DPSC Eligibility Refuter — adversarial pass on all six concepts

Role: eligibility prosecutor. Brief: kill concepts on §4-5 grounds if possible; a survivor is genuinely safe. Read: Guidelines V2 pp.4-30 (verbatim quotes below), stream1/2/3-concepts.md in full. Date: 11 Jun 2026. Standard applied: CLEAR = no exposure a hostile assessor could plausibly act on, as drafted. WOUNDED = at least one exposure that could cost eligibility or a criterion score unless fixed before 2 July. KILLED = do not submit as designed.

Verdict table

No kills. The genuinely killable shapes were already rejected as alternates (Family Hub, SEA consortium, First Nations Gateway, physical hub, employer program). What follows is every chargeable exposure, with quotes.

Key guideline text relied on (verbatim)

• §4 chapeau (p.14): “We cannot provide a grant if you receive funding from another government source for the same purpose.”
• §5.4 (p.23): “delivery of systemic or individual advocacy (excluding self-advocacy)”; “funding in support of individuals”; “to support medical or diagnostic referrals”; “activities that duplicate existing ILC Program funded projects unless adding additional scale and/or scope”; “activities that duplicate those undertaken by NDIS Partners in the Community (Local Area Coordination and/or Early Childhood Early Intervention) organisations”; “services funded by other government services, including NDIS capacity building supports”; “activities duplicate the function of the Disability Gateway (e.g. activities that seek to collate information on all disability-services, across all disability types, onto a single platform)”; “activities that are already funded on an ongoing basis by other Australian, state or territory, or local government programs”; “activities for which other Commonwealth, state, territory or local government bodies have primary responsibility”; “activities that organisations are obliged to undertake as part of their legal or operational obligations including reasonable adjustment under the Disability Discrimination Act 1992”; “salaries where the salary forms part of the organisation’s/individual’s usual responsibility”; “research purposes where research is the sole grant activity”; “subsidy of general ongoing administration”.
• §4.4 (p.17): CfP attaches only “if you are currently delivering an activity under the below Information, Linkages and Capacity Building (ILC) Program streams that is determined by the department to be similar”: “Individual and Family Capacity Building 2025-26 (Closed Non-Competitive)” and “Information Access and Referral 2025-26 (Closed Non-Competitive)”. Cessation “no later than one business day before the new grant activity commences”; unspent funds rollover “only… where the scope of your current ILC Program grant/s sufficiently aligns”.
• §4.3 (pp.15-16): regulated activity if it “involves substantial one-on-one contact with people with disability using the service (whether the contact is in person or by other means)” or “involves regular engagement with people with disability using the service over a prolonged period”. “All personnel working on the grant activity must maintain… Working with Children check / Working with Vulnerable People registration (or equivalent…)”.
• §5.1 (p.20): “People with disability must be involved in the design and implementation of the grant activities.” “Supports must not replicate activities already funded by other Commonwealth government programs, including the National Early Childhood Program.”
• §5.2 (p.21): remote delivery requires ASGS-remote category AND “an existing physical address in the regional/remote area the activities are to be delivered in, or be part of a consortium with a partner who has an existing physical address in this area.”
• §2.1 (p.6): “This grant opportunity aims to distribute funding to meet the unique needs of all Australians with disability under the age of 65, their families, carers and kin.” Supports “may provide benefit to children aged 0-8 and their families as part of a broader service offer or scope” but must not “solely target children aged 0-8” nor replicate the National Early Childhood Program.
• §2.1.1 (p.7): family cohort — “Family and Carers Capacity Building activities will aim to deliver supports that empower families, carers and kin of people with disability to support their loved ones and advocate for them.” (The Guidelines themselves authorise family advocacy-for within the family cohort — shields both family streams.)
• §7 (p.27): two applications per stream “must be different and cannot be seeking grant funding for the same activity/ies”; “Giving false or misleading information is a serious offence.”
• §7.2 (p.28): “The application must identify all other members of the proposed group.”

