MAIN DOCUMENT LINKS
● Evidence Table link ● NATIONAL DISABILITY INSURANCE SCHEME ACT 2013 - SECT 3 Objects of Act (Item 1) [LINK] ● What principles do we follow to create your plan? [LINK] ● Transitional rules 2024 (Item 4) [LINK] ● What does NDIS fund? (Item 7) [LINK] ● NDIS Act Section 10 criteria: [Chapter 1] ● NDIS Supports for Participants Rule 3.1(c) [LINK] ● Mainstream and community supports (item 13) [LINK]
Explanatory Notes
Links provided by Reviewer as indicated. If links or references not provided by the Reviewer we have added the Act/Rules/OGs which appear to correspond to the Reviewer statements to comparison.
Legend:
BLUE = distinguishes whats the same between the act/NDIS website and what the reviewer has written. YELLOW = Differences/discrepancies between the NDIS Act/Website and what the Reviewer has written. dark Blue = Chat GPT interpretations
128 Discrepancies (including repeats)
Is it possible that this entire template has been reworded by ChatGPT or AI directed to remove the choice and control and completely disempower the participant? ChatGPT said: Yes — it is absolutely possible, and increasingly likely, that this kind of internal review wording was either generated, assisted, or templated using AI (including large language models like ChatGPT) — but trained or directed under internal NDIA rules or cost-saving priorities, not the participant-focused lens required by the NDIS Act. Here’s why your suspicion is both valid and serious:
Basis of Decision – Internal review (s100)
I have assessed the request in accordance with section 100 of the NDIS Act and determined the following cannot be provided as they do not satisfy the requirements for funding through the NDIS. I have outlined details for each of the requests below and why they do not meet the criteria. You can find further information about these requirements in the National Disability Insurance Scheme (Supports for Participants) Rules 2013, section 34 of the National Disability Insurance Scheme Act 2013 and Our Guidelines.
I don’t agree that the Reviewer has outlined correctly:
- The requirements for funding
- The eligibility criteria
- Why they do not meet the eligibility criteria
- Has not made the decision in line with the National Disability Insurance Scheme (Supports for Participants) Rules 2013, section 34 of the National Disability Insurance Scheme Act 2013 and Our Guidelines.
| No. | Act/Rule SAYS THIS | Reviewer Says This | Discrepancies |
|---|---|---|---|
| 1.1(i) | NDIS Act Section 34(1)(c) LINK “the support represents value for money in that the costs of the support are reasonable, relative | ||
| NDIS supports need to represent Value for Money in that the Costs of support. | Act says |
National Disability Insurance Scheme Amendment (Securing NDIS For Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
| Reference | Text |
|---|---|
| 5.1(i), 6.1(i), 7.1(i), 8.1(i), 9.1(i), 10.1(i), 11.1(i), 12.1(i), 13.1(i), 14.1(i), 15.1(i), 17.1(i), 23.1(i), 24.1(i)) | to both the benefits achieved and the cost of alternative support;” |
| Not in line with Act. | |
| Act does not say “Need to“ | |
| “when compared to the benefits to be achieved.” has been added. | |
| the support are reasonable relative to both the benefits achieved and the cost of alternate support when compared to the benefits to be achieved. |
National Disability Insurance Scheme Amendment (Securing the NDIS For Future Generations) Bill 2026
Submission 4245 - Supplementary Submission The value-for-money test in section 34(1)(c) misstates the law. The NDIS Act requires that the cost of a support be reasonable relative to the benefits achieved and the cost of alternatives. It does not require a comparison of predicted benefits between competing supports. The insertion of “when compared to the benefits to be achieved” introduces a hypothetical, comparative test that is not contained in the Act and may improperly raise the bar for demonstrating value for money.
What Does NDIs Fund? Item 7
[LINK] Purchasing the support is likely to reduce the costs of funding for other supports in the long term (ndis Supports for Participants Rule 3.1(c)).“
“For example, purchasing the support is likely to reduce the cost of funding other supports in the long term.” “Costs” is made singular to “cost”, “For” is omitted. “…of the funding of supports for the participant in the long term”. appears to be adapted from a list of eight criteria (item 7)
The Example omitted.(for example, some early intervention supports may have value for money given their potential).
National Disability Insurance Scheme Amendment (Securing the NDIS For Future Generations) Bill 2026
Supplementary Submission 4245 - Page 5
15.1(ii), 17.1(ii), 23.1(ii), 24.1(ii)
s \support represents value for
to including both the direct and indirect\
money in that the costs of the avoid or delay reliance on more costly supports;\costs related to managing and
support are reasonable, relative costly supports); delivering other supports.
\to both the benefits achieved and “Cost of funding other supports” is likely to be understood more narrowly as simply the dollar amount required to fund those supports.\nThe CEO is to consider the following matters: …
The Matters Include:
(c) whether funding or provision of the support is likely to reduce the cost of the funding of supports for the participant in the long term (for example, some early intervention supports may be value for money given their potential to avoid or delay reliance on more costly supports);
The Reviewer’s version could narrow or shift the interpretation of the provision. While it may appear similar at first glance, it does not fully capture the legislative intent behind the original wording in the Act. In legal, policy, or funding decisions under the NDIS, sticking closely to the statutory language helps avoid misapplication.
She has not made a comment on the information available: The Evidence Table and OT report. [LINK]
The evidence meets the criteria because:
AT OT letter dated 18.12.24 states Risks if not provided and states it will cost more if I don’t have the support. (3.1c)
“Without this technology she will not
National Disability Insurance Scheme Amendment (Securing the NDIS For Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
The text seems to be from Principles we follow to create your plan.pdf LINK.
It removes consideration of the personal. The outcome is for the benefit of the NDIS/The Insurer, not the participant. Choice and Control has been removed from the participant and handed to the insurer (Cookie Cutter formula).
ChatGPT: Why this matters:
- ● The NDIS Act (s34) requires supports to be reasonable and necessary for the individual.
- ● A support that’s cheaper in general may not be appropriate for the person in question.
- ● Removing ‘you’ risks undermining the intent of
1.1(iii) OG – Principles we follow to create your plan.pdf LINK Repeated 2.1(iii), 5.1(iii), 6.1(iii), 7.1(iii), 8.1(iii), 9.1(iii), 10.1(iii), 11.1(iii), 12.1(iii), 13.1(iii), 14.1(iii), 15.1(iii), 17.1(iii), 23.1(iii), 24.1(iii)) when compared to alternative options that may provide you with the same outcome at a similar or lower cost I am not satisfied the requested support meets this criteria. The LINK provided by the reviewer does not include this text.
evaluations: be able to achieve her goal in a timely manner and will require increased formal support from paid support workers.” 18.12.24 OT report LINK. Evidence Table MAIN SUPPORT REPORT FOR MONITOR (Repeated 2.1(iii), 5.1(iii), 6.1(iii), 7.1(iii), 8.1(iii), 9.1(iii), 10.1(iii), 11.1(iii), 12.1(iii), 13.1(iii), 14.1(iii), 15.1(iii), 17.1(iii), 23.1(iii), 24.1(iii))
individualised funding decisions if interpreted narrowly.
1.2(i) NDIS Act Section 34(1)(d) NDIS Act Section 34(1)(d) criteria: “To meet this criteria” has been (Repeated 2.1(i), 5.2(i), 6.2(i), 7.2(i), criteria: Effective and beneficial Effective and beneficial added 8.2(i), 9.2(i), 10.2(i), 11.2(i), 12.2(i), Act NDIS Act Section 34(1)(d) To meet this criteria the support will 13.2(i), 14.2(i), 15.2(i), 17.2(i), “For the participant” has been(Repeate LINK: be, or is likely to be effective and 23.2(i), 24.2(i)) removedd 2.1(i), beneficial, having regard to current 5.2(i), “(d) the support will be, or is good practice and evidence. “and evidence” has been 6.2(i), likely to be, effective and ChatGPT added. 7.2(i), beneficial for the participant, 8.2(i), having regard to current good current good practice (standard 9.2(i), practice” methods or strategies known to 10.2(i), work well).evidence adds an extra 11.2(i), layer 12.2(i), 13.2(i), Removing “the participant” alters 14.2(i), the intention of the Act 15.2(i), 17.2(i), The modified version does change 23.2(i), the intention of the Act. It: 24.2(i)) ● Shifts away from a participant-specific test; ● Potentially narrows what qualifies as “good practice”; ● Risks excluding supports that are reasonable and necessary under the Act but lack formal evidence.
Not in line with Act.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
A visually smaller heading underneath that:
The LINK provided by the reviewer does not include this text. ChatGPT: It alters the intent by tightening the test beyond what the Act requires. Does this change the intention of the Act? ✅ Yes — it significantly alters the intent of s 34(1)(d) by:
- Introducing a higher standard of proof (“sufficient evidence to demonstrate”) than the Act requires.
- The Act says “likely to be effective and beneficial…having regard to current good practice.”
- It does not require
redacted
Is the support effective and beneficial?
LINK “When we decide if a support is effective and beneficial, we look at what is current good practice.” This means we consider if there is sufficient evidence to demonstrate the requested support is likely to be effective and beneficial for someone with similar disability support needs and assist in progressing towards NDIS goals. I am not satisfied this support meets this criteria.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
-
Requiring participants to prove or demonstrate effectiveness through a high threshold of evidence.
-
Shifting away from current good practice:
- “Current good practice” includes professional consensus, disability expertise, and sector-accepted supports — even where there is limited formal evidence.
- The reviewer replaces this broad test with a more restrictive, q uasi-clinical or academic standard.
-
Removing participant-centered language:
- Focuses on generic evidence and removes the “for the participant” framing.
- That contradicts the NDIS’s requirement that supports be judged based on individual need.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
Why These Changes Are Legally and Procedurally Problematic
-
They rewrite section 34(1)(d) of the NDIS Act:
- The Act requires only that the support be “likely to be effective and beneficial for the participant, having regard to current good practice.”
- None of the added hurdles (sufficiency, demonstration, impersonality) are part of the legal test.
-
They impose undefined thresholds:
- What is “sufficient”?
- Who decides how much evidence is enough?
- Is a therapist report enough? A clinical trial?
-
These questions highlight that the standard is being
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
A key concern with this approach relates to:
- It raises arbitrarily and potentially applied inconsistently.
