Submission 157

0405 288 407 hello@elevateallied.com.au 8/31 Dwyer St, North Gosford NSW 2250

Submission to the Senate Inquiry

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

May 25, 2026

I am an Occupational Therapist and owner of a small, allied health business providing services to children, adolescents and adults with neurodevelopmental disabilities, intellectual disability, psychosocial disability and physical disability. I work directly with participants and families across clinic, school and community settings and regularly support people with significant functional impairments to access, understand and navigate the NDIS.

I appreciate the importance of ensuring the long-term sustainability of the NDIS. However, I hold significant concerns that many of the proposed amendments within the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 risk undermining participant safety, reducing access to essential supports, and shifting the Scheme away from its original intent of providing individualised, functional and person- centred support.

Many of the proposed changes appear focused on cost containment rather than improving participant outcomes, equity or access to meaningful supports. From a clinical perspective, I am concerned these reforms will disproportionately impact people with complex neurodevelopmental, psychosocial and intellectual disability presentations, particularly those who already experience difficulty navigating systems, advocating for themselves, or accessing alternative services.

Concerns regarding access to the Scheme

The proposed introduction of standardised functional capacity assessments raises significant concern. Neurodevelopmental disability, psychosocial disability and intellectual disability are highly variable and context-dependent. A person’s functioning often fluctuates across environments, sensory demands, social expectations and support availability. A standardised assessment tool is unlikely to accurately capture the complexity of these presentations or the cumulative functional impacts experienced in daily life.

The current model, which allows treating clinicians to provide detailed evidence regarding functional impact across real-world settings, provides a far more accurate representation of disability and support needs. Standardised tools risk excluding participants whose impairments are not easily quantified in brief assessment contexts, despite experiencing significant lifelong disability.

I am also deeply concerned about provisions requiring participants to trial “all appropriate” treatment before accessing the NDIS. In practice, many participants face substantial barriers

Submission 157

to accessing treatment, including long waitlists, workforce shortages, geographic limitations and financial constraints. This is particularly relevant in mental health and neurodevelopmental spaces, where access to specialised services is already extremely limited.

These provisions risk delaying access to essential supports during critical developmental periods, particularly for children and adolescents. They also fail to recognise that many disabilities are lifelong and that treatment may improve coping or functioning without removing the underlying disability or support needs.

Limited access to alternative supports and services

The Bill appears to assume that alternative systems will adequately meet participant needs if NDIS access or funding is reduced. This does not reflect the reality experienced by clinicians, participants or families.

Public health, mental health, education and community services are already significantly overstretched. Many participants currently rely on the NDIS precisely because other systems cannot provide timely, accessible or disability-specific support. Removing or limiting NDIS access without first ensuring alternative systems are appropriately funded and accessible risks leaving highly vulnerable people without support altogether.

This concern is particularly significant for participants with psychosocial disability, autism, ADHD, intellectual disability and complex behavioural presentations who often require coordinated, multidisciplinary and ongoing support that is not available through mainstream services.

Concerns regarding planning changes and reassessment limitations

The proposed restrictions on plan reassessments are particularly concerning. Disability and functional capacity are not static. Participants frequently experience changes in support needs due to developmental transitions, mental health deterioration, changes in informal supports, school transitions, burnout, behavioural escalation, family breakdown, housing instability or physical health decline.

Restricting reassessments only to “significant and ongoing” changes risks preventing participants from accessing timely adjustments when supports are clearly no longer adequate. The proposal that running out of funding early would not itself justify reassessment is especially concerning from a clinical and safeguarding perspective.

This is likely to result in increased crisis presentations, carer burnout, school disengagement, family breakdown and hospitalisation, ultimately increasing pressure on other systems and creating higher long-term costs.

Submission 157

4. Concerns regarding ministerial powers and reduced safeguards

I hold serious concerns regarding the extent of powers proposed to be granted to the Minister, including the ability to introduce funding caps, alter supports through legislative instruments, change pricing structures, and make significant operational changes after passage of the legislation.

These powers appear excessively broad and reduce transparency, accountability and participant protections. Of particular concern is the ability to reduce funding below what has already been determined to be “reasonable and necessary”. This fundamentally changes the purpose of the Scheme and creates substantial uncertainty for participants, families and providers.

The ability for plans to be suspended or revoked where participants are deemed “uncontactable” also raises serious safeguarding concerns, particularly for participants with psychosocial disability, cognitive impairment, trauma histories, homelessness risk, executive functioning difficulties or communication impairments. Many of the people most reliant on support are also those most likely to struggle with administrative processes.

5. Concerns regarding reversal of Eastham and removal of whole-of-person approaches

I am particularly concerned by the proposed reversal of the “whole of person” approach confirmed in CEO of the NDIA v Eastham [2026] FCA 147. In clinical practice, disabilities do not occur in isolation. Participants frequently experience multiple interacting impairments that collectively impact functioning, participation, regulation, safety, communication and independence. Attempting to artificially separate which impairments “directly” cause a support need does not reflect the lived reality of disability and will create significant confusion, inconsistency and inequity in planning decisions.

For participants with autism, ADHD, psychosocial disability, intellectual disability, trauma histories and chronic health conditions, impairments often overlap and interact in complex ways. Supports are most effective when they address the participant as a whole person within their real-life environment, not as a collection of isolated diagnoses. The proposed changes risk creating fragmented and inadequate support arrangements that fail to meet participant needs and ultimately reduce functional outcomes and participation.

6. Concerns regarding “effective and beneficial” supports

The proposed changes prioritising generalised peer-reviewed evidence over lived experience and treating clinician evidence are also concerning. Many neurodevelopmental and psychosocial interventions require highly individualised approaches. Clinical outcomes are often dependent on the participant’s sensory profile, trauma history, communication style, regulation capacity, environment and therapeutic relationship. There is rarely a single standardised intervention pathway that is universally effective.

Submission 157

Reducing the weight given to treating clinicians and participant outcomes risks excluding supports that are demonstrably beneficial in practice simply because large-scale evidence is limited or emerging.

Conclusion

While I support efforts to improve consistency, reduce fraud and ensure the sustainability of the NDIS, I am concerned that the proposed Bill prioritises financial containment over participant wellbeing, functional outcomes and safety.

The proposed amendments risk:

• reducing access to the Scheme for people with genuine disability-related functional impairment;
• increasing administrative burden and barriers for participants and families;
• undermining individualised and whole-of-person support approaches;
• reducing participant safeguards and review rights;
• shifting responsibility onto already overwhelmed families and informal supports;
• increasing pressure on under-resourced mainstream systems; and
• creating poorer long-term outcomes for participants and communities.

I urge the Senate Committee to carefully reconsider these proposed amendments and undertake broader consultation with participants, families, clinicians, disability advocates and small providers working directly within the sector before progressing legislation of this scale and significance.

The NDIS should remain grounded in individualised, evidence-informed and person-centred support, with appropriate safeguards to ensure sustainability does not come at the expense of participant safety, dignity and meaningful participation.

Thank you for the opportunity to provide this submission and for considering the perspectives of clinicians, participants and families directly impacted by these proposed reforms.

Yours sincerely,

Carrie Hardie Occupational Therapist Owner, Elevate Allied Health Elevate Allied Health