My Submission (Number 15) on the NDIS Bill (2024)
Here is my submission (number 15) to the Senate Standing Committees on Community Affairs Inquiry into National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Bill 2024 [Provisions] published on the Parliament of Australia website. This submission is now protected by Parliamentary Privilege.
On 21 May 2024, I gave testimony to the Senate Inquiry into the Bill. The focus of my opening statement, was the NDIA’s lack of capability to implement, and a Bill that recklessly ignores this fact.
This submission is an expose of the NDIA and a detailed teardown of PACE, Cyber security vulnerabilities, lack of data security, and ignorant of Risk.
Remember the Services Australia $200 million Entitlement Calculation Engine (ECE) that was dumped by this government, by Bill Shorten as Government Services Minister? And the dumped Department of Home Affairs $250 million Permissions Capability Platform?
Well the Budget Calculation Instrument - on which this whole Bill rests - is a recast of these dumped "calculation" programs.
All three are essentially the same concept. And why would the government expect a different outcome for the NDIA Budget Calculation Instrument, where **HALF A BILLION DOLLARS** has already been wasted by Services Australia and Department of Home Affairs on abandoned attempts at the same concept.
This Bill puts an Algorithm (the Budget Calculation Instrument) - yet to be defined - beyond the reach of administrative review. This is a terrifying world first.
Here is an excerpt from my submission, warning the States and Territory governments what will happen:
"These are the catastrophic risks emanating from a Review and a Bill, theorising a concept without any regard for actually what is involved in implementations; or more correctly, ignoring the lack of capability to implement.
And in the hazardous era of algorithms, this Budget Calculation Instrument proposal cluelessly showcases a world first. This Bill puts an algorithm (the Budget Calculation Instrument) - yet to be defined - beyond the reach of administrative review. This submission cites cases in other jurisdictions, where the application of algorithms in administrative decision making in relation to funding, created risk to life and resulting in death.
👉 My prediction is that with such profound organizational cultural and capability deficits, combined with the extraordinary powers to be vested in the CEO, implementation will fail; Participants will suffer harm; and the NDIS will implode.
What does this look like?
The narrative will shift from ‘“financial sustainability” to a volatile political and bureaucratic posture reacting to an out of control crisis of system wide harm. Payments will be disrupted and erratic; services suspended or stopped; administrative data breaches, data defects, and lost documents will escalate uncontrollably. This system now under unnecessary extraordinary duress, will be preyed upon by cyber and other criminals. No amount of money spent on smart fraud detection systems can reverse or stop that which is recklessly set in train. People will suffer harm, and face risk to life. This is already happening, as evidenced by the horrific cases on the robondis.org website, escalating complaints, and out of control backlogs.
👉 The State and Territory governments - having part-funded the NDIS for a decade - will be forced to step in."
