Submission 150 — The Whole Child Pty Ltd — NDIS Future Generations Bill

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 150

Submission to the Senate Community Affairs Legislation Committee

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

Submitted by:

Crystel Poggioli Director and Clinical Lead The Whole Child Atherton Tablelands, Far North Queensland

Email: support@thewholechild.com.au

Phone:

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 150

Introduction

Thank you for the opportunity to provide this submission.

I am a senior paediatric occupational therapist and the Director and Clinical Lead of The Whole Child, a rural paediatric occupational therapy practice based on the Atherton Tablelands in Far North Queensland.

Our practice currently employs six occupational therapists, alongside therapy assistants, administration support and a Child and Family Wellbeing Practitioner. We provide services across the Atherton Tablelands and surrounding regional communities including Atherton, Mareeba, Tolga, Walkamin, Kairi, Malanda, Millaa Millaa, Ravenshoe, Mount Garnet and Bibhoora.

Between approximately 15% and 30% of the children and families we support are Aboriginal and Torres Strait Islander families, depending on referral trends and outreach demands at the time.

I have worked across government, non-government and private practice settings for approximately three decades. My experience includes Education Queensland, Queensland Health, community health, outreach work, non-government services and long-term private practice.

I support the need for a sustainable NDIS and improved early supports for children and families. However, I am deeply concerned that the current reform direction may unintentionally destabilise regional private paediatric (and general) allied health services that have invested heavily in building skilled teams, trusted local relationships and flexible models of care that are producing meaningful functional outcomes for children and families.

Relevance to the Bill

I understand this inquiry is specifically considering the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

My submission focuses on the practical consequences of changing access, eligibility and support pathways without adequate safeguards for continuity of care, regional workforce sustainability and service access.

The Bill should not be considered only through the lens of reducing expenditure. It should also consider which parts of the current system are delivering meaningful outcomes for participants, including children and families, particularly within regional communities.

Over many years, private paediatric allied health providers have built responsive, relationship-based and community-connected models of care that often operate with considerable efficiency despite complex workforce and service delivery challenges. Many

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 150

private practices have invested heavily in workforce development, outreach, supervision, local partnerships and long-term continuity of care.

As business owners operating within real financial constraints, many of us are also very aware that there are opportunities to reduce unnecessary system costs without weakening frontline services. In my experience, many administrative and bureaucratic processes within the NDIS consume substantial clinician time and public funding while adding limited practical value for participants and families.

For example, clinicians are frequently required to produce lengthy reports and repeated additional evidence requests for supports that are clinically straightforward and based on clear functional need. In many cases, these decisions to request additional information may be made without direct input from clinicians with expertise in the relevant functional area. This creates significant administrative burden, delays support for families, increases costs to the Scheme, and reduces the amount of clinician time available for direct therapeutic work with participants.

I believe there are opportunities for reform that would improve sustainability through greater trust in experienced clinicians, reduced duplication, more streamlined processes and stronger use of practical clinical judgement, rather than through changes that may unintentionally weaken the regional workforce and service infrastructure currently supporting children, families and other participants.

Key concern

My central concern is not simply about changes to funding pathways. It is that the current reform direction risks weakening some of the most skilled, responsive and outcomes- focused parts of the existing paediatric (and broader disability) support system, while many of the underlying structural problems within the NDIS remain insufficiently addressed.

Over many years, regional private allied health providers have built highly skilled teams, strong local partnerships and flexible models of care that are producing meaningful functional outcomes for participants, including children and families. In many cases, this work reduces long-term support needs by building independence, participation and functional capacity during childhood and adolescence.

At the same time, many providers have experienced increasing administrative burden, repeated requests for evidence, inconsistent decision-making processes and limited meaningful clinician input into the design of funding and service systems.

In my experience, there are substantial opportunities to improve the sustainability of the NDIS through reducing duplication, streamlining administrative processes and making better use of experienced clinical judgement. However, the current reform narrative has at times risked portraying allied health providers primarily as a cost pressure within the Scheme,

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 150

rather than recognising the significant long-term value many providers create for participants, families and communities.

I am deeply concerned that reforms aimed at reducing Scheme growth may unintentionally weaken a regional workforce and service infrastructure that has taken many years to build and which is already supporting pressures that other systems are struggling to absorb.

Schools are already managing increasing numbers of children with complex behavioural, emotional regulation and developmental needs. Hospitals and public health services are already operating under significant strain. Many regional communities do not have surplus service capacity waiting to replace existing allied health supports if those services reduce or disappear.

In many regional areas, private paediatric (and general) allied health services have become deeply embedded within the broader community, education and health systems that families depend upon.

