National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1009
Submission to the Senate Community Affairs Legislation Committee National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submitted by: Kristy Waugh Accredited Social Worker | Play Therapist Connected Kiddos Early Intervention | Townsville, North Queensland AASW Member
Introduction
Thank you for the opportunity to provide a submission to the Senate Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.
I am an Accredited Social Worker and play therapist working in private practice in Townsville, North Queensland, and a member of the Australian Association of Social Workers. My practice, Connected Kiddos Early Intervention, provides attachment-based, trauma-informed early intervention for young children with developmental delay, disability, neurodivergence, trauma histories, social-emotional difficulties, regulation challenges and complex family circumstances. I work closely with parents, caregivers, schools, childcare settings and allied health teams to support children’s functional capacity, participation, emotional regulation, relationships and everyday wellbeing.
I am making this submission because the proposed changes have serious real-world implications for young children and families in my region, and for the providers working with them. I write from both clinical and professional experience, and from a commitment to the children and families whose outcomes depend on timely, appropriate and accessible support.
I absolutely understand the importance of a sustainable NDIS. However, sustainability cannot be achieved by shifting disability-related support needs onto exhausted families, under-resourced schools, long health waitlists, stretched childcare services and thin regional service systems.
Unmet disability-related need does not disappear when funded support is reduced. It is transferred — to families, teachers, educators, health services and child protection systems, many of which are already under significant pressure.
Key Issues
My submission relates particularly to proposed changes affecting eligibility, permanence, substantially reduced functional capacity, available treatment, available supports, mainstream services, informal supports and the distinction between ordinary parental responsibility and disability-related capacity building. These changes, individually and together, risk creating significant access barriers for children and families who currently have genuine disability-related needs.
- Children may be found ineligible before realistic alternatives exist Proposed changes to eligibility criteria, including the requirement to demonstrate ‘substantially reduced functional capacity’ and the increased emphasis on permanence,
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1009
available treatment and other service systems, will create access barriers for young children
- particularly those with developmental delay or emerging disability.
In regional Queensland, families may wait significant periods for paediatric and developmental assessment through public pathways, or may be unable to access those pathways at all. Private multidisciplinary assessment can cost several thousand dollars, placing it out of reach for many families. If eligibility increasingly depends on diagnosis, or on evidence that all available treatment has been exhausted, children will be disadvantaged not because they do not have significant needs, but because the systems required to evidence those needs are unavailable or unaffordable.
A child’s functional needs do not disappear because the system requires a diagnostic label their family cannot realistically obtain.
- The reality of what families are already carrying A principle central to developmental practice is that children do well when they can. When children are struggling to participate at home, in childcare, at school or in the community, this is rarely because they are unwilling. It is most often because their developmental, sensory, communication, regulation or social-emotional needs are not yet being adequately understood or supported.
The same principle applies to parents and caregivers. Parents do well when they are supported.
In my clinical work, I regularly see parents who are exhausted, overwhelmed and isolated. These families are not only parenting their child. They are also coordinating therapy appointments, school meetings, paediatric reviews, reports, NDIS plan reviews, behaviour support, diagnostic waitlists, funding decisions and service gaps. For many families, navigating the school, health and disability systems has become a part-time or full-time undertaking alongside their parenting and paid work.
Any increased reliance on informal supports, parental responsibility or mainstream systems must be tested against the reality of what families are already carrying. Parents are not asking the NDIS to replace their parenting. They are asking for disability-related support so they can safely and effectively parent a child whose needs exceed what would reasonably be expected for a child of the same age.
- Capacity building is not ordinary parenting Capacity building supports must not be misread as ordinary parental responsibility, and this distinction must be clearly legislated.
For young children, disability-related support is often delivered through parents and caregivers. This does not make the support optional, nor does it place it outside the appropriate scope of the NDIS. Caregiver coaching, co-regulation support, relationship- based intervention, developmental guidance, social-emotional support and school or childcare liaison are disability-related capacity building supports. They help parents understand their child’s needs, respond during dysregulation, support communication and emotional development, build predictable routines, and enable the child to participate safely and meaningfully across daily life.