1. Speak Strong NT (Stream 1, individual) — WOUNDED, fixable

Exposure 1.1 — SACID CB&PLG / PATH duplication is named in the concept but never defended (FIXABLE)

The concept volunteers the collision: cohort includes “people with intellectual disability (continuing the SACID CB+PLG cohort)” and Activity 1 “builds on (and formally succeeds)… the SACID co-facilitation model DAS already runs.” CB&PLG ($250,304, to 30 Jun 2027) is a live ILC IFCB peer-support program for the same cohort in the same town; PATH ran to Jun 2026. Hostile assessor reading at assessment time (H2 2026, while CB&PLG is live): §5.4 “activities that duplicate existing ILC Program funded projects unless adding additional scale and/or scope”. The eligibility self-check table (§11 of the concept) defends Speaking Up under this exclusion but is silent on CB&PLG/PATH — the only ILC duplication actually argued is the one DAS holds, not the one it delivers under SACID. Fix: add CB&PLG and PATH to the duplication row by name: both end before the 1 Jul 2027 activity start (CB&PLG 30 Jun 2027, PATH Jun 2026 — do NOT call CB&PLG 3-year anywhere); claim the “additional scale and/or scope” carve-out explicitly (new SDM stream, family stream, paid workforce, 10+ communities, all disability types not just ID).

Exposure 1.2 — §4.4 position on Speaking Up contradicts the Stream 3 file (FIXABLE — must reconcile before ANY submission)

Stream 1 Concept A: “Condition for Participation (§4.4) acknowledged: written termination arrangement for Speaking Up, ceasing no later than one business day before commencement” and “seek approval to apply unspent funds where scope aligns.” Stream 3 file §0: “DAS holds neither directly (Speaking Up is the ILC Individual Capacity Building grant executed Jun 2024…)”. Both cannot be true. §4.4 only catches the two named 2025-26 Closed Non-Competitive opportunities. A grant executed Jun 2024 is prima facie NOT one of them — in which case (a) the CfP does not bite, (b) the unspent-funds rollover mechanism in §4.4 is unavailable and Concept A’s plan to roll Speaking Up underspend has no legal pathway, and (c) writing a termination arrangement into the application that the department didn’t ask for is noise. If Speaking Up was re-papered under the 2025-26 CNC extension round, the Stream 3 analysis is wrong instead. Fix: pull the actual Speaking Up grant agreement, confirm which grant opportunity ID it currently sits under, and state ONE consistent §4.4 position across all six applications (the form declaration of agreement to the CfP is mandatory regardless). Also resolve the SACID pass-through question — DAS “currently delivering an activity under” the IFCB 2025-26 CNC stream via SACID’s MOU is a hostile-readable trigger DAS cannot itself discharge (it cannot terminate SACID’s agreement). The Stream 1 file already queues this for Grant.ATM by ~24 June — that question must actually be sent.

Exposure 1.3 — “supported decision-making coaching for individuals” (COSMETIC)

One-liner: “supported decision-making coaching for individuals and their families.” Hostile reading: 1:1 coaching on a person’s live decision = “funding in support of individuals”. Defence is strong — “supported decision-making” is a named program objective (“supported decision-making initiatives”, §2) and named IFCB activity, so the generic exclusion cannot swallow the named activity — but the phrasing invites the fight. Fix: never pair “coaching” with “individuals” in application text. Use “supported decision-making education and practice clinics (group-based)”.

Exposure 1.4 — “Ask for a Review” module (COSMETIC here; see Workbench for the full version)

Teaching people to request an NDIS internal review is self-advocacy education delivered as a group module — squarely inside the “(excluding self-advocacy)” carve-out and Stream 1’s “self-advocacy education”. Survives because nothing is produced for a specific person’s matter and no one acts for anyone. Keep it that way: if drafting ever adds individual review-preparation assistance, this concept inherits the Workbench problem.

Exposure 1.5 — cohort/NECP drafting gaps (COSMETIC)

Cohort says “people with disability of any type” with no age bound; the family stream is all-ages. §2.1 scope is under-65; §5.1 bans replicating the National Early Childhood Program and §2.1.1 bans family supports that “solely target children aged 0-8”. Fix: state the under-65 focus and the NECP non-replication sentence in the application. (Families/carers/kin are squarely in scope — §2.1 and cohort 2 — no exposure there.)

Survives cleanly

Advocacy exclusion (program IS the named exception; referral protocol + firewall); funding-in-support-of-individuals (group delivery, peer wages are §5.3 delivery wages); Gateway (no information collation, links out); research; admin subsidy; DSI Act (concept concedes regulated-activity likelihood and uses the §4.3 determination pathway — “None of the above” is correctly NOT claimed); remote address (DAS Alice Springs office, ASGS Remote); entity type (Incorporated Association, §4.1); budget floor/cap.