Thriving Kids and the risk to regional provider sustainability

The Australian Government has described Thriving Kids as a national system of supports for children aged 8 and under with developmental delay and/or autism with low to moderate support needs, alongside their families and carers.

I support the principle of earlier and more accessible supports. However, the implementation approach emerging from NSW raises serious concerns regarding the future role of private paediatric allied health providers.

NSW has stated that Thriving Kids services will primarily be delivered through government agencies and NGOs commissioned by the Department of Communities and Justice, with possible arrangements for private providers “where required”.

While Queensland has not yet released its final implementation approach, this has created significant concern across the regional allied health sector that established private providers may be substantially excluded from future foundational support systems.

This is not a minor implementation detail.

In regional communities like ours, private paediatric allied health services currently provide: • direct therapy and assessment • outreach services including to Aboriginal and Torres Strait Islander families and communities • parent coaching • school and kindergarten collaboration • collaboration and coordination with medical services (GP, paediatrician, community health and mental health services) • collaboration with allied health services • clinician supervision and workforce development

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 150

• continuity of care across many years

There is also significant concern across the sector that the proposed funding allocations within future foundational support systems may be insufficient to deliver meaningful outcomes for many children with complex developmental, behavioural, emotional regulation and functional needs.

While some children may benefit from lower intensity supports, many children currently described within “low to moderate” categories still present with highly complex functional challenges that substantially impact participation, family functioning, education and long- term developmental outcomes.

I am concerned that future systems may expect organisations to support significantly larger numbers of children with substantially lower levels of funding and reduced capacity for individualised, relationship-based intervention.

If this occurs, there is a risk that services become increasingly focused on throughput rather than meaningful functional outcomes.

In practice, this may result in children receiving lower intensity or shorter-term interventions that are insufficient to create lasting improvements in independence, participation, emotional regulation and daily functioning, particularly for children with more complex presentations.

This risks creating a system that may appear more financially efficient in the short term, while ultimately shifting increasing burden and cost onto families, schools, mental health services, hospitals and other community systems over time.

If experienced regional allied health services become financially unviable or are substantially reduced, the consequences are likely to extend far beyond individual businesses. Communities risk losing highly skilled clinicians, longstanding therapeutic relationships, local workforce capacity and flexible models of care that are already delivering meaningful long- term outcomes for children and families.

Regional realities

Private paediatric allied health practices in regional Queensland operate within an extremely challenging workforce environment.

Recruitment of paediatric clinicians to Far North Queensland is exceptionally difficult and requires significant investment in supervision, mentoring, relocation support and workforce development.

Like many regional providers, our practice previously experienced very long waiting lists due to workforce shortages and demand exceeding available local service capacity. Over the past 12 months, we made substantial financial and supervisory investment into recruitment

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 150

and workforce growth, including employing two new graduate occupational therapists and two overseas-trained practitioners.

Maintaining a stable and experienced paediatric workforce in regional Australia requires long-term commitment and considerable business risk from private providers.

Practices like ours do not simply deliver therapy. They help sustain the regional allied health workforce itself.

Longstanding regional partnerships

Our practice has longstanding working relationships with: • local hospitals • GPs • paediatricians • schools • kindergartens • allied health providers • Aboriginal and Torres Strait Islander health services • local NGOs • Child Safety services

These relationships have developed over many years and are critical to coordinated care in rural and regional communities.

We also invest substantial time into regional workforce development initiatives, including supporting programs such as Grow Rural through Health Workforce Queensland to encourage long-term workforce attraction and retention in Far North Queensland.

Experience across service systems

I have worked across government, non-government and private sectors and deeply respect many clinicians and workers within those systems.

However, my experience has been that private practice often allows a level of flexibility, continuity, responsiveness and relationship-based support that is difficult to replicate within larger systems, particularly in regional communities.

Private practice has allowed us to: • adapt supports around real family circumstances • provide continuity of care over many years • collaborate flexibly across homes, schools, kindergartens and health services • respond quickly to changing needs

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 150

• support children before difficulties escalate further • build long-term therapeutic relationships with children, families and communities • focus strongly on practical functional outcomes and long-term independence

In many cases, this work helps reduce future support needs by building children’s capacity, participation and independence throughout childhood, adolescence and young adulthood.

This flexibility and continuity matter greatly in rural and regional settings where service alternatives are limited and where trusted local relationships take many years to build.

Examples of long-term functional outcomes

Example 1

Prior to the introduction of the NDIS, one child in our region was unable to access occupational therapy services despite significant functional difficulties.

