NDIA Accountability Project

Concerns regarding functional capacity assessments and contextual understanding of disability

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Submission 1749

Submission to the Senate Community Affairs Legislation Committee

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

Submitted by: Sarah Collison Occupational Therapist Director – Verve OT & Verve OT Learning

Introduction and Background

This submission is informed by over 20 years of Occupational Therapy practice, extensive work within the NDIS since the Hunter trial phase and ongoing engagement with Occupational Therapists, participants and families across Australia through clinical practice, training, supervision and professional education forums. The concerns raised within this submission are also informed by a national webinar delivered in May 2026 regarding the proposed legislative changes and the practical implications for participants, families and clinicians.

I acknowledge the importance of ensuring the long-term sustainability of the NDIS. However, i am deeply concerned that several proposed amendments within this Bill risk fundamentally changing how disability, functional capacity and support need are understood within the Scheme. In my view, many of the proposed reforms move the NDIS further away from individualised and contextual assessment and toward increasingly standardised, restricted and cost-driven decision-making.

A major concern throughout the disability sector is that the proposed reforms appear to have been developed with insufficient understanding of how disability presents in real-world environments. Disability does not occur in isolation from housing, transport, relationships, sensory demands, trauma, fatigue, behavioural regulation, communication barriers, support systems and environmental accessibility. Occupational Therapists assess function within context because context is often the very thing that determines whether a person can safely participate in daily life.

Throughout recent consultation and professional discussion, there has been a growing concern that the cumulative effect of these reforms risks creating a system where participants must become increasingly unsafe, unsupported or functionally compromised before assistance is provided.

Submission 1749

Area of Concern - Functional Capacity and Changes to Eligibility

One of the most concerning aspects of the proposed legislation is the attempt to redefine functional capacity by assessing what a person can do:

  • without assistance from other people,
  • without assistive technology or modifications, and excluding environmental and personal circumstances as far as possible.

As an Occupational Therapist, this is deeply concerning because function does not exist in isolation. Function is not simply about whether a person can physically complete a task in a single moment or controlled environment. Function is about how a person manages to participate in real life, within real environments, across an entire day, week and lifespan.

Occupational Therapists assess function in context because context is often the very thing that determines whether a person is safe, independent and able to participate meaningfully in daily life. We assess how people function within their homes, schools, workplaces and communities. We consider the impact of fatigue, sensory processing, emotional regulation, behavioural presentation, trauma history, environmental accessibility, support systems, routines and assistive technology.

The proposed definition appears to intentionally strip away many of these contextual factors. In practice, this risks creating an artificial picture of disability that does not accurately reflect the participant’s actual support needs.

For example, I work with autistic young adults who present as highly articulate and capable during appointments. They may attend university part-time, communicate well verbally and appear independent in structured environments. However, this presentation is often only possible because substantial scaffolding exists behind the scenes. Parents may provide constant prompting to initiate tasks, manage routines, regulate emotions, organise appointments, prepare meals, monitor wellbeing and prevent shutdown or emotional escalation. Without that support structure, the participant may experience severe executive dysfunction, inability to initiate activities of daily living, emotional dysregulation and significant decline in functioning.

Similarly, a participant with psychosocial disability may appear calm, regulated and capable during a one-hour assessment appointment, yet be unable to sustain this level of functioning consistently across daily life. Their ability to leave the house, attend appointments or engage socially may depend heavily on support workers, routines, emotional co-regulation or carefully managed environments. If those contextual supports are excluded from consideration, there is significant risk that the participant’s disability-related support needs will be underestimated.

Submission 1749

Another example is a participant with stroke-related left-sided weakness who mobilises with a walking stick. On a brief assessment, the participant may appear independently mobile. However, in their actual home environment they may require hands-on assistance from another person to safely negotiate stairs due to reduced balance, fatigue and fall risk. If assessment focuses only on what the participant can do in isolation, without considering the environmental realities of their home, there is risk that critical support needs may not be recognised.

This concern becomes even more significant for participants with fluctuating disability. Many conditions do not present consistently day-to-day or even hour-to-hour. Participants with multiple sclerosis, chronic fatigue conditions, psychosocial disability, epilepsy, autism or acquired brain injury may demonstrate periods of relatively good functioning followed by periods of substantial deterioration. Assessing function in a decontextualised or overly “objective” way risks missing the cumulative impact of fatigue, emotional regulation, sensory overload and functional sustainability over time.

