Catholic Health Australia has made a submission on New Framework Planning and proposed amendments to the NDIS Supports Transitional Rules. CHA supports a planning framework that reduces repeated assessments and gives participants greater flexibility, and the submission pays particular attention to whether assessed needs will translate into funding sufficient to purchase the support required in practice, including shared staffing costs, safe delegated care and sustainable informal support.

Assessment that recognises support already in place

CHA supports an assessment process that brings together the participant’s account, existing evidence and targeted professional assessment where required, but further explanation is needed about how these sources will be considered together. A guided conversation may provide valuable insight, and its findings must be understood in the context of the person’s daily life. Achievements made possible through assistance, established routines or clinical oversight should not be interpreted as evidence that this support is unnecessary.

Greater clarity is also needed about the modified I-CAN instrument and targeted assessment scales. The Department should publish the modifications, rating definitions, validation findings and known limitations, including their application to people with complex or fluctuating needs and diverse cultural and communication requirements. Assessors need sufficient training, time and access to specialist expertise to apply these methods appropriately.

Evidence from people who know the participant over time

In Supported Independent Living, established staff may recognise changes in behaviour, communication, health and daily functioning that are difficult to convey during a single assessment. The rules should provide a formal pathway for this evidence, alongside input from support coordinators and treating professionals, with the participant’s consent or appropriate authority. This should preserve the person’s involvement in decisions, require disclosure of relevant provider interests and ensure that significant differences between sources are explained.

Assessment requirements should also be proportionate to what remains unclear. Suitable clinical reports, behaviour support plans and service records should be reused, with further evidence requested only to resolve an identified gap, and participants told why additional information is needed, how it will be obtained and who will meet the cost.

Reports that connect evidence to funding

The assessment report should enable participants to understand how the evidence has been interpreted and how its conclusions will inform their plan. Participants should have an opportunity to review and respond to a draft before it is used to approve a plan. Scores should be accompanied by definitions, and any outstanding evidence requirements should be identified separately from a finding that support is unnecessary.

Recording a support ratio does not establish whether the combined funding will sustain the staffing needed across a household. CHA members encounter circumstances in which a change in one resident’s needs increases the staffing requirement beyond the combined funded arrangements. The Circle of Support section should also capture the duration, reliability and sustainability of informal assistance, including the carer’s willingness and capacity to continue, because frequency alone provides an incomplete basis for determining whether assistance can replace paid support.

When a replacement assessment should be available

A replacement assessment should be available where the original assessment no longer provides a reliable basis for approving a plan, whether through a change in circumstances or through limitations in the assessment itself. The rules should recognise both, so that participants are not required to demonstrate deterioration before an inaccurate assessment can be addressed. Relevant circumstances include assessment during an atypical period such as acute illness or hospitalisation, missing communication adjustments or the absence of a chosen support person, omission or misinterpretation of clinical evidence, and recording or scoring errors.

Where the discrepancy is apparent in existing records, another privately funded report should not be required simply to establish that an error has occurred. The response should be proportionate to the problem, and where an unresolved assessment places essential support or safety at risk, an urgent pathway and interim arrangements should prevent the participant from carrying the consequences of administrative delay.

Shared living and shared staffing costs

Shared living requires an explicit method for calculating and apportioning support costs. Individual assessment must remain central, while recognising that the staffing needed to support one resident can affect the household arrangement. A method that calculates the justified shared staffing requirement and apportions costs according to individual needs could operate within In-home and Community Supports, separately recognising individual assistance, avoiding double counting and preserving choice over where and with whom people live. Worked examples should address different support ratios, overnight arrangements, changing needs and temporary vacancies where the staffing required for remaining residents does not fall in proportion to occupancy.

Community participation and the informal supports offset

Participants differ in the assistance required to leave home, travel, communicate and participate safely. The Department should explain the basis of the proposed default community supports amount and how additional funding will be determined where assessed needs exceed it. CHA members have reported reduced community access and increased isolation among SIL participants despite protections for in-home support, and preserving assistance at home must be accompanied by sufficient support to sustain relationships and participation outside it. On transition, reduced service use following an earlier funding reduction should not be interpreted as evidence of reduced need.

