National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1273
Dear Committee Members,
I am an occupational therapist and principal OT of a private occupational therapy practice providing services to NDIS participants. In our practice, we work with participants who have complex functional needs, including complex psychosocial disability, physical disability, degenerative conditions, amputation, cognitive and communication difficulties, and all have significant barriers to daily living and community participation.
My submission relates to the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. I understand that the proposed reforms are intended to support the long- term sustainability of the NDIS and move decision-making towards a more consistent assessment of functional need. I support the principle that NDIS decisions should be based on disability-related functional impact, rather than diagnosis alone. My concern is that any new assessment and budget-setting process must be designed and applied in a way that accurately captures real functional support needs. Consistency is important, but it should not come at the expense of individualised assessment, clinical reasoning or proper consideration of the supports that allow a participant to function safely and reliably.
Functional capacity should be assessed in context. In our practice, participants may be managing daily tasks because the right structure is already in place. This may include familiar routines, environmental setup, assistive technology, prompting, supervision, family support or support worker input. This should be recognised as successful supported functioning. I have significant concerns that this can be mistaken for evidence that support is no longer required. A support needs assessment must therefore identify not only whether a task is completed, but how it is completed, whether it is safe, whether it is reliable, what support is required, and what would happen if that support was reduced or removed. Without this level of analysis, functional capacity can be overstated and the participant’s ongoing need for support can be misunderstood. This level of analysis often needs strong familiarity of the person’s home situation, environment, past history and supports – all of which are gained as part of ongoing occupational therapy involvement and may be missed in a brief interaction with an unfamiliar assessor. This is particularly important where participants have complex psychosocial disability, that may include impaired planning, poor safety judgement, communication difficulty, limited insight into their own support needs, all combined with reduced informal support. In these situations, self-report or brief interactions may not show the full picture. A participant may report that they complete meals, personal care, appointments or community access independently, while others are actually prompting, organising, supervising, preparing the environment, correcting errors or managing risk in the background. I am not suggesting that structured assessment tools have no role. A consistent assessment process may improve fairness if it is well- designed and properly implemented. However, assessment tools should support professional judgement, not replace it. For participants with complex or context-dependent support needs, evidence from occupational therapists and other suitably qualified professionals should remain available, considered and influential in planning and funding decisions. Occupational therapists are trained to assess the interaction between the person, the task and the environment.
I am also concerned about the proposed reduction to social, civic and community participation supports. For many participants, these supports are the practical mechanism that allows them to leave home, attend appointments, maintain routines, practise communication, reduce isolation, and participate in ordinary community life. Reducing these supports risks increasing isolation, carer strain, loss of functional skills, reduced community participation and reliance on more intensive disability supports. A common example from our practice is participants with complex psychosocial disability who are physically able to mobilise but cannot independently access the community because of symptoms of psychosis including hallucinations or paranoia. With structured support, these participants can often attend appointments, build familiar routines, practise community access, reduce reliance on overwhelmed family, and reduce
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1273
the likelihood of crisis responses. A broad reduction to social and community participation funding would directly reduce this functional progress.
I am also concerned about the proposed reduction to capacity building daily activity supports. These supports are not optional extras. Occupational therapy and related supports help participants develop routines, learn safer ways to complete daily tasks, trial assistive technology, reduce risks at home, improve community access, and build skills that reduce reliance on higher-cost supports later. Reducing access to these supports risks reducing the very interventions that help participants build and maintain functional capacity.
I am also concerned about any proposal that limits unscheduled reassessments to exceptional circumstances. Participant needs do not only change at planned review dates. In practice, reassessment may be required after a change in disability-related function, loss or reduction of informal support, housing instability, carer breakdown, falls, equipment failure, increased psychosocial risk, or new safety risks. If reassessment pathways are too narrow, participants may be left with supports that no longer match their functional needs.
I ask the Parliament to amend the Bill and related implementation arrangements to ensure that: Functional capacity and support needs are assessed individually and in context. Support needs assessments identify the supports, prompts, routines, environmental setup, assistive technology and supervision required for safe and reliable functioning. Assessment tools are used to support professional judgement, not replace it. Eligibility and funding decisions are not made through fully automated processes, algorithms or unsupported checklist tools. OT evidence remains available and influential where a participant has complex, fluctuating or context-dependent functional needs. Funding decisions remain based on individual disability-related support need, not broad category reductions or class-wide rules. The proposed reductions to capacity building daily activity supports and social and community participation supports are removed. Participants retain practical pathways for reassessment when their circumstances, risks or functional needs change. Occupational therapists are included in assessment design, implementation, pricing and future NDIS reform processes. Pricing and integrity reforms support access to a sustainable, clinically governed allied health workforce.
The NDIS should be sustainable, but sustainability should not be achieved by reducing access to the supports that help people build skills, reduce risk, maintain routines and participate in community life. Individualised, context specific assessment of function should not be removed from the Scheme and I believe that occupational therapy is central to understanding functional need and supporting participants to live more safely and independently.
Kind regards,