The APS has made a submission to the Senate Community Affairs Legislation Committee’s Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.
While the APS recognises that there is a need for a financially sustainable NDIS, our submission raises serious concerns about provisions in the Bill and the process by which this Bill has been developed. We are concerned that these reforms would harm participants, undermine the role of psychologists and other NDIS providers, and weaken the foundations and intent of the Scheme itself.
Our concerns about process
The APS is troubled by the speed at which this legislation is being progressed. Reforms of this scale, affecting more than 750,000 participants, demand thorough consultation with professional bodies, participants, and the disability community. This has not occurred and is not planned. Several key measures in the Bill have been developed without any specific consultation. The Bill also defers critical details to future rules that have not yet been developed or scrutinised. Overall, the Bill’s approach is disproportionate how it seeks to improve the financial sustainability of the Scheme. The harms to participants and the Australian community which will emerge from the implementation of the Bill have not appropriately recognised.
Key points in our submission
- "All Appropriate Treatment": The proposed requirement that prospective participants exhaust all appropriate treatment before accessing the NDIS is practically and professionally unworkable for people with psychosocial disability, intellectual disability, and neurodevelopmental conditions like autism. It ignores real-world barriers including the inappropriateness and limits of Medicare services, workforce shortages, and geographic inequity. These reforms also reflect a biomedical model that is inconsistent with neurodiversity-affirming practice and contemporary understandings of disability which should underpin the NDIS.
- Direct Causation: The Bill replaces the existing legislative requirement that a NDIS support must directly address the functional limitations of a participant’s disability. The proposed stricter "direct and immediate" cause requirement will harm participants with co-occurring mental health conditions, where eligible and ineligible impairments interact in complex, clinically inseparable ways.
- Evidence Hierarchy: The Bill's proposed ranking of evidence, which places population-level evidence from randomised control trials (RCTs) above demonstrated individual outcomes, is inconsistent with how evidence-based psychological practice actually works. It will lead to the defunding of individually tailored and effective interventions. There is also a significant risk of the misapplication of evidence for Aboriginal and Torres Strait Islander peoples. Proposed caps on therapy intensity (such as 25 hours per discipline per year) are an administrative override of professional judgment.
- SCCP Budget Cuts: A proposed 50% cut to Social, Civic and Community Participation budgets will hit participants with psychosocial disability hardest. For people living with severe and persistent mental illness, community participation is not a lifestyle add-on; it is a core part of evidence-based psychosocial recovery.
The APS is calling on the Committee to recommend the delayed commencement of key provisions until adequate consultation has occurred, that the Bill establish a formal standing role for professional bodies in the development of NDIS rules, and for the Department to conduct a targeted impact assessment on participants with psychosocial disability before these changes take effect.
We will continue to engage with the Committee, the Department of Health, Disability and Ageing, and the NDIA on this Bill and in our ongoing advocacy for a principled, sustainable and evidence-based NDIS.
View submission