GRANN Submission to the Senate Community Affairs Legislation Committee National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission to the Senate Community Affairs Legislation Committee

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

Submitted by Gladstone Region Autistic & Neurodivergent Network Inc. (GRANN)

To the Senate Community Affairs Legislation Committee,

The Gladstone Region Autistic & Neurodivergent Network Inc. (GRANN) thanks the Committee for the opportunity to provide feedback regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

GRANN is a Queensland-based not-for-profit organisation led by and working alongside autistic and otherwise neurodivergent people, families, carers, and community members. We advocate for neurodiversity-affirming, trauma-informed, culturally responsive, and human-rights-based approaches across disability systems, education, healthcare, and community life.

Our submission draws upon lived experience, community consultation, disability scholarship, frontline advocacy concerns, and the realities faced by autistic and neurodivergent people across regional Queensland and broader Australia. We are particularly concerned about the impacts this Bill may have on:

• Autistic and otherwise Neurodivergent participants
• people with psychosocial disability and intellectual disability
• multiply disabled individuals
• rural and remote communities
• First Nations peoples
• culturally and linguistically diverse (CALD) communities
• LGBTQIA+ neurodivergent people
• women and gender-diverse people
• individuals experiencing poverty, housing instability, family violence, or institutional trauma

While GRANN acknowledges the importance of ensuring the long-term sustainability of the NDIS, sustainability cannot come at the expense of accessibility, dignity, safety, autonomy, or human rights.

We urge the Committee to carefully consider the structural, psychological, cultural, and practical consequences of the proposed reforms and to adopt the recommendations outlined within this submission.

Thank you for considering our contribution.

Sincerely,
Gladstone Region Autistic & Neurodivergent Network Inc. (GRANN)

1. Human Rights and Neurodiversity Framework

GRANN submits that all NDIS reforms must be interpreted consistently with Australia’s obligations under the United Nations Convention on the Rights of Persons with Disabilities (CRPD), including rights to autonomy, community participation, supported decision-making, freedom from discrimination, cultural safety, and equal recognition before the law.

Neurodivergence is not inherently pathological. Autism, ADHD, Tourette’s, dyslexia, intellectual disability, psychosocial disability, and other neurodevelopmental differences are part of natural human diversity. Many barriers experienced by neurodivergent people arise not from neurology itself, but from inaccessible systems, stigma, poverty, sensory-hostile environments, institutional exclusion, diagnostic inequity, and inadequate support structures.

The NDIS must therefore operate from a neuro-affirming, trauma-informed, culturally responsive, and human-rights-based framework rather than deficit-based assumptions centred on productivity, behavioural conformity, or normative functioning.

GRANN is concerned that aspects of the proposed Bill risk shifting the NDIS further toward surveillance, compliance, gatekeeping, and cost containment at the expense of participant wellbeing and inclusion.

2. Concerns Regarding Functional Capacity Assessments

GRANN holds significant concerns regarding proposals for standardised functional assessments and centralised eligibility testing.

Autism, ADHD, psychosocial disability, intellectual disability, and other neurodevelopmental differences present heterogeneously across contexts, environments, communication modes, trauma histories, sensory conditions, support access, and co-occurring disabilities. Functional capacity is not static, linear, or reliably measurable through a single deficit-based assessment tool.

Many autistic and neurodivergent people experience fluctuating functioning depending on:

• Autistic burnout
• sensory overload
• trauma exposure
• masking demands
• mental health
• chronic illness
• environmental accessibility
• social expectations
• communication stressors

A participant may appear articulate or “capable” during a brief assessment while simultaneously being unable to sustain employment, education, self-care, social participation, executive functioning, emotional regulation, or independent living over time.

GRANN is deeply concerned that standardised assessment systems may reproduce harms seen internationally where disabled people are disbelieved, retraumatised, excluded, or forced to perform distress in order to access support.

Particular risks exist for:

• women and gender-diverse Autistic people who mask heavily
• First Nations participants whose communication styles differ from dominant assessment norms
• CALD participants facing language barriers
• individuals with trauma histories
• intellectually gifted autistic people whose adaptive functioning difficulties are overlooked
• adults diagnosed later in life
• rural participants without access to specialist clinicians
• people with co-occurring psychosocial disabilities
• participants unable to afford repeated specialist reports

GRANN strongly opposes any assessment model that reduces disability access to algorithmic scoring systems, short-term observation, productivity measures, or narrow behavioural interpretations.

We recommend:

• multidisciplinary and contextual assessment processes
• strong appeal mechanisms
• participant input into assessments
• culturally safe assessment pathways
• recognition of fluctuating and invisible disability
• reduced reassessment requirements for permanent disabilities
• safeguards against automated decision-making

3. Diagnostic Gatekeeping and Socioeconomic Inequity

Access to diagnosis in Australia is profoundly unequal.

