Ensure any functional capacity framework used for NDIS access reflects the real-world impact of blindness (Provider advocacy) | External submission

Submission 839

Ph 1800 033 660   | E bca@bca.org.au   | W bca.org.au | ABN 90 006 985 226

Submission to Senate Inquiry: National

Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill

2026

1 June 2026

Lodged online: Lodge my submission – Parliament of Australia

Author:

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Submission 839

Contents

Executive Summary…………………………………………………………………………………………..4
About Blind Citizens Australia……………………………………………………………………………5
Response to proposed National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026……………………………………………………………………..6

Schedule 1 – Access and Planning Measures ………………………………………………………………6

Part 1 - Defining functional capacity ………………………………………………………………………….6

Recommendation 1: Ensure any functional capacity framework used for NDIS access or planning is co-designed with the blindness and vision impaired sector, reflects the real world functional impact of blindness and vision impairment, and is conducted by appropriately qualified professionals with expertise in blindness-specific supports ………6

Part 3 - Strengthen link between an impairment and need for support…………………………….8

Recommendation 2: Ensure new access tests and requirements related to appropriate treatment and functional capacity account for the complex and cumulative nature of disability experienced by people who are blind or vision impaired……………………..8

Part 4 - Support determinations………………………………………………………………………………..10

Recommendation 3: Reject blanket reductions to NDIS participant plans and ensure any funding or eligibility reforms are subject to strong legislative safeguards, independent disability-specific impact assessment and review rights…………………………………………..10

Recommendation 4: Recognise that NDIS supports for people who are blind or vision impaired - including social, civic and community participation supports - are essential to health and safety and should not be replaced by increased reliance on informal supports or mainstream systems. ……………………………………………………………………………………….10

Recommendation 5: Prioritise reform to NDIA administrative efficiency before reducing NDIS participant supports……………………………………………………………………………………13

Recommendation 6: Decisions affecting participant rights and entitlements must remain subject to strong safeguards, transparency and co-design with people with disability….14

Part 7 - Plan suspensions…………………………………………………………………………………………15

Recommendation 7: Prohibit suspension of participant plans for non-response unless there is evidence that the NDIA has provided information in the participant’s preferred accessible format, undertaken accessible follow-up processes, and confirmed that accessibility barriers are not preventing engagement. ……………………………………………..15

Part 8 - Tightening meaning of permanence to reduce access where an impairment can be treated…………………………………………………………………………………………………………………..16

Recommendation 8: Expressly preserve specialist-certified access for bilateral permanent vision loss………………………………………………………………………………………….16

Recommendation 9: Explicitly recognise blindness and permanent vision impairment as lifelong conditions that do not require repeated proof of permanence or ongoing

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Submission 839

reassessment where diagnosis is confirmed by an appropriately qualified ophthalmologist or specialist………………………………………………………………………………..17

Part 9 - Eligibility based on access to other services …………………………………………………..17

Recommendation 10: Ensure people who are blind or vision impaired are not excluded from the NDIS unless accessible, adequate and equivalent supports are genuinely available through mainstream or alternative service systems and ensure reforms do not shift disability support responsibilities onto families, carers or inaccessible community systems. …………………………………………………………………………………………………………….17

Schedule 2 – Fraud measures…………………………………………………………………………………..19

Part 1 - Registration of NDIS providers & Part 2 - Civil penalties and regulatory powers.19

Recommendation 11: Implement a proportionate, risk-based provider regulation framework that preserves participant choice and workforce sustainability for blindness specific supports…………………………………………………………………………………………………19

Schedule 3 – Governance arrangements ……………………………………………………………………21

Recommendation 12: Preserve transparency, review rights and accountability by mandating publication of how participant budgets are calculated, providing funding decisions and draft plans in accessible formats prior to approval, and publicly reporting disability-specific data on eligibility decisions, reassessments, support reductions and appeals involving people who are blind or vision impaired. …………………………………….21

Recommendation 13: Require all major NDIS reforms affecting participant rights, eligibility or funding to be subject to minimum consultation periods, accessible consultation materials and genuine co-design with people with disability, consistent with the principle of “nothing about us without us”. ………………………………………………………21

BCA NDIS Participant Stories……………………………………………………………………………..22 Case study 1 – Use of supports …………………………………………………………………………….22

Case study 2 - Impact of cuts to funding………………………………………………………………..23

Case study 3 - Informal supports and caring duties as a person with a disability…………24

Executive Summary Blind Citizens Australia (BCA) is deeply concerned that the proposed reforms

prioritise cost containment over disability outcomes, shifting the NDIS away from its

rights-based foundations toward a more restrictive and budget-limited system. While

framed as measures to improve sustainability and address fraud, the practical effect

for many people who are blind or vision impaired will be reduced access to essential

supports that prevent isolation, injury, deterioration and exclusion from community

life.

