychologists must practise in a way that minimises risk of harm; recognise and respond appropriately to vulnerability and trauma; and adapt communication and intervention strategies to meet the individual needs of the client. This aligns directly with trauma informed principles of safety, choice, collaboration, and minimising re-traumatisation.

Relevant section: Part 3 – Safe and Effective Psychological Practice

3. Informed Consent and Supported Decision-Making Psychologists must communicate in ways that are developmentally and cognitively appropriate; support client autonomy; and ensure understanding before obtaining consent. For neurodivergent clients, this supports adapted communication, sensory consideration, and supported decision-making.

Relevant section: Informed Consent Provisions within Working with Clients

4. Professional Competence Psychologists must work within their scope of practice; maintain competence in working with specific populations; and seek supervision or refer when appropriate. This obliges psychologists to develop competence in neurodiversity-affirming and trauma-informed approaches where relevant to their client population.

Relevant section: Professional Competence (Part 3)

5. Non-Discrimination and Equity Psychologists must not discriminate on the basis of disability and must provide equitable access to services. This forms a clear regulatory foundation for neurodiversity-affirming practice.

Relevant section: Non-Discrimination and Equity Provisions

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Appendix B: Annotated Reference List and Evidence Summary

This appendix provides a summary of the peer-reviewed literature, statutory frameworks, and national data cited in this submission. This evidence forms the clinical and evidentiary basis for the concerns raised regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

Australian Bureau of Statistics. (2022). Survey of Disability, Ageing and Carers (SDAC): Summary of Findings. ABS.

• Clinical Evidence: Identifies that 5.5 million Australians live with disability, with 2.2 million experiencing “severe or profound” impairment.

• Relevance: Demonstrates that the NDIS is already a highly targeted scheme, supporting only a subset (approx. 35%) of those with the most significant disabilities. It refutes the narrative of systemic over-inclusion.

Australian Government. (2025). National Autism Strategy 2025–2031. Department of

Social Services.

• Clinical Evidence: The Commonwealth’s official policy framework acknowledging autism as a lifelong, multisystem neurodevelopmental disability with high rates of co-occurring conditions.

• Relevance: Establishes that the Government’s own strategic policy recognizes the inseparability of disability and health, directly contradicting the restrictive definitions proposed in Section 10 of the Bill.

Belcher, H. L., Morein-Zamir, S., Stagg, S. D., & Ford, R. M. (2022). Shining a light on a hidden population. Journal of Autism and Developmental Disorders, 52(5).

• Clinical Evidence: Highlights that autistic individuals (particularly women and girls) who lack formal diagnosis or present with high-masking traits experience severe internal distress and social impairment.

• Relevance: Supports the argument that “observable functioning” is an unreliable metric for determining support needs and that withdrawing support based on surface presentation is clinically dangerous.

Bottema-Beutel, K., et al. (2021). Adverse events in autism intervention research: A meta analysis. Conservation Biology, 35(1).

• Clinical Evidence: A meta-analysis highlighting the lack of monitoring for adverse effects in behavioral interventions.

• Relevance: Supports the concern that pushing participants toward certain behavioral therapies without safeguards or affirming alternatives may lead to unrecognized psychological harm.

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Cederlöf, M., et al. (2016). Nationwide population-based cohort study of psychiatric and somatic comorbidity in autism spectrum disorder. Molecular Autism, 7.

• Clinical Evidence: Confirms that autistic individuals have significantly higher rates of both psychiatric and physical (somatic) health conditions (e.g., EDS, gastrointestinal, and autoimmune disorders) compared to the general population.

• Relevance: Establishes the biological inseparability of “disability” from “health” symptoms, proving that these needs are directly attributable to the autistic profile.

Diemer, M. C., et al. (2025). Comparative analysis of autistic women across the lifespan. Autism Research.

• Clinical Evidence: Found that late-diagnosed women often accumulate multiple incorrect psychiatric diagnoses and experience significant trauma before their autism is identified.

