National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1141
Senate Community Affairs Legislation Committee Inquiry
26/5/2026
Practical Concerns Regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
I am writing this submission as a Speech Pathologist with 39 years’ experience, currently working with children, adolescents and families in The Hills Shire and surrounding communities (NSW).
Like many frontline providers, I understand the need to improve the long-term sustainability of the NDIS and address fraud and misuse within the Scheme. However, there are significant concerns regarding the practical implementation and likely unintended consequences of several measures proposed in the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.
From a clinical and operational perspective, many families are already struggling to navigate an increasingly complex system. Schools are overwhelmed, public health waitlists are extensive, and many regional families rely heavily on small private practices because there are few alternatives available locally. In this context, reforms that reduce flexibility, delay reassessment processes, narrow access pathways or increase administrative burden risk creating significant downstream impacts for children, families and community services.
One key concern relates to the proposed changes around functional capacity and access eligibility. The Bill proposes assessing functional capacity “without assistance from other people, assistive technology or modifications” and excluding environmental circumstances as far as possible. While consistency in decision making is important, this approach risks failing to reflect how disability presents in real-world settings, particularly for neurodivergent children and children with developmental delay.
Many children function very differently depending on environmental demands, sensory load, school expectations, family capacity and access to supports. A child who appears verbally capable in a structured assessment may still experience profound functional impairment in everyday school participation, emotional regulation, social communication or adaptive functioning. Removing environmental context from assessment may unintentionally disadvantage children whose impairments are less visible or fluctuate across settings.
There is also concern regarding the proposal to tighten reassessment criteria and extend reassessment decision timeframes from 21 days to 90 days. In practice, children’s needs can change rapidly due to school transitions, escalating behaviours, mental health deterioration, family breakdown, puberty, burnout, exclusion from education settings or loss of informal supports. The proposed requirement for “significant and ongoing” changes may create barriers for families seeking timely adjustments before situations reach crisis point.
This is particularly concerning for neurodivergent children whose support needs often fluctuate. Many families already report difficulty obtaining reassessments and plan reviews. Additional restrictions may increase family stress, contribute to escalation of behaviours, and ultimately place greater pressure on schools, emergency departments, child protection systems and mental health services.
The proposed strengthening of the link between supports and impairments that directly meet disability criteria also raises practical concerns. In clinical practice, children rarely present with neatly
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1141
Practical Concerns Regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
separated areas of need. Communication, emotional regulation, sensory processing, anxiety, learning difficulties, executive functioning and social participation are deeply interconnected. Restricting supports to only those viewed as directly arising from a specific impairment risks creating artificial distinctions that do not reflect how children function in daily life.
There are also likely impacts on service viability and workforce sustainability, particularly in regional areas. Small allied health practices are already managing rising costs, workforce shortages, extensive unpaid administration and high levels of clinician burnout. Increased compliance obligations, uncertainty around funding, delayed reassessment processes and reduced plan flexibility may make it financially unviable for some providers to continue servicing complex clients, particularly in rural and regional communities where travel and workforce recruitment are ongoing challenges.
If smaller providers reduce services or close, families will experience even longer waitlists and reduced access to local supports. This may disproportionately impact children requiring early intervention, multidisciplinary input or regular therapy to maintain participation in education and community life.
There is also concern that reducing access to flexible early intervention supports may create poorer long-term outcomes and higher long-term costs. Early intervention often prevents later escalation. Children who receive timely support are more likely to participate successfully in education, develop functional communication and self-regulation skills, maintain community participation and reduce reliance on intensive services later in life.
Finally, while addressing fraud is important, reforms should avoid creating systems that unintentionally punish legitimate participants, families and ethical providers through excessive administrative burden or delayed access to necessary supports. Most families accessing the NDIS are already under considerable strain and most small providers are operating with limited administrative capacity.
Practical Recommendations
-
Ensure functional capacity assessments retain appropriate consideration of real-world environmental impacts, particularly for neurodevelopmental conditions and children.
-
Maintain accessible and timely reassessment pathways for children and participants with fluctuating or escalating support needs.
-
Introduce safeguards to ensure regional, rural and small providers are not disproportionately impacted by administrative and compliance changes.
-
Preserve flexibility within plans to allow responsive supports during periods of transition, burnout, school difficulties or family crisis.
-
Undertake extensive consultation with frontline clinicians, families, educators and regional providers before implementation of major access and planning changes.
-
Monitor the impact of reforms on waitlists, provider availability, school participation and family stress, particularly in regional communities. Page | 2
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1141
Practical Concerns Regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
The long-term sustainability of the NDIS matters deeply. However, sustainability should not be achieved through reforms that unintentionally reduce access to essential supports, delay intervention or destabilise already stretched families and community services. Sustainable reform requires practical implementation, realistic timelines and meaningful consultation with the people delivering and relying on these supports every day.
Certified Practising Speech Pathologist B. App. Sci. (Sp. Path.), M.A. MSPA, MLDC
Supporting children and their families since 1987
Page | 3