In early childhood, supporting the parent-child relationship is often the intervention. This is particularly true for children with developmental delay, disability, neurodivergence, trauma histories, anxiety, sensory processing differences, communication delays and significant regulation difficulties. The evidence base for relationship-based early intervention, including Theraplay, AutPlay, Marte Meo and Synergetic Play Therapy approaches, consistently demonstrates that building caregiver capacity is a core mechanism of positive developmental outcomes, not a supplement to it.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1009
Parents should not have to become case managers, therapists, advocates and system navigators simply because their child has a disability.
Without a clear legislative distinction between ordinary parental responsibility and disability- related capacity building, support needs will be shifted from the NDIS onto already exhausted families. The functional impact on children will be real, even if it is not immediately visible within the NDIS data.
- A support is not available simply because it is named in legislation The Bill appears to place greater weight on whether support can be provided through families, informal supports, mainstream services or future Foundational Supports. In principle, those systems matter. In practice, they are not yet ready, and for regional communities, they may not be for some time.
We do not currently have the workforce, funding, training or service capacity to treat these systems as realistic alternatives to NDIS-funded capacity building support. In regional communities like Townsville, families are already facing:
• Long waitlists for public paediatric and developmental assessment • Limited allied health workforce, particularly in child-specific or disability-informed practice • Restricted access to developmental and early childhood mental health supports • Schools and early childhood settings managing significant complexity with constrained specialist support • GPs who are frequently the first point of contact for developmental concerns but who lack specialist training in childhood development and cannot provide the level of assessment or coordinated support these children need • Child protection systems that are already overwhelmed and unable to place children with complex developmental or disability-related needs in appropriate foster or kinship care - leaving some children as young as three years old in residential care facilities staffed by workers without specialist developmental or disability qualifications • Foundational Supports and Thriving Kids pathways that are not yet established or operational A support is not ‘available’ simply because it is named in legislation or policy. It is only genuinely available if a family can access it: in their location, within a realistic timeframe, at a cost they can afford, at a level that meets their child’s functional needs.
A future pathway is not an available support. A system without workforce is not an available support.
- The service gap is already visible Families are already being redirected between systems. They are told to approach schools, health, paediatrics, parenting programs, private therapy or community supports. Too often, no single system takes responsibility for meeting the child’s functional needs.
Many of these children are too complex for general parenting supports, cannot access timely health or education support, and currently rely on disability-related capacity building to participate safely and meaningfully across daily life. If Government intends for children and families to access support outside the NDIS, those supports must be in place before eligibility is narrowed or capacity building is reduced.
Families should not be moved out of one system before another system is ready to receive them.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1009
A Regional Case Example
The following example is de-identified and shared with the family’s knowledge and support.
I am currently supporting a child approaching her sixth birthday whose NDIS plan is due to end around that milestone as per a recent call from the NDIS team to the child’s guardian. This child continues to have clear developmental, social-emotional and functional support needs across daily life, including difficulties with communication, co-regulation, transitions and participation at home, in childcare and in the community.
She does not yet have a formal diagnosis. This is not because her family has not sought help. Public paediatric diagnostic pathways in her area have significant wait times. The family does not have the financial means to fund a private multidisciplinary assessment, which can cost several thousand dollars. Her community allied health team has provided assessments, reports and clinical recommendations outlining her ongoing needs. This has not been sufficient for her to continue receiving NDIS support beyond age six.
This is precisely the type of child this Bill must account for.
She is too old to continue under the developmental delay pathway without a diagnosis, yet she cannot access a timely public diagnostic pathway, her family cannot afford private assessment, and alternative Foundational Supports are not yet available in a way that can meet her needs. In practice, this is a service cliff.
Her functional needs will not change on her sixth birthday. Her family’s need for guidance, capacity building, co-regulation support, developmental intervention and coordinated care will not resolve because the system has moved on. What will change is the availability of funded support to meet those needs.
The Committee should be able to clearly identify where children like this are meant to receive timely, affordable, developmentally appropriate and disability-informed support. If that pathway does not yet exist, the legislation should not proceed as currently drafted in this area.
Downstream Impact on Families and Broader Systems
Impact on family wellbeing When families are not supported, the risk is not simply that a child misses therapy. The risk is that the family system becomes increasingly overwhelmed. This may include:
• Caregiver burnout, anxiety and depression • Sibling stress and reduced family cohesion • Reduced capacity to maintain routines and support school attendance • Increased crisis presentations to health and mental health services • Increased risk of family breakdown or out-of-home care involvement These risks are heightened for families already managing trauma, poverty, housing stress, domestic and family violence, foster or kinship care arrangements, medical complexity or limited informal support networks - all of which are common in the families I support in North Queensland.