2. Self-Advocacy Workbench (Stream 1, consortium) — WOUNDED, deepest single exposure in the portfolio

Exposure 2.1 — the review case-file builder is individual advocacy with the advocate removed (FIXABLE in framing, residual risk in substance)

Concept wording: “Ask for an Internal Review (build my own case file)”; “AI-assisted… document checklist assembly”; one-liner: “turns deep NDIS plan-and-appeals advocacy expertise into participant-operated preparation tools… build my own review case file”. Guideline: §5.4 excludes “delivery of systemic or individual advocacy (excluding self-advocacy)” and “funding in support of individuals”. Hostile reading, fully argued: what an NDIS Appeals advocate does for a client is assemble the review case — evidence checklist, documents, arguments, preparation for the meeting. The Workbench does exactly that, for a specific person’s specific live matter, at scale, with DAS’s appeals methodology inside it. “Self-advocacy” in the carve-out and in §2’s objectives is consistently EDUCATION-shaped (“programs that educate individuals about their rights”; “self-advocacy education”, §2.1.1). A tool whose output is an individual’s appeal dossier is not education about rights — it is matter-specific casework support delivered by software. Compounding: the Commonwealth already funds individual review/appeals support (DSS NDIS Appeals program — which DAS itself holds), engaging §5.4 “activities that are already funded on an ongoing basis by other Australian… government programs” and “activities for which other Commonwealth… bodies have primary responsibility.” Defence (why this is not a kill): the person operates everything themselves; nothing advises on or acts in the matter; the carve-out has no textual limit to “education only”; supported decision-making and “mentoring” are named activities that are equally individual-facing; NDIS Appeals funds advocate REPRESENTATION for people who cannot self-advocate, which the Workbench expressly refers out. The textual defence is real. But this is the one concept where the hostile reading attacks the core product rather than the framing. Fix (do all of it): (1) kill the phrase “case file” everywhere — “build my own case file” becomes “get ready to ask for a review: know the steps, gather your own documents, practise what to say”; (2) reposition outputs as the person’s own preparation notes and checklists, never a “file” or “dossier”; (3) state in Criterion 1, in terms: “the Workbench provides no advice on, and takes no step in, any individual’s matter; people needing someone to act for them are referred to NDAP/NDIS Appeals providers — this program funds zero advocate hours”; (4) add the complementarity sentence: equips people who CAN self-advocate, freeing separately-funded advocacy for those who cannot; (5) pre-empt with a de-identified Grant.ATM question by ~20 June (“are participant-operated self-advocacy preparation tools within the self-advocacy carve-out?”) so an FAQ answer exists on the record.

Exposure 2.2 — “Understand My Plan” / “Get Ready for My Plan Meeting” vs LAC duplication (FIXABLE)

§5.4: “activities that duplicate those undertaken by NDIS Partners in the Community (Local Area Coordination…)”. In metro/regional Australia (the Workbench is national), LACs do explain plans and prepare participants for plan meetings. The concept’s table only argues “not plan implementation (LAC)” — too thin for a national product whose first two pathways are plan-understanding and plan-meeting preparation. Fix: argue the distinction in the application: LAC is NDIA-delivered, individualised navigation done WITH/FOR the participant; the Workbench builds transferable self-advocacy capability the person keeps. Also note “services funded by other government services, including NDIS capacity building supports” — state explicitly that the Workbench is not plan-funded capacity building and charges nothing.

Exposure 2.3 — Stream 3 reclassification (FIXABLE, already mitigated)

A national digital tool reads as a Stream 3 information product to a tired assessor. The concept’s own mitigation (lead with peer coach network, capability outcomes, zero information/referral function) is correct — it must survive into the criterion text, and outcome measures must stay capability/action, not reach/visits.

Exposure 2.4 — consortium mechanics (FIXABLE, procedural)

§7.2: “The application must identify all other members of the proposed group.” Eight partners in 3 weeks; the fallback (submit with 6 named) is compliant — but do not name any partner without written in-principle agreement (§7: false or misleading information is an offence). Partners screened against §4.2 lists — planned, keep it. Partner-hosted coaches deliver a likely regulated activity: DAS as grantee carries the §4.3 CoC obligation; the stated determination-pathway position is the right one (“None of the above” correctly not claimed).

