The MAJOR Concerns with the Reform Bill
Functional Eligibility:
NDIS is already meant to look at impairment, not label, but they don’t – they look at the label in an attempt to justify minimizing supports, by taking a functional capacity assessment that states 12-19 hours of support required per day, and saying “well, this person has 4 disability level conditions, and 3 medical – so we will fund 2 hours a day”
They already ignore actual levels of impairment, even after someone has had to prove EACH listed disability as meeting all the disability criteria, namely permanence (have tried all treatments available and appropriate) and significant impairment caused and lifetime support required for it…
Which leads into my next point, changes to access – AN ATTACK ON POOR AND MIDDLE INCOME DISABLED PEOPLE
Schedule 1 Part 8 and 9
The changes they want to make under section 25A, means that if a person cannot afford to access a treatment, or they would need to fly and stay in another state to try the treatment (even if they can’t afford it) – they will be denied access. So this is doing exactly the opposite of what auntie Pauline has suggested, it’s not means testing NDIA so that people who need it most can access it – it is punishing poor people for not being able to afford the treatment.
And to show you the extent of this disgusting suggestion, I’ll again use the example of someone with complex and multiple disabilities:
A person has autism, they have PTSD because they were forced to do uncomfortable things and mask all their life and OCPD as a response to that fear of “doing it wrong” as they had always been screamed at for it and punished. Whether or not we agree that all of these directly relate to autism is immaterial, the point is that all of these can be debilitating. Now they need to seek out each medical and non-medical treatment available. Public health has years long waitlists, if you even get in at all (I was referred a year ago for ECT and have heard nothing back, the ECT is to address the depression/PTSD that “may” cause fibromyalgia or FND.
Medicare
Gives only 5 sessions per calendar year for specialists (OT, speech, dietician, physio, ect)
National Disability Insurance Scheme Amendment (Securing the NDIS For Future Generations) Bill 2026
Submission 4254
10 Sessions for psychology
FND requires the “neuro” version to ensure they don’t worsen the condition; autism requires a specialist in autism and likely PDA who is also trauma informed.
Let’s say each requires 6 months of OT, speech and physio…
Explain to me exactly how this should happen?
And perhaps an equally major concern, is whether a treatment is deemed appropriate if it reduces for example PTSD impairment, but causes insomnia so severe that sleeping tablets can’t counteract it… or causes OCD to go into overdrive and has the patient pulling out large patches of their hair every day for hours at a time…
The reason NDIS has “blown out” and is so much larger than Medicare is because Medicare DOES NOT take care of the chronically ill, nor those between disability and chronic illness.
It also doesn’t provide for the stepping stone to be able to access NDIS – the ability to get a functional capacity assessment done (8-15 hours of OT)
Better Alternatives to address the concerns – TARGET PROVIDERS FIRST, not participants
Scaled pay rates for sole traders and other businesses without overheads like rent and utilities of an actual office/clinic
the NDIS has “Price Limits”, which most providers use, and misrepresent, as the set rate. There is no competition in any of the markets in NDIS, and greed drives people out of direct employment and into self-employment, meaning companies struggle to retain sufficient choice of workers for participants, and greedy individuals charge twice their worth in any other industry unqualified and inexperienced.
Example using support workers:
Actual worth on SCHADS (casual rate to account for leave) + superannuation + $1/hour for business costs (insurance is less than 50c/hr for full time hours).
Why so little? Because that’s all the additional cost they require over 38 hours a week. The taxpayer isn’t there to subsidize their desire to work less than that while ripping off people with disabilities because they already pay 9.09% less in employment related expenses than employees do—because they don’t charge GST but can claim it back on expenses.
National Disability Insurance Scheme Amendment Bill 2026
Submission 4254
Level 1 SCHADS Employees
off the street with an ABN only, maybe a police check if participants are lucky. $32.875 casual $36.82 including superannuation Charging the maximum $70.23 means they are wasting $32.41 per hour of taxpayers’ money. Over 46 weeks (so assuming they use all the sick and annual leave they accrue), that’s $56,652.68 per year PER WORKER of wasted taxes The text “per worker” appears bold on page image. That means 1 individual working hard to earn around $190,000 per year is paying JUST THE EXCESS that one of these people are overcharging disabled people. Assuming only 1,000 of these workers exist (and we all know that they actually make up closer to the majority), that’s $56.6 million in wasted taxes alone.