The concern is not simply theoretical. The proposed definition creates real risk that participants may:

  • appear “less disabled” during short assessments,
  • fail to meet eligibility thresholds,
  • receive reduced funding,
  • or be assessed as more independent than they truly are in daily life.

This is particularly concerning when considered alongside the proposed Support Needs Assessment process, which is intended to be conducted by NDIA-employed assessors who are not allied health professionals and may not have the clinical skillset required to identify hidden support needs, compensatory strategies or fluctuating presentations.

I am also concerned regarding the increased power handed to future NDIS Rules to determine assessment thresholds, methodologies and what must or must not be considered in assessment. There is significant risk that this may lead to increasingly standardised or benchmark-style assessment models that reduce clinical reasoning and fail to capture the complexity of real-world disability.

From a clinical perspective, many participants are functioning only because extensive support systems are already in place. Excluding those supports from assessment does not remove the disability. It simply risks making the disability less visible on paper.

In my view, functional capacity assessments must continue to consider the interaction between the person, their environment and the supports required for safe and sustainable participation. Any assessment approach that intentionally removes context risks

Submission 1749

fundamentally misunderstanding disability and underestimating the real-world support needs of participants.

Area of Concern - Permanence and “Appropriate Treatment”

I am deeply concerned regarding the proposed tightening of the definition of permanence and the increasing emphasis on “appropriate treatment” within the legislation.

Many lifelong disabilities require ongoing treatment, therapy, rehabilitation or intervention. This does not mean those disabilities are temporary, nor does it mean the person is expected to recover to a point where disability-related support is no longer required.

In Occupational Therapy practice, it is common to work with participants who will continue engaging in therapy for many years, not because their condition is expected to resolve, but because intervention assists them to:

  • maintain function,

  • reduce deterioration,

  • support emotional regulation,

  • improve safety,

  • prevent escalation,

  • maintain participation,

  • or reduce long-term decline.

For example, an autistic child may continue engaging in Occupational Therapy, psychology or speech therapy throughout childhood and adolescence. The purpose of that therapy is often not to “cure” autism. Rather, therapy may support emotional regulation, sensory processing, participation, safety, social understanding and independence over time. The participant may still have lifelong disability and ongoing support needs despite engaging in therapy for many years.

Similarly, a participant with psychosocial disability may continue engaging in psychology, medication management and allied health intervention indefinitely. Their presentation may fluctuate over time and periods of stability may only occur because substantial treatment and support systems are already in place. Ongoing treatment does not mean the psychosocial disability is temporary. In many cases, the treatment is what prevents significant deterioration or crisis.

Another example is a participant with a degenerative neurological condition such as multiple sclerosis or Parkinson’s disease. These participants may engage in ongoing

Submission 1749

physiotherapy, Occupational Therapy and exercise programs for years in order to slow decline, maintain mobility and preserve independence for as long as possible. The existence of ongoing therapy should not create an argument that the disability is therefore not permanent.

I am concerned that the proposed wording creates significant ambiguity regarding:

  • what constitutes “appropriate treatment,”,

  • who determines when treatment has been sufficiently exhausted,,

  • whether refusal of treatment may impact eligibility,,

  • and whether participants may be expected to pursue ongoing intervention indefinitely in order to prove permanence.

There is also significant concern that many supports currently viewed as “capacity building” may increasingly be reframed as treatment. This creates risk for participants who can only access many of these interventions once they are actually participants of the NDIS. In practice, this may create a circular problem where a person is told they have not exhausted appropriate treatment options, despite only being able to access those interventions through the Scheme itself.

This concern becomes particularly significant for participants experiencing:

  • financial disadvantage,,

  • regional or rural workforce shortages,,

  • long public waitlists,,

  • trauma histories,,

  • medication side effects,,

  • cultural barriers,,

  • or limited access to specialist services.

For example, I work with participants in regional areas who may wait many months or years to access psychiatry, psychology or specialist medical services. Others simply cannot afford private intervention outside the NDIS. Some participants may also decline particular treatment pathways because of previous trauma, adverse side effects or lack of clinically meaningful benefit. These realities do not make the disability any less permanent.

