Submission 989 May 2026
Submission regarding the NDIS Future GeneraƟons Bill 2026
Privacy: I request my name and details be withheld due to the inclusion of de-idenƟfied clinical examples involving vulnerable parƟcipants.
Summary of Key Concerns
This submission outlines concerns regarding: increasing standardisaƟon of NDIS planning and funding reduced flexibility and individualisaƟon of supports proposed reducƟons to social and community parƟcipaƟon funding narrowing recogniƟon of complex disability and whole-person funcƟoning The submission draws on real-world clinical examples from my work as a Speech Pathologist supporƟng children and adults with severe and complex disability.
Introduction
I am a Speech Pathologist working with children, adolescents, and adults accessing the NDIS across community, home, school, and clinic settings in South Australia.
I support participants with a wide range of disabilities and support needs, including Autism, Intellectual Disability,
Global Developmental Delay, Cerebral Palsy, Down Syndrome, Stroke and Brain Injury, rare genetic syndromes,
acquired communication disorders, lifelong motor speech disorders, complex communication needs, and swallowing disorders (dysphagia). Many of the participants I support have severe and complex disability and require highly individualised, multidisciplinary, and long-term supports to safely participate in daily life.
I am writing to express serious concern regarding aspects of the proposed NDIS Future Generations Bill 2026 and the likely impact these changes may have on participants with communication disability and complex support needs.
My concerns are based on direct clinical experience supporting participants and families navigating disability every day. The people I support are among the most vulnerable members of our community. Many cannot independently advocate for themselves, manage complex administrative systems, explain changing needs, or safely function without substantial support.
Communication disability affects far more than speech. It affects safety, emotional regulation, behaviour, education, employment, healthcare access, relationships, decision-making, social participation, and independence. For many participants, communication disability exists alongside significant physical, cognitive, intellectual, sensory, neurological, and medical complexity.
I am particularly concerned about proposed changes which may reduce individualised supports, increase standardisation of planning and funding, reduce social and community participation supports, and narrow the recognition of complex disability and whole-person functioning.
In my clinical experience, the participants most likely to be adversely affected by these changes are those with the highest support needs and the least capacity to advocate for themselves.
The following submission outlines several key concerns based on the real-world experiences of participants and families I currently support through my work as a Speech Pathologist.
Key Concern 1: Loss of Individualised Supports and Increased Standardisation of Funding and Planning I am deeply concerned about proposed changes which may increase standardisation within the NDIS through funding caps, reduced flexibility, algorithm-driven planning processes, and the removal of key principles relating to individualised and person-centred supports.
In my clinical experience, Speech Pathology intervention cannot safely or effectively be delivered through standardised yearly limits, generic funding formulas, or “one size fits all” planning approaches.
Participants with communication disability and complex support needs require highly individualised supports which vary significantly depending on:
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Submission 989 May 2026
diagnosis and severity developmental stage medical complexity life transitions communication ability behavioural and emotional regulation needs family capacity and informal supports safety risks ability to participate in education, healthcare, and community life
Even participants with the same diagnosis may have vastly different functional needs and support requirements.
I am particularly concerned about the potential impact on young children with severe developmental disability requiring intensive and consistent early intervention.
Real-life clinical example I currently support a young child with Global Developmental Delay, Intellectual Disability, and a rare neurogenetic syndrome who presents with significant communication delay and high support needs across all areas of daily functioning.
This child has made slow but meaningful progress through regular Speech Pathology intervention, including increased engagement with others, increased use of gesture and non-verbal communication, emerging verbal communication skills, and improved ability to participate in family interactions and daily routines.
Importantly, regression has already been observed during periods where therapy was interrupted or reduced.
In this case, Speech Pathology support is not supplementary or optional. It is foundational to the child’s long-term communication development, emotional regulation, participation, learning, and future independence.
A standardised therapy cap or reduced flexibility within planning processes would not reflect this child’s level of need or developmental vulnerability.
Early childhood intervention is not interchangeable across participants. Some children require periods of increased support intensity during critical developmental windows. Delays or interruptions during these periods may result in loss of skills, increased long-term disability, greater educational support needs, and substantially increased long term system costs.
I am concerned that movement toward increasingly standardised funding models risks prioritising administrative efficiency over clinical need and functional outcomes.