Survives cleanly

Gateway (no directory, no service collation — the §5.4 example shape is absent); research; fees; remote (DAS’s own Alice address anchors NT remote; national option per §5.2 needs “equitable national coverage within the life of the grant” — Y3 QLD/WA/ACT satisfies it; the 18-month test in §3.2 only binds >$1.25M/yr asks, which this is not — drop the gratuitous §3.2 citation); budget under cap every year; evaluation 2.6%.

3. Open Doors Central Australia (Stream 2, individual) — WOUNDED, fixable and light

Exposure 3.1 — DDA compliance-subsidy reading of the core activity (FIXABLE — framing already exists, must persist verbatim)

§5.4 excludes “activities that organisations are obliged to undertake as part of their legal or operational obligations including reasonable adjustment under the Disability Discrimination Act 1992.” Note the wording is “organisations”, not “the applicant” — a hostile assessor can read free access reviews + action plans as subsidising REVIEWED organisations’ discharge of their own DDA obligations (a venue would otherwise pay an access consultant to meet them). This attacks the core mechanic, which is why the concept cannot be CLEAR. The concept’s defence is the strongest available: inclusion-experience reviews not Premises Standards/DDA compliance audits; action plans split “legal floor — your obligation, not funded here” from “inclusion uplift”; no funds flow to reviewed organisations; Stream 2’s own definition (“build the capability of organisations to adapt their services”) authorises the shape. Fix: the A11 framing must appear in Criterion 1 text and budget notes verbatim, and the review framework/report templates must actually contain the legal-floor/uplift split (assessors may ask for the instrument).

Exposure 3.2 — the public Access Map is a Stream 3 artefact inside a Stream 2 application (COSMETIC→FIXABLE)

The map “so people with disability know what to expect before they arrive” is information provision to people with disability — Stream 3’s job (“Information, Advice and Referral… to benefit all people with disability”). One output won’t reclassify the concept, but it dilutes stream purity and gives a Gateway-pattern-matcher something to circle. Fix: frame the map as the published evidence layer of organisational change (count “organisations listed/improved”, not “users informed”); keep it clearly secondary; state the Gateway distinction in one line (venue access attributes for two SA3s ≠ “all disability-services, across all disability types, onto a single platform”).

Exposure 3.3 — systemic-advocacy adjacency in provenance language (COSMETIC)

The evidence section cites the Leadership Group’s “voted advocacy priorities”. Reviews that pressure organisations to change, plus a public map and recognition tiers, can be hostile-read as systemic advocacy infrastructure. The activity itself is opt-in capability support — Stream 2’s definition protects it — but don’t hand over the word. Fix: in application text, “advocacy priorities” becomes “community priorities”; never describe reviews as holding organisations to account.

Exposure 3.4 — vehicle lease line structure (COSMETIC)

§5.3: “total vehicle leasing expenditure cannot exceed 10% of the funding or $50,000, whichever is the smaller figure” and travel costs “cannot be added to the amount used to lease/purchase vehicles”. The budget line “Travel + vehicle lease… 20/24/24” combines them. Fix: split into two lines; keep the lease component ≤$50k across the grant (smaller figure applies at this grant size).

Survives cleanly

Advocacy (capability feedback to organisations; peers speaking from own experience = excepted self-advocacy); funding-in-support-of-individuals (assessor pay = §5.3 delivery wages); research (data collection is an eligible §5.1 component); ILC/LAC/other-program duplication (no peer-review program exists in these SA3s; DRI ended 30 Jun 2026); DSI Act (“None of the above” is defensible — service users are organisations; assessors are workforce, not service users — and the concept correctly accepts department determination anyway); §4.4 (organisational capability vs Speaking Up’s individual capacity building — not similar; declare and let the department test); remote address; entity; fees; capital works (none — the physical hub was rightly rejected).

4. The Inclusion Engine (Stream 2, consortium) — CLEAR, conditional

The cleanest concept in the portfolio. Organisation-facing throughout, no individual supports, no directory, no casework adjacency, Stream 2’s definition is almost a description of the concept (“build the capability of organisations to adapt their services, so they are disability inclusive and accessible”).

