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NDIS Evidence Advisory Committee – NDIS supports are safe, suitable and cost-effective for people with disability – OTA Submission – MARCH 2026

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NDIS Evidence Advisory Committee – NDIS supports are safe, suitable and cost-effective for people with disability – OTA Submission – MARCH 2026

Introduction

About Occupational Therapy Australia

OTA is the peak membership body representing occupational therapists nationally. We empower and elevate over 34,000 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 OT 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 therapists enable meaningful participation in everyday life activities by leveraging strengths and addressing barriers to function within personal, social and environmental contexts.

Occupational therapists partner with NDIS participants to build everyday living skills, increase independence and achieve meaningful participation in the activities, roles and settings that are important to them. Using a biopsychosocial approach, occupational therapists consider the dynamic interaction between the person, their chosen occupations and life activities, and their environment to identify strengths and barriers to participation in everyday life. Occupational therapists support individuals through tailored, evidence-based approaches aligned with the participant’s needs and goals, which may include skill development and capacity building, functional supports, assistive technology or environmental modifications.

In the context of children, paediatric occupational therapists focus on helping children build functional, meaningful skills in everyday life and work to ensure that any behavioural approach is developmentally appropriate, strengths based and aligned with the child’s sensory, emotional and occupational needs.

Occupational therapy has a specific and clearly defined scope of practice, which is outlined in OTA’s capability frameworks. We recommend that the Committee refer to these documents to better understand the occupational therapy role and scope relevant to supporting NDIS participants & children under

the Thriving Kids Initiative. These documents can be accessed via this link: https://otaus.com.au/capability-frameworks.

Background

The Australian Government established the NDIS Evidence Advisory Committee (the Committee) to ensure that NDIS supports are safe, suitable and cost-effective for people with disability.

In February 2026, the committee will be reviewing the following supports:

  • early intensive behavioural interventions.

  • positive behaviour support for older children and adults.

  • robot-assisted gait training.

  • social skills training as a disability support for children and young people.

Further information can be found here: https://consultations.health.gov.au/evidence-advisory-committee-eac/february-2026/

OTA Feedback

OTA’s submission is intended to provide the Evidence Advisory committee guidance on where to refer for evidence on the above supports. We provide advice on how practice relates to evidence-based approaches; the ways that these supports are delivered, and the workforce delivering them, are integral to whether or not they support a safe and cost-effective scheme. We provide advice relating to all four of the supports being reviewed by the Committee.

It is important to note that the evidence base for the supports under review is constantly being updated, as new research is being conducted and the evidence base grows and/or shifts. In particular, as discussed below, we are seeing a shift in relation to the evidence base that supports Applied Behaviour Analysis, and approaches based on this. There is a live debate about the appropriateness of such approaches, and whether they are neurodiversity-affirming, and align with human rights. The Committee should keep a close eye on the evidence in relation to these approaches, beyond this consultation.

We refer the Committee to the work of the Autism CRC, including their Best Practice Framework for Early Childhood Interventioni and their National Guideline for supporting the learning, participation, and wellbeing of autistic children and their families in Australia.

Early intensive behavioural interventions

Early intensive behavioural interventions (EIBI) are a family of intensive Applied Behaviour Analysis (ABA)-derived programs typically used to target specific outcomes related to behavioural characteristics, communication, and adaptive skills in Autistic childrenii.

From an occupational therapy perspective, early childhood intervention should support participation in everyday life, not only isolated skill acquisition. Best practice includes approaches that are child and family centred, neurodiversity-affirming, individualised, strengths-based, holistic, trauma informed, and culturally safeiiiiv.

The evidence-base for EIBI is mixed. Available evidence suggests potential benefits for some children in specific skill-acquisition domains; however, it does not support effectiveness across broad domains or across all Autistic children and familiesv. The fit of any intervention depends on the child’s goals, needs, context, and family priorities. Evidence is also limited regarding the extent to which gains transfer into meaningful participation across home, school and the community.

Concerns have also been raised by contemporary academics and consumer and advocacy groups about the extent to which EIBI style approaches align with contemporary principles of early childhood intervention and neurodiversity-affirming practice, particularly where intervention priorities emphasise compliance or normalisation of behavioursviviiviii.

