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Physical Disability Australia (PDA) has lodged its submission on the eight proposed new framework planning rules for the NDIS. As the national peak Disabled People’s Organisation for people with physical disability, PDA represents many of the Scheme’s longest standing and highest-needs participants – people who rely on the NDIS for daily personal care, assistive technology, home and vehicle modifications, and the supports that let them work, study, parent and participate in community life.
Here’s a summary of where PDA stands.
What PDA supports
The submission welcomes several genuine improvements in the proposed framework:
- Flexible budgets that give participants real choice and control and reduce the burden of tightly itemised plans.
- Transparency in how budgets are calculated, a direct response to years of unexplained plan decisions.
- Consistency, with a structured needs assessment process that could end the “postcode lottery”.
- Clear transition communication and a commitment to regularly review the rules.
- New plan variation pathways that could improve responsiveness if designed well.
Where the concerns lie
PDA’s central worry is sequencing. Consultation on how participants transition to and spend new plans happened before consultation on how support needs are assessed and budgets are built. In other words, stakeholders were asked to comment on the house before seeing the foundations. PDA has asked that earlier rules be re-opened once the full package is visible.
Beyond sequencing, the submission flags six key risks for people with physical disability:
- Assessment tools may fail to capture fluctuating, degenerative and complex co-occurring needs.
- Impairment notices could leave out secondary impacts such as pain, fatigue, continence, and pressure care that are central to a person’s support needs.
- “Stated supports” may reduce flexibility and delay access to high cost AT and home modifications.
- Plan variation may be too slow for people whose condition is progressing or who face sudden change.
- Budget methods may lean too heavily on averages and algorithms, without room for location, environment and individual circumstances.
- Safeguarding limits on spending may be applied too broadly, undermining choice and control.
The 15 recommendations
PDA’s recommendations are practical and specific. Highlights include:
- Release all eight rules together and co-design the Assessment and Budget Method rules with DPOs.
- Independently validate assessment tools for physical, degenerative and fluctuating disability and publish the results before rollout.
- Give participants at least 90 days’ written notice of transition, with the option to defer during hospitalisation or an AT order in progress.
- Guarantee no funding reduction solely because a participant moves to a new framework plan.
- Create a fast-track variation pathway for degenerative conditions, hospital discharge and urgent AT failure.
- Pre-approve routine AT and consumables so participants aren’t trapped in repeated quote-and-approval cycles.
- Fund independent advocacy during transition, publish disaggregated outcome data, and schedule a formal review within 12–18 months.
The bottom line
PDA’s message is that the direction is right, but the details matter enormously for people with high physical support needs. Consultation is not co-design, and rules that drive funding outcomes deserve the most scrutiny, not the least. Continuity of essential supports, transparent and reviewable decisions, and genuine responsiveness to individual circumstances must be built into the framework from the start.
