National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1020
Practical Concerns Regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
To the Community Affairs Legislation Committee,
Thank you for the opportunity to provide feedback regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.
I am an AHPRA-registered Occupational Therapist and small business provider working across the Macarthur and Wollondilly regions of NSW. I have more than 10 years’ experience delivering paediatric occupational therapy supports across public health, private practice, outreach and community settings, including regional and remote outreach through Far West Local Health District and the Royal Flying Doctor Service.
I currently support children and families experiencing developmental delay, autism, ADHD, sensory processing differences, emotional regulation challenges and participation difficulties across home, education and community environments.
I understand the need for long-term sustainability and integrity within the NDIS. However, I am concerned that aspects of the proposed reforms may create significant unintended consequences for children, families and frontline services if implementation is not carefully managed.
The proposed changes to functional capacity assessments and access pathways raise particular concerns for neurodivergent children and children with developmental delay. In practice, many children present very differently across environments. Some children mask difficulties at school, cope for short periods before significant dysregulation at home, or rely heavily on caregiver support, environmental modifications and scaffolding to participate successfully in everyday activities.
I am concerned that more standardised or restrictive approaches to assessing functional capacity may not fully capture the real-world impact these children experience across daily life, particularly when difficulties are inconsistent, relational or heavily influenced by environmental demands.
I am also concerned about proposed limitations around plan reassessments. While reducing inappropriate reassessment requests is understandable, there is a risk that children experiencing emerging developmental, behavioural or functional challenges may struggle to access timely adjustments to supports during critical developmental periods.
For many children, small unmet needs escalate quickly. Delayed access to support can contribute to worsening emotional regulation difficulties, school disengagement, family stress and increasing support needs over time.
These concerns are particularly significant for culturally and linguistically diverse families, Aboriginal families and families with lower health literacy. Many families already experience substantial barriers navigating disability,
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1020
education and health systems, including language barriers, limited confidence advocating within systems and difficulty understanding complex processes. As systems become more restrictive or administratively burdensome, there is a real risk that vulnerable families will be disproportionately excluded from early developmental support.
I also acknowledge the importance of sustainability, accountability and outcome-focused practice across the sector. Therapy should remain purposeful, functional and linked to meaningful participation outcomes for children and families.
At the same time, developmental progress for neurodivergent children is often gradual and non-linear. Skill development, emotional regulation and participation frequently require repetition, caregiver support and implementation across multiple environments before meaningful change generalises into daily life. For this reason, reforms should support clear goal setting, routine progress review and functional outcome measurement while still allowing flexibility for clinically appropriate support intensity and duration.
I also believe it is important that discussions regarding therapy utilisation accurately reflect the realities of frontline clinical practice.
Direct therapy sessions represent only one component of paediatric disability support. Significant additional time is routinely required for session planning and preparation, caregiver communication, collaboration with schools and educators, development of visual supports and resources, documentation and progress review, ongoing professional development, and multidisciplinary coordination.
This work is essential to safe, coordinated and effective intervention, yet much of it occurs outside direct face-to-face therapy time.
I am concerned that reforms focused primarily on reducing costs or therapy utilisation without recognising the broader realities of clinical service delivery may unintentionally undermine workforce sustainability, increase clinician burnout and contribute to further workforce attrition across the sector.
Smaller private providers currently form a significant part of the paediatric disability workforce, particularly in outer metropolitan, regional and underserved communities. If reforms unintentionally reduce the viability of these services, the likely outcomes will include increasing waitlists, reduced local access to support, loss of trusted therapeutic relationships and greater pressure on families, schools and community systems.
My views are also shaped by personal experience.
I became interested in paediatric occupational therapy partly because of my uncle, who lived with a significant disability. Growing up, I saw firsthand both the incredible dedication of family carers and the long-term consequences when people do not receive the right supports early enough.
My grandparents worked hard to keep him out of institutional care, however he remained highly dependent
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1020
throughout adulthood, requiring support for most aspects of daily living and relying heavily on family care across his lifetime. As a child, I remember helping teach him step-by-step self-care skills such as toothbrushing and showering, and seeing the significant improvements in his confidence, wellbeing and participation when he was supported to engage more meaningfully in the community.
Looking back now as both a clinician and family member, I often think about how different his long-term outcomes may have been if he had access to early developmental intervention and participation-focused supports as a child.
The importance of early intervention is not simply about therapy. It is about promoting long-term independence, participation, dignity and quality of life. It is also about reducing long-term reliance on informal carers, health systems and crisis-based supports.
When children receive the right supports early, families are often better able to sustain caregiving roles, children are better able to participate in education and community life, and long-term outcomes across health, wellbeing and independence can improve significantly.
I believe it is important that these broader long-term outcomes remain central to conversations about sustainability and reform.
Recommendations
- Ensure functional capacity assessments appropriately reflect neurodevelopmental presentations across different environments.
- Maintain practical and timely pathways for reassessment where children’s needs evolve.
- Protect access to early intervention and developmental supports during critical developmental periods.
- Support clear goal setting and outcome-focused practice while maintaining flexibility for clinically appropriate intervention.
- Recognise the broader realities of paediatric clinical workload and workforce sustainability.
- Consider the impacts on culturally and linguistically diverse families, Aboriginal families, regional communities and vulnerable populations.
- Continue meaningful consultation with frontline clinicians, families and community providers throughout implementation.
Thank you for considering this submission and the practical impacts these reforms may have on children, families and communities across Australia.
Kind regards,
Occupational Therapist Macarthur and Wollondilly Regions
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1020