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

Submission 1400

To The Senate Submission Panel, I am writing this Senate Submission letter to express my concerns about: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill. The following is a list of my concerns regarding the proposed amendment to the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill.

Area of Concern 1: Refining Functional Capacity As an Occupational Therapist, I am concerned that the proposed definition of functional capacity risks creating an artificial picture of disability by excluding the impact of assistive technology, environmental supports and human assistance. Many participants I work with function safely only because extensive supports and adaptations are already in place. Assessing people outside their real-world environments may significantly disadvantage participants with invisible disabilities, fluctuating conditions, psychosocial disabilities, or autism, particularly those who mask or rely heavily on routine, prompting and co-regulation.In my clinical experience, all the participants I support rely significantly on their informal supports and environmental accommodations and modifications to participate in everyday activities. Working in the disability space for over six years has repeatedly shown that assessing a participant’s functional capacity requires considering them across their natural environments (home, school, community), along with usual support persons and accommodation needs, which helps gain accurate understanding of each person’s support requirements.

Area of Concern 2: Tightening the Definition of “Permanent” DisabilityI am concerned about requiring individuals exhaust appropriate treatment before impairments can be considered permanent. Many lifelong disabled patients continue therapy aimed at maintaining functionality, slowing decline, improving quality life; ongoing treatments should not prevent access to necessary services. Additionally, disadvantaged include those unable afford private care due financial constraints or living rural areas where driving is impossible as result of physical limitations.Specifically within my professional practice some clients need continuous therapies recalling learned skills owing executive functioning impairment affecting ability recall information steps tasks many depend parents daily activity prompts caused by variable abilities regulation challenges families cannot afford private therapy impacting safety concerns sustainability family units.

National Disability Insurance Scheme Amendment Bill

Submission 1400

Area of Concern 3: Supports must arise “Directly” From Impairment

In practice, disability support needs often stem from the interaction of impairment with environmental factors rather than impairment alone. For instance, participants might need assistance due to executive functioning impairment\nsensory settings or community obstacles \nhinder safe participation.I worrythattheproposedwordingcould narrow the understandingofdisability-relatedneedsandoverlooktheadactualcircumstancesinwhichdisablethappens.

Area of Concern 4:“ValueforMoney”

Iamconcernedthatthestrengthenedvalue-for-money provisionsmayincreasingly prioritise lower-cost supports,evenwheretheydonotprovideequivalent safety,independenceorlong-term sustainability.Inoccupationaltherapypracticecheaper alternativesarenotalwaystrulycomparableandanleadto increasedcarerburden,reducedparticipationandhigher long-termcostsifsupportsfail.

Area of Concern5：“Effective and Beneficial“EvidenceHierarchy I am concerned that the proposed hierarchy of evidence may reduce weight given participant-specific clinical reasoning lived experience. Many participants have highly individualisedsupportneedsthatdo notfitneatwithinpublishedresearchevidence This may disproportionately disadvantage people rare conditions psychosocial disability complex presentations .

Increased Reliance on InformalsupportsandParents In myclinicalexperience parentschildrenwith disabilitiesoftenperformthesame broad parenting tasks as otherparentsbut with significantly greater intensity frequency complexity For example supervision involve constant line-of-sight monitoring behavioural de escalation overnight care or management significant safetyrisks.I am concernthe proposedwordingrisks oversimplifyingdisability-relatedcareanymay increasepressureonfamiliesalreadyprovidingsustainable levelsof support

inmycliniexperience parentsof childrena disabilitie xperience extended periods (years) parental teachingbehavioural co-regulationconstant saftymonitoringfor childandsiblingemotional exhaustion compared typical developingchildren Thefrequencyintensity theseaspects caring for a child disabilitysignificantly impact family dynamics, parent sibling relationships lead to extended disruption workforce participation which negatively affects families financial capacity.

Change Whole Person Assessment:

Iamconcernedthattheproposed wordingmaymoveSchemeawayfrom whole-person assessment.Inclinicalpractice,supportneeds oftenariseinteraction multiple impairments environmental barriers andparticipation demands.

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

Submission 1400

I have supported participants with multiple diagnoses that affect their ability to participate across environments. Assessments need to consider how these diagnoses interact with the person’s natural environments to maintain the person’s safety, dignity and quality of life.

Area of Concern 8: Controlling Inflation

I am concerned that extending reassessment decision timeframes from 21 days to 90 days may leave participants without appropriate supports during periods of crisis, deterioration or carer breakdown. In my practice, participants have required early review due to a change in circumstances, including marital break downs caused by cumulative stress from child disabilities’ behaviors concern; an unforeseen acute medical impairment parent which has meant no longer able provide high level support to children disability.

Area of Concern 9: Funding cuts, Funding caps and Ministerial Powers

I am concerned about proposed powers allowing percentage-based funding reductions & funding caps groups participant significantly undermining individualized planning within national disability insurance scheme clinical practice participants same diagnosis often vastly different functional needs environmental barriers require decisions based broad cohorts capped categories risk oversimplifying disability result receiving below what is needed maintaining safety participation independence.

Clinical observation capped funding does not provide individual therapy family build skills critical times development trauma skill development social isolation increase carers burnout reliance informal supports capacity support disability own challenges put at further vulnerability social isolation real-life implications bill for people with disability their informal networks significant potential burden other services including mental health hospital admissions homelessness family breakdowns carer burnout school disengagement crisis-driven intervention long-term system costs. Kind regards,