Updated September 2026 — from official government guidance

The NDIS Amendment (Securing the NDIS for Future Generations) Act 2026 received Royal Assent on 20 August 2026. New plan reassessment and variation rules commenced on 27 August 2026.

On 1 October 2026 the Minister will make two instruments that formally commence the funding reset and establish the high support needs safeguard pathway.

Source: Australian Government Department of Health, Disability and Ageing, Funding changes for NDIS supports: Safeguards for high support needs participants, September 2026.

Full detail on the funding reset rollout is also available on the Department’s Funding changes for NDIS supports page.

From 1 October 2026 the Australian Government is resetting funding for two categories of NDIS support. This will affect all participants who receive funding for these supports. A separate safeguard pathway has been created for participants with the highest and most complex support needs to ensure they continue to have enough funding to maintain 24-hour disability support safely. This article explains exactly who qualifies, how the pathway works and where a Functional Capacity Assessment strengthens an application.

Download the NDIS form

The current official form for this pathway is linked below so it is easy to find and download.

OFFICIAL NDIA FORM

Download: Plan Variation Request Form

Use this for a minor, urgent or short term change to a participant’s current plan, without a full reassessment.

What is changing from 1 October 2026?

In the 2026-27 Budget the Australian Government announced it would reset funding for two NDIS support categories. The reset applies progressively over 12 months as each participant’s plan is created, reassessed or renewed. It does not change every plan on the same date.

• Social, economic and community participation supports: reduced by 50 per cent. This category was previously referred to as social, civic and community participation supports.
• Improved daily living skills supports: reduced by 10 per cent. This category was previously referred to as capacity building daily activities supports.

The reset only applies to these two categories. Participants continue to receive their current funding until their plan is next created, reassessed or renewed. The NDIA will notify participants before their plan is affected.

Which supports are exempt from the funding reset?

The following support types are not affected by the funding reset and will remain at their current funding levels.

• Supports in the home
• Home and vehicle modifications
• Personal mobility equipment
• Continence and menstrual products
• Specialist Disability Accommodation
• Employment supports
• Disability related health supports
• High intensity supports
• Intensive and complex behaviour supports
• High intensity social, economic and community participation supports
• Customised and wearable technology
• Hearing services

What is the high support needs safeguard pathway?

For some participants the funding reset would create a genuine gap in their 24-hour disability support arrangements. The government has created a specific plan variation pathway to protect these participants. This pathway allows eligible participants to apply to have their funding restored to a level that safely maintains their 24-hour support.

The pathway is not automatic. The NDIA cannot initiate it. The participant or their nominee must apply within 90 days of the funding reset being applied to their plan. If a participant does not have a nominee, they can be assisted by a support worker or advocate to submit the application.

The NDIA may extend the 90 day application window by written notice in exceptional circumstances.

Who qualifies as a high support needs participant?

A participant qualifies as a high support needs participant for this pathway if all three of the following conditions apply.

• Their combined budget for Assistance with Daily Life, Home and Living and Assistance with Social, Economic and Community Participation was $215,030 or more before the funding reset was applied. This figure is equivalent to what 24-hour support at a 1:3 shared ratio typically costs and is used as an objective measure of whether a participant receives near round the clock funded support.
• They receive 24-hour funded NDIS supports for needs arising directly from the impairments they access the NDIS for. This means NDIS funded supports available throughout the day and night which can include a combination of shared supports, individual supports and overnight assistance.
• Those 24-hour supports are delivered at a shared support ratio of at least 1:3, meaning one support worker is shared across no more than three participants at any given time. More intensive arrangements such as 1:1 support also qualify.

Participants living in residential aged care facilities are unlikely to be eligible for this pathway because 24-hour disability supports continue through the aged care facility itself.

A gap worth understanding before you rely on this pathway

Look closely at the second criterion. It is not enough for a participant to need support around the clock. The support they need has to already be funded and delivered by the NDIS across that full 24-hour period.

Picture a participant whose evenings or nights are currently covered by a parent or partner rather than a paid support worker. That family member is doing real, often exhausting, work and the participant’s underlying disability may call for exactly the same level of support whether it comes from a funded worker or an unpaid relative. Under this pathway, only the funded portion counts. A participant in this position can be turned away from the safeguard even though their support needs are just as significant as someone whose hours are entirely paid.

The rule sitting behind this pathway is made through a legislative instrument and instruments of this kind remain open to Parliamentary scrutiny after they are made. For Occupational Therapists, this is a reason to document informal support hours precisely in an assessment, distinct from funded hours so the true shape of a participant’s 24-hour needs is on the record regardless of who currently provides them.

What does “shared support ratio” mean?

A support ratio describes how many participants are supported by a single support worker at one time. A 1:3 ratio means one support worker supports three participants simultaneously. A 1:1 ratio means one support worker is dedicated to a single participant at all times. The NDIA uses the support ratio to assess the intensity, frequency and level of support a participant requires because of their disability.

What test does the NDIA apply before approving the variation?

