Support Coordination and Connection Reform – OTA Submission – October 2026

Introduction

About Occupational Therapy Australia (OTA)

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 meaningful participation in the activities of life.

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 concerned with promoting health, wellbeing and participation through engagement in meaningful and necessary occupations. Occupational therapists understand that a person’s ability to participate is shaped by the interaction between their individual capabilities, the tasks they want to do, their physical and social environment, and the supports available to them.

Occupational therapists are already working in support coordination roles across Australia, alongside other professionals, supporting people to navigate services and coordinate supports around their goals, participation and everyday lives. Their occupational therapy expertise brings an important perspective to understanding the interaction between people, their environments, activities and support networks.

The occupational therapy contribution to support coordination and connection (SCC) centres around the occupational therapist’s expertise in understanding how a person’s health, functioning, environment, routines, relationships, and meaningful activities interact to enable or restrict participation. This enables assessment and coordination that starts from what the participant wants and needs to do, then identifies the barriers and supports required across home, community, education, work, and NDIS services.

Occupational therapists work across the NDIS in a range of roles, including functional and environmental assessment, home modifications, assistive technology, capacity building and complex case management, and practice across disability, health, education and community settings.

This breadth of expertise positions the profession to inform SCC design and strengthen coordination, particularly for participants with complex, fluctuating or intersecting support needs, where accurate assessment and early identification of risk make the greatest difference to outcomes.

Support Coordination and Connection – OTA Submission – October 2026

Recommendations

OTA recommends the SCC model embed structured pathways for participant-led collaborative planning, enabling participants to bring together their SCC workers, treating professionals and other people they choose where this will support their goals.
OTA recommends the SCC+ workforce include access to (and where indicated, be led by) suitably qualified allied health professionals, including occupational therapists, with relevant clinical expertise, to support safe, high-quality coordination for participants with complex needs.
OTA recommends the revised SCC service ensure accountability for the outcome of connection, not just the activity of referrals.
OTA recommends the model set a minimum expectation of face-to-face contact for SCC+ participants and at key transition points, with decisions about virtual delivery informed by functional and environmental assessment.
OTA recommends each participant be given a named SCC worker with direct phone and email contact.
OTA recommends the safeguarding framework draw on existing regulatory infrastructure, such as Ahpra registration, for occupational therapists and other regulated professionals working in SCC+ roles, to give participants independent and enforceable protections.
OTA recommends the Department incorporate participation-focused outcome measurement into the SCC service model from the outset, so that funding recognises progress towards participants’ goals.
OTA recommends the Department establish a structured transition pathway for workers moving into SCC and SCC+ roles, including training and capability building aligned to the skills the new service requires, to lift the quality and consistency of practice across the workforce.
OTA recommends procurement criteria explicitly assess lead organisations’ allied health governance capability, so SCC+ participants receive safe, high-quality coordination from the outset.
OTA recommends caseload standards be developed with direct allied health workforce input, so they reflect what participants with complex and intersecting needs require rather than assumptions carried over from simpler coordination models.
OTA recommends the design of outcome measures be informed by occupational therapy expertise, given the profession’s established experience using participation-focused outcome tools.
OTA recommends the payment model explicitly fund the time required for functional and environmental assessment as part of SCC+ delivery.

Support Coordination and Connection – OTA Submission – October 2026

OTA recommends quality, workforce and safeguarding requirements for commissioned SCC organisations be set nationally, to ensure consistent standards across all service areas.
OTA recommends the Department work directly with OTA and other allied health peak bodies to design the transition pathway, ensuring it recognises practitioners’ existing qualifications and experience and helps lead organisations build allied health capability from the outset.
OTA recommends the Department test proposed SCC+ remuneration and employment models against allied health workforce conditions, to ensure they can attract and retain the expertise the model relies on.
OTA recommends commissioned SCC+ services demonstrate capability in supported decision-making, including identifying and addressing the functional, communication and environmental factors that enable participants to actively engage in decisions about their lives and supports. Occupational therapy expertise should inform the design and delivery of this capability.

Support Coordination and Connection – OTA Submission – October 2026

Response to Consultation Questions

Occupational Therapy Australia (OTA) welcomes the opportunity to respond to the Department of Health, Disability and Ageing’s (the Department’s) consultation on Support Coordination and Connection (SCC) reform. We support the objectives of the reform and offer our feedback constructively, with the aim of helping it succeed.