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Submission 839

Blindness and vision impairment are lifelong disabilities with profound impacts on

mobility, communication, safety, employment, education and participation. Supports

that enable access to information, transport, communication and community life are

not discretionary - they are essential to health, safety, independence and equal

participation. Social, civic and community participation supports are critical because

they enable people to do things that would otherwise be impossible or unreasonably

difficult without assistance.

BCA strongly opposes cuts to essential supports and rejects changes that redefine

“reasonable and necessary” supports primarily around Scheme sustainability rather

than individual rights, inclusion and functional need. Sustainability should instead be

pursued through reducing administrative inefficiency, duplication, unnecessary

compliance burdens and costly, ineffective NDIA appeals against participants.

The “whole of person” approach to supports must be retained so participants with

intersecting disabilities and complex needs are not excluded because needs arise

from multiple conditions.

Efforts to reduce reliance on the NDIS will fail unless governments also address the

inaccessibility of mainstream systems, including transport, healthcare, education,

digital services and community infrastructure. Functional assessments and eligibility

processes must appropriately recognise the distinct and lifelong impact of blindness

and vision impairment, including the disabling impact of inaccessible environments

and systems.

Eligibility pathways for people who are blind or vision impaired should continue to

rely on specialist clinical evidence and avoid unnecessary reassessment and

administrative burden.

BCA is also concerned that safeguarding and provider registration reforms could

reduce access to specialised vision services, trusted providers and disability-specific

expertise that are essential to effective support delivery and equitable participation.

Current NDIS processes are already highly complex and frequently inaccessible for

people who are blind or vision impaired, and further bureaucracy risks creating

additional barriers to access, review rights and meaningful participation in the

Scheme.

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Reduced supports and increased administrative burden will also disproportionately

affect parents, carers, nominees and family advocates - particularly women (and

their dependants), increasing burnout and limiting participation in employment,

education and community life. Similarly, restrictions on reassessments and plan

changes risk leaving participants without adequate support during periods of crisis,

deterioration or major life change.

BCA maintains that reform must be informed by the lived experience of people with

disability, including people who are blind or vision impaired, to ensure the NDIS

remains fair, accessible, functional and genuinely participant-centred.

BCA urges the government to restore the NDIS to its original intent as a rights

based, participant-centred scheme that enables people with disability to live safely,

independently and inclusively in the community. The original vision of the NDIS

recognised that disability is shaped not only by impairment, but also by inaccessible

systems and environments. The NDIS must remain focused on functional need,

independence, inclusion and participant outcomes, rather than being narrowed

through a cost-containment approach. People with disability must continue to have

access to the supports necessary for equal participation, choice, control, and dignity.

About Blind Citizens Australia BCA is the national representative organisation of people who are blind or vision

impaired in Australia. Founded in 1975, BCA is a consumer-led advocacy

organisation run by and for people who are blind or vision impaired. BCA works to

promote equity, inclusion, independence and full participation in all aspects of

community life through systemic advocacy, policy reform and community

engagement.

This submission draws on the lived experience and expertise of people who are blind

or vision impaired across Australia, including people with diverse backgrounds,

circumstances and support needs.

“People who are blind or vision impaired are not passive recipients of support but active contributors to their communities. They participate as workers, volunteers, neighbours, carers, advocates, taxpayers and citizens, and bring critical lived expertise to co-design processes. Structural barriers - not lack of capacity or contribution - are what continue to limit full economic and social participation, including workforce participation.” BCA Member 2026

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

Schedule 1 – Access and Planning Measures

Part 1 - Defining functional capacity

Recommendation 1: Ensure any functional capacity framework used for NDIS access or planning is co-designed with the blindness and vision impaired sector, reflects the real-world functional impact of blindness and vision impairment, and is conducted by appropriately qualified professionals with expertise in blindness-specific supports

Do not introduce assessment tools and frameworks without disability-specific

consultation and testing involving people with lived experience of blindness

and vision impairment.