Conditions (all procedural)

1. §7.2 member identification: “Partner E — DANA-member advocacy org, additional state (TBC)” cannot be named as TBC in the form — “The application must identify all other members of the proposed group.” Either lock Partner E with written in-principle agreement before 2 July or submit NT+SA only (the concept’s own fallback; “multiple states and territories” still satisfied). Do not stretch — §7 false/misleading warning applies.
2. Compliance-subsidy framing must persist into application text exactly as drafted in B11 (“capability uplift beyond minimum compliance”; practice reviews split “legal obligations (yours)” from “inclusion good practice”). Easy Read for small community organisations genuinely exceeds any current legal floor, so this is weaker than Open Doors’ exposure — but it must be said, not assumed.
3. Partner double-funding certifications: the concept’s own note (“check at drafting that no partner holds other government funding for the same activity”) is mandatory work, not a nice-to-have — §4 chapeau and the Indicative Activity Budget template both require it, and DCLS/IADA/SACID all hold adjacent government funding.
4. Stream 3 optics: “Accessible Communications Studio” producing “2,500+ accessible documents” pattern-matches to an information-resources project. The saving distinction — the documents are participating organisations’ OWN program materials, produced BY them, with capability retained in-house — must lead Criterion 1. Keep output metrics organisational (orgs with in-house capability), not document counts, in the headline.
5. SACID: repair before naming (concept already says so), or substitute — a named partner who disputes the relationship at due-diligence time is worse than a smaller consortium.

Survives cleanly

Advocacy; funding in support of individuals; Gateway (processes each organisation’s own documents — nothing resembling the §5.4 example); research; salaries (all funded roles new and project-dedicated — §5.4 “usual responsibility” trap avoided); fees (free during grant; nominal-fee continuation only with prior approval, correctly stated); DSI Act (“None of the above” defensible — org-facing; reviewers are paid workforce); remote (DAS address + partner addresses); admin; capital; budget under cap.

5. CDIS (Stream 3, individual) — WOUNDED, two real exposures

Exposure 5.1 — DAIS double-funding: the sharpest “already funded” collision in the portfolio (FIXABLE, needs heavier treatment than planned)

Guidelines, twice: §4 chapeau “We cannot provide a grant if you receive funding from another government source for the same purpose” and §5.4 “activities that are already funded on an ongoing basis by other Australian, state or territory, or local government programs.” The facts a hostile assessor (or the NT Office of Disability, if consulted) will find: DAS itself holds DAIS — NT-funded, ~$80k/yr, 0.5 FTE, disability information function, Central Australia + Barkly, funded to 2029. Same organisation, same region, same domain, overlapping function (answering disability enquiries), ongoing through the entire grant period. This is not a duplication-of-someone-else’s-program argument; it is “you are asking the Commonwealth to fund a service you are already paid by the Territory to provide.” The concept’s defence (one-paragraph additionality statement: DAIS = 0.5 FTE triage; CDIS = dedicated IAR positions, language/format production, knowledge base, outreach — “no CDIS line item is funded elsewhere”) is the right argument but underweight for the exposure. Fix: (1) the additionality statement goes in Criterion 1 AND the Indicative Activity Budget (the template explicitly requires disclosure of other government funding — DAIS must appear there; omitting it is a §7 false/misleading risk); (2) define the functional boundary in operational terms (DAIS funds the existing triage desk; every CDIS deliverable is net-new: products, languages, outreach circuit, knowledge base, SLAs); (3) separate cost centres named in the application (DAS already runs per-grant cost centres); (4) brief the NT Office of Disability before submission so the two funders hear one story — the concept’s own A.13 mitigation, which should be executed, not held in reserve.

Exposure 5.2 — Gateway duplication (FIXABLE — managed, but assessor-dependent)

§5.4: “activities duplicate the function of the Disability Gateway (e.g. activities that seek to collate information on all disability-services, across all disability types, onto a single platform).” Hostile reading: the Regional Pathways Knowledge Base IS a collation of disability services information, across all disability types, on a single (internal) platform — merely regionally scoped; plus a phone line, plus referral — a mini-Gateway for two SA3s. The concept’s A.11.1 rebuttal is the strongest in the pack (not national; transformation and pathway depth, not collation; languages/formats the Gateway structurally cannot produce; complementarity in writing; “things CDIS will never build” list) and the stream’s own objective 3 (“nationally consistent and locally tailored information”) makes a regional IAR service definitionally fundable — Stream 3 would otherwise be unfundable. Verdict: survivable, but only if A.11.1 lands verbatim in Criterion 1 and the banned self-descriptors (platform/portal/gateway/navigator) stay banned. Fix: as the concept already plans, plus: the knowledge base should be described as “a verified regional pathways resource used by staff to answer enquiries” — staff tooling, never a public collation.