In consulting with members to inform this submission, it was noted that the content provided by the Committee to inform this consultation process appears inconsistent with neurodiversity-affirming approaches, particularly in the context of the Australian Autism Strategy. If this was not the intent, the Committee should be mindful of how the information presented may be received in this way and aim to clarify in future communications.

EIBI interventions should be considered with caution and in context, rather than as a universal evidence-based practice for all Autistic children and families. Their use should be guided by clinical reasoning, the individual child’s needs and goals, family preferences, and consideration of alternative evidence-based intervention approaches.

Alternative evidence-based interventions, that may better align with participation-focused and neurodiversity-affirming practice include cognitive interventions, environmental adaptation, activity & task adaptation, emotional regulation supports, technology-based supports, developmental interventions, and family-centred coaching models. These approaches prioritise meaningful participation, contextual fit and caregiver capacity, rather than focusing heavily on structured skill acquisition.

The Autism CRC National Guideline for supporting the learning, participation and wellbeing of autistic children and their families in Australia is a key practice guide in this area, ensuring that intervention is child- and family-centred, evidence-informed, and focused on meaningful participation and wellbeingix.

Positive behaviour support for older children and adults

Positive Behaviour Support (PBS), also based on ABA approaches, aims to improve a person’s quality of life by understanding why behaviours occur and finding better ways to meet the person’s needs. This may include teaching new skills, supporting regulation, adjusting the environment, and supporting the people around them to respond effectively.

PBS is used by a wide range of NDIS participants, especially those who may need support with distress, safety, or unmet communication, sensory, daily living or environmental needs. According to the NDIS Quality and Safeguards Commission, specialist behaviour support providers work closely with participants, families, carers, and support teams to develop and implement behaviour support plans.

Positive Behaviour Support has a moderate evidence-basexxi. It is supported in some contexts, however outcomes depend on the quality of implementation, person-centred practice and whether the approach addresses underlying needs and participation goals. This approach does require caution as well as effective workforce capability and competency development and organisational managementxii.

Potential risks arise where PBS is reduced to behaviour management alone, without adequate attention to the person’s preferences, communication, sensory needs, or participation goals. In such cases, there is a risk that intervention becomes overly focused on suppressing behaviour rather than improving the underlying environmental fit, skill development, and quality of life that PBS is intended to support.

Additional risks are associated with PBS, including physical and psychological harm, reduced autonomy, and diminished participation. These risks reinforce the importance of PBS being delivered as a proactive, person-centred approach focused on understanding unmet needs, reducing distress, and minimising or eliminating restrictive practices wherever possible.xiii

Occupational therapists can support this approach by helping to contextualise behaviour, identify strengths, and maintain a focus on enablement and participation. This may include sensory assessment, emotional regulation, functional skill development, environmental modification, and collaboration on PBS planningxiv. Occupational therapists supporting this approach utilise trauma-informed and neurodiversity-affirming practices.

PBS in conjunction with other approaches

This approach should be used in conjunction with other supports as appropriate, to achieve outcomes such as enhancing communication, emotional regulation, and participation. These supports include allied health supports, capacity building supportsxv, medical and health supports, environmental supports, routine supports, and early childhood supports.

For example, a multidisciplinary approach may be taken whereby the occupational therapist supports with emotional regulation, routines, or activity and environmental adjustments. A speech pathologist may work with the participant to address communication challenges that are contributing factors to distress or confusion, and a psychologist may suggest trauma-informed supports, coping strategies or identify cognitive and emotional factors contributing to distress.

Another example may include where a participant receives an assessment and treatment for an underlying physical or mental health condition that may influence behaviour, alongside adjustments to their home, school or community environments. A holistic approach that brings together different supports as appropriate can improve outcomes for participants, where behaviour has multiple co-occurring and contributing factors.

Further, while environmental changes are explicitly part of PBS, they could also be implemented through general NDIS core supports.

Early childhood

For children under 9, early intervention pathways complement behaviour support by focusing on skill development, communication, and family support.