From 1 July 2028, the NDIS will move from an open market for support coordination to a new, commissioned SCC service. The reform forms part of a broader redesign of intermediary supports across the Scheme, aiming to lift quality, consistency and safeguarding for participants.

This submission draws on an occupational therapy professional perspective to highlight principles that will improve the quality, consistency and responsiveness of the new SCC model. We advocate for a model that creates the conditions for participants to access occupational therapy expertise when they need it, whether through direct employment, subcontracting or consultation pathways.

Occupational therapists assess how a person’s capacity, environment, activities and support networks interact. This is the same combination of factors the Department has identified as central to SCC eligibility and service design.

Any role for occupational therapists in the new model must be realistic. The occupational therapy workforce is under significant pressure, and remuneration and employment arrangements for SCC+ will need to be viable to attract and retain the allied health expertise the model relies on. We have been careful not to recommend a model that depends on capacity that may not be available.

We note that the consultation paper defers most substantive design decisions, including eligibility criteria, workforce standards and the payment model, to later stages. The success of this reform will depend largely on how those decisions are made, particularly around workforce capability. Without a capable workforce, the reform’s quality, consistency and safeguarding objectives will be difficult to achieve.

While a small but meaningful proportion of occupational therapists work directly in SCC roles, many more work alongside support coordinators. Occupational therapists are also one of the largest allied health workforces in the NDIS. This gives our profession a clear, system-wide view of where coordination works well, where it breaks down, and what the consequences are for participants.

Our recommendations also draw on the profession’s expertise in the interaction between capacity, environment, activity, and support needs that this reform is designed to address. Standards informed by this expertise are more likely to be feasible in practice, easier for providers to meet and more durable across the staged rollout to 2028.

As the national professional peak body representing occupational therapists, we welcome the opportunity to contribute at each subsequent design stage, particularly on eligibility tools, workforce standards and payment model design.

Support Coordination and Connection – OTA Submission – October 2026

Our aim is a model that delivers consistent, high-quality outcomes across the whole system, not just improvements at the level of individual services.

Section 1: What participants want from the new SCC service

1. What is working well in support coordination today that you would like to see in the new SCC service?

The new SCC service should retain the features of current support coordination that enable purposeful connection, continuity and participant control. Occupational therapists understand these principles are critical to good outcomes and a positive participant experience.

Enabling purposeful connection requires more than referring a participant to an available service. It requires coordination, which, to be effective, must consider whether a participant can realistically take part in a proposed support within their everyday environment. When determining whether an available service is going to improve outcomes for the participant, the coordinator needs to consider the fit between the participant, their goals and routines, and the physical, social and contextual features of the setting or service.

When support coordinators bring an understanding of how a participant’s functional capacity and environment shape their participation, supports are better matched to need and emerging risk. An occupational therapist coordinating supports can recognise, for example, when a participant’s home environment, equipment needs or cognitive capacity are driving disengagement, and respond to the underlying cause. This integrated understanding often prevents crises before they escalate, reducing costly downstream interventions.

Continuity comes from relationship-based work. Consistent support helps a participant translate plan goals into practical, everyday routines. Over time, this relationship builds the trust and understanding needed to notice when something changes, such as a decline in function, a shift in health, or pressure on informal supports. Early recognition allows supports to be adjusted before a participant reaches crisis, protecting their wellbeing and avoiding costly escalation. Occupational therapists already do this as part of coordinating supports, turning clinical assessment into concrete changes at home, at work or in the community.

Capacity building should be a core SCC capability and outcome. Support coordination was originally intended to build participants’ capacity to understand their plan, make decisions, navigate services and increasingly manage aspects of their own supports. This intent has often been lost in practice. The new model is an opportunity to restore it.

Good practice supports participants to make informed choices, direct their own supports and assume more of that role over time. None of this is possible without funded time for the SCC worker to understand the participant’s goals, context and support networks. Tightly capped or transactional models risk reducing coordination to a referral exercise.

Support Coordination and Connection – OTA Submission – October 2026

Current support coordination draws much of its strength from direct access to clinical insight. Where coordinators work closely with occupational therapists and other treating allied health professionals, assessment findings shape which supports a participant is connected to, how those supports fit into their daily routines, and when they need to change. This link underpins purposeful connection, continuity and participant control, and OTA wants to see this retained in the new SCC model.

This matters most for participants whose support needs are shaped by functional or environmental barriers. For these participants, effective coordination depends on understanding how their capacity interacts with their environment, and participants themselves, along with the professionals already working with them, hold that understanding.