At approximately 10 years of age, the child was still dependent on intensive daily toileting support and completing bowel motions in a nappy each afternoon. This process could take approximately four hours each day and required substantial parent involvement and supervision. The child was also reliant on continence aids.

Through approximately 18 months of consistent occupational therapy intervention, the child gradually developed the functional, sensory, emotional regulation and self- management skills required for independent toileting.

The child ultimately achieved full toileting independence and no longer required continence aids funded through the NDIS.

This intervention significantly improved the child’s dignity, independence and participation, while also reducing long-term support needs, reducing family burden and reducing ongoing Scheme expenditure.

Example 2

Another teenager presented with extremely severe behavioural, emotional regulation and functional difficulties. At the time of referral, he was unable to attend school and frequently posed significant risk to himself and family members during episodes of dysregulation.

Over several years, our practice provided intensive, relationship-based intervention using a range of therapeutic approaches tailored to suit his developmental, emotional regulation and functional needs.

Importantly, our service was the only therapeutic service the child was willing to engage with consistently over time.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 150

Through long-term intervention, the child gradually developed improved emotional regulation, participation, independence and functional capacity.

The child is now successfully participating in an apprenticeship and has not required use of NDIS funding for approximately two years.

Without this intervention, it is highly likely that the child would have continued to require intensive and costly supports across multiple systems into adulthood.

These types of outcomes are not uncommon within skilled occupational therapy and allied health intervention and highlight the long-term social and economic value of investing in functional capacity, independence, participation and early therapeutic support for people with disability and developmental challenges across the lifespan.

Sustainability, pricing and regional access realities

Financial pressures and workforce sustainability I believe it is important to recognise that many private allied health providers have continued delivering services under increasing financial pressure while attempting to maintain quality, workforce stability and regional access.

Over recent years, private therapy fees outside the NDIS have increased substantially across Australia in response to rising operational costs, workforce shortages, supervision demands, insurance, compliance requirements and broader economic pressures. In contrast, NDIS pricing for most allied health services has remained effectively frozen for extended periods.

This has created increasing financial pressure for providers, particularly in regional areas where service delivery costs are significantly higher.

Despite this, many private providers have continued to invest heavily in workforce recruitment, graduate supervision, outreach services and long-term participant support because of strong commitment to the children and families they support.

I am concerned that reforms may underestimate how close many regional services already operate to financial viability thresholds.

Importantly, I believe there are opportunities to improve the sustainability and cost effectiveness of the NDIS without weakening frontline therapy services.

Administrative burden and clinical expertise

In my experience, skilled clinician input is essential to accurate functional assessment, appropriate support planning and effective long-term participant outcomes within the NDIS.

Occupational therapists are specifically trained in assessing functional capacity, participation, daily living performance and the interaction between a person’s abilities, environments and support needs. Allied health clinicians also have extensive expertise in identifying how functional difficulties impact independence, education, emotional

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 150

regulation, community participation and long-term support requirements across the lifespan.

There are already well-established and evidence-based assessment tools available to support objective evaluation of functional capacity and participation needs, including occupational therapy functional assessment frameworks such as the Perceive, Recall, Plan and Perform (PRPP) System of Task Analysis developed by Dr Chris Chapparo.

There is significant opportunity to make better use of existing clinical expertise and standardised assessment approaches already operating effectively within allied health practice. In my experience, the major inefficiencies often arise not from clinician assessment itself, but from repeated administrative duplication and decision-making processes surrounding that assessment from within the Scheme.

Rather than investing substantial additional public funding into developing entirely new functional capacity assessment systems, there may be considerable value in examining existing evidence-based frameworks and assessment tools already being used successfully within clinical practice.

I do not believe the solution to current system inefficiencies is reducing clinician involvement in assessment and decision-making. Rather, I believe there is significant opportunity to improve sustainability through better use of existing clinical expertise, stronger reliance on evidence-based functional assessment and more streamlined administrative processes within the Scheme.

At present, experienced clinicians are frequently required to repeatedly justify supports that are clinically straightforward and based on clear functional need. Repeated evidence requests, lengthy reporting requirements, duplicated administrative processes and inconsistent decision-making within the NDIS create considerable cost within the Scheme while reducing time available for direct therapeutic intervention.

In many cases, these administrative requirements generate substantial additional work and expenditure without clear evidence that they improve participant outcomes or decision quality. Clinicians are often required to spend large amounts of time responding to repeated requests for further information, additional reports and reassessment processes despite functional needs already being well established through previous assessment and intervention. However, experienced clinicians could provide shorter, clinically focused reports supported by appropriate assessment tools if there were greater trust in professional judgement and reduced duplication within NDIS administrative processes.