Level 2 SCHADS employees
Cert 3/4 or sufficient industry experience required (which many sole traders don’t even have) Fair cost is $45.3455 Over 46 weeks (so assuming they use all the sick and annual leave they accrue), that’s $43,498.98 per year PER WORKER of wasted taxes The text
National Disability Insurance Scheme Amendment (
Securing the NDIS for Future Generations ) Bill 2026 Submission 4254
So just in support workers, in an example where qualification standards are reversed, we have nearly $2 Billion wasted.
This is also based on the community rate, not even home care, and only week day daytime rates, consider:
$98.83 Saturday
$127.43 Sunday
$156.03 Public holiday rate profits
Now, they may argue that it doesn’t take into account note taking time, which brings me to my next recommendation…
Audit invoices and inform participants properly, instead of stating “the provider knows”.
Note taking is charged by SOME/MOST (but not all) therapists DOUBLE.
They fraudulently charge 1 hour face to face and then spend anywhere between 40- 50 minutes doing actual face to face, and then charge another anywhere between 15-30 minutes of note taking/planning. When questioned why the session is shorter than billed, they will say “the hourly rate provides for note taking and planning”… Which is true, as in the maximum rate is what it is to account for UNBILLABLE admin tasks like notes. And notes (and any other non-face-to-face tasks) may only be billed if it is PARICIPANT NEED, NOT legal requirement, business policy, compliance or standard practice.
Yet providers big and small, therapy, support coordination and support work alike, bill for note taking and tell participants it is a requirement (NDIA, legal or otherwise).
Therapists bill $193.99/hour
Support work rates are in the first recommendation.
Between 15 and 30 minutes are billed PER SHIFT/SESSION for notes to cover themselves, not for participant needs.
You can do the calculations on taxpayer funds wasted on this.
Travel to and from Participants
Mobile therapists not only don’t have occupancy costs (rent, utilities, ect), but then charge the maximum rate AND travel. If a business makes the choice to only work in
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4254
the community, why should they be paid for travel time when there is no option to go to a clinic.
They are already covered with the profit from saving on overheads and occupancy, more than covered.
Sole Trader support workers and mobile therapists pretend their home is their “usual place of work”, despite participants arguing that the community is their “usual place of work” and they can only charge between participants – unless they work more than 50% of the time in their home. Paid work, not admin, note taking (billed or unbilled).
Clarification has been sought in writing several times, each time conflicting. Set the record straight in the next Pricing Arrangements and Price Limits
Mandatory calculation of actual cost of running their vehicle for each business/provider, and they can only claim that much from participant plans
As with many other sections, the expectation that participants should negotiate, when there is a significant imbalance of power, is a ridiculous expectation from NDIA
Self-management flaw
Complaints about the cost of plan managers and how participants should self- mange, are overshadowed by the fact that ‘SM participants do not have to hold to PAPL’. What does this mean?
- Providers take this to mean THEY don’t have to keep to PAPL
- Participants get rorted more and faster
NDIA-management flaw
Unless it has recently changed, providers can simply upload invoices and these simply get paid. No checks and balances, no seeing whether services were actually rendered with participant or nominee.
Calculate that fraud
Other price gouging/fraudulent charging methods
domestic and household assistance charged as personal care (which is shower, toilet, feeding, etc) at $70.23 instead of $59.06 or $58.03
National Disability Insurance Scheme Amendment (Securing the NDIS For Future Generations) Bill 2026
Submission 4254
The requirement to bill ACCURATELY leads to 4 hour shifts that have SCP, domestic assistance and personal care in it – charged at one flat rate in the highest category possible.
It also leads to “incremental charging” where mostly support coordinators and support workers will bill in 10, 15, 30 minute or 1 hour increments – regardless of whether it was a 2 minute call. Or it will be 2 minute call billed as 15 minutes because they updated notes or their CRM (unbillable admin). This is a persistent issue.
“Minimum shift” fraud, where providers will state (despite the code of conduct disallowing it) they will only do 2 hours minimum – or even 4. This removes choice and control, once in the agreement, participants feel locked in and even if they do try to change it – will be charged the minimum regardless, or will be left without support.
It also includes cleaners and gardeners who will bill 2 hours plus 30 minutes travel as a minimum, despite “being in the area” that day.
