NDIS Annual Report No 2 of 48 th Parliament – OTA Submission – June 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 activit ies of life. We’re the single, unifying connection point for occupational therapists in the nation, leading the profession through education, support, and advocacy, so every occupational therapist is informed, inspired and fulfilled in their profession.

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

Terms of Reference

The Joint Standing Committee on the National Disability Insurance Scheme (NDIS) is charged with inquir ing into and report ing on the implementation, performance, governance, administration and expenditure of the NDIS . As part of this role, the committee is required to present an annual report to the Parliament as soon as practicable after 30 June each year on its activities during the year.

The committee’s annual report will include an examination of the annual reports of the National Disability Insurance Agency (NDIA) and the NDIS Quality and Safeguards Commission, and the committee can also report on any other matters it considers relevant.

The committee invites submissions from NDIS participants, the broader disability community, family members, informal carers and service providers on the implementation, performance, governance, administration and expenditure of the NDIS.

Introduction

Occupational Therapy Australia (OTA) is pleased to input to the Joint Standing Committee on the National Disability Insurance Scheme (NDIS) . OTA is uniquely positioned to inform the Committee’s examination of the Scheme’s implementation, performance, governance, administration and expenditure.

OTA represents one of Australia’s largest allied health workforces - professionals engag ed across the full breadth of NDIS -relevant service contexts, including disability, mental health, aged care, primary care and veteran services. Occupational therapists deliver the supports of the very heart of the NDIS. This support enable s NDIS participants to achieve their goals, increase their independence, and participate meaningfully in everyday life, work, education and community activities.

Occupational therapists do not observe the NDIS from a distance, but experience its implementation, performance and administration at the frontline, every day, across every state and territory. The insights OTA brings to this submission are grounded in direct, sustained and syst em -wide engagement with the Scheme , making us well placed to serve as a constructive partner to the Committee in its important work.

OTA believes in and supports the NDIS because it places people with disability at the centre of decision making, and enables access to the supports they need to live meaningful lives. OTA will continue to advocate for a strong, sustainable Scheme that is accessible, fair, and backed by a skilled workforce – so participants can achieve their goals and remain engaged in their communities.

Every day , across Australia, people with disability are missing out on the essential services as NDIS reforms constrain access to qualified occupational therapists. The impact is real - compromised participant outcomes, increas ed pressure on families, communities and broader support systems, and an erosion in the Scheme’s ability to deliver on its core purpose.

Chronic underfunding and a lack of workforce support has pushed occupational therapists to breaking point : more than 8% of the workforce exited the NDIS in 2025, and more than 7000 NDIS participants lost access to essential occupational therapy supports as a result.

Pricing has been frozen for eight consecutive years , despite rising costs and increasingly complex participant needs . Many practices have been push ed to reduce service availability, limit intake of higher -complexity participants, or withdraw from regional and ural areas entirely.

NDIS Annual Report No 2 of the 48 th Parliament – OTA Submission – June 2026 2

OTA’s members report they can no longer sustain NDIS work under the current

conditions. Waitlists are growing, mobile and travel-based service delivery is contracting, and regional and remote communities are bearing the greatest burden. Without urgent action, the NDIS risks losing the very workforce it depends on to function.

These concerns reflect a daily reality for occupational therapists: working to sustain NDIS services under conditions that have become untenable. In this submission, we provide recommendations that respond directly to that experience- practical, evidence-grounded reforms, built from the experiences of those at the frontline of the NDIS. Each would strengthen the Scheme’s efficiency and sustainability without further burdening the workforce it depends on.

These recommendations are informed by OTA’s sustained engagement across six NDIS consultation processes between June 2025 and June 2026 - on support lists, provider registration, pricing, framework planning, integrity, and the NDIS Amendment Bill. A summary of those contributions is provided at the end of this submission.

Recommendations

• Recommendation 1 - Streamline Assessment Pathways OTA recommends the Government streamline NDIS assessment pathways (including through the introduction of national templates), establish occupational therapy as the lead profession for functional capacity and support needs (both for assessment and reporting ), and introduce a clearer link between clinical evidence and scheme decisions.

• Recommendation 2 – Assistive Technology OTA recommends the NDIA pursue three complementary reforms to strengthen the role of assistive technology in scheme sustainability: redesign assistive technology application forms to reduce administrative burden on clinicians; establish a national assistiv e technology reissue system to recover value from equipment no longer in use; and create a formal engagement mechanism between occupational therapists, allied health professionals and NDIA staff to address assessment and assistive technology issues on an ongoing basis.