Greater clinician involvement in the design of funding pathways, assistive technology processes and therapy service models could also help create a more practical, responsive and cost-effective system while reducing the likelihood of inconsistent or inappropriate funding decisions.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 150

At present, there appears to be limited transparency regarding the internal administrative costs, duplication and decision-making processes occurring within the Scheme itself, despite significant focus on provider costs and participant expenditure.

Requiring participants and families to repeatedly prove and re-prove longstanding functional difficulties through extensive reporting and reassessment processes creates unnecessary distress, reinforces deficit-focused interactions and diverts time, energy and funding away from genuine capacity-building and therapeutic intervention.

Provider registration and regulatory burden Proposed mandatory NDIS registration requirements for providers are also causing significant concern across the allied health sector, particularly for small and medium regional practices.

Many allied health clinicians are already extensively regulated through AHPRA registration, professional standards, continuing professional development requirements, supervision obligations, mandatory reporting requirements and existing legal and ethical frameworks.

While quality and safeguarding are critically important, there is an opportunity to develop registration pathways that are proportionate, practical and financially sustainable for experienced allied health providers.

Previous programs such as Better Start and Helping Children with Autism operated using significantly simpler provider registration and approval processes that still allowed governments to maintain oversight while reducing unnecessary administrative burden and cost.

In contrast, current NDIS registration requirements can cost providers many thousands of dollars annually and require substantial additional compliance work, particularly for small regional practices already operating under significant workforce and financial pressure.

I am concerned that unnecessarily complex and costly registration processes may further reduce the viability of smaller regional providers and unintentionally discourage experienced clinicians from continuing within the disability sector.

Consideration should be given to lighter-touch registration pathways for AHPRA-registered allied health practitioners who are already operating under robust professional regulatory frameworks.

Regional travel and outreach access

Regional travel funding changes have also had significant impacts on service accessibility in areas such as Far North Queensland.

Our practice has always attempted to deliver outreach services as efficiently as possible, including coordinating multiple clients within communities and allocating practitioners to provide fully booked days (5-7 participants) of outreach services to regional locations.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 150

Despite careful planning and efforts to minimise costs, reductions to travel funding have increasingly limited the viability of outreach service delivery, particularly to smaller and more vulnerable communities.

In practice, this means some children and families, including Aboriginal and Torres Strait Islander families in regional areas, are now experiencing reduced access to services because providers are no longer able to sustainably absorb the true costs associated with travel and outreach.

This is particularly concerning in regions where there are few or no realistic alternative services available locally.

Risks of poorly sequenced reform

I respectfully ask the Committee to consider the following risks:

1. Children with substantial functional difficulties may be categorised as “low to moderate” despite significant impacts on daily life, participation and family functioning.

2. Procurement and commissioning models for Thriving Kids may unintentionally favour large organisations with tendering capacity while excluding experienced local providers with longstanding community relationships and strong functional outcomes.

3. Regional private allied health services that are currently delivering highly responsive, relationship-based and outcomes-focused care will become financially unviable under future funding arrangements.

4. Highly skilled and experienced clinicians will leave the paediatric and disability sector entirely if reforms reduce the viability of models of care that currently allow meaningful long-term outcomes for participants, including children and families.

5. Regional communities risk losing workforce capacity, supervision pathways and locally embedded expertise that have taken many years to build.

6. Participants, including children and families, may lose continuity of care and trusted therapeutic relationships developed over many years.

7. Aboriginal and Torres Strait Islander families in regional communities may face reduced access to culturally safe and community-connected supports.

8. Schools and kindergartens may lose critical local allied health partnerships and practical therapeutic support for children with complex developmental, behavioural and emotional regulation needs.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 150

9. Increasing financial pressure and frozen pricing structures will continue reducing the viability of regional allied health services, particularly outreach services.

10. Reductions to travel funding are already reducing service access for some rural, remote and Aboriginal and Torres Strait Islander communities.

11. Cost shifting to schools, hospitals, families and community systems will increase if skilled early intervention and therapy supports are reduced.

12. Reforms risk weakening one of the most experienced, flexible and outcomes-focused parts of the current paediatric and disability support system without sufficient recognition of the long-term value these services create for participants, families and communities.

Recommendations

I respectfully recommend that the Bill and related reforms include stronger safeguards to ensure:

1. No participant loses funded support until a suitable, accessible and clinically appropriate alternative is genuinely available.

2. Functional impact, participation, environmental context and family capacity are considered alongside diagnosis and broad support categories.

3. Private paediatric allied health providers remain legitimate providers within future foundational support systems, including Thriving Kids.