- They reduce transparency and increase the participant burden: ○ Instead of a guided, goal-linked assessment, the participant is placed in the position of a proving party — like in a legal case. ○ This contradicts the participant-focused, goal-based, and choice-and-control foundations of the NDIS.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
The reviewer has inserted language that does not appear in the NDIS Operational Guideline or relevant legislation, by stating that assistive technology must reduce the need for formal supports. While value for money may be a relevant factor, it is not a mandatory condition that assistive technology reduce formal supports or lower the budget. The review decision improperly adds a new requirement that is inconsistent with the NDIS Act and Guidelines.
2. SUPPORT HRS 8 HRS PER DAY
| REPEAT ERROR | Actual NDIS Act Section 34(1)(c) LINK | REPEAT: “NDIS Act Section 34(1)(c) criteria: Value for money. LINK” |
|---|---|---|
| 2.1(i) | “the support represents value for money in that the costs of the support are reasonable relative to both the benefits achieved and the cost of alternative support;” | NDIS supports need to represent value for money in that the costs of the support are reasonable relative to both the benefits achieved and the cost of alternate support when compared to the benefits to be achieved.” |
| REPEAT ERROR 1.1(i) | Act says |
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
The template has been remade in the image of a different proof based insurance model.
Who does the comparison? Where is the criteria for the comparison? What qualifications?
ChatGPT “
when compared to the benefits to be achieved.”adds a layer of scrutiny, requiring a more detailed justification of the support’s cost based on the expected outcomes.
The reviewer’s rephrasing of the value-for-money test in section 34(1)(c) misstates the law. The NDIS Act requires that the cost of a support be reasonable relative to the benefits achieved and the cost of alternatives. It does not require a comparison of predicted benefits between competing supports. The insertion of “when compared to
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
the benefits to be achieved“ inintroduces a hypothetical, comparative test that is not contained in the Act and may improperly raise the bar for demonstrating value for money.
2.1(ii)
What does NDIS fund? Item 7
“For example, whether purchasing the support is likely to reduce the cost of funding other supports in the long term” The sentence appears to be taken from a list of eight criteria (in item 7). Added “for example”. Excluded “for”. LINK:
“purchasing the support is likely to reduce the costs of funding for other supports in the long term (NDIS Supports for Participants Rule 3.1(c)).“ LINK: > “Value for money… (c) whether funding or provision of the support is likely to reduce the cost of the funding of supports for the participant in the long term (for example, some early intervention supports may be value for money given their potential to avoid or delay reliance on more costly supports);”;
2.1(iii)
OG - Principles we follow to create your plan.pdf and when compared to alternative options that may provide the same SEE REPEAT ERROR 1.1(iii). Not in line with Act.
National Disability Insurance Scheme Amendment (Securing Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
The text seems to be from Principles we follow to create your plan. [LINK]
REPEAT ERROR 1.1(iii) when compared to alternative options that may provide you with the same outcome at a similar or lower cost. I am not satisfied the requested support meets this criteria. “you with” has been omitted. It removes the personal. The outcome is about the NDIS, not the participant. Prioritising the short term benefits of the NDIS over the requirements of the Act.
Act NDIS Act Section 34(1)(d) REPEAT:
NDIS Act Section 34(1)(d) criteria: Effective and Beneficial
REPEAT ERROR 1.2(i) “(d) the support will be, or is likely to be, effective and beneficial for the participant, having regard to current good practice.” to meet this criteria the support will be, or is likely to be effective and beneficial having regard to current good practice and evidence. “For the participant” has been removed.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Supplementary Submission 4245 - Supplementary Submission
2.5 Support budgets in your plan
The funding has been calculated in accordance with Including Specific Types of Supports in Plans Operational Guideline – Personal Care Supports (item 9) .
This guideline also states the NDIA will give consideration to your capacity in completing personal care tasks independently and whether capacity building support could assist you to build your independence.
A LINK provided by the reviewer does not include this text. The text seems to be from Support budgets in your plan . Reviewer added “This guideline also states the NDIA will give consideration to your capacity in completing personal care tasks independently and whether” - Cannot find this quote or reference on any NDIS site. Reviewer changed “help” to “could assist you to”. Reviewer excluded “and skills to help you pursue your goals.”
Feels like they excluded “skills to help you pursue your goals.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
The NDIS Act and Support Budgets in Your Plan guideline both make clear that Capacity Building Supports are designed to develop skills and independence in pursuit of a participant’s goals — not solely independence in personal care tasks.
The reviewer’s changes narrow the intended scope of capacity building, creating a new hurdle that is inconsistent with the legislation and operational guidelines.
2.7 What else do you need to know Referring to What else do you need
to know about deciding if supports meet the NDIS funding criteria? LINK \LINK Or, your disability support needs might increase or decrease over time. This may mean we consider funding more or less supports as a result.\Link Sub section: Your disability support needs might increase or decrease over time. For example, with the inclusion of support such as Occupational Therapy it is anticipated that your independence will increase and subsequently your need for formal supports will decrease. Their Link (Item 19) doesn’t show where they get the wording from. But comparing it with what we can find in the Act: Reviewer excluded “This may mean we consider funding more or less supports as a result.” Reviewer added “For example, with the inclusion of support such as Occupational Therapy it is anticipated that your independence will increase and subsequently your need for formal supports will decrease.” What they’ve done is a rhetorical sleight of hand: they borrow the neutral, balanced language from the NDIS website (which honestly acknowledges that support needs may increase or decrease) — but then only apply it to decreasing support, specifically in service of a cost-saving narrative. The reviewer reproduces NDIS language about support needs increasing or decreasing over time but applies it only to justify a future decrease in formal supports.
National Disability Insurance Scheme Amendment (Securing the NDSIS For Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
Why don’t we fund the same supports as your last plan?
We might fund different supports in your next plan. This is because we will fund supports in your plan based on how we use the NDIS funding criteria at that point in time.
Your needs and situation will most likely change over time. This means it’s likely your NDIS supports and needs for those supports will change over time.
For example, we may have funded supports to help you build your skills in a particular area. Once you have built those skills, you won’t need funding for that anymore. So, we probably won’t include that funding for those supports in your next plan.
Supports to build your skills may have met the NDIS funding criteria before, but the same supports might not meet the criteria in the future.
a misuse of participant-facing guidance. The NDIS Act and guidelines recognise that support needs may increase as well as decrease — particularly with degenerative conditions, changing environments, or emerging functional impacts.
This selective application reframes the intent of the guidance to imply that current supports are conditional on future cost savings, which is inconsistent with the law and the participant-centred foundations of the Scheme.
Why It’s So Problematic
⚠️ 1. Co-opts NDIS language for a different purpose
- The original NDIS line: “Your disability support needs might increase or decrease over time.” is balanced, participant-centered, and reflects reality.
- The reviewer copies this phrasing—but only to
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
or, your disability support needs might increase or decrease over time. This may mean we consider funding more or less supports as a result.
justify funding cuts or “anticipated reductions” in formal supports, not to acknowledge growing needs.
Silently shifts the meaning of ‘change’
![Image: Alert icon]\begin{itemize}
Misrepresents the intent of the NDIS
![Image: Alert Icon] begin{itemize}
- Using ‘decrease in support needs’ as a precondition for approving supports undermines the flexibility, dignity, and personal growth the Act was meant to support.
The NDIS Act requires supports to be effective and beneficial, not cost-reducing. This framing introduces a non-legislative funding condition, and fails to recognise that participants may require more supports over time, not just fewer.
2.10 Is supported independent living However, the evidence available Reviewer excludes: Active disability The reviewer’s definition of “direct suitable for you? How much does not demonstrate the direct support includes support” omits reference to “monitoring support,” which is clearly included in the NDIS’s own guidance. Monitoring — where a support worker supervises and can step in if needed – is essential for many participants whose support needs are intermittent, risk-based or supervision-related.
By excluding this form of support and focusing solely on whether the participant needs constant hands-on assistance, the reviewer has narrowed the definition of eligible support and failed to consider current good practice under s \\Support do you need in your hours of support requested per day. home everyday? LINK Reviewer excludes: “It might also include monitoring support, where a support worker supervises you doing things yourself and can help you if you need it.” Active disability support includes Direct support is where a Support Worker assists you to do something or does something for you. does something for you. It might Based on the evidence available, I am not satisfied your request represents value for money in achieving substantially different outcomes and will be effective and beneficial in meeting your disability needs in addition to the current good practice under Reviewer changes ‘helps you’ to“assists you”.
supports currently funded in your section 34(1)(d). plan. Furthermore, the reviewer imposes a new and unsupported requirement — that the requested support must achieve “substantially different outcomes” — which is not found in the NDIS Act. This raises the bar unlawfully and shifts focus from participant needs to bureaucratic cost justification.
3. CHIROPRACTOR
3.4 NDIS Pricing Arrangements Pricing Arrangements (item 12) Reviewer excluded: (Repeats 4.4, 5.3, 6.3, 8.3, 9.6, and Price Limits 2025-26 v1.0 LINK “where maximum medical 10.6, 11.6, 13.6) (Repeats LINK state therapy supports are intended improvement has been reached” 4.4, 5.3, These support items provide to facilitate functional improvement 6.3, 8.3, therapeutic services to and provide maintenance care where “Therapy must be aimed at Seems like the reviewer tried to 9.6, 10.6, participants (9 or older). Therapy the primary purpose is to provide adjustment, adaption, and building summarise this part of the pricing 11.6, supports are for participants with ongoing support for a participant to capacity for community arrangements, but left out a lot. 13.6) an established disability to maintain a level of functioning. participation.” facilitate functional improvement, where maximum medical “Including long term therapy/support improvement has been reached. required to achieve small incremental gains or to prevent Therapy must be aimed at functional decline.” adjustment, adaption, and building capacity for community participation. Maintenance care can be claimed against a participant’s plan, where the primary purpose is to provide
National Disability Insurance Scheme Amendment (Securing the Future for Generations) Bill 2026
Submission 4245 - Supplementary Submission
ongoing support for a participant to maintain a level of functioning including long term thrapy/support required to achieve small incremental gains or to prevent functional decline.