So participants whose integrity or knowledge cannot be bent, go without supports, because they will not let their funds be rorted and they feel a duty to the taxpayers that fund their supports. Others fold, because their need for support drives them to – or because they believe these people should be paid that.
I had a gardener quote me $142.45 for what took 2 people 20 minutes the last time I had gardening services. Privately, he charges $70/hr
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4254
Double dipping on cancellation providers charging cancellation (or travel) fees, depite filling the worker’s shift with other billable work or not needing to pay the worker.
Participants working as supports that they deliver under NDIS… I know… I WNOW you are thinking what the damn hell!? But yes, participants have cleaning, gardening, social and community participation, support coordination and personal c care funded – but somehow can provide some or all of these supports to others… at those same maximum rates.
Now this is where people get angry with autistic people on the NDIS, and as an audistic person, I understand completely. Because they want to argue body doubling or “just because I can do for others paid, doesn’t mean I can for myself for free”, or “disabled people can work in any industry they want” or even “working does n’t p preclude you from NDIS support…”
All those things are true, the question is – should it be? Is it reasonable and ecessary to fund cleaning for a professional cleaner? Is it reasonable and ecessarily to fund any form of support work for someone who can do it for others, der their own business entity no less? I think not. Not when we are looking at c cutting whole groups of participants because of too much funding being used. When in there are people who can’t work, study or maintain a livable home and at risk of losing their children because of it.
Does this contradict my main statement to target providers before participants? No, it does not.
Mobility, incontinence and other disability supports all overpriced because NDIS pays for it – an attitude many will rub in disabled people’s faces “it’s not your money, it’s taxpayer money, you don’t own it”… “so give it to me” is the silent entitled attitude.
Cleaners $38/hr for the public and then $58/hr for NDIS – no change in services
Psychologist $170/hr and NDIS $232 plus notes
Sensory toys that are now no longer funded, were 2-2.5x the RRP and when it stoppped being funded “massive clearance sales” that were still more than RRP at toy stores.
Lack of qualifications
Support Coordinators level 1 and 2 require NO QUALIFICATION, level 1 maximum (meaning what they all charge) is $80.06/hr and level 2 $100.14/hr
Create a qualification for this position, just like we have bookkeeping qualifications and childcare ones where we create policies, forms, reports and practice
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4254
implementing theory. Mandatory annual training and updates that are face to face so that participants don’t need to educate them.
A poll should be taken to determine how many participants had funds drained due to Support Coordinator actions and subsequently experienced plan reviews independently. My last experience involved an attempt to bill something ridiculous—10 hours solely for onboarding purposes (for reference: onboarding isn’t billable; most individuals receive approximately 12 funding hours annually). When requesting detailed breakdowns, she remained vague and eventually terminated services with me. Subsequently, a termination report was generated containing false statements and opinions contradicting four professional assessments — accompanied by another attempted billing of two additional hours related to this matter. Furthermore, I must mention that this occurred immediately prior to a crucial requested review where no copy was provided because she knew I would challenge its inaccuracies based on available evidence.
The Local Area Coordination (LAC) call center staff and planners often struggle providing accurate or consistent advice regarding plans, permissible activities under Participant Access Plans (PAPL), what can/cannot be funded within those plans, required treatment trials before any given condition is addressed – enabling all treatments to be explored. Participants are directed towards Plan Managers or providers when inquiring about provider charges:
“Hello! Can you confirm whether the service being charged aligns with approved guidelines?” “Oh well, contact your Provider directly.”
”I’m checking if they have committed fraud - could you please advise? ”
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 4254
each NDIS worker in any position and any structure needs to register with NDIA, have an accessible file that confirms police checks etc.
Thriving kids
My understanding is that this will manage autistic kids through school… what about the many who are homeschooled out of necessity?
Lastly, stop making it difficult for families to support their own people
The government takes taxes to redistribute in a “play god” method; there should be a sovereign wealth fund from profits of the country’s resources for those who need it.
Disabled and unemployed family members should be tax deductions for any of their families so they can fairly survive at the tax rates they would have if each of them earned the money themselves. This used to be somewhat accomplished by trusts but now that $55,000 distributed to a disabled family member is taxed at 30% instead of their individual actual effective rate of <10%
Forcing people to beg for scraps from the government.
I say again: this bill and many of the budget changes are to destroy low-income earners.