The participants I support do not fit neatly into standardised systems. Effective disability support requires flexibility, individualisation, clinical reasoning, and recognition of the highly variable ways disability affects real people and families.
I strongly urge the Committee to retain and protect the principles of individualised planning, flexibility, and person centred support within the NDIS framework, particularly for participants with severe and complex disability.
Key Concern 2: Reduced Social and Community Participation Funding
The proposed reduction to social and community participation funding is likely to have significant unintended consequences for participants with communication disability and complex support needs.
For many of the participants I support, community participation supports are not simply recreational or social in nature. They are essential supports which enable participants to safely leave their homes, attend appointments, access healthcare and therapy services, build communication and social skills, maintain relationships, and participate meaningfully in their communities.
Many participants with significant communication disability cannot independently access the community without support workers, family assistance, or disability supports.
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Submission 989 May 2026
Real-life clinical example I currently support an adult participant with acquired communication disability following multiple strokes and seizures, who is trialling AAC (Augmentative and Alternative Communication) supports to improve communication, independence, and participation in daily life.
This participant experiences significant difficulty communicating verbally and requires highly individualised support to build confidence using AAC systems across real-world environments and interactions.
Successful AAC implementation extends far beyond therapy sessions alone. It requires ongoing support, repetition, community-based practice opportunities, collaboration with support workers and family members, and gradual development of confidence using communication systems in everyday life.
Community participation supports play a critical role in enabling this participant to: attend appointments and therapy sessions participate in community activities communicate with unfamiliar people practice functional communication skills maintain social connection and independence reduce isolation and withdrawal from the community
Without these supports, this participant would be at significant risk of increased isolation, reduced communication opportunities, reduced independence, and declining confidence participating in the community.
In my clinical experience, communication skills cannot be effectively developed or maintained in isolation within a therapy room alone. Communication is inherently social and functional. Participants require opportunities, support, and safe environments to apply these skills within everyday life.
I am concerned that substantial reductions to social and community participation funding may disproportionately affect participants with severe communication and cognitive disability who already face significant barriers to participation and inclusion.
Reducing these supports risks increasing social isolation, reducing quality of life, limiting access to therapy and healthcare services, increasing carer burden, and ultimately reducing the very participation and independence outcomes the NDIS was originally designed to support.
I strongly urge the Committee to recognise social and community participation supports as essential functional supports for many participants with communication disability and complex support needs, rather than discretionary or optional services.
Key Concern 3: Narrowing of Disability Definitions and Functional Capacity Assessment
I am concerned about proposed changes which may narrow the recognition of complex disability and whole-person functioning within the NDIS.
In my clinical experience, communication disability and complex support needs do not exist in isolated categories. Participants frequently present with multiple interacting physical, cognitive, neurological, intellectual, behavioural, sensory, communication, and medical needs which collectively affect their safety, participation, wellbeing, and independence.
I am concerned that increasingly narrow or standardised approaches to functional capacity assessment may fail to accurately reflect the realities of severe and complex disability.
Real-life clinical example I currently support an adult participant with Cerebral Palsy and significant physical, cognitive, intellectual, and communication disability who also presents with dysphagia (swallowing disorder) requiring ongoing mealtime management and swallowing safety support.
This participant requires highly individualised and coordinated support across multiple areas of daily life, including: communication support AAC support swallowing and mealtime management emotional support and reassurance
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Submission 989 May 2026
support worker training participation in community activities healthcare access assistance to express preferences, needs, and choices
These needs cannot be meaningfully separated into isolated categories. Communication difficulties directly affect this participant’s ability to express discomfort, make decisions, report symptoms, participate socially, advocate for needs, and maintain relationships.
Similarly, swallowing difficulties are not simply “medical issues”. They affect nutrition, hydration, safety, dignity, social participation, family life, and quality of life.
In these situations, Speech Pathology support is essential rather than optional or supplementary. It is directly linked to: choking risk reduction aspiration risk management safe nutrition and hydration prevention of hospitalisation support worker education communication access participation and quality of life
In my clinical experience, participants with severe disability require flexible, whole-person, and highly individualised support systems. Narrow functional assessments or rigid funding frameworks risk overlooking the complexity of how disability presents in real life.
