Challenge Community Services has provided a formal submission to the consultation on the proposed new planning framework being developed by the National Disability Insurance Agency for the National Disability Insurance Scheme.
As an organisation that works alongside people with disability, families and carers every day, we believe it is critical that policy reform is informed by real experiences. Planning frameworks must support consistency and transparency, but they must also continue to recognise the individuality of each participant and the complexity of their lives.
Our submission to the consultation reflects our commitment to advocating for a system that is fair, flexible and centred on the voices and needs of people with disability. While we support efforts to strengthen the planning process, we emphasised that these reforms must not unintentionally create barriers to the supports people rely on to live safely and independently.
Our submission focused on four key priorities:
1. A framework that preserves individualised planning
One of the strongest themes in our submission was the need to preserve genuine individualisation within any structured assessment framework.
Participants’ needs cannot be understood through impairment alone. Living arrangements, the availability of services in regional communities, the sustainability of informal supports, safeguarding risks, cultural context and fluctuating or progressive conditions all influence the supports someone requires.
While greater consistency can improve clarity across the system, it must not result in a one-size-fits-all approach.
Consistency in the planning process should not equate to uniformity in outcomes.
2. Ensuring capable and culturally responsive assessment
Assessment processes must be conducted by professionals who have the appropriate expertise to understand the complex needs of participants.
Challenge recommended clear minimum qualification requirements for assessors and, where appropriate, alignment between assessors and relevant impairment types. This helps ensure assessments are informed, accurate, and reflective of the realities participants face.
Equally important is cultural competency. Assessment tools and processes must be culturally secure and accessible so that all participants feel safe and supported to share their experiences. Participants should also retain meaningful choice in how assessments are conducted, including access to face-to-face options, particularly for people living in rural and regional communities.
3. Transparency and flexibility in funding decisions
Trust in the planning system relies on participants understanding how decisions about their supports are made.
Our submission highlighted the importance of clearly explaining how assessment outcomes translate into funding decisions. Transparency not only builds confidence in the process; it also helps reduce disputes and uncertainty for participants and their families.
At the same time, planning frameworks must remain flexible. People’s circumstances change, and the NDIS must be able to respond when support needs evolve.
4. Protecting against risk in informal support assumptions
Informal supports such as family members, friends and community networks play an important role in many participants’ lives. However, these supports should never be assumed to be permanent or sustainable.
Challenge recommended that informal supports be documented within planning processes but not relied upon as a basis for reducing funded supports. Plans must allow for timely adjustments where informal or mainstream supports change, become unavailable or are no longer safe.
A word from our Acting CEO
“At the heart of this is the participant and their family. Informal supports play an important role, but assuming families will always be able to provide care places undue pressure on them. Funded supports and subsequent plans must stand on their own. They must provide the stability, safety and flexibility needed when circumstances change, so no one is left vulnerable.”
-Julie May, Acting CEO Challenge Community Services
Continuing to elevate the voices of people with disability
Consultations like this are an important opportunity to strengthen the system by bringing together the insights of participants, families, providers, and advocates.
Challenge Community Services remains committed to contributing constructively to these discussions and ensuring that the voices of people with disability are represented in the policies that shape the future of the NDIS.
By sharing what we see every day across communities, we hope to help build a planning framework that remains transparent, responsive and genuinely centred on the people it exists to support.
You can download and read our full submission below.
