National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1701
To the Senate Community Affairs Committee,
Re: Submission regarding the “Securing the NDIS” Bill
My name is . I am a Paediatric Occupational Therapist and , a paediatric occupational therapy practice based in . I have worked extensively with children and families accessing the NDIS across a wide range of disabilities, including autism, ADHD, intellectual disability, developmental trauma, genetic conditions, psychosocial disability, motor disorders, and complex developmental presentations.
I am writing to express my significant concerns regarding the proposed “Securing the NDIS” Bill and the likely impact these changes will have on children with disability, their families, and the broader healthcare and education systems.
While I understand the importance of ensuring the sustainability of the NDIS, I believe many of the proposed changes risk substantially reducing access to essential supports for children and families who genuinely require them.
As a clinician working directly with families every day, I am already seeing increasing levels of distress related to funding reductions, administrative burden, uncertainty regarding future eligibility, and reduced confidence in the stability of the Scheme. Increasingly, clinicians are spending significant time justifying the existence of disability-related needs rather than delivering intervention. This has substantial impacts on participant outcomes, workforce sustainability, and family wellbeing.
My concerns are outlined below.
Concerns regarding the proposed changes to “permanency”
I am extremely concerned about the proposed expansion of what may be considered an “appropriate treatment” when determining whether a disability is permanent.
Many neurodevelopmental disabilities and lifelong conditions can improve in presentation with appropriate intervention and support. However, improvement in function does not mean the disability has been “remedied.”
Children may develop skills, communication methods, emotional regulation capacity, coping strategies, or independence through therapy and support, while still continuing to experience lifelong disability-related impairments and requiring ongoing support.
I am particularly concerned that:
• therapies which reduce symptoms may be interpreted as evidence that a condition is not permanent
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1701
• inaccessible treatments may still be considered “available” • children may be denied access because they demonstrate improvement with intervention
This creates a concerning paradox where improvement through support may become grounds to remove support.
In paediatric practice, early intervention is often effective precisely because support is provided early and consistently. Punishing improvement by withdrawing access undermines evidence- based practice and long-term outcomes.
Concerns regarding “functional capacity” and standardised assessments
I have significant concerns regarding the move toward formalised functional capacity criteria and standardised assessment tools.
Functional capacity in children is highly context dependent and cannot always be accurately captured through standardised tools alone.
Many children demonstrate:
• fluctuating capacity • masking • context-dependent functioning • sensory and emotional regulation differences • variable presentation across home, school, and community environments
Children may appear capable during brief or highly supported interactions while still requiring extensive support to safely and meaningfully participate across a full day.
In paediatric practice, disability does not always present as static or consistently observable. Functional capacity in children is dynamic, co-regulated, environmentally dependent, and developmentally influenced.
Occupational therapists use clinical reasoning, longitudinal observation, caregiver reports, educator feedback, assessment findings, and functional impact together to understand real-world functioning. Standardised assessment tools alone cannot adequately capture the complexity of developmental disability.
I am especially concerned about the impact this may have on:
• autistic children • children with psychosocial disability • ADHD presentations • trauma-related disability • PDA profiles
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1701
• children with fluctuating regulation and executive functioning capacity
These children often do not fit neatly into rigid assessment frameworks despite experiencing substantial disability-related impairment.
Concerns regarding increased “parent responsibility”
As a paediatric Occupational Therapist, I work closely with families who are already providing extraordinary levels of unpaid care.
The implication that many disability-related supports should instead fall within “reasonable parental responsibility” does not reflect the reality of caring for children with significant disability.
Families are frequently:
• managing unsafe behaviours • coordinating extensive medical and therapy appointments • supporting children with severe emotional dysregulation • providing constant supervision • assisting with feeding, dressing, toileting, sleep, mobility, communication, and community access • unable to sustain employment due to caregiving demands
Parents are often functioning simultaneously as co-regulators, therapy assistants, behavioural support workers, advocates, case managers, and full-time carers. These roles are relentless and frequently unsustainable without appropriate disability supports.
Many parents are already physically, emotionally, and financially overwhelmed.
There is also significant concern regarding families where:
• parents themselves are disabled • families are single-parent households • there are multiple children with support needs • families live rurally with limited access to services • families experience socioeconomic barriers to support
Reducing supports under the assumption that parents can absorb this care load will likely increase caregiver burnout, family breakdown, school refusal, mental health crises, hospital presentations, and long-term system costs.
Concerns regarding reassessments and suspension powers
I am concerned about provisions allowing plans to be suspended if participants are considered “not contactable,” particularly given the lack of clarity around this definition.
Many families I work with experience:
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1701
• housing instability • crisis periods • mental health challenges • executive functioning difficulties • communication barriers • cultural and language barriers
Some families already struggle to navigate the administrative burden of the NDIS despite requiring substantial support.
The risk that vulnerable participants could lose access to essential supports due to administrative barriers is deeply concerning.
Concerns regarding broader impacts on children and early intervention
As a paediatric clinician, I am deeply worried these changes will disproportionately impact children.
Early support changes developmental trajectories. Appropriate intervention can:
• improve communication and independence • support school participation • reduce behavioural escalation • reduce family stress • support emotional regulation • reduce long-term support needs • prevent secondary mental health complications
When support is delayed or removed during childhood, the impacts are not neutral. Development continues regardless.
Without appropriate supports, children can experience widening developmental gaps, school disengagement, social exclusion, mental health deterioration, increased family stress, and escalation of support needs over time.
Children do not become less disabled because support helped them function more successfully.
In many cases, successful intervention is what allows children to participate at all.
Closing statement
I support efforts to improve consistency, transparency, and sustainability within the NDIS. However, I strongly urge the Committee to carefully consider the unintended consequences these proposed changes may have on children with disability and their families.
I am particularly concerned that the proposed legislation may:
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1701
• narrow access for genuinely disabled individuals • disadvantage children with invisible, fluctuating, or neurodevelopmental disabilities • increase caregiver burden • over-rely on standardised assessment processes • reduce access to critical early intervention supports
I respectfully ask the Committee to reconsider these proposed changes and ensure that future reforms remain grounded in:
• clinical evidence • lived experience • developmental science • neurodiversity-affirming practice • and the realities faced by families navigating disability every day.
Thank you for the opportunity to provide this submission.
Paediatric Occupational Therapist