Concerns regarding functional impairment assessments and regional service access (Provider experience)

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1119

Submission to the Senate Community Affairs Legislation Committee

Re: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

I am writing as both:

a regional Occupational Therapist working within the NDIS system, and a parent of a child who accesses the NDIS.

I support the need for the NDIS to remain sustainable and agree that fraud reduction and system accountability are important. However, I am concerned that aspects of the proposed legislation may unintentionally reduce access to the very supports that prevent long-term escalation of disability, carer burnout, crisis presentations, and higher future government expenditure.

As an Occupational Therapist in regional NSW/Victoria, I work predominantly with children and young adults with autism, ADHD, psychosocial disability, intellectual disability, trauma histories, and complex behavioural support needs. Much of my work is not “medical treatment†in the traditional sense. It is practical, preventative work that helps people remain engaged in school, maintain emotional regulation, participate safely in the community, build independence, reduce family stress, and avoid future crisis systems.

I am particularly concerned about reforms that may narrow eligibility or reduce access to supports based on simplified views of functional impairment. Many neurodevelopmental and psychosocial disabilities are not consistently visible. I regularly work with participants who appear superficially capable during short assessments, while privately experiencing severe burnout, emotional dysregulation, school refusal, anxiety, executive dysfunction, sensory overload, social isolation, or inability to manage daily living tasks consistently across environments.

This concern is consistent with issues raised in submissions from other Occupational Therapists regarding the risks of over-reliance on standardised functional assessments without sufficient consideration of fluctuating capacity, environmental context, cumulative fatigue, masking behaviours, and longitudinal evidence from treating clinicians. In practice, functional impairment is rarely static. Participants may demonstrate capacity in highly supported or structured settings while being unable to sustain that functioning independently across home, school, work, or community environments over time.

For example, I work with autistic young people who can attend school for limited periods but require extensive recovery time afterward due to sensory and social exhaustion. Others may technically complete activities of daily living but only with significant prompting from parents or carers, resulting in unsustainable levels of informal support and family burnout. I also see adolescents whose unmet support needs contribute to

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1119

escalating mental health presentations, self-harm risk, school disengagement, or avoidant behaviours that later require far more intensive intervention across health, education, and crisis systems.

These examples reflect broader evidence that early therapeutic and capacity-building supports reduce downstream costs associated with hospitalisation, restrictive practices, justice involvement, homelessness, and long-term unemployment. They also align with the stated intent of recent NDIS reform discussions to improve participant outcomes through earlier intervention, foundational supports, and more coordinated service systems. However, these goals will only be achieved if reforms preserve sufficient flexibility for clinicians to respond to real-world functional impacts rather than relying solely on narrow diagnostic categories or snapshot assessments.

I would also encourage the Committee to provide greater clarity regarding how proposed functional assessments will interact with mainstream systems and how responsibility will be shared between the NDIS and other government-funded services. While I acknowledge the principle that the NDIS should not replace mainstream health, mental health, education, or employment systems, the practical reality is that many participants experience significant functional impairment that extends beyond what mainstream services are funded or able to provide.

For example, a participant may require regular psychology or counselling support directly related to the functional impacts of their disability, yet Medicare-rebated sessions are often insufficient in frequency, duration, or accessibility to meet ongoing needs. Similarly, Disability Employment Services or mainstream educational supports may not adequately address the additional functional barriers experienced by people with complex neurodevelopmental or psychosocial disabilities. In these situations, there should be clearer mechanisms for collaborative funding arrangements, flexible “top-up†supports, or shared-care approaches between mainstream systems and the NDIS where disability-related functional impairment substantially increases support needs.

This approach would be consistent with the intent of the NDIS Act 2013, including supporting participants to pursue social and economic participation and exercise choice and control, while recognising that disability-related functional needs do not always fit neatly within service-system boundaries. It would also align with the broader principles underpinning the Applied Principles and Tables of Support, which recognise that responsibilities may overlap and require practical coordination between systems.

I am also quite concerned about the impact rigid funding boundaries may have on regional participants. In many regional communities, participants cannot simply access the “ideal†provider or service stream because workforce shortages severely limit availability. Families often rely on whichever allied health professional is available locally, or the clinician with whom the participant has established trust and therapeutic rapport. For many autistic participants, people with trauma histories, or individuals with psychosocial disability, therapeutic rapport is not a minor preference — it is often central to meaningful engagement and positive outcomes.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1119

Greater flexibility within participant budgets would allow regional participants to access timely supports from available providers, rather than remaining on extended waitlists while their functioning deteriorates. In practice, this flexibility may ultimately reduce long-term costs by preventing escalation into crisis services, hospital presentations, school disengagement, family breakdown, or higher-intensity funded supports later.

As a sole trader, one of the primary reasons I continue working in this way is to ensure I can care for my children while maintaining the flexibility needed to support both my family and the families I work with. Like many allied health professionals in regional areas, balancing caregiving responsibilities alongside clinical work is only possible because of this flexibility. Changes that increase administrative burden or reduce sustainability for small providers may unintentionally impact clinicians who are already working hard to remain in the sector while caring for their own families.

This is especially relevant for autistic children, ADHD participants, and people who mask difficulties in structured environments. Functional capacity cannot always be accurately measured through snapshot assessments or rigid criteria. Research increasingly shows that autistic girls are more likely to mask social and emotional difficulties, with challenges often becoming more apparent during adolescence as social expectations increase and hormonal changes occur. In my own family, my daughter has benefited from early intervention supports and has made meaningful progress, however as she approaches adolescence at nine years old, we are already seeing increasing complexity in peer relationships, emotional regulation, and social fatigue that requires ongoing support beyond what may be visible in formal assessments.

As a parent, I also see firsthand the invisible labour carried by families of children with disability. My daughter accesses the NDIS, and our family’s daily life involves ongoing coordination of therapy, emotional regulation support, school advocacy, appointments, routines, sensory needs, and planning ahead to prevent dysregulation and burnout.

The supports my daughter receives are not excessive or optional. They are what allow her to:

participate safely in education, engage socially, develop independence, build emotional regulation skills, and reduce the likelihood of requiring more intensive supports later in life.

Without early and consistent intervention, many children do not simply “catch up.†Instead, families often reach crisis point after years of unsupported strain.

I am also concerned about the likely impact on regional providers and workforce sustainability. Regional areas already experience significant shortages of Occupational Therapists, Speech Pathologists, Psychologists and Behaviour Support Practitioners. In areas such as Albury-Wodonga, families already face extensive waitlists for paediatric

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1119