OTA recommends the SCC model embed structured pathways for participant-led collaborative planning, enabling participants to bring together their SCC workers, treating professionals and other people they choose where this will support their goals. (Recommendation 1). Participant-led planning keeps the participant at the centre of coordination and ensures clinical insight informs decisions, including where SCC workers do not deliver therapy themselves. It also preserves purposeful connection, continuity and participant control.

2. What would you most like to see improved in the new SCC service?

The consultation paper lists workforce capability as a potential quality element but sets no minimum capability standard. This is the single greatest risk to the reform’s stated goals of consistency and safeguarding. Without a defined standard, quality will vary as much under commissioning as it does in the current open market.

Capability requires more than a qualification. The Department should define core capabilities for SCC workers, including direct engagement with the participant, person-centred practice, capacity building, supported decision-making, cultural safety, trauma-informed practice, risk identification and local service navigation knowledge.

Direct engagement is the foundation of good SCC. SCC workers need the skills and time to work with the participant themselves: building trust, understanding how they communicate and supporting them to make decisions. This includes meeting in person where needed. Complex needs should prompt greater investment in engaging the participant. Family members and nominees play an important role, but a plan nominee should not become a substitute for this work.

Occupational therapists should be eligible for employment as SCC workers where a participant’s needs relate to complex functional, environmental, communication, health, psychosocial, or safety-related barriers.

Occupational therapists bring safeguards and skills the reform is seeking to build – a professional obligation to practise within scope, a code of conduct enforceable by an independent regulator, and training specific to functional and environmental assessment. These directly address the safeguarding and consistency problems this reform aims to solve.

Support Coordination and Connection – OTA Submission – October 2026

OTA recommends the SCC+ workforce include access to (and where indicated, be led by) suitably qualified allied health professionals, including occupational therapists, with relevant clinical expertise, to support safe, high-quality coordination for participants with complex needs (Recommendation 2).

We also encourage the Department to assign responsibility for outcomes across the support lifecycle. ‘Connected’ should mean the participant is taking part in a support that works for them.

A successful model will provide continuity of support – confirming the participant has accessed the service, helping them adjust where needed, and continuing coordination until a workable solution is in place. OTA recommends the revised SCC service ensure accountability for the outcome of connection, not just the activity of referrals (Recommendation 3).

Case study: Eli

Eli is 12, has cerebral palsy and uses a wheelchair. He wants to play table tennis at his local club, where two of his classmates play. His SCC worker connects Eli and his family with the club and helps with enrolment. They also refer Eli to an occupational therapist to build the skills and make the environmental changes he needs to participate. A support worker helps with transport and inclusion during training and games.

After his first session, Eli says he doesn’t want to go back. Rather than treating this as a lack of motivation or suggesting a different activity, the SCC worker brings together Eli, his family, the OT and the club to understand what went wrong. Together, they identify barriers that need more support. The OT addresses challenges with the change room set-up and the physical demands and pace of training. The support worker works with Eli to decide how much help he wants during training, and schedules transport to suit his energy levels and the training timetable.

Throughout, Eli decides what changes he wants and how much assistance he needs. The aim is to build his confidence and reduce support over time, where appropriate.

The outcome is not simply that Eli has been referred to a club, an OT and a support worker. Eli now attends training, plays alongside his peers, is making friends and is growing in confidence in a community role.

Eli’s case shows the value of SCC as a relationship-based, person-centred function that connects NDIS supports with the environment where participation happens. His initial withdrawal was not a question of motivation. Meaningful participation came from understanding and addressing how the person, activity, environment, relationships and available supports interact.

3. When should SCC be a face-to-face service or a virtual service?

Whether a service should be face-to-face or virtual should be determined by participant need rather than a fixed rule, and occupational therapy practice offers a useful model for how to make that judgement.

Participants with complex physical, sensory, communication, cognitive or psychosocial disability, or with in-home functional or home modification needs, where understanding their everyday context is especially important, should be offered face-to-face contact, particularly at the start of a relationship and at points of

Support Coordination and Connection – OTA Submission – October 2026

significant change. In-person contact helps SCC workers build trust, understand how a participant communicates and engage them directly in decisions about their supports.

Virtual delivery can complement this well for routine check-ins and administrative coordination once trust and understanding are established, extending reach into thin markets without replacing the assessment work that requires physical presence.