Occupational therapists in Australia play a significant and complementary role in PBS, particularly within the NDIS, by helping families and teams understand the child’s behaviour in the context of everyday routines, relationships, sensory needs, communication, and developmental stage. Their perspective is grounded in functional participation, emotional and sensory regulation, environmental fit, and meaningful engagement in home, early childhood, and community settings.xvi

Occupational therapists view behaviour through a functional, holistic lens, considering what a behaviour may be communicating and how it may reflect sensory, emotional, environmental, or occupational needs. They recognise that behaviour is often linked to unmet needs, communication differences, sensory overload, or barriers to participation, and consider how sensory processing, motor skills, regulation, and daily routines shape behavioural responses.

Social skills training as a disability support for children and young people.

Social skills training can be delivered via a range of methods; individually, in groups or as part of universal supports. Outcomes vary but are improved when practice involves parent involvement, peer-mediated practice and opportunities to generalise skills into everyday contextsxvii.

The evidence base for social skills training is moderate. For autistic children, social skills training shows some positive targeted outcomes, however these are variable depending on the type of intervention, how it is delivered and the individual support needs of the child and family. For children with intellectual disability, moderate outcomes in targeted skills may not be consistently generalisable to school and community settings.xviii

Social skills training may support specific social communication outcomes for some children and young people, but it also carries risks where it is delivered in ways that prioritise conformity, masking, or compliance over autonomy, wellbeing, and authentic participation. These risks highlight the importance of individualising participant goals, ensuring the child’s sensory and communication needs are respected, and embedding social learning in everyday contexts.

Social skills training should be considered one component of a broader, participation-focused support plan rather than a stand-alone solution.

Occupational therapists can contribute to social skills training by focusing on the functional and everyday aspects of social participation. This may include supporting a child or young person to manage emotions, read social cues, take turns, join group activities, and build confidence in real-life settings such as home, school, and community environments.

Occupational therapist input is most valuable when social skills are taught in context and linked to meaningful occupations, rather than treated as isolated behaviours. Occupational therapists can also help identify barriers to social participation, such as sensory processing differences, anxiety, fatigue, communication challenges, or environmental demands, and work with families and educators to support generalisation across settings.

Robot-assisted gait training

Robot-assisted gait training is a rehabilitation therapy that uses robotic systems to help people relearn how to walk. These devices guide a patient’s legs through natural walking patterns, helping the brain and body reestablish the complex movements required for walking—such as balance, posture, weight shifting, strength, and endurance.

After a stroke (or acquired brain injury), many survivors experience difficulties with walking. Some can only walk within their home.

“Mobility impairment is one of the most disabling consequences of stroke. Evidence shows that nearly 50% of survivors are left with long-term functional limitations, including reduced walking ability.”xix

Because walking depends on coordinated functions controlled by the brain, damage from a stroke can disrupt these abilities. Restoring the ability to walk is one of the most important goals for people recovering from a stroke. Improved walking can influence long term health and independence.

Robot-assisted gait training offers a structured, repetitive, and safe way for stroke survivors to practise walking movements, which can accelerate recovery and increase exercise capacity, and function can be an important part of their rehabilitation program. By supporting consistent practice and providing precise movement guidance, robotic gait training systems play a critical role in helping stroke survivors rebuild their walking ability.

There are other technologies that can support gait training, such as walking on a treadmill. OTA recommends working with Assistive Technology Suppliers Australia (ATSA) to discuss other supports that people may use to seek similar outcomes.xx

We also recommend consultation with the Australian Physiotherapy Association, as this support falls within the physiotherapy scope of practice and expertise.

However, it is important to note the multidisciplinary nature of supporting participants who often have multiple support needs, and goals that rely on a team working together. For example, occupational therapists contribute a holistic, participation centred approach that ensures robotic gait gains translate into real world function, particularly within the Australian health, social, and disability support systems. Without this, the benefits of gait training may not be realised in relation to the participant’s specific goals; it is meaningful only when it translates into functional and occupation-based outcomes, such as:

  • Independent home mobility (e.g., navigating small bathrooms typical in Australian housing).

  • Accessing public transport (trams, trains, buses).

  • Community mobility (shopping centres, uneven footpaths, outdoor terrain).

  • Work and school participation and commuting.

  • Engagement in leisure activities (accessing beaches, parks, sports clubs, participating in sports and walking-based activities).