Exposure 5.3 — “warm referral that walks alongside people to the right service door” (COSMETIC)

One-liner phrasing. “Walks alongside” + follow-up contact is the exact image of individual advocacy support. Referral is in the stream’s name — the funded activity cannot be the excluded one — and the charter (inform/advise/refer, never represent, escalation protocol, quarterly file audit) is sound. But the phrase does hostile assessors’ work for them. Fix: “walks alongside” does not appear in any application; “three-way warm referral with follow-up confirmation” is the ceiling. Also avoid “health referrals” phrasing anywhere near the ACCHO partnerships — §5.4 excludes funding “to support medical or diagnostic referrals”; say “information about health services and pathways”.

Survives cleanly

Advocacy exclusion (charter + NDAP firewall with client-choice listing — well built); funding in support of individuals (enquiry records only, no brokerage); ILC duplication (FAQ 2.6 permits continuation/expansion; Speaking Up is capacity building not IAR and ends 30 Jun 2027); LAC/ECEI (no LAC in Central Australia; RCC distinction made — keep it explicit); research; §4.4 (low — but inherits Exposure 1.2’s reconciliation obligation: the §4.4 story must match Stream 1’s); DSI Act (correctly conceded as likely regulated — phone advice = “substantial one-on-one contact… by other means”; determination pathway + budgeted CoC costs is the compliant posture; “None of the above” is rightly not claimed); cohort (explicit under-65 + families/carers/kin — exactly §2.1’s wording); remote address (DAS office; FAQ 9.15 community spaces for Tennant Creek); Cat B classification (correct — “phonelines, on-going outreach, or maintaining an online information hub” is the definition); budget floor/cap; admin.

6. Remote Reach (Stream 3, consortium) — WOUNDED, heaviest conditionality

Exposure 6.1 — unsigned ACCO partners are load-bearing for ELIGIBILITY, not just Criterion 2 (FATAL IF NOT FIXED BY 2 JULY; degrades rather than dies)

Two guideline hooks. §5.2: remote delivery requires “an existing physical address in the regional/remote area the activities are to be delivered in, or be part of a consortium with a partner who has an existing physical address in this area.” DAS’s Alice Springs address covers NT claims — but the SA (APY Lands / Outback North and East) and WA (Goldfields / Ngaanyatjarra Lands) remote footprint rests entirely on NPYWC’s addresses, and NPYWC is “To approach immediately” — not approached as at 11 Jun. Congress and Anyinginyi (Barkly access point) are likewise “to approach”. §7.2: “The application must identify all other members of the proposed group” — and §7 makes false or misleading information an offence. Naming NPYWC/Congress/Anyinginyi as group members without at least written in-principle agreement is not a Criterion 2 weakness, it is a probity exposure; submitting without them collapses the cross-border premise, the majority-ACCO-delivery model, and the §3.1 10% First Nations-partnership claim the concept is “built to qualify” for. Fix: exactly what the concept’s B.13 says, executed this week, with a hard gate: any partner not in writing by ~27 June is removed from the member list (described, if at all, as a Year-1 expansion intention, with the SA/WA geography removed from the form’s location claims accordingly). The NT-only fallback (DAS + DCLS + IADA + Inclusion NT) remains an eligible, coherent application.

Exposure 6.2 — same-activity overlap with CDIS under §7 (FIXABLE — currently the weakest de-overlap in the portfolio)

§7: the two same-stream applications “must be different and cannot be seeking grant funding for the same activity/ies.” The stated de-overlap (B funds no DAS front-line IAR in Alice/Barkly) handles delivery but not PRODUCTION: CDIS budgets a 0.5 FTE Accessible Content Producer + first-language production (Pitjantjatjara, Warlpiri, Arrernte, Warumungu) for Central Australia; Remote Reach budgets a DAS-operated production engine making “Western Desert + Top End languages” products — Pitjantjatjara IS a Western Desert language, for an overlapping region. Read side by side (same stream, same assessor pool), DAS appears to seek funding twice for multi-format first-language disability information production in Central Australia. Fix: de-overlap production explicitly in both applications: (a) name disjoint language/region sets (CDIS: the four named CA/Barkly languages for the two SA3s; Remote Reach engine: partner-region languages — Top End, NPY tri-state SA/WA-side, etc.), and (b) add one sentence to each: if both are funded, CA-language production consolidates under [one of them] and the other’s line is redirected — demonstrating the activities are different and non-additive.