I am concerned that the proposed approach risks creating a system where permanence becomes increasingly difficult to establish, particularly for participants with:

  • autism,

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  • psychosocial disability,

  • fluctuating conditions,

  • acquired brain injury,

  • chronic illness,

  • or complex behavioural presentations.

There is also risk that participants may feel pressured to pursue intervention that:

  • is financially unsustainable,

  • clinically inappropriate,

  • poorly evidenced,

  • inaccessible,

  • or unlikely to result in meaningful functional improvement, simply to demonstrate that all “appropriate treatment” has been exhausted.

In practice, many disabilities will always require ongoing management and support. The existence of ongoing treatment should not be interpreted as evidence that the disability itself is temporary.

I am also concerned that the proposed wording may unintentionally penalise participants who are proactive in engaging with therapy and rehabilitation. Participants who actively engage in treatment to maintain function and participation should not be disadvantaged compared to participants who are unable to access services at all.

From a clinical perspective, permanence should not be assessed solely by asking whether further treatment exists. It should also consider:

  • the likelihood of meaningful functional change,

  • the long-term nature of the impairment,

  • the participant’s lived experience,

  • the sustainability of intervention,

  • and whether ongoing supports will continue to be required despite treatment.

In my view, the legislation should clearly recognise that many permanent disabilities still require ongoing therapy, intervention and rehabilitation. Ongoing treatment should not become a barrier to accessing disability support, particularly where the purpose of intervention is maintenance, prevention, emotional regulation or slowing deterioration rather than cure or resolution of impairment.

Submission 1749

Area of Concern - Tightening Reasonable and Necessary

I am deeply concerned that several proposed amendments within the Bill significantly narrow the interpretation of what may be considered “reasonable and necessary” support under the NDIS.

Taken together, these changes appear to fundamentally shift the Scheme away from an individualised understanding of disability and toward a more restrictive, standardised and cost-driven interpretation of support need.

The proposed amendments relating to:

  • supports arising “directly” from impairment,
  • value for money,
  • effective and beneficial evidence requirements,
  • and informal supports cannot be viewed in isolation. Collectively, they substantially narrow how disability-related support need may be interpreted and funded.

One of the most concerning changes is the requirement that supports must arise “directly” from an impairment. The explanatory material further describes this as requiring the impairment to be the “direct and immediate source, cause or origin” of the support need.

From a clinical perspective, this fundamentally misunderstands how disability presents in real-world environments.

Disability-related support needs rarely arise from impairment alone. In practice, support needs emerge through the interaction between:

  • impairment,
  • environment,
  • housing,
  • transport accessibility,
  • fatigue,
  • sensory processing,
  • trauma,
  • communication barriers,
  • behavioural regulation,
  • and the availability of supports.

Submission 1749

Occupational Therapists assess these interactions every day.

For example, I work with participants who require support workers to access the community, not simply because of a diagnosis itself, but because the interaction between their impairment and community environments creates significant safety risk, emotional dysregulation, sensory overload or inability to navigate tasks independently.

An autistic participant may technically have the physical ability to attend a shopping centre independently, yet become so overwhelmed by sensory demands, unpredictability, social interaction and emotional dysregulation that they are unable to safely complete the activity without support. If the environment and contextual factors are intentionally stripped away from consideration, there is risk that the participant’s support needs may no longer be recognised as directly disability-related.

Similarly, a participant with psychosocial disability may require support to attend appointments, manage shopping or engage with the community because anxiety, persona, trauma responses or emotional dysregulation significantly impair participation. These support needs are real and disability-related, even if they are influenced by environmental and interpersonal factors.

Another example is participants requiring Specialist Disability Accommodation or home modifications. Often the support need does not arise purely from the impairment itself, but from the interaction between impairment and an inaccessible or unsafe environment. A participant with mobility impairment may technically be able to mobilise short distances indoors but be unable to safely access their bathroom, negotiate stairs or evacuate during an emergency within their current home environment. The proposed wording risks oversimplifying these situations and disconnecting disability from the environments in which people actually live.