Transitional rules 2024 [LINK:] What does NDIS fund? (item 7)
[LINK] The Act says “generally are not” whereas Decision says “NDIS does not fund”. Chiropractic is not included on the “Not evidence based alternative and complementary therapies” list [LINK]. AHPRA Regulates Chiropractic and defines it as Evidence-Based [LINK] therefore it can be funded.
“Schedule 2 Supports that generally are not NDIS supports—- 9 – Not evidenced based—alternative and complementary therapies - The following: (a) crystal therapy; (b) tarot card reading, psychics, mediums, and clairvoyants; cuddle therapy; d) reflexology; e) aromatherapy; f) sound therapy; g) yoga therapy; h) wilderness therapy; animal therapy, including puppy therapy and goat therapy; j) hair therapy; k) alternative or complementary medicine.”
— ## Acupuncture —
Pricing Arrangements (item 12) [LINK: ] Reviewer excluded:
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Supplementary Submission
3.4 Therapeutic Services to Participants
Therapeutic services to participants (9 or older). Therapy supports are for participants with an established disability to facilitate functional improvement, where maximum medical improvement has been reached.
The primary purpose of therapy must be aimed at adjustment, adaption, and building capacity for community participation. Maintenance care can be claimed against a participant’s plan when its main goal is providing ongoing support that helps them maintain their current level of functioning including long term therapy/support needed to achieve small incremental gains or prevent further decline. “Therapy must be aimed at adjustment, adaptation, and building capacity for community participation.”
“Including long-term therapy/support required to achieve small incremental gains or to prevent functional decline.” Seems like the reviewer’s template tried to re state or summarise this part of the pricing arrangements but left out a lot.
4.6 Transitional Rules 2024 LINK:
REPEAT: As per What does NDIS fund? (item 7) LINK The NDIS doesn’t cover alternative or complementary medicine, including Acupuncture support. Changed wording / Meaning of Act: The Act says “generally aren’t” whereas Decision states
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Supplementary Submission 4245 - Supplementary Submission
(f) sound therapy; (g) yoga therapy; (h) wilderness therapy; (i) animal therapy, including puppy therapy and goat therapy; (j) hair therapy; k) alternative or complementary medicine.”
5. VOCAL THERAPY
5.1(i) Actual NDIS Act Section [ LINK] REPEAT: “NDIS Act Section 34(1)(c) criteria: Value for money.” [ LINK] REPEAT ERROR 1.1(i)
“The support represents value for money in that the costs of the support are reasonable, relative to both the benefits achieved and the cost of alternative support;”
The reviewer adds “when compared to the benefits to be achieved.“ Not in line with Act.
REPEAT: “NDIS supports need to represent value for money in that the costs of the support are reasonable relative to both the benefits achieved and the cost of alternate support when compared to the benefits to be achieved.”
5.1(ii) What does NDIS fund? Item 7 [ LINK]: REPEATED TEXT - This sentence appears to be taken from a list of eight criteria (item 7).
National Disability Insurance Scheme Amendment (Creating the NDIS For Future Generations) Bill 2026
Supplementary Submission 4245 -
the support is likely to reduce the cost of the funding of supports for the participant in the long term (for example, some early intervention supports may be value for money given their potential to avoid or delay reliance on more costly supports);”
5.1(iii)
OG - Principles we follow to create your plan. sdf LINK: when compared to alternative options that may provide you with the same outcome at a similar or lower cost I am not satisfied the requested support meets this criteria.
5.2(i)
Act NDIS Act Section 34(1)(d) LINK: “For the participant has been removed and evidence has been added.” To meet this criteria the support will be, or is likely to be effective and beneficial having regard to current good practice and evidence.
5.2(ii)
Is the support effective and beneficial? LINK: When we decide if a support is effective and beneficial, we look at what is current good practice.
with similar disability support needs They change “we look at” to “we This means we look at if there is and assist in progressing towards consider” evidence that the support works NDIS goals. for someone with similar disability I am not satisfied this support meets They add “Sufficient” support needs and assist in this criteria.” progressing towards NDIS goals” They add “to demonstrate the requested” support
They change “support works for
someone” to “is likely to be effective
and beneficial for someone”
5.3 NDIS Pricing Arrangements REPEAT: Reviewer excluded: REPEAT ERROR 3.4 and Price Limits 2025-26 v1.0 Pricing Arrangements (item 12) “where maximum medical REPEAT LINK LINK improvement has been reached” ERROR These support items provide state therapy supports are intended Seems like the reviewer tried to 3.4 therapeutic services to to facilitate functional improvement “Therapy must be aimed at summarise this part of the pricing participants (9 or older). Therapy and provide maintenance care where adjustment, adaption, and building arrangements, but left out a lot. supports are for participants with the primary purpose is to provide capacity for community an established disability to ongoing support for a participant to participation.” facilitate functional improvement, maintain a level of functioning. where maximum medical “Including long term therapy/support improvement has been reached. required to achieve small incremental gains or to prevent Therapy must be aimed at functional decline.” adjustment, adaption, and building capacity for community participation. Maintenance care can be claimed against a participant’s plan, where the primary purpose is to provide ongoing support for a participant to maintain a level of functioning
including long term therapy/support required to achieve small incremental gains or to prevent functional decline.
5.5 Fair funding to pursue your Referring to Fair funding to pursue Reviewer added “however” THIS ONE NEEDS COMMENT goals LINK your goals (item 8) LINK …However, this doesn’t mean we Intimidating. Vague. This doesn’t mean we fund all fund all support costs associated Reviewer omitted: Also, you may support costs associated with you with pursuing your goals. This is have goals and aspirations we can’t pursuing your goals. Also, you because helping you pursue your fund supports for. The reviewer’s version of this may have goals and aspirations goals is only one of the NDIS funding section removes several important we can’t fund supports for. This is criteria. The supports we fund must Reviewer omitted: This means not and humanising phrases from the because helping you pursue your meet all of the NDIS funding criteria. all supports that help you to pursue original guidance. The removal of goals is only one of the NDIS your goals will be reasonable and “you may have goals and funding criteria. This means not necessary. aspirations we can’t fund supports all supports that help you to for” and “not all supports that help pursue your goals will be Reviewer added “The supports we you pursue your goals will be reasonable and necessary. fund must meet all of the NDIS reasonable and necessary” strips funding criteria.” the context and empathy that help participants understand the intent behind funding rules.
In their place, the reviewer adds the
more rigid line “The supports we
fund must meet all of the NDIS
funding criteria,” which, while legally
correct, is presented without
context. The cumulative effect is a
statement that sounds restrictive,
impersonal, and
exclusion-focused, and does not
reflect the participant-focused
approach required by sections 3
and 4 of the NDIS Act.
NDIS Pricing Arrangements and Price Limits 2025-26 v1.0
(Repeats LINK 6.5)
In particular, these support items can only be delivered by the following specific types of professionals, and therapy assistants operating under the delegation and supervision of one of the following types of professionals…
The reviewer’s summary of the Pricing Arrangements misrepresents the original text by excluding critical components that provide participant flexibility and access. These omissions include:
- The ability for therapy assistants to deliver supports under delegation,
- The pathway for non-standard but qualified therapists to use the “Other Professional” item, and
- The clarification that not all therapy supports are restricted – only certain support items are.
Furthermore, referring to Pricing Arrangements (item 12) LINK, therapy supports can only be delivered by specific types of professionals or have been accepted by an approved quality auditor of the NDS Commission as having the relevant qualifications.
note: Therapists who do not meet the above definitions but who have been redacted should use the “Other Professional” support item.
National Disability Insurance Scheme Amendment (Securing the NDIS For Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
A single line break separates this submission from its preceding content.
The changes outlined above risk making it appear that professional qualifications and Commission approval are interchangeable, which they are not. These changes undermine the participant’s ability to access appropriate, flexible, and lawful therapy supports, and reflect a restrictive reading not supported by the actual Pricing Arrangements.
6. MUSIC THERAPY
6.1(i) Actual NDIS Act Section 34(1)(c) [LINK]
“NDIS Act Section 34(1)(c) criteria: Value for money.” [LINK] REPEAT ERROR 1.1(i) “the support represents value for money in that the costs of the support are reasonable, relative to both the benefits achieved and the cost of alternative support;“ [Reviewer adds “when compared to the benefits to be achieved.” ] Not in line with Act. NDIS supports need to represent value for money in that the costs of the support are reasonable relative to both the benefits achieved and the cost of alternate support when compared to the benefits to be achieved.
6.1(ii) What does NDIS fund? Item 7 [LINK]:
National Disability Insurance Scheme Amendment (Securing the NDIS For Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
The long term (NDIS Supports for Participants Rule 3.1(c)).“ LINK: \“Value for money… (c) whether funding or provision of the support is likely to reduce the cost of the funding of supports for the participant in the long term ((for example, some early intervention supports may be value for money given their potential to avoid or delay reliance on more costly supports);;“
6.1(iii)
OG - Principles we follow to create your plan.pdf [LINK](Principles we follow to create your plan.pdf). REPEAT: and when compared to alternative options that may provide you with the same outcome at a similar or lower cost. REPEAT ERROR 1.1(iii): when compared to alternative options that may provide the same outcome at a similar or lower cost I am not satisfied the requested support meets this criteria. Not in line with act. It Removes the personal. The outcome is about the NDIS not the participant “you with” has been omitted.
6.2(i)
Act NDIS Act Section 34(1)(d). REPEAT: NDIAct Section 34(1)(d) criteria: Effective and beneficial REPEAT ERROR 1.2(i): “For the participant” has been removed “and evidence” has been added. The LINK: To meet this criteria the support will be, or is likely to be effective and beneficial, having regard to current good practice and evidence.
Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
6.2(ii)
The LINK provided by the reviewer does not include this text. The text seems to be from Is the support effective and beneficial? REPEAT ERROR 1.2(ii): “When we decide if a support is effective and beneficial, we look at what is current good practice.” This means we consider if there is sufficient evidence to demonstrate the requested support is likely to be effective and beneficial for someone with similar disability support needs and assist in progressing towards NDIS goals. I am not satisfied this support meets this criteria. They change “we look at” to “We Consider” They add ‘Sufficient’ They add ‘to Demonstrate the Requested’ Support They Change “support works For Someone” To “is Likely to Be Effective And Beneficial For Someone”.