I am particularly concerned that participants with severe communication or cognitive disability may be disadvantaged by systems which rely heavily on standardised assessment processes or narrow definitions of functional impairment.
The participants I support are not defined by a single diagnosis or impairment category. Their needs are complex, interconnected, and often change over time depending on health, support availability, life transitions, and environmental demands.
I strongly urge the Committee to ensure the NDIS continues to recognise the whole-person impact of disability and retains flexibility to support participants with severe and complex needs in ways which are safe, functional, and clinically appropriate.
Broader Concern Regarding the Direction of the NDIS Across all of these concerns, I am worried about the broader direction these proposed changes may take the NDIS. I recognise the importance of ensuring the long-term sustainability of the NDIS. However, in my clinical experience, overly standardised approaches risk poorer long-term outcomes, increased crisis presentations, and greater long term support needs for participants with complex disability.
In my clinical experience, the strength of the NDIS has been its ability, at its best, to provide flexible and individualised supports which recognise that disability affects people differently and that meaningful participation requires more than basic care needs alone.
Many of the participants I support have made significant gains in communication, participation, confidence, independence, and quality of life because they have had access to supports tailored to their individual needs and circumstances.
I am concerned that movement toward increasingly standardised systems, reduced flexibility, narrower eligibility and functional capacity definitions, and reduced community participation supports risks moving away from person centred disability support.
Participants with severe communication and complex disability often require creative, flexible, multidisciplinary, and highly individualised approaches which cannot be adequately captured through rigid funding frameworks or standardised assessment processes.
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Submission 989 May 2026
In my clinical experience, communication support is not simply about speech. It is about enabling people to participate in family life, education, healthcare, employment, decision-making, relationships, and their communities.
For many participants, these supports are directly linked to safety, dignity, autonomy, and basic quality of life.
Recommendations
I respectfully urge the Committee to consider the following recommendations: Do not pass the Bill in its current form. Substantially reconsider and amend aspects of the Bill which risk reducing flexibility, increasing standardisation, limiting participation supports, and narrowing recognition of complex disability. Retain and strengthen the principles of individualised, person-centred planning within the NDIS. Avoid broad standardised therapy caps or funding models which fail to account for the highly variable needs of participants with complex disability. Preserve flexibility within planning and funding processes to allow supports to respond appropriately to changing functional needs, developmental stages, health changes, and life transitions. Protect social and community participation funding for participants who rely on these supports to access therapy, healthcare, communication opportunities, education, employment, and community life. Ensure participants with severe communication, cognitive, physical, and swallowing disabilities are not disadvantaged by narrow functional capacity definitions or standardised assessment processes. Maintain recognition of the whole-person impact of disability, including the interaction between communication, physical health, emotional regulation, cognition, participation, and safety. Ensure Speech Pathology supports relating to communication, AAC, swallowing safety, and mealtime management continue to be recognised as essential supports for many participants with severe and complex disability. Ensure future reforms prioritise long-term functional outcomes, participation, safety, and quality of life for participants rather than administrative simplification alone.
Conclusion
The participants I support are not statistics within a funding system. They are children learning to communicate for the first time, adults working hard to maintain independence and participation despite significant disability, and families managing extraordinarily complex support needs every day.
In my clinical experience, communication and participation outcomes improve when participants receive flexible, individualised, and appropriately funded supports delivered within the context of real life and real relationships.
I am concerned that aspects of the proposed NDIS Future Generations Bill 2026 risk reducing flexibility, increasing standardisation, and narrowing recognition of the realities of severe and complex disability.
For many participants, Speech Pathology support is not optional or supplementary. It is essential to communication, safety, healthcare access, emotional wellbeing, community participation, dignity, and quality of life.
I strongly urge the Committee to carefully consider the likely real-world impact these proposed changes may have on participants with communication disability and complex support needs, particularly those with the highest support needs and the least capacity to advocate for themselves.
In its current form, I believe this Bill risks causing significant harm to participants with disability, particularly those with severe and complex support needs. I do not believe the Bill should be passed by Parliament without substantial reconsideration and amendment to protect the safety, participation, dignity, and long-term outcomes of people with disability.
Privacy: I request my name and details be withheld due to the inclusion of de-idenƟfied clinical examples involving vulnerable parƟcipants. Page 5 of 5