Comprehensive autism and ADHD assessments frequently cost thousands of dollars and involve waitlists exceeding 12 to 36 months, particularly in regional and rural Queensland.

Communities disproportionately affected include:

• low-income families
• First Nations communities
• CALD communities
• women and gender-diverse people
• adults missed during childhood
• people experiencing homelessness
• survivors of domestic and family violence
• people leaving institutional care
• rural and remote families

Any reform that relies more heavily upon formal diagnosis, repeated reassessment, specialist evidence, or extensive documentation risks structurally excluding people already experiencing disadvantage.

GRANN is particularly concerned about the cumulative financial and emotional burden of repeatedly requiring participants to “prove” disability permanence.

Disability support systems should not privilege those with greater financial resources, educational literacy, geographic proximity to specialists, or ability to navigate bureaucratic systems.

4. Funding Adequacy and Restrictive Cost Controls

GRANN is deeply concerned by proposed mechanisms enabling tighter funding caps, restricted support categories, and increased limitations on participant flexibility.

Supports often labelled “non-essential” are frequently the very supports preventing:

• crisis presentations
• school refusal
• family breakdown
• homelessness
• institutionalisation
• hospitalisation
• mental health deterioration
• social isolation
• suicidality

Social participation supports, sensory regulation supports, communication supports, peer supports, support coordination, therapies, and capacity-building services are not luxuries. They are foundational to autonomy, participation, dignity, safety, and long-term wellbeing.

Rigid funding caps fail to recognise that neurodivergent support needs fluctuate significantly across the lifespan and in response to stress, burnout, trauma, environmental change, and access barriers.

GRANN recommends:

• no blanket therapy caps
• participant-centred flexibility
• preservation of capacity-building supports
• legislative oversight of funding restrictions
• protections preventing plan reductions during transition periods
• preservation of participant choice and control

5. Foundational Supports and Service Gaps

GRANN is deeply concerned that proposed “Foundational Supports” remain poorly defined, inconsistently funded, and unavailable across many regional communities.

Participants risk being deemed ineligible for NDIS supports on the assumption that mainstream or foundational systems will provide assistance that does not exist in practice.

Across regional Queensland, families already face:

• severe allied health shortages
• absent autism-specific supports
• long waitlists
• inadequate school inclusion
• inaccessible mental health systems
• transport barriers
• housing shortages
• limited crisis services

Shifting responsibilities away from the NDIS without first guaranteeing accessible, enforceable, and adequately funded alternative systems risks abandoning vulnerable participants.

GRANN strongly opposes reforms that create “service cliffs” where people are assessed as too disabled for mainstream systems but not disabled enough for the NDIS.

6. Automation, Surveillance, and Privacy Concerns

GRANN holds significant concerns regarding increased automation, algorithmic decision-making, data-sharing powers, and digital surveillance mechanisms within the proposed reforms.

Automation within disability systems carries substantial risk when applied to populations whose communication, behaviour, support needs, and presentation may not align with neurotypical assumptions.

Algorithmic systems trained on incomplete or biased datasets may disproportionately disadvantage autistic and neurodivergent participants through:

• inaccurate risk flagging
• inappropriate fraud suspicion
• automated funding reductions
• inaccessible communication systems
• decontextualised behavioural interpretation
• failure to recognise fluctuating support needs

Many Neurodivergent participants already experience significant distress interacting with bureaucratic systems, unclear administrative processes, phone-based communication requirements, and compliance-heavy reporting structures.

Increased automation risks intensifying anxiety, shutdowns, disengagement, and barriers to self-advocacy.

GRANN recommends legislated safeguards requiring:

• meaningful human oversight of all automated processes
• transparent disclosure of algorithmic use
• participant rights to human review
• external auditing for bias and discrimination
• accessible explanations of decisions
• prohibition on fully automated eligibility determinations
• informed consent for data-sharing practices
• rights to correct or delete inaccurate personal information

7. Burnout, Trauma, and Reassessment Harm

Many Autistic and otherwise Neurodivergent people experience cumulative trauma through repeated reassessment, surveillance-oriented systems, disbelief, forced disclosure, and adversarial interactions with disability services.

Participants frequently report:

• needing to exaggerate deficits to access support
• fear of funding loss
• loss of dignity during assessments
• pressure to appear incapable rather than supported
• retraumatisation through repeatedly recounting trauma histories
• exhaustion navigating bureaucratic processes

Repeatedly forcing participants to “prove” permanent disability contributes to autistic burnout, mental distress, shutdowns, suicidality, and disengagement from essential services.

GRANN recommends reducing unnecessary reassessment requirements for permanent neurodevelopmental disabilities and embedding trauma-informed principles across all NDIA systems and processes.

