Inclusive Communities Fund – OTA Submission – August 2026

Introduction

About Occupational Therapy Australia

OTA is the peak membership body representing occupational therapists nationally. We empower and elevate over 36,000 exceptional professionals who in turn work in partnership with individuals and communities to enable meaningful participation in the activities of life. We’re the single, unifying connection point for occupational therapists in the nation, leading the profession through education, support, and advocacy, so every occupational therapist is informed, inspired and fulfilled in their profession.

As one of Australia’s largest allied health workforces, occupational therapists provide essential supports across primary care, aged care, disability, mental health, veteran care and more.

About Occupational Therapy

Occupational therapy is a person-centred health profession concerned with promoting health and wellbeing through participation in occupations. Occupational therapists achieve this by working with participants to enhance their ability to engage in the occupations they want, need, or are expected to do; or by modifying the occupation or the environment to better support their occupational engagement. Occupational therapists provide services across the lifespan and have a valuable role in supporting participants affected by developmental disorders; physical, intellectual, chronic and/or progressive disability; and mental health issues.

Occupational therapists are highly skilled in assessing the degree to which a person’s disability affects their level of function in daily tasks. Given their expertise and area of practice, many occupational therapists deliver services funded by the NDIS. Services focus on promoting independence in activities of daily living and enablement of social and economic participation. These services may include functional capacity assessment and intervention; disability-related chronic disease management; prescription and implementation of assistive technology and/or environmental modifications; mental health interventions; positive behaviour support; driving assessments (when specifically trained to do so); and targeted, goal-focussed rehabilitation.

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Recommendations

OTA recommends the Department confirm the Fund complements, and does not substitute for, adequate individual NDIS funding or other individualised supports for community participation.
OTA recommends the Fund’s guidance material explicitly name allied health professionals, particularly occupational therapists, as a recognised source of expert advice and staff training.
OTA recommends the Department confirm that eligible grant recipients may engage and remunerate occupational therapists, including private practitioners and NDIS providers, as project partners, advisers and training providers.
OTA recommends the Fund’s guidance and assessment criteria explicitly confirm the inclusion of people with psychosocial disability, including disability that is invisible, episodic or fluctuating.
OTA recommends the Fund’s evaluation framework separately assess outcomes for NDIS participants and people with disability outside the NDIS, publicly report outcomes for people with psychosocial disability across both groups, and ensure proportionate reporting for smaller organisations.
OTA recommends the Department adopt flexible partnership models, including remote or hub-based advisory arrangements, and recognise the additional costs of building partnerships and delivering capability-building projects in regional, rural and remote areas.

Report

Occupational Therapy Australia (OTA) welcomes the opportunity to respond to the Department of Health, Disability and Ageing’s consultation on the Inclusive Communities Fund (the Fund). OTA supports a Fund that builds the lasting capability of community organisations rather than funding time-limited service delivery.

We agree that inclusion depends on addressing attitudinal and systemic barriers, not only physical ones, and that community-led, locally responsive design will produce better outcomes than a one-size-fits-all model.

This submission provides feedback on the Fund, and proposes six recommendations covering its relationship to individual NDIS supports, recognition of occupational therapy expertise,

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inclusion of people with psychosocial disability, outcome evaluation and equitable access for regional, rural and remote communities.

The Fund in context

The Fund is being introduced during substantial NDIS reform, including forthcoming changes to eligibility under the NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026, and planned reductions in some participant budget allocations.

The sector is also contending with eight consecutive years in which the NDIS hourly price limit for occupational therapy has remained unchanged, placing increasing pressure on provider viability and participant access to occupational therapy supports and other allied health services.

Taken together, these changes represent a significant tightening of the scheme at the same time as this Fund is positioned as a new investment in inclusion. OTA is concerned that people with disability may experience this period as one of net loss rather than net gain, with reduced access to individualised, evidence-based supports outweighing the benefits of a time-limited fund for community organisations.

OTA situates this consultation within that wider picture, and notes that the Fund is one part of a reform agenda that, overall, is reducing rather than expanding access to the supports that enable genuine community participation.

Alongside this reform, the Fund is being introduced with planned reductions of 50% to budget allocations for Social, Civic and Community Participation and 10% to Capacity Building Daily Activity. OTA’s position, set out in earlier consultations, remains opposed to these reductions.

While the effect will vary according to participants’ existing expenditure, these changes create a material risk of reduced access to individualised supports. A $200 million, three-year capacity-building fund for community organisations, however welcome, cannot substitute for individualised support matched to a participant’s goals and functional needs.

The consultation paper notes that changes to NDIS Social, Civic and Community Participation supports and Capacity Building Daily Activity supports sit outside its scope. It should be made clear that this Fund is intended to complement, not substitute for, adequate individual NDIS funding for community participation. Reduced individual supports alongside a time-limited capacity-building fund risks leaving participants with fewer pathways to genuine, sustained participation.

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OTA urges the Department to consider the Fund’s design in the context of this broader package, and to design and communicate the Fund as a complement to individualised supports, rather than as compensation for reductions to participant budgets.

