Submission 1696
Joanna Caton info@bidgeekidsot.com.au Occupational Therapist
27.05.29
Submission to the Senate Community Affairs Legislation Committee
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
I am an occupational therapist and small business owner working primarily with neurodivergent children, their families and schools in regional Australia through Connect to Grow Occupational Therapy/ Bidgee Kids Occupational Therapy. Much of my business includes NDIS participants and I have a strong background in disability services. My business was born 12 years ago due to an identified need in our community for experienced Occupational Therapy to serve children across the age ranges.
My work includes functional assessments, parent based coaching, and individualised occupational therapy support for children with autism, developmental delays, complex behavioural presentations and other disabilities. My work is person-centred, neurodiversity affirming and evidence based.
This submission focuses on the likely practical impacts of the proposed legislation on children, families, therapists, and small community-based services.
I support the need for a sustainable NDIS and acknowledge the importance of reducing fraud and improving consistency across the scheme. In fact I have had many concerns over the years about NDIS inefficiency and ineffectiveness which has been created by the NDIS system itself.
However, I am concerned that some proposed reforms may unintentionally reduce access to meaningful supports for children with significant functional challenges, while increasing administrative burden and instability for families and providers already operating under pressure.
Functional capacity measures risk inappropriate categorisation of child disability
Submission 1696
Joanna Caton info@bidgeekidsot.com.au Occupational Therapist
The Bill proposes a stronger focus on solely relying on standardised functional capacity assessment to access and planning without proper consideration of clinical observations and information from treating professionals. Standardised tools can be useful as an adjunct to skilled clinical observations but should never be used as a one sized fits all option. One reason for this is that in paediatric practice, functional capacity in children is rarely static or easily captured through standardised measures alone. Children are constantly developing and changing and when disability or eurodivergence is also a factor, children tend not to follow predictable patterns that fit neatly with “standardised” tools.
Many neurodivergent children function very differently across settings, mask difficulties at school or in assessment environments, rely heavily on parent co-regulation and environmental supports, demonstrate uneven skill profiles, experience significant burnout, anxiety or behavioural dysregulation after maintaining function in structured settings
A child may appear verbally capable or academically bright while still requiring extensive support with emotional regulation, social participation, toileting, sleep, sensory processing, flexibility, safety awareness or daily routines.
There is a risk that narrower interpretations of functional capacity will disadvantage children whose disability presentation is less visible, fluctuating or context-dependent.
In practice, this could result in delayed intervention, increased family crisis, school cant (severe difficulty attending school), mental health deterioration, escalation to more intensive and costly supports later.
Functional assessments should continue to include detailed clinical observation, developmental history, caregiver reports and evidence gathered across environments, not solely standardised or centralised assessment processes.
Functional assessments should also be carried out by allied health professionals with a disability experience background and who have been trained to carry out such assessments. Functional assessment is core business of the occupational therapy profession.
Submission 1696
Joanna Caton info@bidgeekidsot.com.au Occupational Therapist
- Increased reassessments and tighter planning processes may destabilise children and families
The proposed tightening of reassessment and planning processes appears aimed at improving consistency and reducing cost growth. However, for many families, the current system is already highly stressful and administratively demanding. Parents of neurodivergent children are commonly managing therapy coordination, school communication, behavioural crises, sleep disruption, medical appointments, emotional regulation needs, reduced workforce participation, and subsequent financial pressure.
Frequent reassessment requirements may unintentionally add even more stress to these families.
Neurodivergent children often require long periods of therapeutic consistency before measurable functional gains become visible. Shorter funding cycles or repeated evidence requests can interrupt progress and create instability for both families and providers.
My concern is that therapists will spend increasing amounts of time producing administrative evidence rather than delivering direct support. I already see this as an issue currently in the NDIS.
- Early intervention risks being narrowed too far
In paediatric disability, early intervention is often preventative, focussed on developing new skills and capacity, supportive of inclusion and focussed on building family capacity.
These outcomes may not always fit neatly within narrow interpretations of “reasonable and necessary” supports.
If funding becomes increasingly tied to immediate measurable outputs or narrowly defined impairment categories, there is a risk that children will lose access to supports that reduce long-term dependence and improve family functioning.
The long-term cost of delayed support is likely to exceed the short-term savings achieved through reduced early intervention access.
Submission 1696
Joanna Caton info@bidgeekidsot.com.au Occupational Therapist
- Fraud reduction measures should not disproportionately burden small providers
There is broad support within the sector for stronger fraud prevention and improved accountability and it is disappointing to see that blame is put on therapists. However, many small paediatric providers are already operating with:
- significant unpaid administrative workload
- workforce shortages (Wagga Wagga consistently has a shortage of OTs for example being a regional area).
- high clinical demand (My practice has always had long waiting lists)
- extensive documentation requirements (which often feel pointless)
- rising compliance costs
Although I support the idea of “enrolment” of providers who serve NDIS participants into some kind of NDIS database, additional registration involving complicated “audits” and reporting requirements are likely to be difficult for small regional providers with limited administrative infrastructure and limited funds. This then may cause private providers to leave the sector which further compounds workforce shortages.
This is particularly concerning in paediatric allied health, where continuity of therapeutic relationship is often critical for engagement and progress. Of particular note is that most allied health professionals already must meet stringent registration requirements of AHPRA.
Recommendations
- Ensure functional capacity assessments for children remain multidisciplinary, contextual and developmentally informed. They should be carried out by allied health professionals who have disability experience, preferably Occupational Therapists or other allied health professionals with transdisciplinary training.
- Avoid over-reliance on standardised assessment tools or narrow functional benchmarks for neurodevelopmental conditions. Include clinical observations and information from treating professionals.
- Preserve continuity of therapy supports where there is evidence of ongoing functional impact, even where progress is gradual or inconsistent.
Submission 1696
Joanna Caton info@bidgeekidsot.com.au Occupational Therapist
4. Reduce repetitive evidence requests and administrative
duplication for families and therapists. 5. Ensure fraud prevention measures are proportionate and do not unintentionally reduce the viability of small regional providers. 6. Include extensive consultation and staged implementation before major planning and eligibility reforms commence. 7. Ensure policy settings recognise the preventative value of early intervention and parent capacity-building. 8. Monitor unintended impacts of reforms on workforce retention, service availability, school participation, family mental health, access in regional communities.
Conclusion
The NDIS does need to be sustainable. However, sustainability should not be achieved by making the system harder to navigate for children and families already under significant strain.
In paediatric practice, the children who appear “less impaired” on paper are often the children most vulnerable to being misunderstood by systems. The flow of effects later on the child’s mental health, education and workforce options can be devastating. Tick a box standardised assessments risk missing the real needs of these people.
Good policy implementation requires recognition that disability in children is complex, relational and deeply shaped by environment, support and regulation capacity. Policy should also include true co-design (not just token “consultation”) with the people on the ground who already provide quality care and with NDIS participants.
Joanna Caton
Occupational Therapist
AHPRA: OCC0001734269 info@bidgeekidsot.com.au