8. First Nations Communities

First Nations autistic and neurodivergent people experience intersecting harms arising from colonisation, systemic racism, geographic isolation, child removal histories, institutional distrust, diagnostic inequity, and culturally unsafe service systems.

Western deficit-based disability frameworks may fail to recognise culturally distinct communication styles, kinship systems, sensory practices, and community-based understandings of disability and support.

Fear of institutional intervention, child protection involvement, or stigma may discourage some families from seeking diagnosis or support.

GRANN recommends:

• increased funding for Aboriginal Community Controlled Organisations
• culturally governed disability services
• culturally safe assessment pathways
• employment of First Nations neurodivergent peer workers
• community-led outreach and navigation supports
• flexible evidence requirements for remote communities

9. CALD and LGBTQIA+ Neurodivergent Communities

CALD Neurodivergent communities often experience additional barriers including:

• language access limitations
• stigma surrounding disability
• migration-related trauma
• limited understanding of the NDIS
• inaccessible information systems
• interpreter shortages

LGBTQIA+ neurodivergent people experience elevated rates of mental distress, discrimination, homelessness, bullying, family rejection, and service exclusion.

Many services remain inadequately trained in supporting people with intersecting neurodivergent, gender-diverse, and culturally diverse identities.

The NDIS workforce must therefore embed:

• Neurodiversity-affirming practice
• LGBTQIA+ inclusion
• cultural safety
• trauma-informed care
• communication accessibility
• supported decision-making principles

10. Workforce and Professional Practice Concerns

The effectiveness of the NDIS relies heavily upon the quality, knowledge, ethics, and accessibility of its workforce.

GRANN is concerned by the ongoing prevalence of deficit-based and behaviourist approaches within parts of the disability sector, including practices prioritising compliance, masking, behavioural normalisation, or suppression of autistic communication styles.

Many neurodivergent participants report harm arising from:

• coercive behavioural practices
• sensory invalidation
• infantilisation
• unsupported communication needs
• pathologising language
• restrictive practices
• inadequate understanding of autistic burnout and trauma

GRANN recommends mandatory NDIA and provider training in:

• Neurodiversity-affirming practice
• trauma-informed care
• supported decision-making
• communication accessibility
• cultural safety
• LGBTQIA+ inclusion
• alternatives to compliance-based behavioural models

Additional investment is urgently required in:

• regional workforce development
• peer-led services
• telehealth accessibility
• rural practitioner incentives
• independent advocacy services

11. Appeals, Advocacy, and Procedural Fairness

Participants must retain accessible, timely, transparent, and fair pathways to challenge NDIA decisions.

GRANN strongly opposes any reforms that reduce participant rights to review, appeal, advocacy, or procedural fairness.

Many neurodivergent participants already struggle navigating legalistic and bureaucratic systems, particularly without advocacy support.

Independent advocacy services are critically underfunded despite increasing demand.

GRANN recommends:

• guaranteed access to independent advocacy
• accessible review processes
• plain-language communication
• trauma-informed appeals systems
• funded support persons during reviews and reassessments

12. GRANN Recommendations

GRANN recommends that the Senate Committee:

1. Retain streamlined or guaranteed access pathways for Autism and permanent neurodevelopmental disabilities.
2. Prohibit fully automated eligibility and funding decisions.
3. Require human rights impact assessments for major NDIS reforms.
4. Embed neurodiversity-affirming and trauma-informed principles within legislation and policy.
5. Reduce unnecessary reassessment requirements for permanent disabilities.
6. Guarantee participant access to independent advocacy.
7. Protect participant data privacy and require informed consent for data-sharing.
8. Prevent funding reductions during transition arrangements.
9. Ensure foundational supports are genuinely funded and accessible before limiting NDIS access.
10. Mandate neurodiversity training for NDIA staff, planners, assessors, and providers.
11. Ensure assessments are multidisciplinary, contextual, culturally safe, and appealable.
12. Increase investment in regional, rural, and peer-led neurodivergent services.
13. Expand culturally safe supports for First Nations and CALD communities.
14. Ensure all reforms uphold participant autonomy, dignity, and supported decision-making rights.

GRANN acknowledges the importance of ensuring the sustainability of the NDIS. However, sustainability cannot be achieved through exclusion, surveillance, gatekeeping, service withdrawal, or shifting burden onto families and already-overstretched mainstream systems.

Autistic and otherwise Neurodivergent people deserve systems grounded in dignity, autonomy, accessibility, cultural safety, and genuine inclusion.

The proposed reforms risk deepening inequity unless significant safeguards, amendments, and community-led redesign occur.

GRANN urges the Senate Committee to carefully consider the lived realities of neurodivergent Australians and to amend the Bill to ensure the future of the NDIS remains rights-based, accessible, and genuinely supportive for future generations.

In solidarity with community,

Gladstone Region Autistic & Neurodivergent Network Inc. (GRANN)