Supporting parents is not separate from supporting children. In early childhood disability support, it is often one of the most effective mechanisms for improving a child’s long-term outcomes.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1009
The Government’s sustainability framing focuses on the cost of the NDIS. It does not account for the downstream cost of not funding early intervention. Reduced capacity building support for families will, predictably, increase pressure on family support services and child protection systems - systems that are already overwhelmed, and that are significantly more expensive to operate than early intervention. Increasing the burden on parents without adequate support will accelerate family breakdown, increase demand on out-of-home care, and push more children into crisis pathways that cost the public far more than the supports being removed. A four-year-old receiving capacity building support through the NDIS costs the Government far less than a four-year-old in residential care.
Impact on schools and early childhood settings Schools, childcare settings and health services are essential partners in a child’s support network. They are not realistic replacements for disability-related capacity building support.
In my clinical work, I regularly liaise with schools and early childhood settings that genuinely want to support children well, but are managing large demands, limited staffing, limited specialist training and increasing complexity. Teachers and educators should not be expected to absorb additional disability-related support needs without the resourcing, training, time and specialist support required to do so safely and effectively.
When NDIS-funded supports are reduced without a realistic alternative, children’s needs often escalate across other systems. This can contribute to school avoidance, exclusion, family distress, caregiver burnout and increased presentations to health, mental health and child safety services. Asking families, teachers and educators to carry more does not reduce need. It redistributes it - at a greater overall cost to the individual, the family, and the public.
Recommendations
I respectfully recommend that the Committee consider the following:
- The Bill should include clear safeguards to ensure children are not excluded from the NDIS, or from capacity building supports, on the basis of theoretical access to mainstream services, informal supports or future Foundational Supports.
- Decision-makers should be required to assess whether other supports are genuinely available in the family’s real-world context, including consideration of cost, wait times, local access, public system capacity, developmental appropriateness, cultural safety, family capacity and whether the support can realistically meet the functional impact of the child’s needs.
- The legislation should clearly distinguish ordinary parental responsibility from disability-related capacity building. Caregiver coaching, co-regulation support, developmental guidance, social-emotional support, relationship-based intervention and school or childcare liaison should be recognised as legitimate disability-related supports where they address the functional impact of a child’s disability or developmental delay.
- Children should not be disadvantaged because diagnostic pathways are unavailable, unaffordable or delayed. Functional evidence from allied health and developmental professionals should be given appropriate weight in eligibility and planning decisions, particularly for young children in regional and remote communities.
- Children should not face a service cliff at age six where they continue to have significant functional needs but cannot access timely diagnostic assessment or alternative support pathways, particularly where their disability is still emerging or unclear.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1009
- Foundational Supports and Thriving Kids pathways must be established, resourced and genuinely accessible in regional communities before children and families are transitioned away from NDIS-funded supports. A future pathway is not an available support.
- The Government should undertake a transparent assessment of the likely downstream impact of reducing disability-related capacity building supports on families, schools, childcare services, health services, mental health services and child safety systems — and report those findings publicly before the Bill is passed.
Conclusion
I support the need for a sustainable NDIS. However, sustainability must not be achieved by narrowing eligibility or reducing capacity building supports before realistic alternatives exist.
Children do well when they can. Parents do well when they are supported. Systems work when they are properly resourced to meet real needs.
For many young children, capacity building support is not an optional extra. It is the support that enables them to communicate, regulate, connect, participate in childcare and school, remain safely within their families, and build the functional foundations for later life. Reducing that support does not reduce the underlying need. It transfers the burden onto the people and systems least equipped to carry it.
The legislation must ensure that children and families are not left without support because an alternative service exists in theory, a diagnosis is expected but inaccessible, or a future support pathway has been announced but is not yet available in the real world - particularly in regional and remote communities where service gaps are already significant.
Unmet need does not disappear. It escalates — and the cost, to children, families and the broader system, is always higher.
Thank you for considering this submission.
Kristy Waugh | Social Worker and Play Therapist | Connected Kiddos Early Intervention | Townsville, North Queensland Submission to the Senate Community Affairs Legislation Committee | May 2026