Require that functional capacity assessments evaluate a person’s capacity in

real-world conditions and do not make assumptions about the independence

of people who are blind or vision impaired.

Require that any eligibility or functional assessment involving blindness or

vision impairment be conducted or reviewed by professionals with

demonstrated expertise in blindness, low vision and blindness-specific

supports.

Require that assessment frameworks explicitly recognise progressive and

fluctuating vision conditions, including the cumulative impact of fatigue, light

sensitivity, visual processing difficulties and variable functional vision.

Rationale

Blindness-related barriers are frequently misunderstood in generic disability

policy design, and generic functional assessment tools frequently fail to

capture the lived impact of blindness and vision impairment.

Functional capacity for people who are blind or vision impaired cannot be

assessed in isolation from the accessibility of the surrounding environment.

Assessments that focus on what a person can theoretically do in controlled

settings fail to account for the real-world impact of inaccessible information,

transport barriers, unsafe environments, digital exclusion, discriminatory

attitudes and limited informal supports on safe and independent participation.

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Many blind and vision impaired people appear high functioning because they

have developed compensatory strategies and rely on specialist supports. The

effective use of assistive technology, orientation and mobility skills, Braille,

screen readers, dog guides or support workers must not be used to justify

reducing eligibility or supports.

The impact of blindness and low vision is frequently underestimated due to

limited community and institutional understanding of the extent to which

everyday activities, communication and participation rely on vision.

Assessors without blindness expertise may incorrectly assume that people

can access printed information, navigate safely, use inaccessible technology,

recognise faces, interpret visual cues or travel independently without risk.

Co-design with people who are blind or vision impaired is necessary to avoid

unintended exclusion.

The Bill contains potentially conflicting policy objectives. While a functional

capacity approach could broaden access by focusing on the impact of

disability rather than diagnosis alone, this sits in tension with the

Government’s stated objective of reducing NDIS growth. There is a significant

risk that functional assessments will be implemented primarily as a cost

containment mechanism rather than a genuine measure of support need.

Part 3 - Strengthen link between an impairment and need for support

Ensure that blindness and vision impairment are assessed holistically, including

through:

 explicit recognition of co-occurring conditions, causative diseases and

secondary consequences associated with blindness and vision impairment;

 assessment of cumulative functional impact across multiple conditions, rather

than considering each condition in isolation;

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 safeguards to ensure the “appropriate treatment” requirement does not create

unreasonable barriers for people with permanent vision impairment linked to

chronic or progressive conditions; and

 acceptance of lived experience evidence, clinical expertise and functional

evidence where peer-reviewed cohort data may be limited due to the low

incidence nature of conditions.

Rationale

The proposed NDIS access reforms risk creating unintended barriers for

people who are blind or vision impaired who also experience co-occurring

conditions, underlying health conditions, or secondary consequences

associated with vision loss.

Assessing conditions separately risks understating the true level of disability

related support required and may result in inappropriate exclusion from the

NDIS or reduced access to necessary supports.

People who are blind or vision impaired commonly experience three broad

categories of co-morbidity:

o co-occurring conditions, such as autism, intellectual disability, psychosocial disability, acquired brain injury, deafness or dementia;

o causative conditions or diseases, such as diabetic retinopathy, glaucoma, age-related macular degeneration or retinitis pigmentosa;

and

o secondary consequences arising from vision loss, including depression, anxiety, falls risk, social isolation and reduced community

participation.

The proposed reforms may apply unevenly across these categories. For

example, people with blindness caused by progressive or chronic health

conditions may be required to demonstrate that all “appropriate treatment”

options have been exhausted before accessing supports, potentially shifting

the focus from functional impact to medical management. Similarly, where

participants experience co-occurring psychosocial disability, autism or mental

health impacts associated with blindness, there is uncertainty about whether

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Submission 839

these support needs will be recognised holistically or excluded as the

responsibility of another system.

There is also a significant risk that people with rare or low-incidence

conditions will be disadvantaged by evidentiary requirements that rely heavily

on large-scale peer-reviewed data, despite strong lived experience evidence

demonstrating substantial functional impact.