CHA remains concerned about the proposed informal supports offset. Family involvement is a social good, and funding arrangements should sustain the relationships that support participants. Any offset must be grounded in evidence about the assistance available, its duration and reliability, the carer’s circumstances and willingness, and whether it can safely replace paid support. Regular contact alone does not establish this.

The cost of delivering complex support safely

Budgets must recognise the work required to deliver complex support safely. Training, competency assessment, clinical delegation and ongoing supervision are integral to high-intensity care, and behaviour support requires resources for implementation as well as specialist plan development. Recording that direct nursing is unnecessary must not imply that training, clinical delegation or ongoing oversight is unnecessary. Where another service system is assumed to meet a need, the calculation should identify the equivalent support available and who is responsible for resolving any gap.

Longer plans must stay responsive

Longer plans can provide stability and reduce the burden of repeated reassessment, but a plan lasting up to five years must remain responsive throughout that period. For people with degenerative, episodic or fluctuating conditions, needs may increase gradually or through repeated episodes without presenting as a single sustained decline, so a series of smaller changes should be considered cumulatively, with access to additional support before the existing arrangement becomes unsafe or a crisis develops.

Relevant changes extend beyond impairment to loss of informal care, a provider withdrawing, changed household composition or staffing requirements, and emerging clinical needs. Published timeframes should cover acknowledgement, decision and implementation, with interim funding available where essential assistance is at risk. The commitment to maintain current plans until new framework plans are approved is welcome, and providers should not be left to carry unfunded essential support while administrative processes are completed.

Changes to the NDIS supports rules

Clearer purchasing rules and access to eligible supports through ordinary retailers can improve choice and reduce administrative burden. Exclusions should account for the disability-related function of an item: proposed exclusions of electronic noise-cancelling headphones, fencing and gates may affect people who use these products for sensory regulation, safety or access, and the Department should explain how an assessed need will be met where an ordinary product performs the required function.

CHA welcomes recognition of worker training within disability-related health supports, and frontline implementation of intensive and complex behaviour support within In-home and Community Supports. Further guidance should explain how these provisions operate alongside specialist Behaviour Support and clinical services. Transport arrangements also require explanation, with worked examples distinguishing Private Vehicle Transport from transport included within another support category.

Removing replacement supports

Removing replacement supports would reduce participants’ ability to use an ordinary product or service instead of a funded NDIS support, even where it meets their disability-related needs safely and at equal or lower cost. Standard commercially available household items are the clearest category affected, particularly for people who use household products to carry out daily tasks with less paid assistance. Before removing the pathway, the Department should identify which existing approvals would no longer be available and assess the consequences for participants.

The eleven recommendations

1. Establish a transparent assessment process that uses suitable existing evidence, provides formal pathways for participant-authorised professional and provider input, and explains assessment scales and delegated care arrangements.
2. Require assessment reports to connect evidence, assessed needs and funding categories, with defined rating scales, explicit consideration of shared and delegated support, and an opportunity to correct the draft.
3. Provide proportionate correction and replacement pathways for changed circumstances and assessment deficiencies, supported by accessible requests, reasoned decisions, defined timeframes and continuity of essential support.
4. Publish and test a transparent budget methodology that addresses shared living, individual participation needs, informal care and the full cost of safe delivery, with explainable adjustments and accountable decisions.
5. Include an accessible budget explanation in each plan, showing shared support calculations and offsets, the scope of funding restrictions and practical pathways for implementation, correction and review.
6. Design variation and reassessment pathways around cumulative needs and changing support arrangements, with proportionate evidence requirements, defined response times and interim funding where essential support is at risk.
7. Implement clearer supports rules with guidance on disability-related eligibility, the funding of specialist and frontline support, and transport arrangements. Provide advance advice and continuity protections for existing approvals and services across old and new framework plans.
8. Map existing replacement approvals against the revised supports lists before removing the pathway, resolve identified gaps and protect continuity while participants obtain appropriate alternatives.
9. Publish complete worked examples connecting assessment, budget calculation and the final plan, including shared living costs, delegated health support and informal care offsets, with explanations of how participants can query decisions.
10. Provide accessible information and supported explanations through trusted services, alongside directly distributed guidance and practical briefings for providers and others assisting participants.
11. Publish an implementation plan addressing outstanding policy questions, system and workforce readiness, and coordination with other reforms. Allow sufficient time to examine the final rules and calculations before commencement, with ongoing evaluation informing updated guidance.