The Occupational Therapy Board of Australia establishes codes, guidelines, and cultural safety expectations that influence how occupational therapists deliver and supervise advanced rehabilitation technologies.xxi

These standards reinforce the occupational therapy role in:

  • Client centred, culturally safe practice.

  • Evidence based intervention planning.

  • Comprehensive risk assessment (fatigue, orthostatic responses, skin integrity).

  • Clear documentation and outcome measurement.

  • Collaboration within multidisciplinary teams.

During OTA’s consultation with members to inform this submission, several OTA members raised concerns, including uncertainty about the Committee’s definition:

“I do not think they have the right definition for robotic assisted gait therapy, they were not comparing the right devices, and the questions did not allow for detailed explanations. They also lacked the understanding that not all gait assisted devices position the client in a standing position as some are seated

depending on what you are trying to focus on. It is also vital that people are trained to use robot-assisted gait equipment by experts and that they are competent to use the equipment.”

– OTA Member and Occupational Therapist

Robot assisted gait trainers are a complex assistive technology, as such they must be prescribed, fitted and utilised by suitably trained and appropriate allied health professionals.

Additional Feedback on Consultation Survey

Some OTA members expressed concerns with the consultation survey. These included difficulty interpreting the survey purpose, due to lack of clarity regarding the intended use of the data. Concerns were raised that the data may be used to inform decisions about therapy supports (occupational therapy), foundational supports, or mainstream services. If this is the intention, the Committee needs to be transparent to enable survey respondents to respond in a fully informed way.

Additional questions from OTA members included:

  • Is the comparison between occupational therapy and Positive Behaviour Support intended to be a direct comparison? If so, it is important to provide an opportunity for specific impact on the role and scope of occupational therapy, given that this distinction may not be apparent to all respondents.

  • What is the rationale for grouping early behavioural interventions including ABA with approaches such as the DIR/Floortime model?

  • Is the survey’s suggestion that social skills training is primarily delivered in groups specifically referring to current NDIS practices, academic papers, or proposed reforms?

  • How are adult perspectives being captured in this review, given that the survey is heavily focused on the school-aged population?

  • How will responses be differentiated across disability groups (e.g. psychosocial disability), particularly in relation to social skills interventions?

  • Is the consultation considering only manualised programs, or does it also include individualised occupational therapy supports delivered within the NDIS?

  • What is the basis for suggesting that sensory integration outcomes may result from social skills group interventions?

  • Why does the survey include questions about delivery by teachers, if the focus is intended to be on disability supports?

Conclusion

OTA welcomes the opportunity to provide this submission to NDIS Evidence Advisory Committee. OTA is available to brief the Australian Government & the NDIS Evidence Advisory Committee on this submission. We are available at policy@otaus.com.au

