Annual Pricing Review for 2027-28 prices – OTA Submission – November 2026 | External submission

Annual Pricing Review for 2027 -28 prices – OTA Submission – November 2026

Introduction

About Occupational Therapy Australia

OTA is the peak professional body representing occupational therapists nationally.

We empower and elevate over 36,000 occupational therapists who in turn work in partnership with individuals and communities to enable participation in the everyday activities, occupations and life roles that are meaningful to them.

We’re the single, unifying connection point for occupational therapists across 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 allied health profession that supports people to participate in the everyday activities that matter to them. Occupational therapists understand that participation depends on the interaction between a person’s capabilities, the tasks they want to do, their environment and the supports available to them.

Occupational therapists assess function where it happens – at home, at school, at work and in the community. They consider whether a person can complete tasks safely and reliably over time, and what assistive technology (AT), home modifications or informal support they need to do so. Their assessments account for fluctuating capacity, diverse presentations of disability, communication needs, cultural context and multiple and interacting needs.

This approach shapes how occupational therapy is delivered. Sessions can be long, frequently home-based, involving travel and requiring detailed reporting. Much of the work happens outside the face-to-face session. It includes coordinating with families, support workers, schools and multidisciplinary teams, coaching the people around a participant and adapting environments and routines.

Capacity building sits at the core of occupational therapy. Occupational therapists work alongside people to develop the skills, strategies and habits that increase independence. Combined with well-matched AT and home modifications, these supports reduce reliance on paid support and deliver savings that recur year after year.

Recommendations

OTA recommends the NDIA:

Lift the occupational therapy price limit by 12.1% to $217.50 per hour from 1 July 2027, in line with the median of the APR’s MBS benchmark.
Index therapy price limits annually, and apply indexation as the default where benchmark evidence is mixed.
Reinstate travel funding for occupational therapy at 100% of the hourly rate.
Maintain a single price limit across face-to-face and non-face-to-face occupational therapy, and not proceed with pricing differentiation by type of service.
Apply any registration or workforce-based differentiation as a positive loading on an uplifted base price, including loadings for registration and for supervision, with no reduction for unregistered providers.
Co-design any complexity loading with participants, providers and the allied health sector before implementation, so it is defined by functional need, linked to demonstrated practitioner capability, supported by plans that fund the hours assessed as necessary, and protected by safeguards against participant selection.
Benchmark therapy prices against comparators that reflect the conditions of NDIS delivery, and incorporate the Fair Work Commission’s findings on the HPSS Award, as set out in Appendices A and B.
Work with OTA to monitor how pricing affects the delivery of effective occupational therapy, using shared indicators and OTA’s annual provider survey, and report each year on whether pricing changes are achieving their intended purpose.

Consultation Response

Occupational Therapy Australia (OTA) welcomes the opportunity to contribute to the National Disability Insurance Agency’s (NDIA) Annual Pricing Review (APR) for 2027–28 prices and stage one of the Therapy Pricing Review.

Our central argument is that NDIS pricing needs to sustain the conditions in which occupational therapists can deliver effective support and achieve good outcomes for participants.

Effective occupational therapy happens where participants live, learn, work and take part in their community. It involves careful assessment, coaching the families and support workers around a participant, collaboration across their support network and regular review. These activities are where outcomes are made. They also depend most on viable pricing.

After eight years of frozen prices and a 50% cut to therapy travel funding, providers are already changing what, how, and where they deliver services. OTA’s 2026 NDIS Provider Survey shows occupational therapists reducing home visits, regional services and support for participants with complex support needs. If these pressures continue, participants risk losing the supports that do most to build their capacity and contain long-term Scheme costs.

The NDIA’s own evidence supports a response. The APR’s Medicare Benefits Schedule (MBS) benchmark places the market rate for occupational therapy above the current price limit.

OTA proposes pricing changes that protect effective delivery. We also propose that OTA and the NDIA work together to monitor whether those changes achieve their intended purpose.

1. Pricing and the conditions for effective support

OTA shares the Australian Government’s commitment to a sustainable NDIS. A sustainable Scheme depends on supports that help participants achieve their goals, and on a workforce able to deliver them.

Price settings shape whether participants can find a provider, how long they wait and what model of support they receive. Pricing therefore determines more than provider viability. It also shapes whether the supports that achieve outcomes remain available.

The NDIS price limit for occupational therapy has been $193.99 per hour for eight consecutive years. Consumer prices have risen by around 28% since 2019. The 2019 price limit would need to be around $247 today to retain its value.1 In 2019 dollars, the current limit is worth about $151. Section 5 sets out why OTA is seeking a smaller, evidence-based increase.