• Recommendation 3 – Environmental Modifications OTA recommends that the NDIA strengthen investment in occupational therapy-led home modification assessment as a demonstrable cost-containment measure - recognising that early, well-targeted environmental modifications, supported by rigorous clinical reasoning, reduce falls, prevent crises, lower reliance on ongoing paid supports, and generate scheme savings that substantially outweigh the upfront cost of assessment and intervention.

• Recommendation 4 – Skill Building OTA recommends that the NDIA explicitly recognise skill building supports delivered by occupational therapists as a Scheme sustainability mechanism - investing in timely, evidence-based capacity building as a strategy to reduce long-term support intensity, lower future scheme liability, and deliver better outcomes for participants across the life of the scheme.

Existing Recommendations

OTA also made 37 recommendations relating to NDIS reform in separate submissions over the period June 2025-June 2026 : nine on support lists, four on registration, three on pricing, six on framework planning, two on integrity, and thirteen relating to the NDIS Amendment Bill. Those recommendations can be read in the full submissions linked at the end of this submission.

Submission

Occupational therapists are among the most frequently engaged practitioners in the NDIS, working daily with participants to assess functional capacity, design support plans, and help people build skills and independence. This proximity to the lived reality of the NDIS - its processes, its friction points, and its unmet potential - gives our profession a distinctive and evidence -informed view on what is working and what is not.

Our members have direct, practical ideas , grounded in evidence -based clinical experience and participant outcomes , that would reduce complexity, reduce duplicated effort, and deliver better value for money. Done well, these changes would save the scheme time and money while delivering meaningfully better outcomes.

The four examples presented here illustrate the breadth and practical nature of the changes we believe would make a difference . Each has been selected to demonstrate how relatively modest adjustments to the way the scheme operates could meaningfully reduce waste, improve participant experience, and contribute to long -term sustainability. They are representative, not exhaustive, and w e offer them to the Committee as a starting point for deeper conversation.

1. Streamline Assessment Pathways

OTA contends that f unctional capacity and support needs assessments in the NDIS could be made significantly more efficient by reducing duplication, establishing a consistent evidence base, and accepting one high -quality assessment across multiple decision points where appropriate.

Currently, participants are routinely asked to provide similar information at each stage of the scheme (access, planning, review, and funding ), which creates unnecessary burden and delay. A more coordinated approach would reduce administrative costs, shorten wait times, and direct scheme resources toward supports rather than repeated paperwork.

As a practical first step, OTA recommends introducing national templates, standard referral pathways, and agreed evidentiary requirements for functional and support needs assessments. This would help clinicians, participants, and decision -makers understand what is required from the outset, reducing follow -up requests and improving the quality of evidence on which decisions are made.

Occupational therapists are central to this reform. They are already the profession best placed to assess how disability affects everyday functioning across home, community, and work environments. Their assessments integrate clinical observation, standardi sed tools, environmental analysis, and participant goals into practical, decision -ready

• recommendations
• combining the clinical rigour and real-world relevance that NDS decision-making requires. No other profession brings this combination of scope and specificity to functional capacity and support needs reporting.

Placing greater confidence in well-prepared occupational therapy assessments earlier in the process would reduce unnecessary reassessments, lower the incidence of disputes about evidence, and shorten the time participants spend waiting for decisions. This would achieve cost savings - not through restricting access, but through increased operational efficiency and reduced process costs. Participants would also directly benefit from spending less time repeating their story , and more time accessing supports that build independence and participation.

This approach would also deliver more consistent evidence, faster decisions, and lower administrative costs , while improving outcomes for people with disability.

Recommendation 1

OTA recommends the Government streamline NDIS assessment pathways (including through the introduction of national templates), establish occupational therapy as the lead profession for functional capacity and support needs (both for assessment and reporting ), and introduce a clearer link between clinical evidence and scheme decisions.

2. Assistive Technology

Assistive technology is one of the most effective levers for improving NDIS sustainability. When the right equipment is provided early (such as mobility aids, pressure care equipment, communication devices, home modifications, or digital prompting tools ) participants can complete daily tasks more safely and independently. This reduces reliance on paid support hours over time, helps prevent injuries and hospital presentations, and strengthens participation in education, employment and community life.

The NDIA’s own Assistive Technology Strategy recognises this link explicitly, connecting better assistive technology provision with reduced recurring costs and improved scheme sustainability. This is consistent with a 2002 study, which found that f or every $1 spent on assistive technology and home modifications, there is a conservative estimated $2 return on investment resulting from savings on the cost of paid carers, support and medical services.