6.3
REPEAT: Pricing Arrangements (item 12) - Link NDIS Pricing Arrangements and Price Limits 2025-26 v1.0 LINK These support items provide therapeutic services to participants (9 or older). Therapy supports are for participants with an established disability to facilitate functional improvement where maximum medical improvement has been reached. REPEAT ERROR 3.4: Reviewer excluded:
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
The adjustment, adaption, and building capacity for community participation. Maintenance care can be claimed against a participant’s plan, where the primary purpose is to provide ongoing support for a participant to maintain a level of functioning including long term therapy/support required to achieve small incremental gains or to prevent functional decline.
6.5 Repeat Error 5.7
NDIS Pricing Arrangements and Price Limits 2025-26 v1.0 LINK
REPEAT: Pricing Arrangements (item 12) LINK, therapy supports can only be delivered by specific types of professionals or have been accepted by an approved quality auditor of the NDIS Commission as having the relevant qualifications.
in particular, these support items can only be delivered by the following types of professionals, and by therapy assistants operating under the delegation and supervision of one of the following types of professions… Note: Therapists who do not meet the above definitions but who have been accepted by an approved quality auditor of the NDIS Commission as having the relevant qualifications, expertise and experience should use the “Other Professional” support item.
National Disability Insurance Scheme Amendment (Securing the NDIS For Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
7. TRANSPORT
7.1(i)
The Actual NDIS Act Section REPEAT: “NDIS Act Section 34(1)(c) criteria:
Value for money.”
Act says ‘alternative’. Decision says ‘alternate.’
Reviewer adds ”when compared to the benefits to be achieved.” Not in line with Act.
7.1(ii)
What does NDIS fund? Item 7 LINK: REPEAT “purchasing the support is likely to reduce the costs of funding other supports in the long term (NDIS Supports for Participants Rule 3.1(c)).“ LINK: “Value for money… (c) whether funding or provision of the support is likely to reduce the cost of the funding of supports for the participant in the long term (for example, some early intervention supports may be value for money given their potential to avoid or delay reliance on more costly supports);”
7.1(iii) OG - Principles we follow to REPEAT: REPEAT ERROR 1.1(iii) The LINK provided by the create your plan.pdf LINK and when compared to alternative reviewer does not include this options that may provide the same text. The text seems to beREPEAT when compared to alternative outcome at a similar or lower cost. Not in line with act. ERROR options that may provide you with I am not satisfied the requested from Principles we follow to It Removes the personal. The 1.1(iii) the same outcome at a similar or support meets this criteria. create your plan.pdf LINK. outcome is about the NDIS not the lower cost participant. “you with” has been omitted.
7.2(i) Act NDIS Act Section 34(1)(d) REPEAT: REPEAT ERROR 1.2(i) “For the participant” has been LINK: NDIS Act Section 34(1)(d) criteria: removed Effective and beneficial REPEAT “(d) the support will be, or is “and evidence” has been Not in line with act. ERROR likely to be, effective and To meet this criteria the support will It Removes the personal. Makes it added. 1.2(i) beneficial for the participant, be, or is likely to be effective and out to be beneficial for the NDIS, not having regard to current good beneficial, having regard to current the participant. practice” good practice and evidence. Adds another hurdle by saying good practice and evidence
7.2(ii) Is the support effective and REPEAT: The LINK provided by the REPEAT ERROR 1.2(ii) beneficial? LINK “This means we consider if there is reviewer does not include this REPEAT “When we decide if a support is sufficient evidence to demonstrate text. The text seems to be from Is ERROR effective and beneficial, we look the requested support is likely to be the support effective and 1.2(ii) at what is current good practice. effective and beneficial for someone beneficial? LINK. with similar disability support needs They change “we look at” to “we This means we look at if there is and assist in progressing towards consider” evidence that the support works NDIS goals. for someone with similar disability I am not satisfied this support meets They add “Sufficient” support needs and assist in this criteria.” progressing towards NDIS goals” They add “to demonstrate the requested” support
They change “support works for
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
7.3 NDIS (Supports for NDIS (Supports for Participants) Reviewer changed “for example” to (Repeats see 18.2, 16.1) (Repeats Participants) Rule 5.1(d) LINK Rule 5.1(d) LINK: Support relates “such as“ 18.2, The NDIS is unable to provide a Reviewer changed “fees” to “bills” 16.1) “it relates to day-to-day living costs support that relates to a day-to-day This Is not in line with the act. (for example, rent, groceries cost such as rent, groceries or Reviewer changed “attributable to” Misquoting what the act says. and utility fees) that are not attributable to a participant’s disability support needs.”utility bills that are not directly relatedor caused by “directly related or caused by”. A direct quotation from this document cannot be provided here due to redaction restrictions and privacy concerns. This support is a day to day livingcost and cannot be funded by the NDSI am sorry but I can’t fulfill your request at this time because it violates my safety guidelines.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
A participant’s transport supports may include the reasonable and necessary costs of taxis or other private transport options for participants who are not able to travel independently.
The reviewer excludes key language from the NDIS Transport Operational Guideline, notably the phrase “as well as transport to and from school for students.” This exclusion creates a misleading impression that transport supports are limited only to those who cannot travel independently and does not acknowledge that school transport is an eligible, reasonable and necessary support where required.
Additionally, removing the word “also” removes the nuance that transport can be provided in combination with other support types. This narrows the meaning and contradicts the broader and more flexible approach set out in the guideline.
National Disability Insurance Scheme Amendment (Securing Our Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
7.5 Including Specific Types of Supports in Plans Operational Guideline - Transport [LINK]
\Including Specific Types of Supports in Plans Operational Guidelines – Transport [LINK] A participant will generally be able to access funding through the NDIS for transport assistance if the which states Transport Level 2 is suitable for participants who are unable to use public transport without substantial difficulty and are working or studying up to 15 hours per week, are participating in day programs and for other social, recreational or leisure activities. Based on the evidence available, Transport Level 2 is suitable for your circumstances. “A participant will generally be able to access funding through the NDIS for transport assistance if the participant cannot use public transport without substantial difficulty due to their disability” “Level 2 - the NDIS may provide $2,676 per year for participants who are currently working or studying part-time (up to 15 hours per week), participating in day programs and for other social, recreational, or leisure activities.”
7.6 Including Specific Types of Supports in Plans Operational Guideline - Transport [LINK]
Furthermore, transport is also considered an incidental cost of everyday life for most people and is therefore also considered a day-to-day living cost. “Transport is an incidental cost of everyday life for most people and, therefore, can also be considered to be a day-to-day living cost.”
8. OT 30 HOURS
8.1(i) Actual NDIS Act Section REPEAT:
The NDIS Act says “alternative”. The Decision says “alternate”. REPEAT:
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
1.1(i)
“money in that the costs of the support are reasonable, relative to both the benefits achieved and the cost of alternative support;” The NDIS supports need to represent value for money in that the costs of the support are reasonable relative to both the benefits achieved and the cost of alternate support when compared to the benefits to be achieved.”
8.1(ii)
What does NDIS fund? Item 7 [LINK]
“For example, whether purchasing the support is likely to reduce the cost of funding other supports in the long term” This sentence appears to be taken from a list of eight criteria (item 7). Added “for example”. Excluded “for”. Value for Money… (c) Whether funding or provision of the support is likely to reduce the cost of the funding of supports for the participant in the long term ( For Example: some early intervention supports may be Value for Money given their potential to avoid or delay reliance on more costly Supports);“. [LINK]
8.1(iii)
OG - Principles we follow to create your plan.pdf [LINK] > REPEAT: and when compared to alternative options that may provide you with outcome at similar or lower cost. I am not satisfied the requested text seems to be from Principles We Follow To. It Removes The Personal.
National Disability Insurance Scheme Amendment (Securing the Future Generations Bill 2026
Submission 4245 – Supplementary Submission
1.1(iii) The same outcome at a similar or lower cost supports meets this criteria. create your plan.pdf [LINK] The outcome is about the NDIS, not the participant. “you with” has been omitted.
Act NDIS Act Section 34(1)(d)
\REPEAT: Act NDIS Act Section 34(1)(d) criteria: Effective and Beneficial To meet this criteria, the support will be, or is likely to be effective and beneficial, having regard to current good practice and evidence. “For the participant” has been removed.\REMOVED “and evidence” has been added. Not in line with act. It removes the personal makes it out to be beneficial for the NDIS, not the participant. Adds another hurdle by saying good practice and evidence.
8.2(ii) Is the support effective and beneficial? [LINK] \REPEAT: “This means we consider if there is sufficient evidence to demonstrate the requested support is likely to be effective and beneficial for someone with similar disability support needs and assist in progressing towards NDIS goals.” I am not satisfied that this support meets this criteria. The LINK provided by the reviewer does not include this text. The text seems to be from is the support effective and beneficial? [LINK]. They change
National Disability Insurance Scheme Amendment (Securing the NDIS For Future Generations) Bill 2026
Supplementary Submission 4245 -
The REPEAT ERROR 3.4
These support items provide therapeutic services to participants (9 or older). Therapy supports are for participants with an established disability to facilitate functional improvement where maximum medical improvement has been reached.
Therapy must be aimed at adjustment, adaption, and building capacity for community participation. Maintenance care can be claimed against a participant’s plan, where the primary purpose is to provide ongoing support for a participant to maintain a level of functioning including long term therapy/support required to achieve small incremental gains or to prevent functional decline.
“where maximum medical improvement has been reached”: Seems like the reviewer tried to summarise this part of the pricing arrangements, but left out a lot. “Therapy must be aimed at adjustment, adaptation, and building capacity for community participation.” “Including long-term therapy/support required to achieve small incremental gains or to prevent functional decline.”
8.5 The pricing recommendations state that the NDIA fund capacity building hours based on support needs with recommendations from allied health professionals, individual circumstances, goals and risks. Travel costs are something you can negotiate with your provider, but we would not increase funding to cover travel costs to the provider. Where did she get this information from?