I am also concerned about the strengthened “value for money” provisions, particularly the increased emphasis on lower-cost “comparable supports” but with the removal of “same outcome”.

In practice, supports are not truly comparable simply because they are cheaper or appear superficially similar.

Occupational Therapy recommendations are based on:

  • safety,

  • functional participation,

  • sustainability,

  • prevention,

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  • long-term outcomes,

  • and reduction of future support needs.

A lower-cost support may appear financially preferable in the short term while creating substantially poorer outcomes in the long term.

For example, I work with participants requiring complex assistive technology or home modifications where a cheaper option may technically provide partial access, but fail to adequately address:

  • falls risk,

  • pressure injury risk,

  • manual handling safety,

  • fatigue,

  • carer burden,

  • or long-term functional sustainability.

Similarly, reducing support worker hours may initially reduce plan expenditure, yet significantly increase:

  • family burnout,

  • behavioural escalation,

  • mental health deterioration,

  • social isolation,

  • safeguarding risk,

  • hospitalisation,

  • or crisis-driven intervention.

I am concerned the proposed wording increasingly reframes disability support through a short-term financial lens rather than a long-term functional and preventative lens.

Another major concern relates to the proposed hierarchy of evidence regarding whether supports are “effective and beneficial.” The legislation prioritises published, peer-reviewed and generalisable evidence above participant-specific evidence and lived experience.

This creates significant concern for participants with:

  • rare conditions,

  • highly individualised support needs,

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  • autism,

  • psychosocial disability,

  • degenerative conditions,

  • or complex behavioural presentations.

Occupational Therapy practice frequently relies on participant-specific assessment and clinical reasoning because disability support is highly individualised. Many supports do not lend themselves neatly to large-scale published evidence.

For example, I may recommend a highly individualised sensory strategy, environmental modification or assistive technology solution based on detailed functional assessment and observed participant outcomes. The intervention may significantly reduce distress, improve participation and reduce escalation for that individual participant, despite limited large- scale published research evidence specific to that exact intervention.

Similarly, many disability supports are not designed to “improve” disability in a measurable way. Their purpose may instead be to:

  • maintain function,

  • reduce decline,

  • improve safety,

  • support emotional regulation,

  • preserve participation,

  • or prevent future deterioration.

I am concerned the proposed hierarchy risks reducing the weighting given to:

  • participant-specific clinical reasoning,

  • lived experience,

  • and observable functional outcomes.

Finally, I am deeply concerned regarding the strengthening of assumptions surrounding informal supports and parental responsibility.

Parents of children with disability often perform the same broad categories of tasks as other parents. However, the intensity, duration and complexity of those tasks may be vastly different.

For example, many families provide:

  • constant supervision,

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  • overnight monitoring,

  • behavioural co-regulation,

  • absconding prevention,

  • seizure management,

  • physical transfers,

  • emotional regulation support,

  • and intensive prompting throughout the day.

A parent supporting a child with autism and severe emotional dysregulation may spend many hours each day managing behavioural escalation, supporting emotional regulation and preventing harm. Another family may sleep in shifts because their child requires constant overnight monitoring due to seizures, absconding risk or behavioural concerns.

While these supports may broadly fall under categories such as:

  • supervision,

  • emotional support,

  • or behavioural support, the intensity and cumulative burden extend far beyond what would ordinarily be expected within typical parenting roles.

I am concerned the proposed wording focuses heavily on the type of support being provided while failing to adequately consider:

  • intensity,

  • frequency,

  • sustainability,

  • emotional burden,

  • sleep disruption,

  • workforce participation impacts,

  • and long-term family functioning.

Reducing formal supports does not eliminate disability-related need. In many cases, it simply transfers that burden onto families already operating beyond sustainable capacity.

Taken together, these proposed amendments risk creating a significantly narrower interpretation of disability-related support need within the NDIS. I am concerned this may result in:

Submission 1749

  • increased support refusals,
  • reduced access to preventative intervention,
  • increased reliance on informal supports,
  • greater crisis escalation,
  • and poorer long-term outcomes for participants and families.

From a clinical perspective, disability support decision-making must continue to recognise the complexity of real-world functioning, environmental interaction and individualised support need. Oversimplifying disability into narrow legislative definitions risks fundamentally misunderstanding the realities of living with disability and providing disability-related care.