Layton, N., & Brusco, N. (2022). The Australian assistive technology equity studies: Improving access to assistive technology for people with disability who are not eligible for the NDIS . Monash University; COTA Victoria. hhttps://doi.org/10.26180/21113887

Occupational Therapists’ Role in Assistive Technology Savings

Occupational therapists are central to realising these savings. A skilled occupational therapy assessment ensures assistive technology is well matched to a participant’s goals, functional needs and environment - identifying the right solution the first time and avoiding the waste associated with over-preservation, under-prescription, or equipment that goes unused.

Occupational therapists adopt a robust process to facilitate successful assistive technology outcomes for NDIS participants that include functional and environmental assessments, equipment trials, adaptation and customisation of equipment in collaboration with assistive technology suppliers and training - so participants and support workers are able to maximally benefit and safely use the prescribed items.

At a system level, occupational therapists contribute to sustainability through consistent evidence-based assessment, recommending scalable and reusable Assistive Technology solutions where appropriate, and reviewing supports over time to ensure prescribed items remain effective.

Three targeted reforms to the NDIS would strengthen this contribution considerably.

First, assistive technology application forms should be redesigned. The current forms are unnecessarily lengthy and repetitive, adding hours to report writing without improving the quality of evidence provided. A more concise, better-structured form would reduce the cost of each assessment to the scheme while maintaining the clinical rigour required for sound decision-making.

Second, the NDIA should establish a national assistive technology reissue system. Equipment that is no longer required by one participant (and still meets relevant quality standards) should enter a managed reissue pool, similar to the existing SWEP model in Victoria, making it available to other participants at significantly reduced cost. The volume of high-value assistive technology currently being disposed of or sold informally reflects a real and avoidable cost to the scheme that a well-designed reissue system could recover.

Delivering a reissue program of this kind is complex, and will require careful consideration of issues such as safety, hygiene, traceability, variety and maintenance. OTA is well placed to support its design and implementation , including how to resolve the core operational challenges a loan or pool program must address. Our capability framework for occupational therapists demonstrates our expertise in this area , establishing a shared expectation of the skills, values and experience the profession brings to assistive technology prescription.

Third, structured engagement between occupational therapists, allied health professionals and NDIA staff should be formalised. Whether through regular informal

Environmental Modifications

Home modifications trade a one-off capital cost for long-term reductions in care demand . Grab rails, ramps, bathroom modifications, improved layouts, and other accessibility features reduce the risk of falls, injuries, manual handling incidents, and hospital admissions - preventing the kind of avoidable crises that generate significant downstream costs.

They also reduce reliance on paid support by making everyday tasks safer and more manageable for participants and their carers.

NDIS guidance already recognises this logic, and funds home modifications where they are related to disability and represent value for money relative to alternative supports. The case for early, well-targeted investment is clear: the cost of a modification is almost always lower than the cost of the crisis it prevents.

Occupational therapists are essential to ensuring that investment is well placed. Their role is to assess how a person actually functions in their environment, identify risks, trial alternatives where appropriate, and determine the least costly option that will safely and effectively meet the participant’s needs.

This clinical reasoning guards against over-prescription, duplication, and poorly matched supports, while improving the likelihood that funded interventions will be used, maintained, and deliver measurable benefit. A skilled occupational therapy assessment protects the scheme from spending that would otherwise fail to produce lasting outcomes. OTA’s capability framework establishes a shared expectation around the skills , values , and experience needed by our profession when prescribing home modifications.

Occupational therapists also support sustainability at a system level. High-quality assessments establish functional impact and support needs clearly from the outset,

Skill Building

Skill building is one of the clearest expressions of the NDIS’s insurance logic. Whe n NDIS participants develop practical capacity in daily living, self -care, routines, mobility, communication, or community access, the need for intensive ongoing support reduces over time , as does their long -term scheme liability. OTA views timely, targeted skill building as an investment that improves participant outcomes while reducing future expenditure. A scheme that funds skill development effectively will, over time, c arry a lighter support burden than one focused purely on care provision or maintenance.

Despite this, skill building remains underfunded and underutilised relative to its potential. Many participants receive supports oriented toward assistance rather than development, meaning the scheme funds the same tasks indefinitely rather than investing in the functional g ains that would reduce that reliance. This is not always the result of poor planning - it often reflects gaps in assessment, unclear expectations about what skill building should achieve, and insufficient support for participants and fam ilies to understand their options.