• Relevance: Demonstrates the failure of mainstream health systems to provide equivalent care, arguing against the efficacy of redirecting autistic participants back to those systems.

Eccles, J. A., et al. (2014). Brain structure and joint hypermobility. British Journal of Psychiatry, 205(1).

• Clinical Evidence: Explores the link between joint hypermobility (common in EDS) and psychiatric symptoms like anxiety, noting specific differences in brain structure.

• Relevance: Supports the clinical link between “invisible” physical disabilities and the neurodevelopmental profile.

Higgins, J. M., et al. (2021). Defining autistic burnout through experts by lived experience. Autism, 25(8).

• Clinical Evidence: Defines “autistic burnout” as a distinct clinical state of functional regression, exhaustion, and reduced tolerance to stimuli caused by the cumulative load of masking and environmental mismatch.

• Relevance: Validates that functional decline in autistic participants is a disability- related event requiring specific scaffolding, not a standard mainstream mental health episode.

Hosozawa, M., et al. (2022). Timing of diagnosis, depression and self-harm in adolescents with autism spectrum disorder. The Lancet Psychiatry, 9(8).

• Clinical Evidence: Found that a later diagnosis of autism is a significant risk factor for the development of depression and self-harm.

• Relevance: Emphasizes that continuous, disability-informed psychological support is protective against acute psychiatric crisis.

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Submission 838

Hull, L., et al. (2021). Is social camouflaging associated with anxiety and depression in autistic adults? Molecular Autism, 12.

• Clinical Evidence: Confirms that “camouflaging” (masking) is a significant predictor of suicidality, anxiety, and depression.

• Relevance: Highlights the danger of the Bill’s emphasis on surface-level presentation, which risks withdrawing supports from those at the highest clinical risk of suicide.

Kupferstein, H. (2018). Evidence of increased PTSD symptoms in autistics exposed to applied behavior analysis. Advances in Autism, 4(1).

• Clinical Evidence: Found a strong correlation between compliance-based behavioral interventions and the later development of PTSD symptoms.

• Relevance: Supports the requirement for neurodiversity-affirming psychological care over compliance-focused behavioral models.

Lai, M.-C., et al. (2019). Autism. The Lancet, 393(10222).

• Clinical Evidence: A comprehensive review noting that 70% of autistic people have co-occurring mental health conditions.

• Relevance: Establishes the clinical standard that mental health issues are the rule, not the exception, in autism, making their separation from disability supports clinically unsound.

Michelini, G., et al. (2024). Where do neurodevelopmental conditions fit in transdiagnostic psychiatric frameworks? World Psychiatry, 23(3).

• Clinical Evidence: Provides a transdiagnostic model showing that neurodevelopmental and psychiatric impairments share common biological and functional pathways.

• Relevance: Directly challenges the logic of Section 10 of the Bill, which attempts to treat disability and mental health as discrete, separable categories.

National Disability Insurance Agency. (2024). NDIS Quarterly Report to Disability

Ministers: Q1 2024-25. NDIA.

• Clinical Evidence: Provides current data on Scheme participation and functional outcomes.

• Relevance: Used to provide the statistical baseline for current Scheme participation compared to broader disability prevalence.

Psychology Board of Australia. (2025). Code of conduct for psychologists. AHPRA.

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Submission 838

• Clinical Evidence: Sets the ethical and professional standards for psychologists, emphasizing safety, informed consent, and advocacy.

• Relevance: Forms the regulatory basis for the psychologist’s obligation to highlight policy changes that pose a foreseeable risk to participant safety.

van der Putten, W. J., et al. (2025). Camouflaging in autism: A cause or a consequence of mental health difficulties? Autism.

• Clinical Evidence: Finds that camouflaging is a survival mechanism leading to significant exhaustion and identity loss.

• Relevance: Reinforces the risk of using “observable presentation” as a measure of a participant’s need for support.

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