1 Reserve Bank of Australia. Inflation calculator. Retrieved 7 October 2026, from https://www.rba.gov.au/calculator/quarterDecimal.html

This submission sets out what effective occupational therapy involves, how current pricing is changing what, how, and where services are delivered, what participants stand to lose, and which pricing changes would protect effective delivery. Supporting evidence and technical analysis are provided in the appendices.

2. What effective occupational therapy looks like

Occupational therapists support people to participate in the everyday activities that matter to them. Participation depends on the interaction between a person’s capabilities, the tasks they want to do, their environment and the supports around them. Effective occupational therapy works on all of these together, through four connected elements of practice.

Working in everyday environments - Occupational therapists assess and intervene where function happens – at home, at school, at work and in the community. Performance in a clinic often differs from performance in daily life. Seeing a participant’s kitchen, bathroom or classroom allows the occupational therapist to identify real barriers, prescribe the right assistive technology (AT) and home modifications and test strategies where they will be used.

Coaching families and support workers - Participants spend far more time with family members, support workers and other people involved in their everyday lives than with a therapist. Sharing knowledge, building skills and developing practical strategies with the people who support them helps embed approaches into everyday routines, extend learning beyond therapy sessions and build capacity over time. This is how capacity building becomes lasting change.

Collaboration - Many participants have several supports in place, including support workers, schools, health services and other allied health professionals. Occupational therapists help align goals, share relevant expertise, and coordinate approaches across this network so supports complement each other. This avoids duplicated effort and inconsistent strategies across environments, supporting consistent, coordinated responses to the participant’s priorities.

Assessment and review - Thorough functional assessment gives planners an accurate picture of need and matches supports to that need. Regular review checks whether strategies are working and adjusts them as needs change. This helps direct funding to supports that make a difference. It also gives the NDIA reliable information for planning decisions, including under new framework planning.

Together, these activities strengthen functional capacity, participation, choice and agency. Where possible, they reduce reliance on more intensive paid supports over time.

Much of this work happens outside a face-to-face clinic session. It involves travel, time with the people around a participant, coordination, documentation and reporting. These are the activities most exposed when pricing no longer covers the cost of service delivery.

Case study: A $5,500 OT and AT investment substantially reduces ongoing support costs

A NSW occupational therapist assessed a participant who had experienced multiple strokes and required two support workers to assist with transfers three times each day.

Following an in-home assessment, the OT recommended a lifter recliner chair costing approximately $4,000. The OT assessment, equipment prescription and reporting involved approximately 8 hours of occupational therapy, bringing the total OT and AT investment to approximately $5,500.

With the chair in place, the participant completed transfers with standby assistance from one support worker. This halved the staffing needed for transfers and reduced support costs by an estimated $40,000 a year. If the participant’s needs remain stable, savings could exceed $200,000 over five years.

The outcome depended on assessment in the participant’s home, accurate AT prescription and a change in how support workers assisted. Current pricing is putting each of these at risk.

3. How pricing is changing what providers deliver

If pricing does not cover the cost of delivering quality occupational therapy, participants risk losing the services that matter most for participation, access and safety. For occupational therapy, this means home and community visits, regional and remote services, support for participants with complex support needs and time with the people around a participant.

This risks a shift toward shorter, clinic-based sessions focused on the individual. That approach is easier to sustain under current pricing, but less effective for many participants.

Providers have absorbed rising wages, compliance obligations, travel costs and practice expenses under frozen pricing. The 50% cut to the therapy travel rate in the APR for 2026–27 prices added further pressure on home and community-based delivery.

Changes already occurring

OTA’s 2026 NDIS Provider Survey (n=233) shows pricing-induced changes are already under way. Three in four respondents (75%) say the price freeze has reduced participant access, with 32% reporting a significant reduction.

Respondents report they:

have reduced or stopped services to regional and remote participants following the travel rate cut (56%)
have waits of six months or longer, or have closed their waitlist (35%)
have reduced services to participants with complex support needs (21%)
have limited or stopped growth plans (47%), and laid off staff or cut hours (13%)
face a moderate or severe impact on business viability (78%).

The NDIA’s own data points the same way. The APR finds therapy markets remain capacity-constrained (page 95). Unregistered therapy provider numbers fell 4.9% while participant numbers grew 12.8%. Registered provider numbers rose 0.5%, leaving a growing share of demand to a largely static registered cohort (page 66).

Provider headcount also understates the effect. A provider who reduces their NDIS caseload, closes their waitlist or stops home visits still appears in claiming data. These changes can reduce what the market can deliver well before providers leave.