A narrow interpretation of “appropriate treatment” could also unfairly

disadvantage people whose blindness is connected to lifelong, degenerative

or chronic medical conditions. In many cases, medical management may slow

progression but cannot restore vision or eliminate the need for disability

related supports.

“It is my experience that increased mobility is misunderstood by many in the community including NDIA employees – and assumptions that mobility aids solve all problems. But this is clearly not the case. I simply cannot ask my guide dog to find the airport gate or to find the toilet when she has not been trained to do so for that specific location. My guide dog cannot find a grocery item for me or an item in a Bunnings outlet. My guide dog cannot choose clothes for me or tell me what colour a shirt is. But she can help me navigate the world safely on routes in which she is trained.” BCA Member 2026

Part 4 - Support determinations

Recommendation 4: Recognise that NDIS supports for people who are blind or vision impaired - including social, civic and community participation supports are essential to health and safety and should not be replaced by increased reliance on informal supports or mainstream systems.

Broad budget reductions will have a disproportionate impact on people who

are blind or vision impaired.

Reject blanket or across the board reductions to participant plans, including

proposed reductions to social, civic and community participation supports

(SCCP) and capacity building daily activity supports.

Recognise that for people who are blind or vision impaired SCCP supports

are fundamental and not discretionary or optional expenditures and prevent

isolation, injury, deterioration and exclusion.

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Support an individualised approach to allocation of participant funding that’s

right for the person, considers an individual’s capacity and capability, social

and family circumstances and the environment/location in which they live.

Reject a narrow interpretation of “health and safety” focused on immediate

risk. Recognise that supporting broader social and economic participation,

independence and inclusion directly impacts health, safety and reduces harm.

Oppose reforms that shift costs onto informal supports (individuals, families)

and states/territories.

Require the Government, in introducing Ministerial powers, to gain a proper

understanding of the way supports are being used by vision impaired

participants. Require independent disability-specific impact assessments

before implementing funding reductions or eligibility reforms.

Include provision for participant plans and budgets to be reviewed when there

is a change in circumstances that includes when informal supports decrease.

Retain strong legislative safeguards and independent oversight of funding

decisions.

Rationale

Blanket cuts to SCCP fail to reflect individual functional needs of people who

are blind or vision impaired and undermines the core principles of the NDIS.

For people who are blind or vision impaired, supports that enable

independence, orientation, mobility, communication and community

participation are often incorrectly viewed as discretionary rather than essential

to safety, wellbeing and inclusion.

NDIS supports frequently fill systemic access gaps, not because of individual

deficits, but because accessibility has not been meaningfully embedded

across government, business, and community settings.

The Department of Health, Disability and Ageing Office of Impact Analysis

NDIS Reforms Impact Analysis report (May 2026) states that “the decision to

reduce this budget was preferred over others because it does not impact the

health and safety of participants. SCCP supports do not provide support for

daily living activities critical to a person’s health and wellbeing, such as

toileting, showering, meal preparation, and household tasks like cleaning.”

BCA challenges the assumption that daily living activities (such as toileting,

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showering, meal preparation, and household tasks like cleaning) are the only

things critical to a person’s health and wellbeing.

For blind and vision impaired participants, SCCP supports are essential

enabling supports that directly impact health and safety, including:

o assistance to travel safely and independently and avoid injury including orientation and mobility assistance

o support to manage risks in unfamiliar situations and environments o support to attend medical and health care appointments and complete paperwork

o support to reduce isolation and maintain mental wellbeing o support to participate in sport and recreation activities o support to undertake grocery shopping and enable meal preparation o support to enable personal care and grooming o support to undertake education, training, paid and voluntary work o assistance to engage with community, civic and cultural life o assist parents to get their children safely to school and engage in extra curriculum, sport and social activities

o assistance to engage with family and friends and develop and maintain relationships.

 Reducing NDIS supports without fully funded mainstream alternatives will

increase unpaid carer burden, put pressure on health and mental health

systems, increase social isolation, and reduce health and wellbeing outcomes

for people who are blind or vision impaired.

 Participant budgets must acknowledge the higher cost of engaging support at

times that attract higher rates such as weekends and public holidays and in

regional and remote areas where markets are thin. Having little or no ’choice

and control’ at weekends or because of where you live is counter to the

purpose of the NDIS.

