There is an insufficient rationale to introduce compulsory Independent Assessments (‘IA’) as a primary input into planning decisions in the NDIS. 2. The introduction of compulsory IAs may conflict with the Convention on the Rights of Persons with Disabilities (CRPD). Disability rights organisations should be funded to carry out Disability Rights Impact Assessments on any such legislative or policy changes that may impact the rights of persons with disabilities. The 2019 findings of the UN Committee on the Rights of Persons with Disabilities should be fully implemented. 3. The introduction of compulsory IAs are in conflict with the current Objects and Principles of the National Disability Insurance Scheme Act 2013 (‘NDIS Act’). 4. Compulsory IAs in their proposed current form are not consistent with the 2011 Productivity Commission Report or 2019 Tune Review findings. 5. There is insufficient evidence to suggest that the introduction of compulsory IAs will result in increased equity and consistency in NDIS planning decisions. 6. There is insufficient evidence to support the existence of widespread ‘sympathy bias’ in participant provided documentation in the NDIS resulting in invalid, inconsistent, or inequitable funding decisions. 7. There is insufficient evidence that compulsory IAs will result in valid planning decisions or will improve transparency of decision-making. 8. The introduction of plan budgets based on IAs without further information about what supports are notionally included in the budget will impede a participant’s ability to have proper reviews conducted by the Administrative Appeals Tribunal (AAT). 9. The impact of the IA process on family members must be carefully considered. In addition, there must be transparency about how IAs will inform plan budgets in relation to expectations of the quantum of family care and support that will be provided to a participant as compared to funded care and support.