Exposure 6.3 — Gateway at scale (FIXABLE — managed)

Same exclusion as 5.2, harder at this footprint: a multi-state network of access points + a central content engine + “one nationally consistent canonical layer” + Y3+ national-remote scaling is the closest thing in the portfolio to a distributed second Gateway. B.11.1’s rebuttal (production infrastructure, not a public collation platform; remote-only coverage class; products the Gateway cannot make; trusted-intermediary delivery; complementarity MOU) is adequate — IF the words platform/portal are never self-applied and the public never “visits Remote Reach” anywhere in the text. The concept knows this; hold the line.

Exposure 6.4 — NDIA Remote Community Connectors (FIXABLE)

§5.4: “activities that duplicate those undertaken by NDIS Partners in the Community”. ACCO-hosted local people helping community members with disability information in remote NT/APY communities is functionally adjacent to the NDIA’s Remote Community Connector program. The concept’s distinction (whole-of-life disability information vs NDIS access; NDIS plan matters referred to NDIA/RCC channels) is right but appears only in the trap table. Fix: put the RCC distinction in Criterion 1 text, with the referral protocol to RCC/NDIA named.

Exposure 6.5 — partner double-funding surface (FIXABLE — mechanism exists)

Congress and Anyinginyi hold substantial NDIS/health/Commonwealth funding; DCLS holds legal-assistance funding. §4 chapeau + §5.4 “already funded on an ongoing basis”. The sub-grant deed certification + per-partner Indicative Activity Budget disclosure the concept specifies is the correct machinery — it must actually be completed per partner, and DAS’s own DAIS additionality statement applies here too (B.11 already says so).

Survives cleanly

Advocacy (network charter + firewall); funding in support of individuals; research; Cat B classification (correct); §4.4 (partners not bound — CfP attaches to the applicant; DAS position per Concept A, subject to Exposure 1.2 reconciliation); DSI Act (regulated likely, conceded; recognised-standards route via partners’ NDIS/health accreditation is a legitimate §4.3 pathway; “None of the above” rightly not claimed); cohort (explicit under-65 + families/carers/kin); budget under $1.25M/yr every year (no §3.2 exception reliance); fees; capital.

Ranked: the 3 most dangerous eligibility exposures across the portfolio

1. The Workbench’s review-preparation tooling (Exposure 2.1, Stream 1 consortium). “Build my own case file” sits exactly on the line §5.4 draws — “delivery of systemic or individual advocacy (excluding self-advocacy)” — and is reinforced by two more exclusions (already-funded NDIS Appeals support; Commonwealth primary responsibility). It is the only exposure in the portfolio where the hostile reading attacks the concept’s core product rather than its framing, and it sits inside DAS’s flagship national bid. Reframe to preparation-skills language, kill “case file” everywhere, fund zero advocate hours in terms, and lodge the de-identified Grant.ATM question by ~20 June.

2. CDIS vs DAIS (Exposure 5.1, Stream 3 individual). The only exposure that is a checkable fact rather than an interpretation: DAS already receives NT government money, to 2029, for a disability information function in the identical region. §4’s chapeau is absolute (“We cannot provide a grant if you receive funding from another government source for the same purpose”). Survival depends on a functional-boundary additionality case made in the criterion text AND the budget template disclosure AND a pre-briefed NT funder — not a single paragraph.

3. Remote Reach’s unsigned load-bearing partners (Exposure 6.1, Stream 3 consortium). NPYWC/Congress/Anyinginyi are simultaneously the §5.2 remote-eligibility instrument for SA/WA, the §7.2 member-identification obligation, the 10% First Nations-pool claim, and the concept’s entire delivery model — and none has been approached. Three weeks. Anything not in writing by ~27 June comes out of the application, and the geography claims shrink with it.

Reconcile-before-anything (portfolio hygiene, not ranked): the §4.4 Speaking Up contradiction between the Stream 1 and Stream 3 files (Exposure 1.2). All six applications declare a CfP position; they must declare the same, correct one. Verify the grant opportunity ID on the actual Speaking Up agreement, and send the SACID pass-through question to Grant.ATM by ~24 June.