Submission 1695

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

This submission outlines some of my concerns regarding this proposed Bill. Those concerns are based on my experience as an Occupational Therapist (OT) working within the NDIS model and an awareness of how the proposed changes will impact the people I work with.

Support Needs Assessment tool and process

The proposed new tool is the ICAN to be used by NDIA staff and administered via technology – phone or zoom call (I anticipate). The assessment will not be face to face and not administered by a trained allied health professional.

I am concerned the results will not provide an accurate picture of the person’s needs. There is no observation of a person doing the task in their environment. There is no consideration for any individual compensations or strategies the person requires to do the task. For example – a person with psychosocial disorder tells you they shower independently. Some participants I meet consider independent showering is to shower when they feel comfortable showering and this can be once every 4-5 days.

Sitting with them, you can smell body smells, you can see the unkempt state of their room. This is not adequate to meet hygiene standards. The reasons they do not shower daily can be many and varied and are unique to their life experiences. They will not tell a person over the phone these unique features. They may struggle with motivation to complete basic hygiene. They may experience specific challenges such as hearing voices from the shower rose or believing people are watching them in the shower and this is not a safe place.

They can only shower when the people supporting them structure the experience to be safe. They are at risk of personal hygiene (skin infections) and body odour that is not easy to manage in social settings.

There can be major discrepancies between what a participant describes as being independent with showering and what the people who know them well consider are basic hygiene standards. These nuances will not be picked up in a phone conversation with a person who does not know them well.

Occupational Therapists are trained and well equipped in functional assessments to consider the person, their environment and the interplay between those features to undertake a task. This will not be captured in the ICAN process. The results will not be an accurate representation of what is needed. There is reduced clinical discretion with the focus on an objective narrow assessment that will not be flexible or represent individual needs.

I understand the participant will not be able to see a draft of the assessment results before it is submitted. I would question if this enables the participant to feel confident the information about them is accurate or presents a realistic picture of their needs.

New Framework planning

I understand the participant will receive a total budget – some will be flexible and some non-flexible. There will be increased responsibility on the participant to plan how the funds are spent for allied health and support work.

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I question whether some of the participants I work with will have the capacity to make those decisions without support. This would seem to me to be designed by people who do not understand the needs of people living with a disability. There will be risks participants do not get the support they need. For example: A participant with an intellectual disability may spend all their allied health budget on speech services because they enjoy working with the speech pathologist. They do not enjoy doing the muscle stretches with the physio so will allocate more for speech and leave limited or none for physio. If the physio work is not done the participant may be at risk of muscle shortening and contractures which could be prevented with regular physio sessions. At the worst-case surgery may be required for contracture management and long-term loss of function. Some participants will not have the capacity to make these decisions and need assistance or risk missing important therapy.

What defines permanence of disability? There are many reasons why a person may not follow up every option for treatment.

• Limits of spatial access for rural participants
• Cost of travel and accommodation when the participant needs to travel
• Availability and access to specialist services I wonder who decides when a person has exhausted all treatment options? Is this a medical framework? In my experience, parents of participants already talk about a burden of guilt for not being able to follow up every treatment option (family needs v individual needs, cost, days off work, days away from other family members.) For adult participants, the frustration of trying a service that did not provide anything of benefit again. They make the decision to manage as best they can with what they have and get on with life routines. I question who makes this decision in the best interest of an individual. It is life changing to be in scheme such as the NDIS or to be excluded.

Changes to reasonable and necessary criteria There needs to be safeguards around choosing the lowest cost option just based on financial considerations. For example: As an OT I may prescribe a shower chair with adjustable height and swing away arm rests that is more expensive than a basic shower chair. My justification for the prescription is based on - The person may grow and need height adjustment - The person may spend time in different houses of family members and need to take the chair with them. In some bathrooms, the height needs to be one level to reach the taps, in another house it needs to be another level. - The person may need to complete a sideways transfer in one house due to limited space and need swing away arm rests. The cheapest option of a standard shower seat would not achieve the same outcome. Consideration needs to be given to the person, their environment and the task – this is unique for each person. There is the risk the lowest cost option will be a wasted item because it does not meet the participant’s needs. This would then be a waste of money and resources.

Expectation of Informal Supports

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It appears there is an assumption that parents need to take on ALL the load for ALL the care of their child regardless of the level of disability. Most parents already compromise on so many levels to provide informal support. I question this blanket assumption and again ask that individual circumstances need to be considered.

• Some children will progress and retain skills. Some children have regression of skills (Childhood dementia, autism disorder). Most parents anticipate the need for supervision and personal care will decrease over time. For some parents with children who have very complex needs, this does not happen. In some cases, the need for care increases.
• It is vastly different to toilet and bathe a 4-year-old to doing those same tasks for a 14- year-old.

What is considered effective and beneficial? It appears the changes to the bill will be applying generalised guidelines based on published peer review literature, evidence practice models.

For some participants, there are no ‘cohort’ studies or evidence models because they are unique in their range of impairments and circumstances. Again, the proposed changes are suggesting participants will follow this path because this is what we know. Example: I have been asked to provide support for a 17-year-old learner driver who lives with brittle bone disorder. I can not find any evidence from research as to what is definitely going to work for this learner driver. My proposed plan is that we will need to trial a range of options. There are many individuals that you cannot predict what is going to work. There is the knowledge and wisdom of lived experience that is valuable to consider but often you need to try a range of options. I cannot rely on blanket generalisations of a study that sort of reflect my participant’s needs because I am not sure what they are yet.

Decision time framework being extended from 3 weeks to 3 months For participants living with fluctuating and degenerative conditions they may die while waiting for a decision over 3 months. Should a person suddenly start to decline, they are likely to end up in the local hospital and be waiting for safe discharge which requires equipment and extra supports for care needs.

I do have many concerns the proposed changes will result in ‘blanket and generalised’ plans where care is not based on holistic assessment by someone qualified to do so.

I agree the NDIS is a valuable scheme and does need to be overhauled but the proposed changes are likely to result in participants I work with being left vulnerable and at risk.

Occupational Therapist, northern NSW E: 27/05/2026