OTA recommends the model set a minimum expectation of face-to-face contact for SCC+ participants and at key transition points, with decisions about virtual delivery informed by functional and environmental assessment (Recommendation 4).

Continuity of contact is important regardless of delivery mode. OTA recommends each participant be given a named SCC worker with direct phone and email contact (Recommendation 5).

4. What participant groups will benefit most from the SCC service? What do their needs for connection and coordination of supports look like?

Participants with complex and intersecting needs, including psychosocial disability, cognitive impairment, sensory processing differences and those engaging with multiple overlapping service systems, will benefit most, provided the workforce has the skills, knowledge, experience and support to work effectively with that complexity.

People in these circumstances often need coordination that accounts for fluctuating capacity, cognitive load and environmental barriers to engagement, which is precisely the assessment lens occupational therapists apply.

This participant group also includes participants with developmental delay, progressive conditions, complex family circumstances, housing instability or access barriers linked to rural or remote location, all of which shape how support needs present and how engagement is best supported.

An occupational therapist coordinating supports for a participant with an acquired brain injury, for example, can recognise when memory or executive function difficulties, not disengagement, are contributing to issues such as missed appointments, and adjust the support approach accordingly.

Without access to this expertise in the SCC+ tier, there is a risk that participants with the most complex needs receive coordination from workers least equipped to understand the salient factors that contribute to their support challenges.

Complexity can also lead coordinators to shift their engagement to family members, nominees or treating professionals because it is administratively easier. The SCC model should expect and fund SCC workers to invest the time needed to engage directly with participants who have complex needs. This is where skilled engagement makes the greatest difference to a participant’s choice and control.

Support Coordination and Connection – OTA Submission – October 2026

5. What experience, skills and knowledge do you look for in an SCC worker?

For SCC+ roles specifically, the Department may wish to consider formal qualifications in a relevant regulated discipline, such as occupational therapy, or equivalent demonstrated capability, combined with experience in functional and environmental assessment, trauma-informed practice and complex case management.

Participants who need SCC+ require a coordinator who understands how functional capacity, environment, health, safety, equipment, routines and service systems interact. Occupational therapists bring a structured framework for understanding these interactions, developed through university training and maintained through continuing professional development requirements under Ahpra registration.

In a coordination role, an occupational therapist does more than confirm a referral has been made. They consider whether the participant can realistically access, participate in and sustain that support in everyday life. Their knowledge of assistive technology, home modifications, housing, trauma-informed practice and cultural safety helps them judge whether a proposed support will work for the participant, and what else needs to be in place for it to succeed.

This is most relevant when circumstances change. Occupational therapists are skilled at practical problem-solving when supports break down, services are unavailable or a participant’s needs shift. They also take a holistic approach to coordinating supports through major transitions, such as hospital discharge, a change in housing, moving between schools or entering employment.

Occupational therapists also bring specific expertise in capacity building. They identify what is limiting a person’s independence, then use practical, graded approaches to build the skills, routines, confidence and supports that enable greater self-direction over time. In an SCC context, this helps participants take on more of the coordination role as their capacity grows.

For general SCC roles, a combination of relevant qualifications and demonstrated coordination experience is appropriate. Occupational therapy input still improves the quality of coordination at this tier. It helps ensure barriers to participation, such as inaccessible environments, unsuitable assistive technology, communication demands or disrupted routines, are understood and addressed by the supports a participant is connected with. General SCC workers should therefore have access to allied health consultation, ideally occupational therapy, when a participant’s needs are found to be more complex than initially assessed.

Building this consultation pathway into the service model, rather than leaving it to individual provider discretion, would ensure consistent access to this expertise nationally. Across both tiers, the value occupational therapists bring to participants and the NDIS is their ability to turn coordination into practical, sustainable support arrangements.

Support Coordination and Connection – OTA Submission – October 2026

6. What would help you feel safe when receiving SCC services and encourage you to report an issue if needed?

Safety depends on clear, independent complaints pathways and confidence that SCC workers are subject to enforceable professional standards, not just organisational policy.

Occupational therapists already meet this bar through Ahpra registration, which gives participants an existing, trusted, independent avenue for raising concerns about professional conduct, separate from the commissioned provider itself.

Participants also need assurance that SCC workers are free from conflicts of interest, particularly financial links to service providers, and that they can maintain an ongoing relationship with a trusted worker rather than facing frequent turnover. Regular reflective supervision for SCC workers would further support safe, high-quality practice.