Even if a participant meets the definition of a high support needs participant the NDIA will only approve a variation if both of the following are true.

• The funding remaining after the reset is not enough to safely maintain 24-hour disability supports.
• The funding remaining is not enough to maintain the support ratio that was previously considered reasonable and necessary for the participant’s disability support needs.

Where a genuine gap is confirmed the NDIA calculates the additional funding required to close it. The increase can only apply to Assistance with Daily Life and Home and Living supports. It cannot be applied to the two reduced categories and cannot exceed the amount originally cut from the participant’s plan.

Decision timeframes

Once an application is received the NDIA has 21 days to decide whether the participant meets the definition of a high support needs participant. If eligible the NDIA has a further 21 days to decide whether to vary the plan. The NDIA can notify the participant if additional time is needed.

How is the application actually made?

Because this pathway operates as a plan variation the application is made using the same form the NDIA uses for every plan variation request, not a separate high support needs form.

The current version of the form can be downloaded directly from the NDIA: Plan Variation Request Form.

If a participant’s situation instead calls for a full plan reassessment, for example where their broader support needs have changed on an ongoing basis the correct form is the Plan Reassessment Request Form.

The NDIA’s general guidance on how a plan variation works is available at What is a plan variation on ndis.gov.au.

Why does a Functional Capacity Assessment matter for this pathway?

Whether a genuine support gap exists after the funding reset is not a simple arithmetic calculation. It depends on the specific hours of support a participant requires across different times of day and different settings the support ratio needed at each point and the direct link between those support requirements and the participant’s eligible disability impairments.

A Functional Capacity Assessment completed by an independent Occupational Therapist provides exactly this clinical detail. A well structured assessment documents the following.

• The specific hours and intensity of support required across morning, daytime, evening and overnight periods with the support ratio needed at each.
• Why the participant’s support requirements arise directly from their eligible impairments rather than from unrelated circumstances.
• Whether the level and nature of support required varies across different environments such as the home and community settings.
• The safety implications of a reduced support ratio for a participant with high and complex support needs.

Because the NDIA’s decision depends on comparing the support ratio genuinely required against what remains funded after the reset, clinical evidence that sets out this detail clearly by time of day and by setting provides the strongest foundation for a successful variation application.

Plan ahead: the 90 day clock starts from your next plan change, not from 1 October 2026

The funding reset applies to each participant’s plan when it is next created, reassessed or renewed. The 90 day window to apply starts from that date, not from 1 October 2026.

Families and support coordinators supporting a participant with high and complex needs are encouraged to commission a current Functional Capacity Assessment before a scheduled plan reassessment or renewal. This means a variation application can be prepared promptly if a gap emerges.

Contact Sina OT as soon as a plan reassessment or renewal is approaching.

What does this look like in practice?

The Department’s own guidance illustrates how the variation test is applied with two worked examples. Two adapted scenarios show how a genuine gap is calculated and approved and how an application can fail even when someone technically meets the eligibility criteria.

Scenario: a genuine gap is identified and funded

A participant living in Supported Independent Living has a large plan that funds 24-hour support across a mix of ratios, including some hours drawn from his community participation budget. When his plan is reassessed, his community participation funding is cut by half under the reset. Because he had been relying on that funding to help cover part of his at-home support the reduction leaves a genuine two hour daily gap in his 24-hour arrangements. His nominee applies for a variation and the NDIA calculates the specific extra funding needed to close that two hour gap at the support ratio he actually requires and adds it back into his home and living budget rather than his community participation budget. The increase is capped at the amount originally cut.

Scenario: eligibility alone is not enough

A second participant has complex needs and clearly meets the high support needs definition. However, her community participation funding was already classified and funded as high intensity support which is exempt from the funding reset entirely. When her plan is renewed, only a small amount is trimmed from an unrelated, unaffected part of her budget and her 24-hour arrangements are not touched. Her nominee applies for a variation, but because no actual gap exists in her funded 24-hour support the application is declined. Meeting the eligibility definition is necessary, but it is not sufficient on its own. The NDIA still needs to see a genuine funding shortfall against the support ratio already considered reasonable and necessary.

Do you always need a brand new Functional Capacity Assessment?

Not necessarily and it helps to be precise about what “current” actually means here since the NDIA does not apply one single rule across every situation.

What “current” actually means, by purpose

Plan reassessment: evidence must be dated within 4 months of the request and after the current plan was approved. This is a fixed, stated rule in the NDIA’s guidelines.

Plan variation, including this high support needs pathway: there is no fixed recency rule. The NDIA’s guidance simply requires evidence to be current enough to support the specific change being requested which is a matter of judgement rather than a set number.

General access and eligibility evidence: NDIA guidance describes this as generally no older than 12 months, worded as guidance rather than an absolute cutoff.

A report several years old is not automatically invalid outside a reassessment, but the further it sits from the participant’s current presentation the less weight it carries and the more likely a delegate is to ask for something more recent regardless of the technical rule.