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
9. EXERCISE PHYSIO
The table below outlines aspects related to Exercise Physiology within the context of the National Disability Insurance Scheme.
| 9.1(i) | Actual NDIS Act Section 34(1)(c) [link] | “NDIS Act Section 34(1)(c) criteria: Value for Money [link]”. REPEAT: | | :––––– |
| : |
|---|
| : |
| –––––––––––––––––––– |
REPEAT ERROR 1.1(i) |
9.1(iii) OG - Principles we follow to REPEAT: REPEAT ERROR 1.1(iii) The LINK provided by the create your plan.pdf LINK and when compared to alternative reviewer does not include this options that may provide the same text. The text seems to beREPEAT when compared to alternative outcome at a similar or lower cost. Not in line with act. ERROR options that may provide you with I am not satisfied the requested from Principles we follow to It Removes the personal. The 1.1(iii) the same outcome at a similar or support meets this criteria. create your plan.pdf LINK. outcome is about the NDIS not the lower cost participant. “you with” has been omitted.
9.2(i) Act NDIS Act Section 34(1)(d) REPEAT: REPEAT ERROR 1.2(i) “For the participant” has been LINK: NDIS Act Section 34(1)(d) criteria: removed Effective and beneficial REPEAT “(d) the support will be, or is “and evidence” has been Not in line with act. ERROR likely to be, effective and To meet this criteria the support will It Removes the personal. Makes it added. 1.2(i) beneficial for the participant, be, or is likely to be effective and out to be beneficial for the NDIS, not having regard to current good beneficial, having regard to current the participant. practice” good practice and evidence. Adds another hurdle by saying good practice and evidence
9.2(ii) Is the support effective and REPEAT: The LINK provided by the REPEAT ERROR 1.2(ii) beneficial? LINK “This means we consider if there is reviewer does not include this REPEAT “When we decide if a support is sufficient evidence to demonstrate text. The text seems to be from Is ERROR effective and beneficial, we look the requested support is likely to be the support effective and 1.2(ii) at what is current good practice. effective and beneficial for someone beneficial? LINK. with similar disability support needs They change “we look at” to “we This means we look at if there is and assist in progressing towards consider” evidence that the support works NDIS goals. for someone with similar disability I am not satisfied this support meets They add “Sufficient” support needs and assist in this criteria.” progressing towards NDIS goals” They add “to demonstrate the requested” support
They change “support works for
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
9.6 NDIS Pricing Arrangements REPEAT: REVIEWER EXCLUDED: “where maximum medical improvement has been reached” ERROR 3.4 REPEATED. These support items provide therapeutic services to participants (9 or older). Therapy supports are for participants with an established disability to facilitate functional improvement, where maximum medical improvement has been reached.
Therapy must be aimed at adjustment, adaption, and building capacity for community participation. Maintenance care can be claimed against a participant’s plan, where the primary purpose is to provide ongoing support for a participant to maintain a level of functioning including long term therapy/support required to achieve small incremental gains or to prevent functional decline.
The reviewer seems like they tried to summarise this part of the pricing arrangements but left out a lot.
- PHYSIO
10.1(i) Actual ndis Act Section 34(1)(c) LINK REPEAT “ndis Act section 34(1)(c) criteria: Value for money.” Link Act says
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
ERROR 1.1(i)
“the support represents value for money in that the costs of the support are reasonable, relative to both the benefits achieved and the cost of alternative support;“ NDIS supports need to represent value for money in that the costs of the support are reasonable relative to both the benefits achieved and the cost of alternate support when compared to the benefits to be achieved. Reviewer adds “when compared to the benefits to be achieved.” Not in line with Act.
REPEATED ERROR 1.1(ii): The sentence appears to have been taken from Item 7 criteria list - added ‘for example’ excluded ‘for’
10.1(ii) What does NDIS fund? Item 7 LINK: REPEAT: “For example, whether purchasing the support is likely to reduce the cost of funding other supports in the long term” “purchasing the support is likely to reduce the costs of funding for other supports in the long term (NDIS Supports for Participants Rule 3.1(c)).” LINK:
Value for money…
(c) Whether funding or provision of the support is likely to reduce the cost of the funding of supports for the participant in the long term (for example, some early intervention supports may be value for money given their potential to avoid or delay reliance on more costly supports);”.
10.1(iii) OG – Principles we follow to create your plan.pdf LINK REPEAT “and when compared to alternative options that may provide the same outcome at a similar or lower cost.” The reviewer provided link doesn’t include this text; it seems like its coming from principles we follow. Not in line with act.
National Disability Insurance Scheme Amendment (Securing the NDIS For Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
ERROR 1.1(iii) options that may provide you with the same outcome at a similar or lower cost I am not satisfied the requested support meets this criteria. create your plan.pdf [LINK]. It Removes the personal. The outcome is about the NDIS not the participant. “you with” has been omitted.
10.2(i) A Act NDIS Act Section 34(1)(d) REPEAT: NDIS Act Section 34(1)(d) criteria: Effective and beneficial “For the participant” has been removed [LINK:] Not in line with act. It Removes the personal. Makes it out to be beneficial for the NDIS, not the participant. Adds another hurdle by saying good practice and evidence. REPEAT ERROR 1.2(i) “(d) the support will be, or is likely to be effective and beneficial for the participant, having regard to current good practice.” To meet this criteria the support will be, or is likely to be effective and beneficial, having regard to current good practice and evidence. “and evidence” has been added.
10.2(ii) is the support effective and beneficial? [LINK] REPEAT: “This means we consider if there is sufficient evidence to demonstrate the requested support is likely to be effective and beneficial for someone with similar disability support needs and assist in progressing towards NDIS goals.“ I am not satisfied this support meets this criteria. The LINK provided by the reviewer does not include this text. The text seems to be from Is the support effective and beneficial? [LINK]. They change
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Supplementary Submission
REPEAT ERROR 3.4
- These support items provide therapeutic services to participants (9 or older). Therapy supports are for participants with an established disability to facilitate functional improvement where maximum medical improvement has been reached.
Therapy must be aimed at adjustment, adaption, and building capacity for community participation.
Maintenance care can be claimed against a participant’s plan, where the primary purpose is to provide ongoing support for a participant to maintain a level of functioning including long term therapy/support required to achieve small incremental gains or to prevent functional decline.
LINK state therapy supports are intended to facilitate functional improvement and provide maintenance care where the primary purpose is to provide ongoing support for a participant to maintain a level of functioning.
improvement has been reached” Seems like the reviewer tried to summarise this part of the pricing arrangements, but left out a lot. “Therapy must be aimed at adjustment, adaptation, and building capacity for community participation.” – “Including long term therapy/support required to achieve small incremental gains or to prevent functional decline.”
10.9 Referring to Pricing Arrangements (item 12), Therapy support cannot be used for massage delivered directly to impact a body part or body system; as these supports are more appropriately funded by the health system. Changed “these support items” to
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Supplementary Submission 4245 - Supplementary Submission
11.1(i)
Actual NDIS Act Section REPEAT: “NDIS Act Section 34(1)(c) criteria: Value for money.” REVIEW ERROR 1.1(i): “the support represents value for money in that the costs of the support are reasonable, relative to both the benefits achieved and the cost of alternative support;“ Reviewer adds ”when compared to the benefits to be achieved.” Not in line with Act.
REPEAT REVIEW ERROR 1.1(i): The NDIS supports need to represent value for money in that the costs of the support are reasonable relative to both the benefits achieved and the cost of alternate support when compared to the benefits to be achieved.
11.1(ii)
What does NDIS fund? Item 7 LINK: REPEATS:
“For example, whether purchasing the support is likely to reduce the cost of funding other supports in the long term” This sentence appears to be taken from a list of eight criteria (item 7). Added
11.1(iii) OG - Principles we follow to REPEAT: The LINK provided by the create your plan.pdf LINK and when compared to alternative REPEAT ERROR 1.1(iii) reviewer does not include this options that may provide the same text. The text seems to beREPEAT when compared to alternative outcome at a similar or lower cost. Not in line with the Act. ERROR options that may provide you with I am not satisfied the requested from Principles we follow to It removes the personal. The 1.1(iii) the same outcome at a similar or support meets this criteria. create your plan.pdf LINK. outcome is about the NDIS not the lower cost participant. “you with” has been omitted.
11.2(i) Act NDIS Act Section 34(1)(d) REPEAT: REPEAT ERROR 1.2(i) “For the participant” has been LINK: NDIS Act Section 34(1)(d) criteria: removed Effective and beneficial REPEAT “(d) the support will be, or is “and evidence” has been Not in line with the Act. ERROR likely to be, effective and To meet this criteria the support will It removes the personal. Makes it added. 1.2(i) beneficial for the participant, be, or is likely to be effective and out to be beneficial for the NDIS, not having regard to current good beneficial, having regard to current the participant. practice” good practice and evidence. Adds another hurdle by saying good practice and evidence
11.2(ii) Is the support effective and REPEAT: The LINK provided by the REPEAT ERROR 1.2(ii) beneficial? LINK “This means we consider if there is reviewer does not include this REPEAT “When we decide if a support is sufficient evidence to demonstrate text. Thai text seems to be from ERROR effective and beneficial, we look the requested support is likely to be Is the support effective and 1.2(ii) at what is current good practice. effective and beneficial for someone beneficial? LINK. with similar disability support needs They change “we look at” to “we This means we look at if there is and assist in progressing towards consider” evidence that the support works NDIS goals. for someone with similar disability I am not satisfied this support meets They add “Sufficient” support needs and assist in this criteria.” progressing towards NDIS goals” They add “to demonstrate the requested” support
They change “support works for
National Disability Insurance Scheme Amendment (Securing the NDIS For Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
Someone” to “is likely to be effective and beneficial for someone“
11.6 NDIS Pricing Arrangements and Price Limits 2025-26 v1.0
The following applies:
REPEAT ERROR 3.4
These support items provide therapeutic services to participants (9 or older). Therapy supports are for participants with an established disability to facilitate functional improvement, where maximum medical improvement has been reached.
Therapy must be aimed at adjustment, adaption, and building capacity for community participation. Maintenance care can be claimed against a participant’s plan, where the primary purpose is to provide ongoing support for a participant to maintain a level of functioning including long term therapy/support required to achieve small incremental gains or to prevent functional decline.
Pricing Arrangements (item 12)
LINK state therapy supports are intended to facilitate functional improvement and provide maintenance care where the primary purpose is to provide ongoing support for a participant to maintain a level of functioning.
Reviewer excluded: “where maximum medical improvement has been reached”. Seems like the review summarised this part of the pricing arrangements but left out a lot. “Therapy must be aimed at adjustment, adaptation, and building capacity for community participation.” “Including long term therapy/support required to achieve small incremental gains or to prevent functional decline.”