4. Commissioning pathways are accessible to small and medium regional practices, not only large organisations.

5. Greater clinician consultation should occur in the design of therapy funding models, travel arrangements, assistive technology processes and administrative systems to improve cost effectiveness, reduce unnecessary bureaucracy and strengthen participant outcomes.

6. Rural, remote and outreach loadings are built into future funding models.

7. Continuity of care is protected during transition arrangements.

8. Regional provider impact assessments are undertaken before major access changes commence.

9. Aboriginal and Torres Strait Islander communities are consulted locally regarding continuity, cultural safety and access.

10. Workforce sustainability is considered central to implementation planning.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 150

11. NDIS pricing structures should reflect the real costs of delivering high-quality allied health services, particularly in regional and remote communities where recruitment, supervision, outreach and workforce retention costs are significantly higher, and where prolonged pricing freezes have created increasing pressure on service viability.

12. Travel funding arrangements should support sustainable outreach service delivery for rural, remote and Aboriginal and Torres Strait Islander communities.

13. Administrative and reporting requirements should be streamlined where clinically appropriate, allowing experienced clinicians to spend more time delivering direct support to participants and families rather than responding to duplicated evidence requests and unnecessary administrative processes.

14. Reform implementation should recognise the long-term economic value of skilled early intervention and therapy services in reducing future support needs, increasing independence and reducing downstream pressure on schools, hospitals, mental health services and community systems.

15. Greater use should be made of existing evidence-based functional assessment tools and occupational therapy functional capacity frameworks to support consistent, objective and clinically informed decision-making within the Scheme.

16. The Scheme should place greater trust in experienced clinician judgement and reduce unnecessary duplication in reporting and reassessment processes, particularly where functional needs are longstanding and well established.

17. Greater transparency should be provided regarding administrative expenditure, duplicated processes and decision-making systems within the NDIS to help identify opportunities for improved efficiency and reduction of unnecessary Scheme costs.

18. Reform efforts should prioritise reducing duplicated administrative processes and excessive evidence requirements within the NDIS before reducing frontline therapy supports and participant access to services.

19. Funding decision-making processes should involve stronger input from clinicians with relevant functional and disability expertise, particularly regarding assistive technology, functional capacity and therapy support decisions.

20. Administrative requirements placed on clinicians should be proportionate, evidence- based and clearly linked to improving participant outcomes and decision quality.

21. Before investing substantial public funding into developing new functional capacity assessment systems, consideration should be given to existing evidence-based allied health assessment frameworks and tools already used effectively within clinical practice, including occupational therapy assessment approaches such as the PRPP System of Task Analysis.

22. Provider registration pathways should be proportionate, practical and financially sustainable, particularly for small and medium regional allied health providers.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 150

23. Consideration should be given to simplified or reduced-burden registration pathways for AHPRA-registered allied health practitioners who are already subject to extensive professional regulation and oversight.
24. Registration models for allied health providers should be low-cost or government- funded wherever possible, similar to previous approaches used within programs such as Better Start, Helping Children with Autism and Medicare provider recognition systems.

Closing statement

I support reform that strengthens the long-term sustainability, fairness and effectiveness of the NDIS.

However, I do not believe sustainability will be achieved through approaches that unintentionally weaken experienced frontline allied health services already delivering meaningful functional outcomes for participants, including children and families, particularly within regional communities.

Over many years, private paediatric and allied health providers across Australia have invested heavily in workforce development, outreach services, supervision, infrastructure and long-term therapeutic relationships in response to national policy directions and increasing community need.

In many regional communities, these services have become deeply embedded within broader health, education and community systems supporting participants and families. They represent not only service providers, but also critical workforce infrastructure, clinical expertise and longstanding community relationships that have taken many years to build.

In my experience, there are significant opportunities to improve the sustainability and cost effectiveness of the NDIS through greater clinician consultation, reduced administrative duplication, more streamlined processes, stronger use of evidence-based functional assessment and greater trust in experienced clinical judgement.

Importantly, skilled occupational therapy and allied health intervention often reduces long- term support needs by building functional capacity, independence, participation and emotional regulation across childhood, adolescence and adulthood.

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 150

Well-designed early and ongoing intervention should be viewed not only as an expense within the Scheme, but also as an investment that can reduce future pressure on families, schools, hospitals, mental health services and other community systems.

I respectfully ask that future reforms proceed with careful consideration of workforce sustainability, regional service realities, continuity of care and the long-term value experienced allied health providers contribute to participants, families and communities across Australia.

Thank you for considering this submission.

Crystel Poggioli Director and Clinical Lead The Whole Child Atherton Tablelands, Far North Queensland

Email: support@thewholechild.com.au Phone:

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