If a participant already has a Functional Capacity Assessment that still accurately reflects their presentation, but it was not written with this specific safeguard pathway in mind, a full new assessment is not always the right starting point.

In this situation an addendum letter can often do the job instead. An addendum draws on the findings, clinical reasoning and evidence already established in the original assessment and adds the specific detail the high support needs pathway requires: the support hours and ratios needed across a full 24-hour period, how those needs would be affected by the funding reduction and the resulting support gap. It is a shorter, more targeted document than a full reassessment of the participant’s presentation because that clinical picture already exists.

A new full Functional Capacity Assessment is the better option where the existing report no longer reflects the participant’s current presentation or does not contain enough detail about daily and overnight support needs to be extended through an addendum. Whether an addendum or a new assessment is the right fit depends on how well the existing report still describes the participant today which is worth discussing directly with the Occupational Therapist involved.

What if the situation is urgent right now?

The 90 day window above only opens once the funding reset has actually landed on a participant’s plan. For a participant facing genuine risk before that point or while a broader review is already underway, four separate pathways exist. These pathways are not mutually exclusive and can be used together depending on the situation.

1. Urgent internal review

Available once an internal review is already underway or being requested. It applies where there is a risk to health or wellbeing, a risk of homelessness or unstable accommodation, informal supports at risk such as a carer becoming unavailable, a rapidly worsening disability, a pending hospital discharge or an urgent need for assistive technology, home modifications or Supported Independent Living. The urgency is flagged at the time the review is requested. The NDIA then contacts the participant within 48 hours and completes the review as soon as reasonably possible, rather than following the standard 60 day timeframe.

How to act: call the NDIA directly on 1800 800 110 and state clearly that the situation is urgent or flag urgency in writing when the internal review is first requested. No separate form exists for flagging urgency itself.

2. Crisis or emergency funding through a plan variation

Available independently and does not require an existing review to be underway. Where a significant change in functional capacity, informal supports or living arrangements creates an urgent, once-off or time-limited support need the NDIA can vary the current plan to add crisis or emergency funding without completing a full reassessment. This follows the standard 21 day variation decision timeframe, extendable to 28 or 50 days and remains the fastest route to get funding added when a participant is not already mid-review.

How to act: submit the Plan Variation Request Form or call the NDIA on 1800 800 110 if the situation cannot wait for the form to be completed and lodged.

3. Participant-requested plan change during a pending review

Where an internal or external review is already in progress and a participant’s situation changes the participant can separately request a plan reassessment or plan variation, run alongside the existing review rather than replacing it. This still follows the normal 21 day or 90 day decision timeframe.

How to act: call the NDIA on 1800 800 110 and mention the review already underway, then submit whichever form fits the change: the Plan Variation Request Form for a targeted change or the Plan Reassessment Request Form for a broader ongoing change.

4. CEO-initiated plan change during a pending review

Where the NDIA itself becomes aware that a participant’s situation has changed while a review is underway, it can vary or reassess the plan on its own initiative, folding the decision into the review already in progress. This can happen without the participant making a formal request at all.

How to act: no form or call is required to trigger this pathway since the NDIA initiates it. It is still worth telling the NDIA about any relevant change directly, by phone on 1800 800 110 or through the case manager handling the existing review so it can be actioned rather than missed.

Quick reference: which pathway fits?

Review rights

Participants can request a review of any decision made under this pathway, including decisions about whether they meet the definition of a high support needs participant and whether the plan variation is approved. An internal review must be requested within 3 months of the decision.

Who can refer to Sina OT for a Functional Capacity Assessment?

Referrals are accepted from participants and families, support coordinators and legal representatives. Sina OT provides independent Functional Capacity Assessment for participants with high and complex support needs across Adelaide, Melbourne and Sydney. All assessments are completed in person in the participant’s home and community environment and are prepared with close reference to current NDIS legislation and NDIA guidelines.

Disclaimer

This article is provided for general information purposes only and does not constitute legal, financial or individualised clinical advice. It reflects the NDIS legislation and NDIA guidance published as at September 2026 and may not reflect subsequent amendments, rule changes or NDIA operational updates. Readers should always confirm current requirements directly with the NDIA or at ourguidelines.ndis.gov.au and seek independent legal advice for matters relating to a specific plan, decision or Administrative Review Tribunal matter. Nothing in this article should be relied upon as a substitute for an individualised Functional Capacity Assessment conducted by an appropriately qualified Occupational Therapist.

Refer to Sina OT

Sina OT is an independent Occupational Therapy practice providing Functional Capacity Assessment across Adelaide, Melbourne and Sydney.

Sina OT has completed Functional Capacity Assessment for participants with high and complex support needs across a range of disability presentations. Assessments are prepared to meet current NDIA evidence requirements and are suitable for high support needs plan variation applications, plan reassessments and Administrative Review Tribunal matters.

Where a participant already has a current Functional Capacity Assessment, an addendum letter addressing this safeguard pathway specifically can also be arranged, rather than a full new assessment.

Services are available in English and Farsi (Persian).