OTA recommends the safeguarding framework draw on existing regulatory infrastructure, such as Ahpra registration, for occupational therapists and other regulated professionals working in SCC+ roles, to give participants independent and enforceable protections (Recommendation 6).

7. What else should we consider when designing the future SCC service?

We encourage the Department to consider two further issues: outcome measurement and workforce transition.

Too much support coordination capacity is consumed by administration, emails, referrals and coordination activity that produce little meaningful change for participants. If the future payment model rewards this activity, such as contacts made or referrals completed, it will not drive the quality improvement the reform intends. Providers will optimise for whatever is measured. The new model should fund and measure effective engagement with participants and the outcomes it achieves.

Meaningful SCC outcomes include:

increased participation in everyday life, community, education or employment
increased ability to make and direct decisions about supports
increased capacity to understand and use their plan, navigate supports, solve problems and manage aspects of their supports more independently
established supports that are sustained and working effectively in everyday life
reduced reliance on crisis responses through early identification and resolution of issues
progress towards greater independence or reduced reliance on formal support, where appropriate and desired by the participant.

Support Coordination and Connection – OTA Submission – October 2026

Occupational therapy already uses validated, internationally recognised outcome measurement tools. These assess a participant’s functional performance and participation in goals that matter to them, rather than counting service contacts.

OTA recommends the Department incorporate participation-focused outcome measurement into the SCC service model from the outset, so that funding recognises progress towards participants’ goals (Recommendation 7). This would also give the Department a much stronger evidence base for demonstrating the reform’s success to Government and participants.

Many existing support coordinators are likely to move into roles with the new commissioned SCC providers. Without deliberate investment in their capability, the reform risks changing the service structure while carrying current levels of practice into the new model.

OTA recommends the Department establish a structured transition pathway for workers moving into SCC and SCC+ roles, including training and capability building aligned to the skills the new service requires, to lift the quality and consistency of practice across the workforce (Recommendation 8).

Qualifications alone do not guarantee quality or participant outcomes. A transition pathway would complement the qualification requirements we suggest for SCC+ roles and deliver a real uplift in practice across the SCC system. It would also connect naturally with outcome measurement, giving providers and workers a shared understanding of what good practice looks like and how it is measured.

Support Coordination and Connection – OTA Submission – October 2026

Section 2: Service provider models and approaches

1. What commissioning arrangements would best balance participant outcomes, quality, sustainability and choice and control?

A model that requires lead organisations to maintain a panel of allied health subcontractors, rather than absorbing all delivery in-house, would best balance these objectives.

This would preserve participant access to occupational therapy and other allied health expertise within a commissioned structure, while retaining the consistency and accountability benefits the Department is seeking.

Funding arrangements should also minimise conflicts of interest, for example by sitting outside individual participant plans where appropriate, and should reward relationship building, capacity building and participation rather than transactional activity alone.

Requiring lead organisations to demonstrate, as part of procurement, how they will access occupational therapy expertise for SCC+ participants would ensure this is not left to chance or cost-cutting once contracts are in place.

2. What provider types would be best placed to be a lead organisation? Why do these characteristics matter?

Organisations with demonstrated allied health governance capability, established local service networks and a track record of safe, quality-assured practice are best placed to lead.

Cultural safety capability should also be a selection criterion, alongside allied health governance capacity, given the diversity of the NDIS participant population. These criteria are important because SCC+ participants require a level of clinical judgement and risk management that generalist administrative providers may not hold in-house.

An organisation with allied health leadership, or well-established partnerships with allied health providers, including occupational therapists, is better positioned to manage complex caseloads safely, as allied health input is built into the provider’s structure.

Given the above, OTA recommends procurement criteria explicitly assess lead organisations’ allied health governance capability, so SCC+ participants receive safe, high-quality coordination from the outset (Recommendation 9).

3. What are the advantages and disadvantages of the lead organisation model?

The model offers consistency, clearer accountability and simplified oversight for the Department, which addresses genuine problems with the current fragmented market.

Support Coordination and Connection – OTA Submission – October 2026

Its main disadvantage is the risk of reduced market diversity, particularly for smaller providers, including occupational therapy-led practices, that currently serve regional and complex-needs participants well.

If lead organisations have no obligation to engage these providers, valuable expertise built up over years could disappear from the market entirely rather than simply being reorganised.

A formal subcontracting requirement, with allied health expertise, including occupational therapy, named as a required capability for SCC+ delivery, would preserve the advantages of the lead organisation model while mitigating this disadvantage.