 Support planning must recognise that blindness-related supports primarily

address barriers created by inaccessible environments and information and

may be required on both a routine and episodic basis.

 Replacing individualised supports with block-funded community alternatives

will undermine participant choice and control which is a foundational principle

of the NDIS.

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 Capacity building cannot eliminate many blindness-related support needs

because society, information and everyday environments remain inherently

visual. For people who are blind or have low vision, ongoing support is often

essential for equitable participation.

“Social and community participation supports are important to enable me to live independently in the community. This is particularly for maintaining my home which is important as the way you keep your house is a measure people use to judge your competence as a person. Social and community participation is important for basic grocery shopping. This is because staff in busy supermarkets are either unable or unwilling to locate and help with checkouts. The online shopping websites are very difficult to use with screen reading software. Social and community support was particularly important for me in managing my home and fulfilling my caring responsibilities to my wife when she was with me.” BCA Member 2026

Recommendation 5: Prioritise reform to NDIA administrative efficiency before reducing NDIS participant supports

Reduce unnecessary evidence requirements for permanent disability.

Embed accessibility by default across all NDIA systems and communication.

Establish simplified approval processes for commonly used assistive

technology and supports associated with blindness and vision impairment.

Recognise the long-term cost benefits of appropriate supports and

accessibility.

Rationale

For people who are blind or vision impaired, significant costs are generated by

NDIA processes that require repeated justification for supports that are clearly

reasonable, necessary and linked to permanent disability.

Participants are frequently required to obtain expensive specialist reports to

justify relatively low-risk purchases such as assistive technology, despite

blindness and vision impairment being lifelong conditions with well

established support needs.

Requiring repeated assessments and reassessments in these circumstances

creates unnecessary expense for participants, providers and the NDIA,

without improving outcomes.

Substantial inefficiencies arise when information, communication and

documentation are not provided by the NDIA in accessible formats from the

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outset. Delays caused by inaccessible letters, portals, forms and planning

processes often require additional follow-up, advocacy, complaints and

administrative intervention, increasing costs across the system while

undermining participant independence and informed decision-making.

“As people who are blind or vision impaired our needs around assistance with daily living are different from other NDIS participants. We don’t specifically need support around toileting, showering and feeding but we do need support such as shopping for clothes, colour matching, cleaning stains, household cleaning, servicing air conditioning units, cleaning windows, grocery shopping, getting around the community such as for medical appointments. Generally Ubers and taxis don’t take us all the way into a building to find a specific office, apartment number, accessing local cafés by orienting us to the entrance and interior.” BCA Member 2026

Recommendation 6: Decisions affecting participant rights and entitlements must remain subject to strong safeguards, transparency and co-design with people with disability.

Ensure any expansion of ministerial powers under the NDIS framework be

subject to strong parliamentary oversight, public transparency and mandatory

consultation with people with disability and representative organisations.

Rationale

Increased ministerial discretion creates uncertainty for participants,

particularly where powers may be used to narrow access to supports, redefine

eligibility, or limit what is considered “reasonable and necessary” without

adequate consultation with people with disability.

For people who are blind or vision impaired, uncertainty around support

access can have immediate consequences for safety, independence,

communication, mobility and community participation.

Powers that allow rapid or broad changes to operational rules should not be

used to introduce cost-cutting measures that undermine the rights-based

intent of the NDIS or reduce access to essential supports.

“As a legally blind person I need assistance to attend health care appointments because our health system continues to be inaccessible to me. I can’t read the forms or fill out the paperwork. I can’t find the consulting rooms because the signage is poor and the lifts don’t announce what floor I am on. I can’t read the instructions for aftercare or medication management because the print is inaccessible to me. I need support to find my way and keep

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myself safe. I can’t rely on friends and family to always be available to do this as they have their own lives to lead. I want to be independent and maintain my privacy just like everybody else.” BCA Member 2026

Part 7 - Plan suspensions

Power to suspend NDIS participant plans where participants can’t be contacted will

disproportionately impact people with disability who don’t consistently receive

information in accessible, appropriate or usable formats. Ensure participant plans

cannot be suspended based on non-contact unless the NDIA has first:

 demonstrated that all communication has been provided in the participant’s

preferred and accessible format;

 used multiple accessible communication methods and reasonable follow-up

attempts;

 confirmed that accessibility barriers are not contributing to the lack of

response;

 engaged nominees, advocates, support coordinators or other authorised

contacts where appropriate; and

 provided accessible warnings and review mechanisms prior to any

suspension decision.