12. PODIATRIST
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Supplementary Submission 4245 - Supplementary Submission
12.1(i)
Actual NDIS Act Section REPEAT: “NDIS Act Section 34(1)(c) criteria: Value for money.” REPEAT ERROR 1.1(i): “the support represents value for money in that the costs of the support are reasonable, relative to both the benefits achieved and the cost of alternative support;“ REVIEWER adds ”when compared to the benefits to be achieved.” Not in line with Act.
NDIS supports need to represent value for money in that the costs of the support are reasonable relative to both the benefits achieved and the cost of alternate support when compared to the benefits to be achieved.
12.1(ii)
What does NDIS fund? Item 7 LINK:
“purchasing the support is likely to reduce the costs of funding for other supports in the long term” Added “for example”. Excluded “for” REPEATS from a list of eight criteria (item 7).
LINK:
Value for money…
(c) whether funding or provision of the support is likely to reduce the cost of the funding of supports for the participant in the long term (for example, some early intervention supports may be value for money given their potential to avoid or delay reliance on more costly supports);
12.1(iii) OG - Principles we follow to REPEAT: REPEAT ERROR 1.1(iii) The LINK provided by the create your plan.pdf LINK and when compared to alternative reviewer does not include thisREPEAT options that may provide the same text. Thai text seems to beERROR when compared to alternative outcome at a similar or lower cost. Not in line with act. 1.1(iii) options that may provide you with I am not satisfied the requested from Principles we follow to It Removes the personal. The the same outcome at a similar or support meets this criteria. create your plan.pdf LINK. outcome is about the NDIS not the lower cost participant. “you with” has been omitted.
12.2(i) Act NDIS Act Section 34(1)(d) REPEAT: REPEAT ERROR 1.2(i) “For the participant” has been LINK: NDIS Act Section 34(1)(d) criteria: removed Effective and beneficial REPEAT “(d) the support will be, or is “and evidence” has been Not in line with act. ERROR likely to be, effective and To meet this criteria the support will It Removes the personal. Makes it added. 1.2(i) beneficial for the participant, be, or is likely to be effective and out to be beneficial for the NDIS, not having regard to current good beneficial, having regard to current the participant. practice” good practice and evidence. Adds another hurdle by saying good practice and evidence
12.2(ii) Is the support effective and REPEAT: The LINK provided by the REPEAT ERROR 1.2(ii) beneficial? LINK “This means we consider if there is reviewer does not include this REPEAT “When we decide if a support is sufficient evidence to demonstrate text. Thai text seems to be from ERROR effective and beneficial, we look the requested support is likely to be Is the support effective and 1.2(ii) at what is current good practice. effective and beneficial for someone beneficial? LINK. with similar disability support needs They change “we look at” to “we This means we look at if there is and assist in progressing towards consider” evidence that the support works NDIS goals. for someone with similar disability I am not satisfied this support meets They add “Sufficient” support needs and assist in this criteria.” progressing towards NDIS goals” They add “to demonstrate the requested” support
They change “support works for
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
someone” to “is likely to be effective and beneficial for someone“
12.6 - NDIS (Supports for Participants)
\ NDIS (Supports for Participants) Rule 5.1(b) [LINK]
A support will not be provided or funded under the NDIS if: (b) it is not related to the participant’s disability; or. \ NDIS (Supports for Participants) Rule 5.1(b) [LINK]: Support is not related to the participant’s disability. The link provided does not include any of what she wrote below the first sentence. The source of this information was from NDIS website: is the support related to your disability?. The reviewer has changed the wording as well: ‹ Reviewer changed “we’ll only” to “the NDIS can’t”. ‹ Reviewer added “it’s not”. ‹ Reviewer changed “your” to “the participants”. ‹ Reviewer added
to both the benefits achieved and the support are reasonable relative the cost of alternative support;” to both the benefits achieved and the cost of alternate support when compared to the benefits to be achieved.”
13.1(ii) What does NDIS fund? Item 7 REPEAT: This sentence appears to be taken REPEAT ERROR 1.1(ii) LINK: “For example, whether purchasing from a list of eight criteria (item 7) REPEAT the support is likely to reduce the ERROR “purchasing the support is cost of funding other supports in the Added “for example” 1.1(ii) likely to reduce the costs of long term” Excluded “for” funding for other supports in the long term (NDIS Supports for Participants Rule 3.1(c)).” LINK:
“Value for money…
(c) whether funding or provision of
the support is likely to reduce the
cost of the funding of supports for
the participant in the long term
(for example, some
early intervention supports may
be value for money given their
potential to avoid or delay
reliance on more costly
supports);”
13.1(iii) OG - Principles we follow to REPEAT: REPEAT ERROR 1.1(iii) The LINK provided by the create your plan.pdf LINK and when compared to alternative reviewer does not include this options that may provide the same text. Thai text seems to beREPEAT when compared to alternative outcome at a similar or lower cost. Not in line with act. ERROR options that may provide you with I am not satisfied the requested from Principles we follow to It Removes the personal. The 1.1(iii) the same outcome at a similar or support meets this criteria. create your plan.pdf LINK. outcome is about the NDIS not the lower cost participant. “you with” has been omitted.
National Disability Insurance Scheme Amendment (Securing the Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
13.2(i)
Act NDIS Act Section 34(1)(d) The LINK: https:// NDIS Act Section 34(1)(d) criteria: Effective and Beneficial
(d) the support will be, or is likely to be, effective and beneficial for the participant, having regard to current good practice
to meet this criteria the support will be, or is likely to be effective and beneficial, having regard to current good practice and evidence.
ERROR 1.2(i): “For the participant” has been removed.
Not in line with act. It Removes the personal. Makes it out to be beneficial for the NDIS, not the participant. Adds another hurdle by saying good practice and evidence. “and evidence” has been added.
13.2(ii)
is the Support Effective and Beneficial? LINK “When we decide if a support is effective and beneficial, we look at what is current good practice.” REPEAT ERROR 1.2(ii).
The LINK provided by the reviewer does not include this text. The text seems to be from Is the support effective and beneficial? LINK. They change
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Supplementary Submission 4245 - Supplementary Submission
ERROR 3.4
These support items provide therapeutic services to participants (9 or older). Therapy supports are for participants with an established disability to facilitate functional improvement, where maximum medical improvement has reached.
Therapy must be aimed at adjustment, adaption, and building capacity for community participation.
“Including long term therapy/support required to achieve small incremental gains or to prevent functional decline.”
A summary of this part of the pricing arrangements but left out a lot.
13.8 Supports That Are Not NDIS Supports (Item 7)
Referring to What does NDIS fund? (item 7), the NDIS does not fund time-limited recovery oriented services and therapies where the predominant purpose is treatment directly related to the person’s health status, including pain management. This support is more appropriately provided by Mainstream and community support (item 13). Added “including pain management” Item 7 does not state anything about NDIS not supporting Pain Management. Chronic pain is seen as a disability that can be funded by NDIS if its permanently disabling and all medical avenues have been explored: There was a tribunal that found chronic pain is a disability.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
rrehabilitation or post-acute care.” “In this instance, chronic pain conditions were determined to be a disability for the purposes of the NDIS. However, in this case, on the basis that there are suitable treatment options (which are most appropriately provided by the public health system) that had not been fully explored, the AAT decided not to overturn the original decision because JM’s disability was not considered permanent.”
another tribunal case [LINK] “Given the findings of permanency, being a severe disability and that the Applicant suffers constant and disabling pain, together with the fact that there are supports that the Applicant will require which cannot be provided by the healthcare system or commonly used items as contended by the Respondent, the Tribunal finds that on the preponderance of evidence the Applicant is likely to require support under the NDis for her lifetime within the meaning of section 24 (1)(e).”
Additionally - Supports that are not “NDIS Supports” [LINK]: “Equipment or assistive products prescribed or issued as a result of
National Disability Insurance Amendment (Securing the Future Generations) Bill 2026
Supplementary Submission 4245 - Supplementary Submission
A knee brace issued following an acute knee ligament injury after sport or gardening accident.
14. DIETICIAN
14.1(i) Actual NDIS Act Section 34(1)(c)
“the support represents value for money in that the costs of the support are reasonable relative to both the benefits achieved and the cost of alternative support;”
The support needs to represent value for money in that the costs of the support are reasonable, compared with the benefits to be achieved. Reviewer adds ”when compared to the benefits to be achieved.”
REPEAT ERROR 1.1(i): Not in line with Act.
14.1(ii) What does NDIS fund? Item 7 [Link]
“purchasing the support is likely to reduce the costs of funding other supports in the long term” For example, whether purchasing the support is likely to reduce the cost of funding other supports in the long term.
**REPEAT ERROR 1.1(ii). Added
National Disability Insurance Scheme Amendment (Securing the NDIS For Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
(c) whether funding or provision of the support is likely to reduce the cost of the funding of supports for the participant in the long term (for example, some early intervention supports may be value for money given their potential to avoid or delay reliance on more costly supports).“;
14.1(iii)
The OG - Principles we follow to create your plan.pdf REPEAT: and when compared to alternative options that may provide you with the same outcome at a similar or lower cost. I am not satisfied the requested support meets this criteria.
14.2(i)
Act NDIS Act Section 34(1)(d) LINK: “For the participant” has been removed
REPEAT:
“To meet this criteria the support will be, or is likely to be effective and beneficial, having regard to current good practice and evidence.”
14.2(ii)
Is the support effective and beneficial?LINK REPEATE:
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
1.2(ii) at what is current good practice. effective and beneficial for someone with similar disability support needs and assist in progressing towards NDIS goals. bенeficial? [LINK] They change “we look at” to “we consider” I am not satisfied this support meets this criteria.” They add “Sufficient”. They add “to demonstrate the requested” support They change “support works for someone” to “is likely to be effective and beneficial for someone”
14.6
NDIS (Supports for Participants) Rule 5.1(b) [LINK]
A support will not be provided or funded under the NDIS if: (b) it is not related to the participant’s disability; or? is the support related to your disability? [LINK] We’ll only fund a support if it relates to your disability. This means there must be a direct link between your disability support needs and the NDIS supports we fund. We consider if the support addresses your disability support needs.