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References

  • i Occupational Therapy Australia. (2024). Position statement: Occupational therapy roles in behaviour support, early intervention and neurodiversity-affirming practice.
  • ii Reichow B, Barton EE, Boyd BA, Hume K. Early Intensive Behavioral Intervention (EIBI) for Young Children with Autism Spectrum Disorders (ASD): A Systematic Review. Campbell Systematic Reviews 2014:9 DOI: 10.4073/csr.2014.9
  • iii National Best Practice Framework for Early Childhood Intervention, Department of Health, Disability and Ageing, https://www.health.gov.au/our-work/national-best-practice-framework-for-early-childhood-intervention?language=en
  • iv Capability Framework for Occupational Therapists Working with Children, Young People and Families, Occupational Therapy Australia, https://otaus.com.au/resources/capability-framework-for-occupational-therapists-working-with-children-young-people-and-families
  • v Reichow, B., Barton, E.E., Boyd, B.A. and Hume, K. (2014), Early Intensive Behavioral Intervention (EIBI) for Young Children with Autism Spectrum Disorders (ASD): A Systematic Review. Campbell Systematic Reviews, 10: 1-116. https://doi.org/10.4073/csr.2014.9
  • vi Leaf JB, Cihon JH, Leaf R, McEachin J, Liu N, Russell N, Unumb L, Shapiro S, Khosrowshahi D. Concerns About ABA-Based Intervention: An Evaluation and Recommendations. J Autism Dev Disord. 2022 Jun;52(6):2838-2853. doi: 10.1007/s10803-021-05137-y. Epub 2021 Jun 16. Erratum in: J Autism Dev Disord. 2022 Jun;52(6):2854. doi: 10.1007/s10803-021-05200-8. PMID: 34132968; PMCID: PMC9114057.
  • vii Wilkenfeld DA, McCarthy AM. Ethical Concerns with Applied Behavior Analysis for Autism Spectrum “Disorder”. Kennedy Inst Ethics J. 2020;30(1):31-69. doi: 10.1353/ken.2020.0000. PMID: 32336692.
  • viii Graf-Kurtulus, S., & Gelo, O. C. G. (2025). Rethinking psychological interventions in autism: Toward a neurodiversity-affirming approach. Counselling and Psychotherapy Research, 25, e12874. https://doi.org/10.1002/capr.12874
  • ix National Best Practice Framework for Early Childhood Intervention, Department of Health, Disability and Ageing, https://www.health.gov.au/our-work/national-best-practice-framework-for-early-childhood-intervention?language=en
  • x Beqiraj L, Denne LD, Hastings RP, Paris A. Positive behavioural support for children and young people with developmental disabilities in special education settings: A systematic review. J Appl Res Intellect Disabil. 2022 May;35(3):719-735. doi: 10.1111/jar.12989. Epub 2022 Feb 23. PMID: 35199433; PMCID: PMC9306923.
  • xi LaVigna, G. W., & Willis, T. J. (2012). The efficacy of positive behavioural support with the most challenging behaviour: The evidence and its implications. Journal of Intellectual & Developmental Disability, 37(3), 185–195. https://doi.org/10.3109/13668250.2012.696597
  • xii Konstantinidou, I., Dillenburger, K., & Ramey, D. (2023). Positive behaviour support: a systematic literature review of the effect of staff training and organisational behaviour management. International Journal of Developmental Disabilities, 69(1), 29–44. https://doi.org/10.1080/20473869.2022.2123199
  • xiii Leif ES, Fox RA, Subban P, Sharma U. ‘Stakeholders are almost always resistant’: Australian behaviour support practitioners’ perceptions of the barriers and enablers to reducing restrictive practices. Int J Dev Disabil. 2023 Feb 1;69(1):66-82. doi: 10.1080/20473869.2022.2116908. PMID: 36743316; PMCID: PMC9897749.
  • xiv Perez, M., Carlson, G., Ziviani, J. and Cuskelly, M. (2012), Contribution of occupational therapists in positive behaviour support. Aust Occup Ther J, 59: 428-436. https://doi.org/10.1111/j.1440-1630.2012.01036.x
  • xv NDIS. (2024). Capacity building supports: Operational guidelines. National Disability Insurance Scheme. https://www.ndis.gov.au
  • xvi Occupational Therapy Australia. (2024). Position statement: Occupational therapy roles in behaviour support, early intervention and neurodiversity-affirming practice.
  • xvii Alahmari FS, Alhabbad AA, Alshamrani HA, Almuqbil MA. Effectiveness of social skills training interventions for children with autism spectrum disorder: A systematic review and meta-analysis. Saudi Med J. 2025 Mar;46(3):226-237. doi: 10.15537/smj.2025.46.3.20240788. PMID: 40096975; PMCID: PMC11918677.
  • xviii Jacob US, Edozie IS and Pillay J (2022) Strategies for enhancing social skills of individuals with intellectual disability: A systematic review. Front. Rehabilit. Sci. 3:968314. doi: 10.3389/fresc.2022.968314
  • xix Akter, C., Rahman, M. H., Kakuli, S. A., Islam, F., Rahman, Z., Bulbul, A. H., & Faruk, O. (2026). Assessing the gait parameters and walking performance of stroke survivors: a cross-sectional study. Bulletin of Faculty of Physical Therapy, 31(1). https://doi.org/10.1186/s43161-026-00341-2
  • xx ATSA. (2023). Assistive technology and robotic gait rehabilitation: National guidance for practice. Assistive Technology Suppliers Australia.
  • xxi Occupational Therapy Board of Australia. (2023). Codes, guidelines and standards for occupational therapy practice. Australian Health Practitioner Regulation Agency.