4. What would be appropriate regional areas to use for SCC service areas?

SCC service areas should align with Primary Health Network (PHN) boundaries. Occupational therapy workforce distribution, referral relationships and service gaps already map closely to these boundaries.

Using PHN boundaries would keep established local relationships and referral pathways intact. It would also allow the Department to draw on existing PHN workforce and needs assessment data to check whether each region has sufficient occupational therapy and allied health capacity before finalising commissioning arrangements.

Boundaries should be adjusted where needed to reflect the service areas of Aboriginal Community-Controlled Health Organisations and thin-market conditions. This would ensure communities served by a single community-controlled organisation are not split across SCC regions, and that regions with few providers are configured to remain viable. These adjustments would help service areas match the practical realities of the communities they serve.

5. How might SCC providers manage variable need among the participants it supports? Which workforce, caseload, and service capacity factors should be considered?

Caseload settings should account for the intensity of functional and environmental assessment and coordination required for SCC+ participants, not just contact frequency or participant numbers.

A caseload standard based purely on headcount will under-resource SCC+ workers, particularly where participants require more intensive coordination around functional and environmental barriers and engagement with multiple supports and services.

OTA recommends caseload standards be developed with direct allied health workforce input, so they reflect what participants with complex and intersecting needs require rather than assumptions carried over from simpler coordination models (Recommendation 10).

6. Which payment and funding approaches would best support participant outcomes, workforce sustainability and innovation?

OTA supports a blended model that combines secure base funding with a modest outcomes-focused component, rather than a purely activity-based fee.

Support Coordination and Connection – OTA Submission – October 2026

This approach would help address the over- and under-servicing problems the Department has identified with the current fee-for-service model. It would also avoid the opposite risk of a block payment that removes any incentive for active engagement with participants.

Outcome measures should focus on effective engagement, functional progress and participation, such as the outcomes outlined in our response to Section 1, Question 7. SCC workers can influence outcomes, but they cannot control them. Service availability, changes in a participant’s circumstances and participant choice all affect whether and when outcomes are achieved. For participants receiving SCC+, meaningful progress may take considerably longer.

For these reasons, base funding should form the core of the model. Linking payment too closely to outcomes risks making SCC+ financially unviable, which would reduce access for the participants who most need intensive or longer-term coordination.

The payment model should also fund the practical costs of the role, including travel and outreach in regional and remote areas and time for reflective supervision.

OTA recommends the design of outcome measures be informed by occupational therapy expertise, given the profession’s established experience using participation-focused outcome tools (Recommendation 11).

OTA also recommends the payment model explicitly fund the time required for functional and environmental assessment as part of SCC+ delivery (Recommendation 12).

7. What quality, workforce and safeguarding requirements should apply to commissioned SCC organisations?

Commissioned SCC organisations should meet minimum capability standards for SCC+ roles, conflict-of-interest controls and independent complaints handling. Where an SCC worker belongs to a registered profession, providers should verify their registration, such as how occupational therapy is registered through Ahpra. These requirements give the Department an enforceable and auditable standard.

Requirements should also cover cultural safety and ongoing professional development, including access to regular supervision, so quality is maintained over time rather than assessed only at contract commencement.

OTA recommends quality, workforce and safeguarding requirements for commissioned SCC organisations be set nationally, to ensure consistent standards across all service areas (Recommendation 13).

For workers who are Ahpra-registered, the existing register also gives the Department an independent verification mechanism, reducing the need to build a new system from scratch.

Support Coordination and Connection – OTA Submission – October 2026

8. How can the future SCC model attract, build and retain workforce capability, including retaining participant relationships?

OTA supports a defined transition pathway that formally recognises current occupational therapists’ and allied health support coordinators’ qualifications and experience. This would retain valuable expertise and relationships, ensuring this workforce is not required to compete as new entrants against generalist applicants with no established participant relationships.

Retaining experienced occupational therapists in the support coordination workforce during transition would directly support the continuity the Department has identified as an implementation priority. Clear eligibility for SCC roles and recognition of existing experience would give these practitioners confidence to remain in the workforce, allowing participants to keep the relationships and knowledge their support depends on.

Retention requires realistic caseloads and clear career pathways for occupational therapists and other allied health professionals in SCC+ roles, alongside access to ongoing training and professional supervision.

