Submission 1473

Submission to the Senate Community Affairs Legislation Committee

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

to the committee,

I am writing as a paediatric occupational therapist who provides telehealth services to children and families accessing the national disability insurance scheme (ndis). through my clinical work, i support children with autism, adhd, intellectual disability, developmental delay, psychosocial disability, sensory processing differences, emotional regulation difficulties, executive functioning challenges and complex behavioural presentations. i work closely with families who are already under immense pressure navigating disability, school demands, behavioural challenges, financial stress and limited access to services.

while i acknowledge the importance of ensuring the long-term sustainability of the ndis, i am deeply concerned that the proposed national disability insurance scheme amendment (securing the ndis for future generations) bill 2026 risks significantly weakening the foundational principles of the scheme. in my view, the bill moves the ndis away from a person-centred, individualised model of support and toward a standardised, fiscally driven system that does not adequately reflect the realities of disability or the lived experiences of participants and families.

one of my greatest concerns relates to the proposed changes to the definition and assessment of functional capacity. occupational therapists assess people within the context of their real lives. function cannot be accurately understood in isolation from environmental supports, assistive technology, routines, emotional regulation strategies, sensory needs, fatigue, executive functioning or the availability of informal supports. the proposed legislation appears to require participants to be assessed without these contextual factors being considered. this approach fundamentally contradicts occupational therapy practice and risks creating an unrealistic and reductionist understanding of disability.

many of the children i support may appear capable during short structured interactions but experience substantial impairment in daily life. for example, i work with children who can engage appropriately for a brief telehealth session but require constant prompting, co-regulation, emotional support, supervision and environmental structuring throughout the rest of their day. i support children who mask their difficulties in formal settings but experience severe dysregulation, shutdowns, aggression, anxiety or exhaustion once demands increase.

if these contextual supports and fluctuating presentations are ignored during assessment, many participants may incorrectly appear “high functioning” despite requiring extensive daily support.

the proposed functional capacity framework also fails to adequately account for fluctuating disability and fatigue. many participants can complete tasks briefly but experience significant

Submission 1473

e post-exertional exhaustion, sensory overload or deterioration afterward. A snapshot assessment cannot capture the cumulative impact of disability across an entire day, week or month. This is particularly concerning for people with autism, psychosocial disability, chronic fatigue conditions, neurological conditions and executive functioning impairments.

I am also deeply concerned about the increasing standardisation of funding and planning proposed throughout the Bill. Disability is highly individual. Two children with the same diagnosis can have vastly different support needs depending on their communication abilities, sensory processing, trauma history, family supports, behavioural complexity, emotional regulation, cognitive profile and environmental circumstances. Occupational therapy recommendations are developed through detailed clinical assessment considering safety, participation, family sustainability, long-term outcomes and preventative intervention.

The proposed powers allowing funding caps, benchmarked supports and percentage-based funding reductions risk oversimplifying disability and ignoring individual circumstances. Many supports categorised as “community participation” or “capacity building” are not optional extras. They are essential supports that maintain safety, mental health, participation, skill development and family functioning. Reducing these supports does not remove the underlying disability-related need. Instead, it transfers the burden onto families, schools, hospitals, emergency systems and unpaid carers.

I am particularly concerned about the proposed reductions to social and community participation supports and therapy funding. In my clinical experience, community access supports are frequently used for essential daily activities such as attending appointments, accessing the community safely, building emotional regulation capacity, preventing isolation and supporting independence. Similarly, therapy supports are preventative in nature. Occupational therapy intervention often reduces long-term support needs by improving emotional regulation, participation, independence, safety awareness, self-care capacity and caregiver sustainability. Reducing access to therapy may create short-term financial savings while increasing long-term costs through hospitalisation, family breakdown, school refusal, safeguarding concerns and mental health crises.

The proposed reassessment changes are also deeply concerning. Extending reassessment decision timeframes from 21 days to 90 days may leave participants without adequate supports during periods of crisis, deterioration or carer burnout. In clinical practice, reassessment requests are often made because something has already become unsafe or unsustainable. Families frequently seek additional support only once they are approaching breaking point. Delays of up to three months could significantly increase risk to participants and carers alike.

I am also concerned about the growing reliance on administrative and standardised assessment processes that may not adequately recognise the complexity of disability. Occupational therapists assess the whole person. We consider the interaction between

Submission 1473

impairments, environmental barriers, sensory processing, communication, trauma, fatigue, behaviour, emotional regulation and participation demands. Support needs rarely arise from one isolated impairment. Narrowing assessment frameworks risks excluding participants whose disabilities are cumulative, intersecting or not easily measurable through standardised tools.

As a telehealth Occupational Therapist, I also work with families in regional and underserved areas where access to services is already limited. The proposed treatment and permanence requirements may disproportionately disadvantage participants who cannot afford private therapy, specialist appointments or repeated assessments, or who live in areas with significant workforce shortages. Many families are already struggling to access appropriate services. Requiring exhaustion of “all appropriate treatment” before accessing support risks creating impossible barriers for vulnerable participants.

Ultimately, I believe this Bill risks shifting the NDIS away from its original purpose as a rights- based, person-centred insurance scheme grounded in individualised support and participant wellbeing. I am deeply concerned that these reforms will disproportionately impact children, people with invisible and fluctuating disabilities, families already experiencing carer burnout, and participants with complex support needs.

I respectfully urge the Committee to reconsider the proposed reforms, preserve individualised and whole-of-person assessment approaches, strengthen safeguards, retain participant- centred planning principles and ensure funding decisions remain grounded in real-world functional need rather than broad fiscal targets.

A sustainable NDIS should not simply reduce expenditure. It should preserve dignity, participation, safety, inclusion, family sustainability and long-term wellbeing for people with disability.

Thank you for considering this submission.