REPEAT: NDIS (Supports for Participants) Rule 5.1(b) LINK: Support is not related to the participant’s disability. The NDIS can’t fund a support if it’s not related to the participant’s disability. There must be a direct link or a connection between the disability and the supports funded. We look at whether the support addresses disability support needs. This support is not related to the participant’s disability and cannot be funded by the NDIS.
The link provided does not include any of what she wrote below the first sentence. The source of this information was from NDIS website: Is the support related to your disability?. The reviewer has changed the wording as well:
- Reviewer changed “we’ll only” to“the NDIS can’t”.
- Reviewer added
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
- Reviewer changed “consider if” to “look at whether”
- Reviewer omitted “your”
15. NECK BRACE/ COLLAR
15.1(i) Actual NDIS Act Section REPEAT:
Act says “alternative”. Decision says “alternate.” REPEAT ERROR 1.1(i)
34(1)(c) LINK “NDIS Act Section 34(1)(c) criteria:
Value for money. LINK Not in line with Act.
REPEATERROR “the support represents value for Reviewer adds ”when compared to
1.1(i) money in that the costs of the the benefits to be achieved.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
The text below relates to page 61 of an official document.
Principles we follow to create your plan.pdf LINK
- OG - Principles we follow to create your plan.pdf [LINK]
REPEAT: and when compared to alternative options that may provide the same outcome at a similar or lower cost I am not satisfied the requested support meets this criteria. The reviewer notes: The
redactedprovided by the reviewer does not include this text. The text seems to be from Principles we follow to create your plan.pdf [LINK]. “you with” has been omitted. REPEAT ERROR 1.1(iii) Not in line with act. It Removes the personal. The outcome is about the NDIS not the participant.
Act NDIS Act Section 34(1)(d): Effective and beneficial
- Act NDIS Act Section 34(1)(d) – “(d) the support will be, or is likely to be, effective and beneficial for the participant, having regard to current good practice.” To meet this criteria the support will be, or is likely to be effective and beneficial, having regard to current good practice and evidence. REPEATED TEXT: NDIS Act Section 34(1)(d) criteria: Effective and Beneficial The reviewer notes:
“For the participant” has been removed and “evidence” has been added. REPEAT ERROR 1.2(i) Not in line with act. It removes the personal. Makes it out to be beneficial for the NDIS, not the participant. Adds another hurdle by saying good practice and evidence.
National Disability Insurance Scheme Amendment (Securing the NDIS For Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
15.2(ii)
The text seems to be from Is the support effective and beneficial?
“When we decide if a support is effective and beneficial, we look at what is current good practice. This means we look at if there is evidence that the support works for someone with similar disability support needs and assist in progressing towards NDIS goals“
REPEAT: “This means we consider if there is sufficient evidence to demonstrate the requested support is likely to be effective and beneficial for someone with similar disability support needs and assist in progressing towards NDis goals.” I am not satisfied this support meets this criteria.
National Disability Insurance Scheme Amendment (Securing the Future for Generations) Bill 2026
Submission 4245 - Supplementary Submission
The Participants) Rule 5.1(d) LINK “it relates to day-to-day living costs (for example, rent, groceries and utility fees) that are not attributable to a participant’s disability support needs”
NDIS (Supports for Participants) Rule 5.1(d) LINK: Support relates to day-to-day living costs.
The NDIS is unable to provide a support that relates to a day-to-day living cost such as rent, groceries or utility bills that are not directly related or caused by a participant’s disability support needs. This support is a day to day living cost and cannot be funded by the NDIS.
“such as” Reviewer changed “fees” to “bills” This Is not in line with the act. Misquoting what the act says. Reviewer changed “attributable to” to “directly related or caused by”.
Assistive Technology (item 17)
LINK “When we talk about assistive technology, we mean equipment, technology and devices that help you do things you can’t do because of your disability. Or things that help you do something more easily or safely.”
REPEAT: Assistive Technology (item 17) LINK means equipment, technology and devices that help you do things you can’t do because of your disability, assist you to increase your independence and reduce your need for formal supports.
The link provided by the reviewer does not include the highlighted part of the sentence. Seems to be added?
Supports that are not “NDIS Supports”
LINK: “Standard furniture, fixtures or fittings. For example, lounges, beds, fire alarms, blinds.”
What does NDIS fund? (item 7) GP and Neurologist Recommended Organizing Drawers on Wheels LINK the NDIS does not fund standard furniture. NDIS Act Section 10 criteria LINK (Chapter 1): outlines supports, services and items which can and cannot be purchased using NDIS funds. DOES NOT MENTION
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
The support represents value for money in that the costs of the support are reasonable, relative to both the benefits achieved and the cost of alternate support;“ NDIS supports need to represent value for money in that the costs of the support are reasonable relative to both the benefits achieved and the cost of alternate support when compared to the benefits to be achieved.
What does NDIS fund? Item 7: “purchasing the support is likely to reduce the costs of funding other supports in the long term (NDIS Supports for Participants Rule 3.1(c)).” Value for money… (c) whether funding or provision of the support is likely to reduce the cost of the funding of supports for the participant in the long term for example, some early intervention supports may be value for money given their potential to avoid or delay reliance on more costly supports);
og - Principles we follow to create your plan.pdf link and when compared to alternative options that may provide the same text. The text seems to be redacted.
National Disability Insurance Scheme Amendment (Securing the NDIS For Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
The following errors have been noted:
- REPEAT ERROR 1.1(iii):
- when compared to alternative options that may provide you with the same outcome at a similar or lower cost.
- I am not satisfied the requested support meets this criteria.
- from Principles we follow to create your plan.pdf [LINK]. “you with” has been omitted. It Removes the personal. The outcome is about the NDIS, not the participant.
REPEAT ERROR 17.2(i): Act NDIS Act Section 34(1)(d) LINK: NDIS Act Section 34(1)(d) criteria: Effective and Beneficial Not in line with act. It removes the personal. Makes it out to be beneficial for the NDIS, not the participant. Adds another hurdle by saying good practice and evidence
REPEAT ERROR 1.2(i): “(d) the support will be, or is likely to be, effective and beneficial for the participant, having regard to current good practice.” To meet this criteria the support will be, or is likely to be effective and beneficial, having regard to current good practice and evidence.
REPEAT ERROR 17.2(ii): Is the support effective and beneficial? [LINK] “When we decide if a support is effective and beneficial, we look at what is current good practice. This means we look at if there is evidence that the support works for someone with similar disability support needs and assist in progressing towards NDIS goals” REPEAT: “This means we consider if there is sufficient evidence to demonstrate the requested support is likely to be effective and beneficial for someone with similar disability support needs and assists in progressing toward NDS goals”. I am not satisfied this support meets this criteria. The LINK provided by reviewer does not include this text. The text seems to be from Is the Support Effective And Beneficial? [LINK]. They change
Assistive Technology (item 17)
The link provided by the reviewer REPEAT ERROR 1.3 REPEAT “When we talk about assistive LINK Assistive Technology (item 17) does not include the highlighted part ERROR 1.3 technology, we mean equipment, AssistIVE TECHNOLOGY (ITEM 17) LINK means equipment, technology and devices that help you do things you can’t do because of your disability, assist you to increase your independence and reduce your need for formal supports. teCHNOLOGY AND DEVICES THAT HELP YOU DO THINGS YO CAN’T DO BECAUSE OF YOUR DISABILITY OR THINGs That HELp yOU dO SOMETHINg MORE EASILY Or SAFELY.”
Recliners and lift chairs
“To work out whether an electric NDIS support for you we require evidence that assists us to determine if the recliner chair will be effective and beneficial in meeting your needs in the long term, can be used safely by yourself and whether lower cost options have been explored that could assist you to achieve the same or similar outcomes.” Reviewer summarises information about the evidence needed for a “recliner chair” into just: “We require evidence“ Reviewer
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
A lift chair also needs to show it’s value for money. This may include giving us evidence from a therapist or clinician that shows either:
- a comparable support, such as a more standard chair, would not be adequate in meeting Brenda’s disability support needs
- the lift chair would likely reduce the long-term cost of other supports, for example home care support hours.”
18. WHITEBOARD
The following text repeats information previously presented on this page regarding funding guidelines under Rule 5.1(d):
NDIS (Supports for Participants) Rule 5.1(d): Support relates to day-to-day living costs.
The NDIS is unable to provide a support that relates to a day-to-day living cost such as rent, groceries or utility bills that are not directly related or caused by a participant’s disability support needs. This support is a day to day living cost and cannot be funded by the NDIS.
National Disability Insurance Scheme Amendment (Securing the Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
The following text discusses assistive technology.
“When we talk about assistive technology, we mean equipment, technology and devices that help you do things you can’t do because of your disability. Or things that help you do something more easily or safely.”
A discussion on what is funded under NDIS:
Assistive Technology (item 17) LINK means equipment, technology and devices that help you do things you can’t do because of your disability; assisting to increase independence and reduce need for formal supports.
Supports not considered ‘NDIS Supports’. LINK: “Standard household items including garden), appliances tools and products such as dishwashers, fridges washing machines non-modified kitchen utensils crockery food processors electric toothbrushes floor rugs beanbags standard mattresses bedding”
What does NIDS fund? (Item 7): “The NDS doesn’t fund standard household items. The Act Section 10 criteria outlines services/items which cannot be purchased using NDIA funds.” A Whiteboard isn’t a typical Household Item. It wasn’t explicitly stated in the list, nothing from this example resembles a whiteboard.
The Reviewer did not explain how it was determined a whiteboard would qualify as an item within a home when directly linked with disabilities - nor why any direct relationship between these two factors are irrelevant.
“Whiteboards used during music composition – post its & magnets have been effective at helping Catherine organise thoughts support information processing memory while composing opera. When Catherine starts creating musical notation mobile white board featuring staves will assist her memory improve info process.”
her to use a range of postures”.