Allied health peak bodies are well placed to support this work. We understand how our members practise, what qualifications and competencies they hold, and what supervision and professional development they need to work safely and effectively. We also have direct channels to practitioners, allowing us to communicate changes clearly and support members through the transition.

OTA recommends the Department work directly with OTA and other allied health peak bodies to design the transition pathway, ensuring it recognises practitioners’ existing qualifications and experience and helps lead organisations build allied health capability from the outset (Recommendation 14).

Remuneration and employment models are also crucial to retention. Occupational therapists face strong demand across health, disability and aged care, and SCC+ roles will need competitive conditions to attract them, whether through direct employment or subcontracting. This means funding SCC+ roles at rates that reflect occupational therapists’ clinical expertise and the costs of maintaining registration, including professional development, supervision and insurance.

OTA recommends the Department test proposed SCC+ remuneration and employment models against allied health workforce conditions, to ensure they can attract and retain the expertise the model relies on (Recommendation 15).

9. How should local knowledge and community connection be defined and assessed?

OTA defines local knowledge and community connection as an understanding of the services, supports and relationships available in a region, and how they work in practice. This includes:

knowledge of local health, disability and community services, and established referral relationships with them

Support Coordination and Connection – OTA Submission – October 2026

connections with specialist organisations, such as Disability Representative and Carer Organisations, Aboriginal Community Controlled Organisations and Aboriginal Community Controlled Health Organisations
knowledge of the local market for disability-related equipment and goods, including assistive technology, home modifications and mobility equipment, covering availability, cost, wait times and suitability.

Local knowledge and community connection should be assessed at two stages.

During commissioning, lead organisations should provide evidence of established local connections, verified through letters of support or formal agreements with local health, disability and community services, specialist organisations and community-controlled organisations. They should also demonstrate access to allied health practitioners with established local networks.

During delivery, the Department should monitor whether this knowledge translates into effective connection for participants. Reporting could include referral outcomes, time taken to connect participants with supports, and participant feedback on whether supports met their needs.

Occupational therapists working in regional areas build strong referral networks through years of practice with local health and disability services. They also understand the local equipment market through their work prescribing assistive technology and home modifications. Lead organisations that employ or partner with occupational therapists can draw directly on this knowledge.

10. How can the SCC service best support participants in regional, rural and remote areas, or other thin markets, where support options may be limited?

Two approaches to increase support options in thin markets are expansion of funded telehealth and workforce incentives.

Occupational therapy already has established telehealth-supported outreach models for assessment and review, developed to serve communities in thin markets. In best practice, outreach models should be paired with periodic in-person visits. OTA would welcome the opportunity to share this experience with the Department as implementation planning progresses.

The SCC service can only connect participants to supports that exist locally. In regional, rural and remote areas and other thin markets, allied health workforce shortages already limit those options. A commissioned model is likely to widen this gap. Providers will concentrate resources where delivery costs are lower and workforce is easier to recruit, unless commissioning arrangements direct them elsewhere.

Workforce supply is therefore a determinant of whether the SCC model can deliver equitable access to support. Where occupational therapists and other allied health professionals are scarce, SCC providers will struggle to connect participants to the capacity-building and functional supports they need. The Department may therefore consider building targeted incentives into SCC commissioning to attract and retain allied health professionals in thin markets. These could include thin-market price loadings, funded travel and outreach, and support for blended telehealth and in-person delivery.

Support Coordination and Connection – OTA Submission – October 2026

Occupational therapists working within SCC teams can strengthen connection in thin markets, where formal supports may be limited or unavailable. They combine functional expertise and problem-solving skills with local knowledge of services, equipment suppliers and community resources. This helps participants and their families identify practical adaptations and alternative support pathways across community, mainstream and informal options.

11. How can the SCC service best support participants who face additional barriers, including those experiencing complex and overlapping support needs or requiring decision-making support?

The SCC service can best support these participants by ensuring SCC+ workers have the capability to understand how a participant’s strengths, circumstances, environment and support networks interact to influence participation and to coordinate an individualised response.

Occupational therapists hold expertise specifically in this combination of factors, including how to support decision-making capacity through environmental adjustment and communication support rather than simply documenting a capacity limitation. The starting point should be what support or adjustment will enable the participant to engage in the decision, rather than defaulting to family members, nominees or professionals to make or direct decisions on their behalf.

This is directly relevant to participants requiring decision-making support, where the wrong approach can inadvertently reduce a person’s autonomy. OTA recommends commissioned SCC+ services demonstrate capability in supported decision-making, including identifying and addressing the functional, communication and environmental factors that enable participants to actively engage in decisions about their lives and supports. Occupational therapy expertise should inform the design and delivery of this capability (Recommendation 16).