Area of Concern - Funding Cuts, Pricing Powers and Ministerial Powers

I am extremely concerned by the broad ministerial and pricing powers introduced within the proposed legislation and the significant shift these changes represent away from individualised funding and toward increasingly centralised financial control of the Scheme.

While the stated intent of the reforms is to improve sustainability of the NDIS, there is substantial concern that many of these powers may ultimately prioritise cost containment over individual functional need, safety and long-term participant outcomes.

One of the most concerning aspects of the Bill is the proposed ability for support determinations and funding mechanisms to:

  • reduce funding by specified percentages,
  • impose caps or limits on categories of support,
  • apply restrictions to groups of participants,
  • and create benchmark-style funding arrangements based on support types or participant cohorts.

From a clinical perspective, this is deeply concerning because disability is highly individualised.

Two participants with the same diagnosis may have vastly different:

  • functional presentations,
  • behavioural support needs,
  • trauma histories,

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  • communication abilities,

  • environmental barriers,

  • informal support systems,

  • sensory processing difficulties,

  • fatigue presentations,

  • and participation goals.

In Occupational Therapy practice, support recommendations are based on detailed functional assessment and the participant’s actual day-to-day support needs, not on averages or broad assumptions about diagnostic groups.

For example, two autistic participants of similar age may present completely differently in terms of:

  • emotional regulation,

  • community access,

  • executive functioning,

  • risk awareness,

  • sensory processing,

  • and independence.

One participant may require only minimal prompting and occasional support, while another may require substantial daily assistance to manage routines, regulate emotions, maintain safety and participate in community environments. Funding caps or benchmarked support models risk flattening these differences and creating systems where participants are funded according to generalised assumptions rather than actual functional need.

Similarly, participants with psychosocial disability may experience fluctuating support needs that do not fit neatly into standardised funding categories. Some participants may function relatively independently during periods of stability while requiring significant support during periods of deterioration, trauma activation or mental health decline. Benchmark-style funding models are poorly equipped to respond to this complexity.

I am also deeply concerned by the proposed powers relating to pricing controls and pricing determinations within the disability market.

Submission 1749

While pricing oversight and market stewardship are important, there is significant concern that increasing pricing powers may further destabilise an already strained disability workforce.

Occupational Therapy service delivery within the NDIS involves substantial work that extends well beyond face-to-face appointments. Clinicians regularly undertake:

  • complex report writing,
  • risk assessment,
  • multidisciplinary liaison,
  • safeguarding considerations,
  • documentation,
  • travel,
  • environmental assessment,
  • equipment trials,
  • stakeholder communication,
  • functional analysis,
  • and significant administrative workload associated with compliance and evidence requirements.

There is concern that pricing decisions may increasingly focus on limiting hourly rates or reducing expenditure without adequately recognising the complexity and non-billable workload associated with safe and high-quality disability practice.

This is particularly concerning in regional and rural areas where workforce shortages already significantly impact access to allied health services. If pricing structures become increasingly restrictive, there is substantial risk that experienced clinicians may leave the disability sector entirely or reduce the complexity of participants they are willing or able to support.

In practice, this may disproportionately impact:

  • participants with complex support needs,
  • participants in regional or remote areas,
  • participants requiring intensive report writing or advocacy,
  • and participants with behavioural, psychosocial or safeguarding complexity.

Submission 1749

I am also concerned about the broader power to reduce funding through percentage- based reductions or support determinations linked to “scheme sustainability.”

Reducing access to:

-   therapy,

-  support workers,

-  capacity building supports,

-  community participation,

-   assistive technology,

-   or preventative intervention may create short-term savings while significantly
   increasing long-term costs elsewhere.

For example, reducing support worker hours for a participant with psychosocial disability may initially reduce plan expenditure, yet contribute to:

-   social isolation,

-  mental health deterioration,

-   crisis presentation,

-   hospital admission,

-  housing instability,

-   or increased interaction with emergency and justice systems.

Similarly, reducing therapy supports for a child with autism may reduce opportunities for early intervention, emotional regulation support, sensory regulation and family capacity building, potentially resulting in greater long-term support dependence and increased family breakdown.

