National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 1483
I am an Occupational Therapist and co-owner of a small private paediatric therapy clinic in Melbourne’s inner north. We have been operating for 15 years. We provide Occupational Therapy and Speech Pathology to children with complex developmental needs, including Autism, Sensory Processing Disorder, and other developmental challenges.
I am writing this submission in a personal capacity, based on 25 years of clinical work as an Occupational Therapist with children and families.
I support the intent to make the NDIS sustainable. No one wants to see the scheme collapse. But I am concerned that several provisions of this Bill will have unintended consequences that harm the children and families I work with, without delivering the savings the government expects. My concerns are practical, not political. They come from watching how policy changes impact families and children, and the long term impacts of restricting access to early intervention.
defining functional capacity: The Bill introduces a definition of functional capacity that excludes environmental and personal circumstances to assess a child’s “intrinsic ability.” This sounds reasonable in theory. In practice, a child’s functioning cannot be separated from their environment.I assess children every week who present very differently depending on the setting. A childwho cannot sit for formal assessment may engage well at home or parents’ presence.A mild delay might fall apart entirely when surrounded by peers.The idea is unrealistic because it strips away context which affects development.It especially problematical for young kids and those w/ autism whose capacity depends heavily upon relationships, familiarity & sensory environments.
Also worried about assessments designed by non-paediatric experts using tick-box methods missing genuine needs under existing lists already excluding many significantly impaired but unclassified children.
The thresholds re substantially reduced func cap aren’t yet developed so Parliament must pass legislation before seeing actual threshold determining support eligibility.Is responsible community input? Limits unscheduled plan reassessments: The bill restricts requests only participants authorised representatives limiting occasions where an update can occur.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 1483
I understand the concern about unscheduled plan re-assessments in a general sense, but I see a different problem. Many of the families I work with are exhausted, overwhelmed, and navigating complex systems. They do not know when they should ask for a reassessment. Their rely their therapist flagging child’s needs changed equipment stopped working new diagnosis changes picture. If condition deteriorates develop new needs gap between time therapist identifies need parent navigate reassessment request could be months without appropriate support especially true culturally linguistically diverse backgrounds experiencing financial stress single parents stretched. The allows NDIA initiate assessments own initiative safeguard But am confident Agency workforce system identify children whose needs escalating That current falls Therapists Families those that these Children their best.
Strengthen link impairment need supports
This provision requires Supports can provided address directly impairments disability early intervention requirements challenge here children developmental delays disabilities present overlapping sensory processing differences may anxiety communication delay appear withdrawn oppositional experience link Impairment functional need linear easy document bureaucratic test real risk children Complex overlapping presentations will have Support reduced because delegate decides particular need linked listed impairment lead more report writing appeals less therapy increase demand Administrative Review Tribunal already struggling.
Reasonable necessary supports The clarifies funding some supports actual cost providing them also introduces principles guide considered reasonable necessary including consideration what scheme fund whole If NDIS pays than cost Providing Therapy providers like my clinic face simple choice cross subsidise other reduce quality close Small operate thin margins cannot absorb ongoing underpayment if becomes financially unviable deliver therapists leave sector move private fee service work This is happening.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 1483
For families, this means fewer providers accepting NDIS participants and longer waitlists. The families who can afford to pay privately will get care. Those who cannot will go without.That is not equity. That is a two tier system.
Tightening permanence
The Bill introduces the concept of “all appropriate treatment” before an impairment is considered permanent.
For many children, especially those with autism, the question of what constitutes “all appropriate treatment” is not straightforward.Autism is not an illness that gets treated and cured.It is a neurotype.Early intervention supports skill development but it does not make the underlying impairment go away.I am concerned that this provision will be used to argue that a child who has not tried a particular therapy does not have a permanent impairment even if that therapy is not evidence based or available locally or affordable.The Bill also links this to access to other service systems.If a child could access supports through a state-based program like Thriving Kids they may be found ineligible for the NDIS even if their impairment is significant.This creates a situation where a child’s NDIS access depends on the quality and availability of state services which vary enormously across the country.
Provider registration claim timeframes record keeping I support measures that address fraud.But some provisions will impose heavy administrative burden small providers The 90 day claim timeframe will challenging family slow provide information change plan managers spend chase invoices confirming bookings A window means payment delayed provider loses income entirely Mandatory registration all providers increase costs.Registration fees compliance reporting audit preparation are trivial clinic These passed participants price limits absorbed either way reduce resources direct therapy As allied health professional already multiple points federal government Further duplication at NDIA level won’t regulation highly regulated profession simply create more paperwork greater costs
The broader impact workforce Service Availability My main concern combined effect these changes accelerate exits from market We in national allied shortage.NDIS Review itself acknowledged If add tighter access reduced funding,more
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 1483
administrative burden, and more regulatory risk, experienced therapists will leave. Many will move into private practice serving only private paying clients. Others will leave clinical work entirely. For families, this means longer waitlists and less choice. In many areas this may mean no access to therapy at all. The children who need support most will be the ones who lose access first.I also note that no provision in this Bill addresses the underlying workforce shortage. There is no investment in training, supervision, or retention of paediatric therapists. The Bill focuses entirely on demand reduction without addressing supply.
Conclusion and RecommendationsI do not oppose reform. The NDIS needs to be sustainable. But this Bill risks creating a system that is financially sustainable in the short term at the cost of long-term outcomes for children, families, and communities.My recommendations are:
- Do not pass the functional capacity provisions into law until the NDIS rules defining thresholds and assessment methods have been published and the community has had a genuine opportunity to review them.- Amend the plan reassessment provisions to allow treating therapists to flag changes in a child’s needs and trigger a review process rather than placing full responsibility with parents.- Ensure reasonable necessary support determinants include funding levels sufficient enough cover costs delivering quality care, not less.- Include an impact statement regarding any change reducing funds increasing regulatory burden so Parliament can see likely effect service availability.- Phase out changes accessing children align actual Thriving Kids services planned availability avoid gaps support.I would happy provide further detail committee these points.