Rationale

For people who are blind or vision impaired, inaccessible communication

remains a persistent and systemic barrier across government and service

systems, including inaccessible letters, PDFs, online portals, forms and digital

notifications and is a consistent complaint received by BCA in relation to the

NDIS.

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Participants may be incorrectly classified as “uncontactable” not because they

are disengaged from the NDIS, but because communications have not been

provided in formats they can independently access or respond to.

Delays in receiving accessible information can be compounded by reliance on

third parties, inaccessible digital systems, communication preferences not

being followed, changes in support arrangements, or limited access to

advocacy and administrative assistance.

“The NDIA kept sending me printed copies of communication even though I repeatedly told them I couldn’t read it. It was too large for my letterbox so had to be collected from the post office which was such a waste of time and money.” BCA Member 2026

Part 8 - Tightening meaning of permanence to reduce access where an impairment can be treated

Recommendation 8: Expressly preserve specialist-certified access for bilateral permanent vision loss

Expressly preserve streamlined NDIS access for people with permanent

bilateral vision loss, either through a dedicated preservation clause in

proposed section 9B(4) or through a binding commitment that Category A

NDIS Rules will continue to recognise specialist-certified permanent blindness

as sufficient evidence of disability access eligibility.

Oppose any requirement that participants must exhaust “all appropriate

treatment” before accessing the NDIS where treatment cannot restore

functional vision or eliminate disability-related barriers.

Ensure inability to access treatment due to cost, geography, service

availability or accessibility does not prevent access to the NDIS.

Ensure lived experience and treating practitioner evidence are given

significant weight when determining whether supports are effective and

beneficial, particularly where peer-reviewed evidence is limited for low

incidence disability cohorts such as blindness and vision impairment.

Rationale

Currently, certification by an ophthalmologist of permanent blindness in both

eyes provides a recognised streamlined pathway to NDIS access under List A

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of the Operational Guidelines. The Bill does not expressly preserve this

pathway. Instead, the new functional capacity framework commencing on 1

January 2028 defers key eligibility settings to Category A NDIS Rules, which

have not yet been released and are not subject to merits review. This creates

significant uncertainty for people who are blind or vision impaired, as existing

streamlined access arrangements could be amended, narrowed or removed

administratively in the future.

Recommendation 9: Explicitly recognise blindness and permanent vision impairment as lifelong conditions that do not require repeated proof of permanence or ongoing reassessment where diagnosis is confirmed by an appropriately qualified ophthalmologist or specialist.

Repeated reassessment processes are inefficient and burdensome for people with disability.

Rationale

For many people who are blind or vision impaired, impairment is permanent,

non-recoverable and clinically verifiable with well-established functional

impacts.

Requiring repeated reassessment creates unnecessary administrative

burden, distress and cost, without improving scheme integrity.

Tougher proof of “permanent disability” will exclude people unable to access

specialists and disadvantage those in rural areas or with fewer resources.

This will worsen inequality and delay access to support.

Part 9 - Eligibility based on access to other services

 Reject eligibility settings that exclude people from the NDIS because they

receive support through aged care, compensation or other mainstream

systems where those systems do not provide equivalent disability-specific

supports.

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 Recognise that inaccessible mainstream systems increase, rather than

reduce, reliance on disability supports for people who are blind or vision

impaired.

 Reject the assumption that families, carers or informal supports can substitute

for funded disability supports for people who are blind or vision impaired.

 Ensure the NDIS does not shift unreasonable caring responsibilities onto

families due to funding caps or restrictive planning practices.

Rationale

Without strong foundational supports, tighter eligibility settings and plan

reductions could leave blind and vision impaired people without access to

essential assistive technology, orientation and mobility training, daily living

supports, obtain accessible information and maintain health and safety.

Efforts to reduce NDIS costs must acknowledge that these costs do not

disappear when removed from the NDIS - they simply shift elsewhere.

In the absence of adequate supports, the burden falls on other service

systems, or more commonly, on the participant and their informal networks.