Another major concern is that the proposed powers appear to create increasing distance between:

-   individual functional assessment, and:

-   final funding outcomes.

A participant may still demonstrate clear disability-related support need, yet broader policy settings or pricing determinations may ultimately limit what can actually be funded.

This represents a significant philosophical shift within the Scheme.

Submission 1749

The original intent of the NDIS was individualised and person-centred support based on reasonable and necessary need. The proposed reforms create concern that funding may increasingly be determined through:

  • actuarial modelling,
  • benchmarked assumptions,
  • expenditure targets,
  • or broader fiscal policy objectives, rather than detailed understanding of the participant’s actual lived experience and support requirements.

I am also concerned about the lack of clarity regarding:

  • safeguards,
  • transparency,
  • review mechanisms,
  • and consultation processes associated with these powers.

The ability for future governments or Ministers to alter funding arrangements, support caps or pricing structures through Rules or determinations creates significant uncertainty for:

  • participants,
  • families,
  • providers,
  • and the broader disability workforce.

From a clinical perspective, disability support should not be viewed solely through a short-term financial lens. Many supports that appear costly upfront ultimately reduce:

  • hospitalisation,
  • family breakdown,
  • safeguarding concerns,
  • homelessness,
  • carer burnout,
  • and long-term dependence on crisis systems.

Reducing funding does not reduce disability-related need. In many cases, it simply transfers cost and burden onto:

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  • families,

  • health systems,

  • housing systems,

  • crisis services,

  • and informal supports.

I am concerned that the cumulative effect of these proposed powers risks creating a more restricted, standardised and financially driven Scheme that moves further away from the original principles of individualisation, flexibility and participant-centred support.

Area of Concern - Change to Whole of Person Assessment

I am deeply concerned that the proposed legislative changes move the NDIS further away from whole-of-person assessment and toward increasingly narrow, fragmented and impairment-specific interpretations of disability and support need.

In Occupational Therapy practice, people are not assessed as isolated diagnoses or individual impairments. We assess how the person functions as a whole within their actual life circumstances. This includes understanding how:

  • multiple impairments,

  • psychosocial factors,

  • trauma,

  • sensory processing,

  • fatigue,

  • communication difficulties,

  • behavioural regulation,

  • environmental accessibility,

  • housing,

  • transport,

  • relationships,

  • and support systems interact together to influence participation, safety and independence.

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Many participants do not experience disability through one single impairment operating in isolation. Rather, their support needs arise because multiple factors interact cumulatively over time.

I am concerned the proposed amendments increasingly narrow the interpretation of support need by requiring stronger attribution of supports to particular recognised impairments and separating disability from the broader environmental and functional realities in which people live.

This creates significant concern for participants with:

  • intersecting disabilities,
  • cumulative functional impacts,
  • psychosocial complexity,
  • trauma histories,
  • fluctuating conditions,
  • behavioural support needs,
  • and complex environmental barriers.

For example, I work with participants who may technically have physical capacity to complete certain tasks but are unable to safely or sustainably participate because of the combined impact of:

  • fatigue,
  • sensory overload,
  • emotional dysregulation,
  • trauma responses,
  • cognitive overload,
  • and inaccessible environments.

A participant with autism may physically be able to catch public transport independently, yet become so overwhelmed by sensory input, unpredictability, social interaction and anxiety that they are unable to safely access the community without support. The support need does not arise solely from one isolated impairment. It arises from the interaction between the participant’s disability and the demands of the environment around them.

Similarly, a participant with psychosocial disability and intellectual disability may require support because the cumulative interaction between emotional regulation difficulties, cognitive limitations, trauma history and environmental stressors creates substantial safety

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and participation barriers. Attempting to isolate one “primary” cause of support need risks fundamentally misunderstanding the participant’s lived experience.

Another example is participants requiring mobility supports, environmental modification or community access support because of the interaction between impairment and inaccessible environments.

A participant with significant vision impairment may require mobility equipment or support to safely access the community, not simply because of the impairment itself, but because public transport systems, road crossings, unfamiliar environments and navigation demands create substantial participation barriers. Similarly, a participant with mobility impairment may technically be able to ambulate short distances indoors, yet be unable to safely manage their home environment because of stairs, bathroom access issues, uneven surfaces or emergency evacuation concerns.