Changes anticipated

Two in three respondents (67%) expect to stop, or are considering stopping, NDIS services in the next one to three years. As a result of the price freeze, respondents expect to collectively stop servicing at least 3,800 participants.

These figures reflect stated intentions, and not all will translate into exits. However, they signal the direction of the market and the scale of change that could follow if current pressures continue. Recommendation 8 proposes how OTA and the NDIA could track whether these intentions are realised.

4. What participants stand to lose

The participants most exposed to these pressures are those who rely on intensive, specialised, context-based or coordinated support.

Home and community-based services - Home modifications, AT prescription and many daily living goals cannot be adequately assessed or addressed in a clinic. When travel is underfunded, providers reduce home visits or limit them to participants nearby. Participants with mobility limitations and those who need support in their own environment lose the setting where therapy works best. They also lose choice about where, when and how they receive supports, which is central to choice and control and reflected in the NDIS Practice Standards.

Regional services - In regional, rural and remote areas, a single provider reducing services can leave participants with no local option. Rebuilding supply is likely to cost more than retaining it. The NDIA may need to fund alternative commissioning or pay higher prices to attract new providers, and participants may go without supports while these arrangements are established. Gaps can also delay hospital discharge where a participant is waiting for a home assessment, modifications or AT.

Support for complex needs - Participants whose support needs are multiple or interact with one another, including situations involving distress, safety risks or environmental barriers to participation, may require more extensive assessment, coordination, risk management and senior clinical input. Under a flat price that no longer covers costs, this work is the least viable to deliver. These participants are likely to be among the first to lose services and the most likely to see their needs escalate without them.

For the Scheme, the consequences compound. Capacity-building funding can go unused while participants wait. Needs that could have been addressed early escalate into more intensive, ongoing paid supports. Planners receive less reliable functional information to inform decisions. Each outcome works against the NDIA’s goals for a sustainable Scheme and a well-functioning market.

5. Pricing changes that protect effective delivery

OTA’s recommendations aim to restore and protect the conditions for effective occupational therapy service delivery in the NDIS. They respond to problems already evident, and can be monitored over time.

Recommendations 1 and 2: Restore the value of the price limit

An adequate base price is the foundation for every other setting. Differentiation, loading or a line item applied to a price that no longer covers costs is unlikely to restore viability.

The APR’s own evidence supports an increase. Its MBS benchmark converts to an hourly median of $217.50 and a 75th percentile of $237.00 (Table 59, page 180). The current limit of $193.99 sits below this range. The only comparator below the price limit is Private Health Insurance (PHI) data from a single anonymised insurer, which serves a different cohort through simpler, clinic-based services (see Appendix A).

The APR describes these results as mixed signals and maintains the current price (pages 89 and 181). Without indexation, maintaining a price is a real cut. Over eight years, this decision rule has reduced the real value of the price limit by more than 20%.

OTA recommends lifting the price limit by 12.1% to $217.50, the median of the APR’s MBS benchmark. We have chosen this figure for three reasons:

First, it rests on the NDIA’s own evidence. The benchmark draws on a sample the APR describes as robust (page 89), which gives the NDIA a clear basis for the increase.

Second, it is a measured step that recognises the Government’s focus on Scheme sustainability. It sits at the bottom of the MBS reference range.

Third, annual indexation from this point would prevent further erosion and give providers the certainty to invest in their workforce.

The increase also reflects a further year of rising costs since OTA sought an 11% uplift last year.

Recommendation 3: Fund travel so supports reach participants where they live

Delivering therapy in everyday environments is best practice and, for many participants, their preferred choice. Travel funding makes it possible. Reinstating travel at 100% of the hourly rate would help protect home-based and regional services, two of the areas where respondents have already reduced services.

Recommendation 4: Price all the work that makes therapy effective

Coaching, collaboration, scoring, clinical interpretation, documentation, and reporting often take place away from the participant. The APR’s own consultation data shows 28% of time in 60–90 minute therapy sessions is non-direct work. This work is skilled, and much of it fulfils NDIA reporting requirements.

New non-face-to-face line items introduced in the APR for 2026–27 prices make this work more visible. OTA is concerned this visibility could be used to justify lower rates. A lower rate could create a financial incentive to cut the activities that deliver lasting outcomes and support quality, safeguarding and accountability. A single price limit across all occupational therapy work keeps pricing aligned with effective practice and supports participant safety.

Recommendations 5 and 6: Use differentiation to reward the conditions for effective delivery

Well-designed differentiation can steer the market toward better practice. To work as an incentive, it needs to sit on top of a base price as a positive loading.