Occupational therapists are well placed to ensure that NDIS investment is directed where it will make the greatest difference to a participant . Through holistic assessment and clinical reasoning, occupational therapists apply restorative, reablement, and rehabilitative approaches that distinguish between skill -building supports that genuinely enhance independence and those that are unnecessary, duplicative, or unlikely to deliver measurable benefit.

The recommendations of occupational therapists are holistic, and typically draw on the most effective mix of interventions - environmental modifications, assistive technology,

• skill development, carer education, and graded intervention
• ensuring that funding is purposeful, proportionate, and targeted at reducing future support needs rather than simply maintaining the status quo.

Realising the full sustainability benefit of skill building requires a system that actively supports occupational therapists to do this work well. That means clear referral pathways, consistent evidentiary standards, and NDIS planning processes that create genuine space for capacity building goals. It also means recognising the upfront investment required for high-quality assessment and targeted intervention, and understanding that this investment pays dividends over the life of a participant’s plan.

The NDIS’s insurance logic requires deliberate policy settings that elevate evidence-based capacity building as a strategic priority.

Recommendation 4

OTA recommends that the NDIA explicitly recognise skill-building supports delivered by occupational therapists as a Scheme sustainability mechanism - investing in timely, evidence-based capacity building as a strategy to reduce long-term support intensity, lower future scheme liability, and deliver better outcomes for participants across the life of the scheme.

Previous Submissions

OTA was pleased to be an active and consistent voice in NDIS policy reform from June 2025 to June 2026. Across six formal submissions, OTA drew on the frontline experience of occupational therapists working daily within the NDIS to provide evidence-based analysis and practical recommendations on the issues shaping the Scheme’s future. The breadth of these contributions reflects OTA’s sustained commitment to constructive engagement across the full scope of NDIS reform.

In July 2025, OTA submitted on NDIS Support Rules, highlighting broad concern that the current framework for support lists is too rigid, inconsistently applied, and is actively harming participants by blocking access to clinically appropriate supports. OTA presented nine recommendations which collectively provide a more flexible, transparent, and inclusive framework that better serves participants and practitioners.

In November 2025, OTA submitted on NDIS Practice Standards and registration framework. OTA called for minimising regulatory friction and alignment with existing AHPRA registration. OTA presented four recommendations to ensure that regulatory reforms are proportionate, evidence-based, and developed in genuine partnership with the allied health sector.

In February 2026

OTA submitted to the NDIA’s 2026 Annual Pricing Review (APR) , noting that current pricing settings for occupational therapy are critically inadequate, sustai nable, and are actively driving providers out of the scheme . Frozen hourly rates are forcing providers to reduce services, withdraw from complex and regional areas, and exit the scheme altogether. OTA presented three pricing recommendations to reflect our urgent concern s over inadequate NDIA fee settings .

In March 2026

OTA submitted on draft NDIS New Framework Plan Rules , raising extreme concern about the potential impact of the proposed New Framework Planning rules for occupational therapy , particularly the new assessment tool (I -CAN). OTA presented six framework planning recommendations which collectively urge the government to slow down, increase transparency , and ensure occupational therapists are central to the design and delivery of the new NDIS planning framework.

In April 2026

OTA submitted on integrity, fraud and non -compliance within the NDIS . OTA welcome d efforts to tackle fraud and serious organised crime in the NDIS, and position ed clinical governance as directly connected to scheme integrity. OTA presented two recommendations to ensur e that occupational therapy expertise informs NDIS oversight , and that workforce development is recognised as a key safeguard against poor practice.

In May 2026

OTA submitted on the NDIS Amendment Bill 2026 , noting that , as drafted , the Bill posed significant risk to participants, the occupational therapy workforce, and the Scheme’s long -term integrity. OTA presented thirteen recommendations to improve the Bill, focused on safeguarding clinical integrity, participant rights, and alli ed health workforce sustainability.

Conclusion

The NDIS is at a critical juncture. The reforms underway will shape the Scheme , and the lives of people with disability , for decades to come. OTA urges the Committee to consider the evidence and recommendations presented in this submission carefully, and to use its oversight role to press for reforms that are clinically grounded, workforce -sustainable, and genuinely centred on participant outcomes.

OTA remains committed to providing rigorous, evidence -based input into the policies and reforms that shape the NDIS and the broader disability support sector. We stand ready to work constructively with government and the NDIA , and look forward to continuing this record of active engagement in the year ahead.

OTA is available to brief this committee about this submission . We are available at

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.

NDIS Annual Report No 2 of the 48th Parliament – OTA Submission – June 2026