In practice, Occupational Therapists frequently identify that support needs arise through the interaction between:

  • impairment,
  • environment,
  • task demands,
  • risk,
  • and participation expectations.

This is consistent with contemporary disability frameworks, including the International Classification of Functioning, Disability and Health (ICF), which recognises that disability occurs through the interaction between a person’s health condition and contextual factors, rather than existing purely within the individual.

I am concerned the proposed legislative direction risks shifting the NDIS toward a narrower biomedical model of disability, where supports are increasingly assessed through isolated impairment categories rather than whole-of-person functioning.

This creates significant risk for participants whose needs do not fit neatly within:

  • single diagnoses,
  • standardised impairment categories,
  • or simplified assessment frameworks.

It also risks disadvantaging participants whose disability-related support needs are heavily influenced by:

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  • trauma,
  • housing instability,
  • psychosocial complexity,
  • sensory processing,
  • environmental accessibility,
  • or cumulative functional burden.

From a clinical perspective, whole-of-person assessment is essential for safe and accurate understanding of disability-related support need.

Without consideration of the broader contextual factors influencing participation and functioning, there is significant risk that:

  • support needs may be underestimated,
  • risk factors may be missed,
  • preventative supports may be reduced,
  • and participants may be assessed as more independent than they truly are in everyday life.

I am also concerned that increasingly narrow assessment approaches may encourage fragmented decision-making, where supports are assessed in isolation rather than considering the participant’s overall functioning, sustainability and long-term wellbeing.

For example, reducing support worker hours may appear reasonable if viewed in isolation from:

  • carer burnout,
  • behavioural escalation,
  • housing instability,
  • community participation,
  • fatigue,
  • or mental health deterioration.

However, when the participant is assessed as a whole person, it may become clear that reducing one support creates substantial increased risk across multiple areas of life.

In my view, the NDIS must continue to recognise that disability is complex, contextual and highly individualised. Assessment processes should preserve whole-of-person clinical

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reasoning and continue recognising the interaction between impairment, environment and participation rather than attempting to artificially separate them.

Area of Concern - Controlling Scheme and Plan Inflation

I am deeply concerned that the proposed measures aimed at controlling “scheme and plan” inflation risk fundamentally shifting the NDIS from a preventative, responsive and participant-centred scheme toward a more restricted and crisis-driven system.

While sustainability of the NDIS is important, there is significant concern that many of the proposed reforms approach sustainability primarily through:

  • restricting access,
  • tightening reassessment pathways,
  • reducing flexibility,
  • and limiting opportunities for participants to seek increased support when circumstances change.

In practice, disability and support needs do not remain static.

Participants experience:

  • deterioration,
  • injury,
  • behavioural escalation,
  • mental health decline,
  • carer burnout,
  • equipment failure,
  • housing instability,
  • changing family circumstances,
  • and fluctuating functional capacity over time.

One of the most concerning aspects of the Bill is the proposal to extend reassessment decision timeframes from 21 days to 90 days while also narrowing reassessment pathways and increasing evidentiary thresholds.

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From a clinical perspective, reassessment requests are rarely made casually. In many cases, they occur because a participant or family has already reached a point of significant stress, risk or unsustainability.

For example, I work with families who seek reassessment because:

  • ageing parents can no longer physically manage transfers,
  • behavioural escalation has increased risk within the home,
  • support arrangements have broken down,
  • a participant has experienced repeated hospital admissions,
  • or environmental arrangements are no longer safe.

These situations often deteriorate gradually over time. Families may spend months attempting to manage increasing support needs before finally seeking reassessment once they have reached exhaustion or crisis point.

A 90-day reassessment timeframe in these situations is extremely significant.

For a participant experiencing escalating behavioural distress, housing instability or carer breakdown, three months without adequate supports may result in:

  • hospitalisation,
  • homelessness,
  • safeguarding concerns,
  • mental health deterioration,
  • school disengagement,
  • family collapse,
  • or entry into more intensive crisis systems.

I am particularly concerned that the proposed narrowing of “exceptional circumstances” and increased evidentiary requirements may create barriers for participants whose deterioration is:

  • gradual,
  • fluctuating,
  • difficult to objectively measure,
  • or heavily influenced by contextual factors.