The existence of natural supports cannot be assumed, nor should reliance on

them be treated as an obligation. Over-reliance risks reinforcing power

imbalances, straining relationships, and ultimately diminishing a participant’s

wellbeing.

When supports are withdrawn or restricted, the cost to the participant can

manifest as increased stress, reduced independence, and poorer mental

health, placing further pressure on already stretched health systems.

Schedule 2 – Fraud measures

Part 1 - Registration of NDIS providers & Part 2 - Civil penalties and regulatory powers

Recommendation 11: Implement a proportionate, risk-based provider regulation framework that preserves participant choice and workforce sustainability for blindness-specific supports

Proposed expansion of provider regulation and penalty provisions risks creating

significant unintended consequences for the specialist blindness service workforce.

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Ensure any new provider registration preserve participant choice and control,

particularly for blindness-specific supports delivered by small or specialised

providers.

Adopt a tiered, risk-proportionate registration framework that imposes higher

regulatory obligations only where supports involve significant safeguarding

risks.

Streamline registration for sole practitioners and small providers (under

$500,000 NDIS-derived turnover).

Recognise that many participants safely and effectively use unregistered

providers and preserve participants’ ability to choose providers outside the

registration system where appropriate safeguards exist.

Provide transitional funding, administrative support and streamlined

compliance pathways for small, community-based and blindness-specialist

providers to meet registration requirements.

Require all registered providers to demonstrate compliance with recognised

accessibility standards in communication, digital systems, information

provision and participant engagement. Ensure provider quality includes

accessibility, not only clinical or administrative compliance.

Automatically recognise established vision specialist training pathways. For

Assistive Technology, where no national credential exists, extend recognition

to employer-delivered training by vision specialist organisations.

Publish a workforce sustainability impact statement before each mandatory

registration phase, addressing low-incidence cohorts including people who

are blind or vision impaired.

Establish an accessible compliance-dispute pathway modelled on the Fair

Work Commission unfair dismissal jurisdiction (Fair Work Act s 596).

Adopt graduated penalties for registration or compliance errors, with a focus

first on remediation and education prior to enforcement action.

Rationale

Provider registration status alone is not a complete indicator of quality.

The Bill expands provider regulation following the National Disability

Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026,

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including civil penalties of up to $3.3 million for “serious contraventions” of

provider obligations. While safeguards and oversight are important, the scale

of penalties and compliance obligations may disproportionately impact sole

practitioners and small specialist providers.

The blindness-specific workforce is small, highly specialised and

geographically dispersed, with many orientation and mobility, assistive

technology, braille and peer support services delivered by sole traders or

small organisations, particularly in regional, rural and remote areas.

Increased registration, auditing and reporting requirements may discourage

providers from remaining in the NDIS market, further reducing already limited

service availability.

There is also uncertainty about how “serious contravention” provisions will

apply in practice, particularly for providers without dedicated compliance

resources. The cumulative burden of registration, audits, reporting, key

personnel checks and ongoing regulatory oversight may create significant

financial and operational risk for small providers operating in thin markets.

Blindness-specific supports are fundamentally different from high-risk

personal care or restrictive practice environments and should be regulated

proportionately to their level of risk.

Participants who are blind or vision impaired often rely on long-standing

relationships with specialist providers who offer continuity, flexibility, cultural

safety and highly specialised expertise. If providers exit the sector due to

compliance costs or regulatory uncertainty, participants may lose access to

essential supports and experience reduced choice and continuity of care.

Provider regulation reforms should be accompanied by proportionate

compliance pathways for low-risk specialist providers, alongside stronger

accessible complaints mechanisms, participant education, independent

advocacy and proactive monitoring of accessibility compliance across the

NDIS system.

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Submission 839

Schedule 3 – Governance arrangements

Require mandatory publication of how participant budgets are calculated.

Require explanations for funding decisions in accessible formats.

Require participant access to draft plans in preferred accessible format before

approval.

Publicly monitor the impact of tighter eligibility and assessment reforms and

publish disability-specific data on access decisions, reassessments, support

reductions and appeals involving blindness and vision impairment.

Rationale

Transparency and accessibility are essential to ensure reforms do not

disproportionately exclude or disadvantage people who are blind or vision

impaired and to enable meaningful review, accountability and procedural

fairness within the NDIS.

 Compressed consultation timeframes on major NDIS reforms undermine

meaningful engagement with people with disability, representative

organisations and the broader community.

