Submission 1540

From: Sent: Tuesday, 26 May 2026 2:08 PM To: Community Affairs, Committee (SEN); Subject: Re: Submission: NDIS Future Generations Bill 2026

deeply professional concerns relate to the parts of the Bill that propose significant automated and system-wide funding reductions, alongside provisions that risk narrowing access to the Scheme for children aged 0–8.

Specifically, I am alarmed by:

-  The proposed 10 per cent reduction to capacity-building daily activity supports.
-  The proposed 50 per cent reduction to social, civic, and community participation supports.
-  The expanded Ministerial powers and the transition toward standardised, automated "tick-
  box" assessment tools.

3. Personal Experience: Why the Independent Private Sector is Vital

The true value of occupational therapy lies in our clinical creativity and our ability to support people dynamically within their unique environments. Large corporate and NGO models often restrict this creativity due to heavy administrative burdens and rigid productivity targets.

As an independent private practitioner, I can deliver genuine, flexible, client-centred care that yields real results:

-  The Limitations of Standardised-Only Assessments: While standardised tools have their
   benefits, and give therapists a place to 'start' they are insufficient on their own. For example,

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Standard sensory processing assessments provide different forms for different environments, but they still only offer a rigid snapshot that rarely captures a child’s fluctuating needs.

• The Danger to Complex and Trauma-Informed Care: Crucially, standardised tools fail to capture how trauma and complex comorbidities affect the central nervous system’s fight, flight, or freeze responses. For new graduates or less experienced clinicians, relying strictly on these “tick-box” tools without deeper clinical oversight risks completely misinterpreting a child’s needs.

• The Power of Real-World Observation: I do not establish a therapy plan until I have observed a child across multiple environments—at home, in preschool, and at school—and at different times of day. A child’s behaviour and sensory overwhelm can vary drastically between school and home. Real-world observation is far more valuable for funding efficiency than a rigid, sandardised tool.

• Context-Driven, Transferable Gains: While clinic-based therapy absolutely has its benefits for certain interventions, a child’s goals span across all areas of their life. True therapeutic gains blossom and become transferable when therapy can also happen dynamically where it is needed most. Limiting therapy to a single setting reduces the opportunity for children to learn from each other in real-world, natural environments and natural social contexts.

4. The Urgent Need for Integration vs. The “Thriving Kids” Bottleneck

For years, I have envisioned a collaborative programme exactly like what Thriving Kids promises to be—one that builds robust community opportunities by embedding occupational therapists and speech pathologists directly into the learning environment. This model is proven to take immense pressure off families who are already stretched to their absolute limits trying to coordinate external appointments.

Currently, delivering external therapy within school environments can be logistically challenging. Educators are under immense pressure, and managing various independent external visitors creates an unavoidable administrative burden. However, simply employing therapists directly within the education system creates alternative structural challenges, as history shows that high caseloads and less flexible institutional demands often risk overwhelming clinical staff and limiting their effectiveness.

A far more sustainable, effective option is to utilise a “funding block” model, similar to how schools currently contract external providers for gymnastics or intensive sports programmes. By funding structured, term-to-term contract blocks, independent private OTs can be brought into educational spaces to run targeted, age-appropriate initiatives—such as perceptual motor programmes. This contract-service model completely removes the permanent administrative burden from teachers and ensures a stable, sustainable workflow for clinicians, making therapy a seamless, highly effective part of the educational day.

The need for this integration has never been more urgent. We are now seeing the long-term impact of the COVID-19 pandemic manifest in our daycares, preschools, and early primary years. The babies and toddlers born into pandemic isolation and stress are now entering the education system without their foundational developmental needs having been met. As a result, educators are facing an unprecedented increase in children who are unable to self-regulate.

In my own practice with , I have personally delivered targeted OT programmes by

Submission 1540

going directly into preschools to provide consistent, ongoing support and vital education for educators. This model has been extremely successful, proving that when therapists and educators work hand-in-hand, we can directly address these severe regulation challenges, reduce the burden on staff, and radically improve outcomes for children. Upskilling and supporting early childhood educators is absolutely crucial right now.

However, the current procurement landscape for the NSW Thriving Kids program indicates that private paediatric OTs will only be engaged “where required” as an exception. The independent private workforce represents the bulk of senior clinical expertise precisely because therapists migrate to private practice to protect their clinical standards and avoid corporate burnout. Excluding us from core delivery in favour of already overstretched NGOs and government agencies will trigger immediate bottlenecks at the exact moment the NDSI is retracting:

• Severe Workforce Capacity Deficits: The public and NGO sectors cannot handle the volume.
• Loss of Continuity of Care: Forcing vulnerable children away from trusted, independent OTs onto years-long public waitlists will derail their development.
• Elimination of Choice: Families will lose access to specialised, flexible business models tailored to their child’s unique sensory and emotional needs.

What I Ask Parliament to Do

I strongly support the “No OTs, No NDIS” campaign and urge the Committee to adopt the recommendations put forward by Occupational Therapy Australia (OTA). Specifically, I ask that the Parliament:

1. Reverse the proposed funding cuts to capacity-building and participation supports.
2. Prohibit fully automated funding decisions and ensure functional capacity assessments are conducted via the holistic clinical judgment of qualified professionals.
3. Constrain broad Ministerial powers to ensure decisions remain based on individual, real-world needs, rather than broad, system-wide rules.
4. Formally recognise existing AHPRA regulation to protect a sustainable, clinically governed allied health workforce across both federal and state-interfacing programmes.

The Thriving Kids initiative and the broader NDIS ecosystem simply cannot succeed without the formal, meaningful, and immediate inclusion of the independent private workforce.

Thank you for considering my submission.

Yours sincerely,

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