Many disabilities do not deteriorate in neat, linear or easily measurable ways.

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For example, a participant with psychosocial disability may slowly become increasingly isolated, emotionally dysregulated or unable to manage community participation over time. A child with autism may experience escalating behavioural distress due to increasing sensory, emotional or educational demands as they grow older. An ageing carer may slowly lose physical capacity to continue providing informal supports safely.

These changes may be profoundly significant in real life while still being difficult to demonstrate within narrow reassessment criteria.

I am also concerned about the cumulative impact of these reforms when considered alongside:

  • tighter eligibility requirements,
  • narrower interpretations of functional capacity,
  • increased reliance on informal supports,
  • benchmarked funding approaches,
  • and stronger cost-control mechanisms.

Taken together, there is significant risk that participants may increasingly need to become:

  • more unsafe,
  • more unwell,
  • more functionally impaired,
  • or more socially disconnected before additional supports are approved.

This is deeply concerning because it moves the Scheme away from prevention and early intervention.

Occupational Therapy practice consistently demonstrates that timely supports often prevent significantly greater long-term costs.

For example:

  • timely home modifications may prevent falls and hospitalisation,
  • adequate support worker arrangements may prevent carer breakdown,
  • therapy intervention may reduce behavioural escalation,
  • assistive technology may preserve independence,
  • and early reassessment may prevent housing or placement breakdown.

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Reducing or delaying supports may create short-term financial savings while significantly increasing:

  • hospital admissions,
  • safeguarding risks,
  • emergency accommodation needs,
  • mental health presentations,
  • justice system involvement,
  • and long-term support dependence.

I am also concerned that stricter reassessment processes may disproportionately disadvantage participants who:

  • live in regional or remote areas,
  • cannot afford updated allied health reports,
  • have limited access to treating teams,
  • experience cognitive or psychosocial barriers to advocacy,
  • or lack strong informal support networks.

In practice, participants with the greatest complexity are often the least able to navigate increasingly administrative and evidence-heavy reassessment processes.

Another major concern is that the language surrounding “plan inflation” risks reframing legitimate increases in support need as inherently problematic or financially undesirable.

In reality, many increases in support reflect:

  • ageing,
  • deterioration,
  • changing environmental demands,
  • increased participation goals,
  • reduced informal support availability,
  • or previously unmet need finally being identified.

An increase in funding does not necessarily indicate inefficiency or misuse of the Scheme. In many cases, it reflects the reality that disability and life circumstances evolve over time.

Submission 1749

I am concerned that the proposed reforms increasingly frame sustainability through reduction and restriction rather than through:

  • early intervention,
  • prevention,
  • participant stability,
  • workforce sustainability,
  • and long-term investment in functional outcomes.

From a clinical perspective, a sustainable disability support system is not one that simply spends less in the short term. A sustainable system is one that:

  • prevents crisis,
  • supports participation,
  • maintains safety,
  • preserves informal support arrangements,
  • reduces long-term dependence,
  • and responds flexibly as people’s needs change over time.

In my view, the proposed changes risk creating a system that becomes increasingly reactive, restrictive and crisis-driven, ultimately shifting costs and burden onto:

  • families,
  • health systems,
  • emergency services,
  • housing systems,
  • and informal supports rather than genuinely reducing disability-related need.

Submission 1749

Conclusion

The cumulative effect of these reforms risks fundamentally changing the nature of the NDS.

While sustainability of the Scheme is important, sustainability cannot be achieved simply through narrowing eligibility, restricting access and reducing support flexibility. Poorly supported disability does not disappear. Instead, it re-emerges through:

  • hospital systems,
  • crisis services,
  • homelessness,
  • safeguarding concerns,
  • family breakdown,
  • school disengagement,
  • mental health deterioration,
  • and increased long-term social and economic cost.

I respectfully urge the Committee to carefully consider the real-world implications of these proposed amendments and to ensure that the NDIS remains grounded in:

  • individualised assessment,
  • contextual understanding of disability,
  • participant safety,
  • participation,
  • prevention,
  • and long-term sustainability for people with disability and their families.

Sarah Collison Occupational Therapist Director - Verve OT & Verve OT Learning