Recognise and enable access to occupational therapy expertise

The consultation paper identifies “seeking expert advice on how to make services more inclusive” and “staff training on disability inclusion” as eligible activities under the fund. People with disability and disability-led organisations should remain central sources of expertise about lived experience and the barriers they encounter. This lived-experience expertise can be complemented, where appropriate, by professional advice that helps organisations translate inclusive principles into changes to their environments, activities and practices.

OTA recommends the Fund explicitly recognise allied health professionals, particularly occupational therapists, as providers of expert advice and disability inclusion training. Occupational therapists routinely assess environments and activities for accessibility, and train staff and organisations to embed inclusive practice. Naming this expertise in guidance material would help community organisations identify appropriate partners and strengthen the quality of funded projects.

Community organisations may also need to draw on expertise beyond their existing workforce. The consultation paper identifies NDIS providers as potential partners, but also proposes that NDIS providers and for-profit community organisations would not receive funding directly. It does not specify whether eligible grant recipients may use their funding to remunerate these organisations as expert partners or service providers.

This distinction is important because much of the relevant occupational therapy expertise is located in private practice. This includes small and locally based practices and occupational therapy providers that also deliver NDIS services.

Restrictions on direct grant eligibility should not prevent funded community organisations from engaging and remunerating private occupational therapy practices or other allied health providers for eligible advisory, training or project work. Accordingly, the Fund’s guidance should distinguish between eligibility to receive a grant and eligibility to be engaged as a paid expert partner.

Address the needs of people with psychosocial disability

The consultation paper states that the Fund should work for all people with disability and address attitudinal as well as physical barriers. However, it does not specifically address psychosocial disability. Without explicit guidance, funded projects may bias towards physical accessibility or

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general disability awareness, and overlook barriers associated with disability that is invisible, episodic or fluctuating.

The Fund’s guidance and assessment criteria should therefore explicitly recognise the barriers experienced by people with psychosocial disability. These can include stigma, inflexible attendance requirements, unpredictable environments and risk-management practices based on assumptions rather than individual circumstances. Relevant activities could include lived-experience-led training, flexible or staged participation, clear processes for requesting adjustments and the option to attend with a support person.

The consultation paper also states that the Fund will not pay for direct service delivery and that changes to individual NDIS supports sit outside its scope. This distinction is particularly important for people with psychosocial disability.

Improving the capability of community organisations can remove barriers within those organisations, but it cannot replace the individualised support some people need to establish routines, build confidence, navigate unfamiliar environments and sustain participation when their needs fluctuate. The Fund should therefore complement, and not be presented as delivering or replacing, adequately funded individualised and recovery-oriented psychosocial supports.

Measure meaningful and sustained participation

The consultation paper states that the Fund should create lasting change and support meaningful participation, rather than simply facilitate attendance. Detailing the grants issued, staff trained or attendance levels would show what the Fund delivered, but not whether organisations became more inclusive or people’s experience of participation improved.

Effective evaluation for the Fund should assess whether organisations have removed barriers and embedded inclusive practices, and whether people participate repeatedly or over time, feel welcome and safe, experience belonging, and retain choice and control over their participation.

Feedback from people with disability must be central to this process. Outcomes should be assessed separately for NDIS participants and people with disability outside the NDIS, with outcomes for people with psychosocial disability specifically examined across both groups.

Reporting requirements should be proportionate to the size and value of each grant. The Department should provide simple, consistent evaluation tools so smaller organisations can demonstrate meaningful outcomes without unnecessary administrative burden.

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Consider workforce and access equity

Partnership arrangements between community organisations and disability-led or allied health organisations will be harder to establish where the allied health workforce capacity is already limited, particularly in regional, rural and remote areas.

OTA recommends the Department consider flexible partnership models, including remote or hub-based advisory arrangements, to ensure equitable access to the Fund’s benefits across Australia.

Grant arrangements should also recognise the higher costs of establishing partnerships and delivering capability-building activities in regional, rural and remote communities, and the contribution of private and locally based allied health practices where local capacity is limited.

Partnership models should also support access for Aboriginal and Torres Strait Islander people with disability, including through culturally safe engagement and partnerships with Aboriginal Community Controlled Organisations.

Conclusion

OTA thanks the Department of Health, Disability and Ageing for the opportunity to provide this feedback on the Inclusive Communities Fund.

The Fund can build valuable capability in community organisations, but it should be designed and communicated as a complement to individualised NDIS supports, not as a substitute for them.

Recognising occupational therapy expertise, addressing the needs of people with psychosocial disability, ensuring robust evaluation, and ensuring equitable access for regional, rural and remote communities and Aboriginal and Torres Strait Islander participants will strengthen the Fund’s design and its outcomes for people with disability.

OTA welcomes further engagement with the Department on the development of this Fund, to ensure it delivers meaningful outcomes and improves the lives of people with disability.

We can be reached at policy@otaus.com.au

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