NDIA Accountability Project

Concerns regarding functional capacity assessment and participation supports for children

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

Submission 1531

From: To: ––––Community Affairs, Committee (SEN); - Subject: Submission: NDIS Future Generations Bill 2026 Date: Tuesday, 26 May 2026 1:55:27 PM

Dear Committee Members,

I am writing as a senior paediatric occupational therapist with more than 30 years of experience working across hospitals, schools, community settings, private practice, and family-centred paediatric services.

I am deeply concerned about aspects of the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 and the potential impact these changes may have on children, families, and access to appropriate supports.

My primary concern relates to the proposed approach to functional capacity assessment. In paediatric occupational therapy, a child’s functioning cannot be accurately understood outside of the environments in which they live, learn, play, and participate. A child may appear capable in one setting, yet be unable to participate meaningfully, safely, or consistently in real-world environments such as classrooms, playgrounds, community activities, or family routines. Depending on the child’s capacity, this may or may not be within their chronological age norms, Ot’s are well educated in making these decisions.

Occupational therapists assess not only what a child can do in ideal conditions, but whether they can sustain participation across everyday life demands, transitions, sensory environments, emotional stressors, and changing developmental expectations. Functional capacity is dynamic, context-dependent, and closely linked to regulation, relationships, environmental supports, and participation opportunities.

I am also concerned about increased reliance on automated standardised tools and rule-based decision-making without sufficient professional clinical reasoning and oversight. Many children with neurodevelopmental, psychosocial, trauma-related, sensory, or fluctuating presentations do not fit neatly into “tick-box” systems. Their needs are often complex, layered, and highly influenced by context, requiring a well-trained professional to analyse and make difficult decisions with the client.

In paediatric practice, early intervention and participation supports are not optional extras. These supports help children build regulation capacity, independence, communication, social participation, emotional well-being, school engagement, and long-term functional outcomes. Reducing access to these supports risks increasing family stress, school difficulties, mental health concerns, and future service dependency.

I am particularly concerned about children losing access to appropriate supports before alternative systems such as Targeted or Foundational Supports in Thriving Kids are fully established, clearly operationalised, and accessible in practice.

I respectfully ask the Committee to ensure that:

  • functional capacity assessments remain grounded in real-world participation and environmental context
  • professional clinical judgement remains central to decision-making
  • children retain timely access to early intervention and participation supports
  • reassessment processes remain flexible and responsive to changing needs
  • funding decisions prioritise long-term participation, safety, and developmental

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

Submission 1531

outcomes rather than short-term system savings.

Occupational therapists play a critical role in supporting children to participate meaningfully in family life, education, community settings, and everyday occupations. I strongly encourage the Committee to carefully consider the long-term impacts these proposed changes may have on children, families, and the sustainability of paediatric disability supports in Australia.

Kind Regards, Beryl Smith (OT) Sensory SMART OT Team

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