The approach applied to Social, Community and Civic Participation supports from 1 January 2027 keeps registered price limits and reduces unregistered limits by 10%. Applied to therapy, this approach would not pay registered providers more to cover the costs of registration. A lower unregistered price might encourage some providers to register. Others might reduce their NDIS work or stop providing NDIS services altogether. After eight years of frozen prices, many providers are already weighing these options (see section 3). A further cut risks adding to exits from a market the APR already finds capacity-constrained.

A positive loading is more likely to grow the registered market. Victoria’s Transport Accident Commission (TAC) recently adopted this approach. Since April 2026, OTs who join its OT Access Registry and complete mandatory training receive a higher fee schedule and TAC referrals.

A positive loading for supervision would support the workforce that effective delivery depends on. NDIA pricing arrangements state that supervision costs are included in therapy price limits, but no published cost model shows how. Under the freeze, practices’ capacity to fund senior clinician time for supervision (such as for students and early career OTs) is likely to have declined.

A complexity loading could help providers meet the extra cost of supporting participants with complex support needs. However, the problem has two parts: the price may not cover the cost of delivery, and plans may not fund enough hours. A loading addresses only the first. If plans do not also fund the hours assessed as necessary, a higher rate could reduce the support a participant receives.

Complexity is best defined by functional need and the interaction between a person, their environment and their supports. It also often fluctuates. A diagnosis-based definition is likely to miss much of this variation. Any loading should be co-designed, linked to demonstrated practitioner capability and monitored to prevent providers selecting participants based on price.

Recommendation 7: Benchmark against the delivery model participants need

Benchmarks determine which model of delivery the price can sustain. To protect effective delivery, comparators need to reflect the conditions of NDIS occupational therapy: work in everyday environments, travel, time with the people around a participant, work with participants with complex support needs and detailed reporting. Current benchmarks fall short of this test in several ways:

PHI data, the only comparator below the price limit, comes from one insurer and reflects short, clinic-based sessions with limited reporting
the MBS benchmark draws on a single item code and excludes items involving longer consultations
MBS providers can charge a gap payment to recover the cost above the scheduled fee, while providers working with plan-managed or agency-managed participants cannot
CTP schemes, whose claimants more closely resemble NDIS participants, pay more, but other scheme results are not published
therapy pricing does not draw on the HPSS Award, so the Fair Work Commission’s correction for gender-based undervaluation does not reach the experienced workforce that effective delivery depends on.

Appendices A and B set out the analysis and specific actions in response to these issues.

Recommendation 8: Monitor whether pricing achieves its purpose

Pricing decisions are made once a year, but their effects on delivery build over time. Claiming data shows what is billed. It shows less about which services providers have stopped offering, and to whom. These leading signals matter most for market stewardship.

OTA proposes that OTA and the NDIA work together to monitor the impact of pricing on effective delivery. This would give the NDIA earlier warning of emerging gaps. It would also provide a clear test of whether pricing changes, including the travel rate and new line items, are achieving their intended purpose.

A shared approach could:

agree a small set of indicators linked to effective delivery, such as home and community-based delivery, regional and remote services, services to participants with complex support needs, wait times and intake closures, provider exits and supervision capacity
combine NDIA claiming data with OTA’s annual provider survey, which captures intended exits, intake restrictions and regional withdrawal
review results ahead of each APR and report on whether pricing changes achieved their intended purpose
inform the fit-for-purpose allied health pricing model developed through stage two of the Therapy Pricing Review.

This would support ongoing action, alongside the immediate response needed to the problems already evident.

Appendix A – Benchmarking analysis

Private Health Insurance data

PHI is the only comparator that places occupational therapy below the NDIS price limit. Its hourly median is $146.67 and its 75th percentile is $168.90. Its representativeness is therefore central to the APR’s conclusion.

The PHI dataset for occupational therapy has grown from 6,476 transactions in the previous APR to 34,819. However, it still comes from a single anonymised insurer, and no data from the second PHI source was available for occupational therapy. It remains unclear whether this insurer represents the broader PHI market.

PHI is also an inappropriate comparator for NDIS occupational therapy. The APR acknowledges that PHI data generally reflects higher-income clients. PHI rates are shaped by preferred provider arrangements, under which providers accept lower fees in exchange for referrals. Most extras policies offer limited occupational therapy cover, typically for shorter, clinic-based sessions with simpler record keeping and limited reporting.

The APR suggests separately claimable NDIS items, such as non-face-to-face time and reports, offset these differences. These items fund additional work the NDIS requires. The APR also concedes it cannot quantify how much these items add to total reimbursement (APR’s Appendix B). An unquantified offset is a weak basis for a continued price freeze.

