National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1071
To whom it may concern,
I am writing as an experienced paediatric Occupational Therapist and sole practitioner with more than 15 years of clinical experience supporting children, families, schools, and communities. I currently provide mobile occupational therapy services across homes, schools, and early childhood settings, with a strong focus on functional, family-centred, evidence-based intervention.
I support the need for the long-term sustainability and integrity of the NDIS. I believe strongly in accountability, ethical practice, evidence-based recommendations, and ensuring public funding is used appropriately and responsibly. However, I am deeply concerned that several of the proposed NDIS reforms and planning framework changes may unintentionally undermine participant outcomes, reduce access to skilled therapy supports, and place unsustainable pressure on small allied health providers who are already operating responsibly and efficiently.
As a sole practitioner, I do not operate from a large corporate structure with administration teams, legal departments, or significant financial buffers. I provide direct clinical support, complete reporting and compliance tasks myself, communicate personally with families and schools, absorb travel costs and cancellations, and work hard to maintain continuity of care for vulnerable children and families. Many small providers like myself are not contributing to overspending within the scheme. We are delivering highly individualised, relationship-based intervention that is preventative, functional, and responsive.
My concerns regarding the proposed reforms are outlined below.
- Loss of Clinical Expertise in Planning and Assessment
I am extremely concerned about increasing reliance on standardised assessments, functional assessment tools, and non-clinical assessors to determine participant needs and funding levels.
Occupational therapists develop nuanced clinical understanding through ongoing observation across environments, collaboration with families and schools, and long-term therapeutic relationships. A child’s functional presentation cannot always be accurately captured in a single assessment process or through standardised tools alone.
The proposed framework risks reducing highly complex functional presentations into simplified scoring systems that may not reflect the real-world impact of disability on participation, emotional regulation, safety, learning, social engagement, family functioning, or independence.
OTA has similarly raised concerns regarding transparency, assessor expertise, and the need for genuine co-design and inclusion of occupational therapists within NDIA
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1071
assessment processes.
In paediatrics particularly, progress is rarely linear. Children may appear “capable†in short assessment settings while still requiring significant scaffolding, regulation support, environmental modification, and therapeutic intervention to participate safely and meaningfully in daily life.
- Impact on Early Intervention and Capacity Building
I am concerned that reductions in therapy funding or narrower interpretations of “reasonable and necessary†supports may ultimately increase long-term costs to both families and government systems.
Occupational therapy is not simply maintenance. High-quality therapy builds independence, emotional regulation, school participation, self-care skills, motor development, sensory processing capacity, and family stability. Early intervention often prevents escalation into more intensive supports later.
When therapy is reduced too early, families often experience increased crisis presentations, school disengagement, caregiver burnout, behavioural escalation, and reduced community participation.
- Unsustainable Pressure on Small and Mobile Providers
The proposed reforms may disproportionately affect sole practitioners and community- based providers who deliver highly personalised care.
Many paediatric OTs provide mobile services because children function best in their natural environments. Supporting a child within their classroom, home, kindergarten, or playground provides clinically meaningful information and allows therapy to be embedded into everyday routines and participation.
Changes to travel reimbursement, increasing administrative burden, pricing pressures, and growing compliance requirements are making this model increasingly difficult to sustain.
If experienced clinicians leave the sector due to financial and administrative pressures, families will face even longer waitlists and reduced access to skilled providers, particularly in paediatric and regional services.
- Administrative Burden and Emotional Impact
There has been a significant increase in unpaid administrative work associated with the NDIS over recent years. This includes extensive reporting requirements, repeated justification of clinically appropriate supports, navigating inconsistent planning decisions, responding to funding cuts, and supporting distressed families through reviews and
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1071
appeals.
I regularly spend unpaid evening hours completing reports because families are already overwhelmed. I have intentionally kept my caseload small to maintain ethical and responsive support.
This administrative load reduces time available for direct participant support and contributes significantly to clinician burnout.
As a small business owner, I absorb many of these costs personally because families are already under immense stress and often cannot navigate the system independently.
- Need for Genuine Consultation and Co-Design
I strongly support OTA’s calls for slower implementation, genuine consultation, transparency regarding assessment tools and processes, and meaningful inclusion of allied health professionals in planning reform discussions.
The voices of frontline clinicians, participants, families, and small providers must be included in decision-making processes. Those delivering day-to-day supports have critical insight into what is and is not working within the scheme.
I respectfully recommend that the Government and NDIA:
- Ensure occupational therapists remain central contributors within assessment and planning processes.
- Avoid overreliance on standardised assessment tools or non-clinical assessors when determining individual functional support needs.
- Protect funding for evidence-based therapy supports, particularly early intervention and capacity-building services. Perhaps focus on experienced clinicians or levels to reflect experience, supervision and accountability.
- Improve transparency and consistency in planning and funding decisions.
- Reduce unnecessary administrative burden on small providers.
- Review travel and pricing structures to ensure community-based therapy remains viable.
- Engage in genuine co-design with therapists, participants, families, and disability organisations prior to implementation of major reforms.
I care deeply about the sustainability of the NDIS and the wellbeing of the families I support. I have worked with families and young children far before NDIS was imagined. I worked with families when HCWA and FaHCSIA were the only support for them and all access was cut off when the child turned 6, regardless of their disability. I started a business in 2015 called My Diffability Australia, in order to ensure families left without any support were able to access therapeutic resources, because I saw how desperately families were without support and the dire consequences from that time too.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1071