18.7 Examples of employment …The evidence available reports you The link provided by the Reviewer (Repeats see 22.7, 21.7, 20.7, 19.8) supports that are not NDIS does not contain the wording stated. utilise a whiteboard to develop the (Repeats supports LINK opera. As per What does NDIS see 22.7, Work specific aids and equipment The link that the reviewer provided This was the basis for refusal to fund? (item 7) LINK, the NDIS does21.7, you need for your disability to does not include “work specific aids fund multiple supports related to not fund work-specific aids and20.7, perform your work tasks, and equipment” or mentions of a Catherine’s ongoing goal of 19.8) including modified hardware and equipment required to perform a job. “job”. composing an opera. software This is the responsibility of Mainstream and Community The wording provided by the They have not considered the OT supports to provide (item 13) LINK. Reviewer is not contained in the link report: provided by the Reviewer. “Catherine is not currently able to This wording only appears and only work due to her impairments but is in part in Examples of employment highly motivated to continue to supports that are not NDIS perform and compose music where supports LINK which information possible.” the reviewer did not provide There is nowhere that the evidence Notwithstanding this, the Reviewer states Catherine is doing a job. changed the end of the sentence in that section and added required to This appears to be a sleight of hand perform a job. - an excuse to refuse.
They do not define “job” anywhere.
19. SIT/ STAND DESK
19.6 Assistive Technology (item 17) REPEAT: The link provided by the reviewer LINK Assistive Technology (item 17) does not include the highlighted part REPEAT ERROR 1.3 REPEAT “When we talk about assistive LINK means equipment, technology of the sentence. Seems to be ERROR technology, we mean equipment, and devices that help you do things added? 1.3 technology and devices that help you can’t do because of your you do things you can’t do disability, assist you to increase your
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
A redacted
The evidence available reports you utilise a height adjustable desk whilst working on your opera. As per what does NDIS fund? (item 7) link, the NDIS does not fund work-specific aids and equipment required to perform a job. This is the responsibility of Mainstream and Community supports to provide (item 13).
ROLLER PENS
Assistive Technology (item 17) LINK: When we talk about assistive technology, we mean equipment, technology and devices that help you do things you can’t do because of your disability; assist you to increase your independence and reduce your need for formal supports.
National Disability Insurance Scheme Amendment (Securing the Future Generations Bill 2026
Submission 4245 - Supplementary Submission
things that help you do something more easily or safely.”
20.7 Examples of Employment Supports That Are Not NDIS Supports [LINK]
The evidence available reports …The evidence available reports you utilize roller pens* to develop the opera. As per what does NDIS fund? (Item 7) [LINK], the NDIS does not fund work-specific aids and equipment required to perform a job. This is the responsibility of Mainstream and Community supports to provide (Item 13) [LINK].
Could not find words in reviewers given link, found words in examples of employment supports that are not NDIS supports [LINK] *All words are the same as 18.5 except for height adjustable deck being changed to ‘roller pens’ Reviewer changed the end of sentence.
21. Sticky Notes
Assistive Technology (item 17)
[LINK] “When we talk about assistive technology, we mean equipment, technology and devices that help you do things you can’t do because of your disability assist you to increase your independence and reduce your need for formal supports.“
The link provided by reviewer does not include highlighted part of the sentence seems to be added?
REPEAT: Assistive Technology (item 17)[LINK] means equipment, technology and devices that help you do things you cannot do due to disabilities assists you increasing independence reducing needs for formal support.
20.7 Examples of Employment Supports That Are Not NDIS Supports [LINK]
The evidence available reports …The evidence available reports you utilize sticky notes* to develop opera As per what does NDIS fund? (Item 7) [link], The NDIS doesn’t funds work-specific aids & equipments required perform job This is responsibility Mainstream Community Support provide.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
Maintream and Community supports to provide (item 13)
MAGNETS
Assistive Technology (item 17) LINK The link provided by the reviewer does not include the highlighted part of the sentence. REPEAT: Assistive Technology (item 17) LINK means equipment, technology and devices that help you do things you can’t do because of your disability, assist you to increase your independence and reduce your need for formal supports. “When we talk about assistive technology, we mean equipment, technology and devices that help you do things you can’t do because of your disability. Or things that help you do something more easily or safely.”
Examples of employment supports that are not NDIS supports LINK
Work specific aids and equipment you need for your disability to perform your work tasks, including modified hardware and software.
REPEAT: …The evidence available reports you utilise magnets* to develop the opera. As per What does NDIS fund? (item 7) LINK, the NDIS does not fund work-specific aids and equipment required to perform a job. This is the responsibility of Mainstream and Community supports to provide (item 13).
All words are the same as 18.5 except “height adjustable desk” being changed to
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
to both the benefits achieved and the cost of alternative support;“ the support are reasonable relative to both the benefits achieved and the cost of alternate support when compared to the benefits to be achieved.”
23.1(ii)
What does NIS fund? Item 7 - REPEAT: “For example, whether purchasing the support is likely to reduce the cost of funding other supports in the long term”. This sentence appears to be taken from a list of eight criteria (item 7). Added “for example”. Excluded “for”. LINK: “Value for money… (c) Whether funding or provision of the support is likely to reduce the cost of the funding of supports for the participant in the long term ( for example, some early intervention supports may be value for money given their potential to avoid or delay reliance on more costly supports);”.
23.1(iii)
OG - Principles we follow to create your plan.pdf LINK REPEAT: And when compared to alternative options that may provide the same outcome at a similar or lower cost I am not satisfied the requested support meets this criteria. The LINK provided by the reviewer does not include this text. The text seems to be from Principles we follow to create your plan.pdf LINK. You with has been omitted. Not in line with act. It Removes the personal. The outcome is about the NDIS not the participant.
23.2(i) Act NDIS Act Section 34(1)(d) REPEAT: REPEAT ERROR 1.2(i) “For the participant” has been LINK: NDIS Act Section 34(1)(d) criteria: removed Effective and beneficial REPEAT “(d) the support will be, or is “and evidence” has been Not in line with act. ERROR likely to be, effective and To meet this criteria the support will It Removes the personal. Makes it added. 1.2(i) beneficial for the participant, be, or is likely to be effective and out to be beneficial for the NDIS, not having regard to current good beneficial, having regard to current the participant. practice” good practice and evidence. Adds another hurdle by saying good practice and evidence
23.2(ii) Is the support effective and REPEAT: The LINK provided by the REPEAT ERROR 1.2(ii) beneficial? LINK “This means we consider if there is reviewer does not include this REPEAT “When we decide if a support is sufficient evidence to demonstrate text. The text seems to be from Is ERROR effective and beneficial, we look the requested support is likely to be the support effective and 1.2(ii) at what is current good practice. effective and beneficial for someone beneficial? LINK. with similar disability support needs They change “we look at” to “we This means we look at if there is and assist in progressing towards consider” evidence that the support works NDIS goals. for someone with similar disability I am not satisfied this support meets They add “Sufficient” support needs and assist in this criteria.” progressing towards NDIS goals” They add “to demonstrate the requested” support
They change “support works for
someone” to “is likely to be effective
and beneficial for someone”
23.3 NDIS (Supports for REPEAT: The link provided does not include REPEAT ERROR Participants) Rule 5.1(b) LINK NDIS (Supports for Participants) any of what she wrote below the first 12.6 REPEAT “A support will not be provided or Rule 5.1(b) LINK: Support is not sentence. The source of this
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
The NDIS can’t fund a support if it’s not related to the participant’s disability. There must be a direct link or connection between the disability and the supports funded.
We look at whether the support addresses disability support needs. This support is not related to the participant’s disability and cannot be funded by the NDIS.
A review of wording changes:
- Reviewer changed “we’ll only” to “the NDIS can’t”
- Reviewer added “it’s not“
- Reviewer changed “your” to “the participant’s”
- Reviewer added “or a connection”
- Reviewer changed “your” to “the”
- Reviewer changed “NDIS supports we fund” to “supports funded”
- Reviewer changed “consider if” to “look at whether”
- Reviewer omitted “your”
Assistive Technology (item 17)
LINK REPEAT: Assistive Technology (item 17) LINK means equipment, technology and devices that help you do things you can’t do because of your disability; assist you to increase your independence and reduce your need for formal supports. The link provided by the reviewer does not include the highlighted part of the sentence. Seems to be added?
Specialist Support Coordination
Act says
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4245 – Supplementary Submission
The support represents value for money in that the costs of the support are reasonable relative to both the benefits achieved and the cost of alternate support;“ NDIS supports need to represent value for money in that the costs of the support are reasonable, relative to both the benefits achieved and the cost of alternate support when compared to the benefits to be achieved.“ Reviewer adds “When compared to the benefits to be achieved.”
What does NDIS fund? Item 7 LINK: “For example, whether purchasing the support is likely to reduce the cost of funding other supports in the long term” This sentence appears to be taken from a list of eight criteria (item 7) Purchasing the support is likely to reduce the costs of funding for other supports in the long term (NDIS Supports for Participants Rule 3.1(c)). LINK: “Value for money… (c) Whether funding or provision of the support is likely to reduce the cost of the funding of supports for the participant in the long term (for example, some early intervention supports may be value for money given their potential to avoid or delay reliance on more costly supports);”. OG - Principles we follow to create your plan.pdf LINK The LINK provided by the reviewer does not include this text. The text seems to be from Principles we follow to… and when compared to alternative options that may provide the same outcome at a similar or lower cost.
National Disability Insurance Scheme Amendment (Securing the NDIS For Future Generations) Bill 2026
Submission 4245 - Supplementary Submission
ERROR options that may provide you with I am not satisfied the requested create your plan.pdf [LINK] 1.1(iii) the same outcome at a similar or lower cost. “you with” has been omitted.
Act NDIS Act Section 34(1)(d):
REPEAT: Not in line with act. [LINK] NDIS Act Section 34(1)(d) criteria: “(d) the support will be, or is Effective and Beneficial l Likely to be, effective and beneficial It Removes the personal. Makes it fOr the participant’s been removed out to be beneficial for the NDIS, not to meet this criteria the support will To adds another hurdle by saying good anD evidence“ has been added. bE, Or Is Likely To Be Effective And practice and evidence Beneficial, having regard to current Good Practice and Evidence.
Is The Support Effective and Beneficial? LINK?
REPEAT “This means we consider if there is reviewer does not include this text. The Text seems to be from IS The Link provided by the Error “When We Decide If A Support Is sufficient evidence to demonstrate the Requested support is likely to be THE SUPPORT EFFECTIVE AND 1.2 (ii)Effective and Beneficial, WE look At What Is Current Good Practice.”effective and beneficial For someone BENEFICIAL [link]. They change ‘we Look at” TO ‘We Consider’ this Means We LOOK AT IF THERE IS With similar disability support needs they add