MBS data

The entire MBS benchmark for occupational therapy is drawn from a single item code, MBS item 10958 (page 182). It excludes occupational therapy items under Better Access and for complex neurodevelopmental disorders and eating disorders, which involve longer consultations and higher fees.

The APR describes the occupational therapy sample as robust (page 89). Sample size is only part of the issue. Even a large dataset drawn from one item code captures a narrow slice of practice. A complete dataset would likely widen the gap between the market rate and the NDIS price limit.

Gap payments

Under MBS, providers can charge a gap payment above the scheduled fee. The APR’s benchmark uses the full fee charged. For agency-managed and plan-managed NDIS participants, providers cannot charge a gap. The MBS figure reflects a market price set by providers. The NDIS price limit is a fixed ceiling, so NDIS providers have no means of recovering the difference when the market rate exceeds it.

Other government schemes

The APR’s comparison draws on 102,366 occupational therapy transactions from other government schemes, the largest occupational therapy dataset in the review. Its results are not published by scheme or service type, so the conclusion that these schemes pay less cannot be verified.

The APR’s transaction-level analysis also found CTP schemes pay systematically higher rates than workers’ compensation schemes, reflecting the higher complexity and severity of motor accident claims. CTP claimants more closely resemble many NDIS participants. Published schedules also understate what some schemes pay, including TAC’s confidential OT Access Registry fee schedule.

Actions under Recommendation 7

OTA recommends the NDIA:

7a. Publish the representativeness of the PHI dataset used for each profession and test it for the effect of preferred provider arrangements.
7b. Expand the MBS item codes used for occupational therapy to cover the full range of Medicare billing, including Better Access, complex neurodevelopmental disorder and eating disorder items.
7c. Account for the gap payment flexibility available under MBS when interpreting the benchmark.
7d. Publish the occupational therapy results behind the comparison with other government schemes, separated by scheme and service type.
7e. Apply greater weighting to the comparators most similar to NDIS occupational therapy, including CTP schemes.

Appendix B – Fair Work Commission gender-based undervaluation review

In June 2026, the Fair Work Commission (FWC) finalised its gender-based undervaluation priority awards review, which included the Health Professionals and Support Services (HPSS) Award. The review addressed historical underpayment in female-dominated professions, including occupational therapy, where women make up 92% of the workforce.

The APR commits to incorporating the review’s outcomes into Disability Support Worker (DSW) pricing through the DSW Cost Model. Therapy pricing relies on benchmarking and does not draw on award wages. As a result, the correction flows to one NDIS workforce and not another whose undervaluation the same review established.

OTA recognises that benchmarking aims to preserve comparability with other markets and is not evidence of gendered intent. Our concern is the outcome. Benchmarks drawn from markets shaped by historical undervaluation are likely to carry it forward.

The APR contends that HPSS Award changes will flow through market rates over time. This assumes comparator markets will correct on their own. However, they draw on the same undervalued workforce, and MBS and PHI fees have no link to award outcomes. Waiting risks embedding the undervaluation for several more pricing cycles.

We ask the NDIA to include the HPSS Award as a methodological input. This means testing whether benchmarking produces materially different prices from an HPSS Award-informed model, as DSW pricing responds to Social, Community, Home Care and Disability Services (SCHADS) Award findings. If a gap emerges, the NDIA should explain how it will close it.

Actions under Recommendation 7

OTA recommends the NDIA:

7f. Include the HPSS Award as a formal input to the therapy supports assessment in the 2027–28 APR.
7g. Publish a comparison of therapy price outcomes under current benchmarks and an HPSS Award-informed cost model, and explain how the FWC findings informed therapy price settings.

Appendix C – 2026 NDIS Provider Survey results

OTA conducted the survey from 10 August–11 September 2026 (n = 233). A selection of results is shown below.

Three in four OTs (75%) say the price freeze has reduced participant access, with 32% reporting a significant reduction

Two in three OTs (67%) expect to stop or are considering stopping NDIS services in the next one to three years *

As a result of the price freeze, respondents expect to collectively stop servicing at least 3,800 participants *

35% have waits of six months or longer or have closed their waitlist entirely

21% have reduced services to participants with complex needs

78% report a moderate (43%) or severe (36%) impact on business viability

56% have reduced or stopped services to regional and remote participants following the travel rate cut

Source: OTA 2026 NDIS Provider Survey, conducted 10 August–11 September 2026 (n = 233).

Figures on future service changes reflect respondents’ stated intentions.

Section Heading here

This Guideline sets out the actions needed to develop and approve an OTA Position Statement. It also provides a framework for the Position Statement document to ensure comprehensiveness and clarity.