12. What transition arrangements would minimise disruption and support successful implementation?

Three arrangements would minimise disruption: a recognised transition pathway for existing qualified support coordinators, including occupational therapists, into SCC and SCC+ roles; sufficient lead time for organisations to build allied health capability before the service commences; and early, clear communication with participants about which relationships will continue.

OTA would welcome working with the Department during implementation planning, as outlined in Recommendation 14, so allied health capability is built in from the outset rather than treated as a gap to fill after launch.

Support Coordination and Connection – OTA Submission – October 2026

Benefit to the Scheme

Incorporating an occupational therapy perspective into SCC design helps the new service deliver on the reform’s core objectives of quality, consistency and safeguarding, while supporting the long-term sustainability of the NDIS.

Better participant outcomes Coordination that considers the fit between a participant, their environment and their supports is more likely to lead to sustained participation. Participant-led collaborative planning and accountability for the outcome of connection (Recommendations 1 and 3) shift the measure of success from activity to tangible change in a participant’s life. Building participants’ capacity to manage aspects of their own supports also reduces their reliance on formal coordination over time, supporting the long-term sustainability of the Scheme.
Earlier intervention and avoided costs When coordinators can recognise that a participant’s environment, equipment or cognitive capacity is driving disengagement, they can address issues before they escalate. Connecting a participant with the right allied health input at the right time can prevent costly downstream support. Accurate assessment the first time avoids repeat assessments. Assistive technology matched to functional need avoids the costs of over- or under-prescription. These avoided costs quickly add up across the Scheme.
Consistency without building from scratch Several of our recommendations draw on infrastructure that already exists - occupational therapy offers validated, participation-focused outcome tools (Recommendations 7 and 11). Ahpra registration also offers an independent safeguarding and verification mechanism for regulated professionals (Recommendations 6 and 13). Using these reduces design and administrative costs, shortens implementation timeframes and gives the Department proven models to build from.
A realistic, sustainable workforce Our recommendations are designed around the available workforce. Instead of depending on occupational therapists to fill every SCC+ role, they create the conditions for participants to access OT expertise through direct employment, subcontracting or consultation (Recommendation 2).

Caseload standards and funded assessment time (Recommendations 10 and 12) protect the viability of SCC+ delivery. Co-designing the transition pathway and testing remuneration models (Recommendations 14 and 15) reduce the risk of commissioning a service on capacity that does not exist. They also retain experienced workers and participant relationships through the transition.
A stronger evidence base Measuring functional progress and participation gives the Department clearer evidence of what the reform achieves for Government, participants and the community. This supports continuous improvement across the staged rollout to 2028 and informs future commissioning decisions.

Support Coordination and Connection – OTA Submission – October 2026

Collectively, these benefits support the Government’s objective of an NDIS that delivers better outcomes for participants and remains sustainable for future generations.

Conclusion

OTA has approached this consultation as a systems-level opportunity. Our feedback considers how workforce capability, commissioning arrangements, regional design, payment models and safeguarding mechanisms interact to shape participant outcomes across the whole NDIS.

We have sought to identify where the new commissioning model’s stated objectives of consistency, safeguarding and quality are best supported by existing regulatory and professional infrastructure, and where gaps in the current design could undermine them if left unaddressed.

As a whole, our recommendations point to a single underlying theme - coordination works best when the participant directs it, and it stays connected to the professional insight that makes it effective.

This does not require every SCC worker to be an allied health professional. However, it requires a model that builds in reliable access to that expertise through participant-led collaborative planning, referral pathways and consultation, and that funds these arrangements realistically given current workforce pressures.

Our recommendations on workforce standards, capacity building, safeguarding, outcome measurement and payment design form a coherent position that connection should be built into the model from the outset.

A model built on these principles will improve the quality and responsiveness of coordination for all participants, and help ensure they can access occupational therapy and other allied health supports when their needs call for it.

OTA recognises the scale of the reform task ahead and the Department’s efforts to design a model responsive to a diverse participant population.

We offer our recommendations with the shared goal of a service that works for participants, providers and Government alike. We welcome the opportunity to test and refine them further as the SCC model develops.

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

Support Coordination and Connection – OTA Submission – October 2026

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.

Support Coordination and Connection – OTA Submission – October 2026