Rationale

 Reforms are complex, technical and likely to have significant long-term

impacts on participants’ rights, supports and access to services.

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Submission 839

 Short consultation periods disproportionately disadvantage people who

require accessible information, additional time to consider proposals, or

support to participate in consultation processes.

 This approach weakens the quality of policy development, limits transparency

and accountability, and reduces confidence that reforms are being designed

in partnership with the disability community.

BCA NDIS Participant Stories Case study 1 – Use of supports

Robyn lives on her own in an apartment in an inner south eastern suburb of

Melbourne. She is legally blind. She uses a long cane for mobility. Her apartment

building is located within 150 metres of a transport hub including train, tram and a

bus interchange. Within a 1 km radius of her home, Robyn has access to a

supermarket, medical centre, cafés, cinema, parks, hotels, clothing stores, shoes

stores, post office. To get to the local shops, Robyn has to navigate advertising

boards, outdoor café furniture, people, prams, scooters, dogs on leads and other

obstacles. Sometimes, depending on how busy the street is, how much glare there

is, weather conditions, and her fatigue levels after a busy day, Robyn requires a

support worker to access her local community. She might use the support worker as

a sighted guide or she may ask the support worker to do her errands for her.

Large shopping centres, even with the best way finding Apps are a challenge for her.

The biggest challenge being the moving obstacles. People are far less predictable

than static objects and fixed landmarks. Robyn often says, “If sighted able bodied

people paid the same attention to their environment as people who are blind or

vision impaired, there would be a lot less accidents.” And “I would feel a lot more

safer and at ease walking down the street if I knew everyone was paying as much

attention as me.”

Robyn has 10 hours a week of social, civic and community participation support in

her plan. She uses this support for assistance with shopping both in person and

online, getting to and from medical and social appointments, filling in forms, learning

about new cafés in her local area, accessing café and restaurant menus. Often

online menus and actual menus are inconsistent or the online menu is a photo image

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Submission 839

which is not readable with adaptive technology. Even though she is a proficient user

of technology,

And adaptive technology such as Braille and screen readers on her computer and

iPhone, she finds many forms of digital communication fall just short of accessible.

So she relies on a support worker to read out or transcribe information such as blood

test results, online booking request forms and regional bus timetables in order to

plan visits to her family.

She enjoys walking. One of Robyn’s long term goals, as stated in her NDIS plan, is

to walk the Camino trail in France and Spain. She uses a support worker to provide

sighted guide and navigation support most weeks so she can build her confidence

and ability to use walking tracks.

Case study 2 - Impact of cuts to funding

“Budgets can’t be cut as they are minimal as it is. May seem a lot but it isn’t. To go

out and be part of the community - say to a picnic or concert (just normal things

people do on a Sunday, not a luxury), the weekend cost is $83.00 per hour. Based

on 6 hours (this is not ‘plenty’ of time but minimum if you include travel and parking

time).

6 x $83.00 = $498.00 plus vehicle cost at $1.00 per km.

There are 52-53 Sundays in a year.

To have the ‘privilege’ of mixing in the community, getting out of the home, having

some choice and control, for more than the briefest time (ie not just a 1-2 hour visit to

the shops) would cost 52 x $498.00 = $25,896 PLUS vehicle costs per year.

That doesn’t even allow for a ‘full’ day out (what others take for granted), holiday time

or public holidays. Never mind daily activities costs. Blind and vision impaired people

will be reduced to ‘pets’ like human’s being ‘let out’ to mix from time to time. The

current budgets don’t achieve what is ideal, diminishing the budgets is unjustifiable

and cruel.”

Case study 3 - Informal supports and caring duties as a person with a disability

“Challenges happen to everyone, even if you have a disability. People experience

marriage and family breakdown or bereavement that impact on family supports often

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Submission 839

drastically so there needs to be recognition of the need for family supports. If a

Participant is a sole parent (and has little or no informal supports) their requirement

for assistance for all activities is multiplied. The children have a right to participate in

sport and extra curriculum activates, attend parties, visit their friends, just like any

other children. The alternative is for the children to suffer the isolation of the parent

and the negative consequences on childhood development, confidence and

happiness - producing likely poor outcomes for the family and children and putting

more pressure on society’s resources and services. The children notice they are

missing out.”

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