Submission

Contents

• Submission To The Senate Community Affairs Legislation Committee: [Page number]

Section headings:

Introduction And Background

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Area Of Concern - Functional capacity & changes To eligibility

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Permanence And “appropriate treatment”

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Tightening reasonable & necessary

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Funding cuts, pricing powers & ministerial power*

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Change whole person assessment

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Controlling scheme plan inflation

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Conclusion

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

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 amendmentswithinthisBill risk fundamentally changing how disability.functional capacityand support needare understood withintheScheme.In my view.manyoftheproposedreforms move then DIS further away from individualised anda contextual assessmenta nd toward increasingly standardised.restrictedanda cost-driven decision-making.A major concern throughout thedisability sectoristhat th eproposed reforms appearto have been developedwith insufficient understandingo fhow disabilitypresentsin real-world environments.Disability does not occurina isolationfrom housing.transport.relationships.sensory demands.t rau ma.fatigue.behavioural regulation.communication barriers.support systemsande nvironmental accessibility.OccupationalTher apist assess functionw ithinc ontext because contexti s often them very thingt hatdetermineswhether apaersoncan safelyparticipateindailylife.Throughout recent consultation andreprofessional discussion.there has beengrowingconcerntha ttheadmulative effect o these reformsrisksc reating asystem whereparticipantsmustbecomeincreasingly unsafe.unsupportedorfunctionally compromisedbeforeassistance is provided.

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

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 single moment controlled environment.Functionisabout how apersonmanages toparticipatein reallife withinrealenvironmentsacrossanentireday weekandlifespan.OccupationalTherapistsassessfunctioninthecontextbecausecontextisonoftentheverythingthatdetermineswhetherapersonissafe independentandabletoparticipecmeaningfullyindailylife.We assesshowpeoplefunctionwithintheirhomes schools workplacesandcommunities.Weconsidertheadimpactoffatigue sensoryprocessing emotional regulation behavioural presentation trauma historyenvironmental accessibility support systems routines andaistivetechnology.Theproposeddefinitionappearsaintentionallystripawaymanyofthesecontexual factors.Inpracticethisriskscreatinganartificialpictureofdaydisabilitythadoestotaccuratelyreflecttheparticipant’sactualsupportneeds.For example,Iworkwithautisticyoungadultswhoresentashighlyarticulateandalcapableduringappointments.Theymayattenduniversityparttimecommunicativewellverballyandanappearindependentinstructuredenvironmets.However,thispresentationisan oftenonlypossiblebecausesubstantialscaffoldingexistsbehindthescen.Parentsmay provideconstantpromptingtoinitiatetasks managerroutines regulatemotionsorganise appointmentspreparemealsmonitorwellbeing andpreventshutdownoremotionale escalation.Without that supportsstructure the participant mayexperiencesevereexecutive dysfunction inability to initiate activities of daily livingemotional dysregulationandsignificantdeclinein functioning.Similarlya participant with psychosocial disability ma appearcalm regulated and capable during a onehour assessment appointment yet be unabletosustain this level offunctioning consistentlyacrossdailylife Theireabiltytoleavethehouse attendappointmentsorangagesociallymaybeheavilyonsupportworkersroutines emotionalco-regulationorcarefullymanagedenvironments.Ifthosecontextualsupports areexcludedfromconsideration there is significant riskthattheadisabilit related support needs willbe underestimated.

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

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 due to reduced balance, fatigue and fall risk.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 consideringthe environmental realities of their homethereisriskthatcriticalsupportneedsmaynotbe recognised. The concern becomes even more significantfor participants withefluctuatingdisability.Many conditionsdo nothave consistently day-to-day oreven hour-tourhourParticipantswitthemultiple sclerosischronicfatigconditonspsychosocial disabilityepilepsyautismor acquired brain injury mayshow periodsof relatively good functioning followedby periodsof substantial deterioration.Assessing functioninadecontextualised or overly“objective”way riskeffectively missing them cumulative impact offatigueemotional regulation sensory overloadand functional sustainability over time.Theconcern isnot simply theoretical The proposed definition creates real rix thatparticipants maappear “less disabled during short assessmentsfailto meet eligibility thresholdsreceive reduced fundingor be assessed asmore independent thanthey truly are indaily life.This is particularly concerning when considered alongside thenproposed Support NeedsAssessment processwhich istendedtobe conducted by NDIA-employed assessors whoare not allied health professionals anda maynothavethe clinical skillset required toidentifyhidden support needscompensatory strategiesorflectuating presentations.I am also concerned regardingthen increased power handed to future NDIS Rules todetermine assessmentthresholdsmethodologies and what mustormustnottobecconsideredinassessment.There issignificant riskthat thismaya lead toeincreasinglystandardised orbenchmark-styleassesment models thatreduceclinical reasoninganda failtocapture the complexity ofreal-worlddisability.From a clincal perspective many participants arfunction only because extensive support systems already in placeExcluding those supports from assessemdoesnotremovethedisabilitiyItsimply risks makingthe disability less visible on paper.In my viewfunctional capacity assesmentsmust continue toc onsider interactionbetween thee persontheir environmentanndthesupportsrequired for safeandsustainableparticipation.Anyassesstion approach that intentionally removes context risks

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

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 dandthe increasing emphasis on “appropriate treatment” within the legislation. Manylifelong disabilities requireongoingtreatmenttherapyrehabilitationorintervention.Thisdoesnotmeanthosedisabilitiesaretemporarynordoesitmeanthepersonisexpected to recovertoapointwheredisability-relatedsupportisonlongerrequired.InOccupational Therapy practice itiscustomworkwithparticipantswho will continue engagingin therapyformanyyears nott because theirconditionisepected toreolvebutbecause intervention assiststhemtoo:

• maintain function,
• reducedeterioration,redacted support emotional regulationimprovesafetyprevent escalationmaintain participation or reducelong-term decline.For example an autistic child maycontinueengaging in OccupationalTherapy psychology ora speechtherapyythroughoutchildhoodandolescence The purposeofthattherapy is often not tocure autism Rather theraphy maysuppoiteotionalregulation sensory processingparticipationsafetysocialunderstandingandindependence over time. Theparticipantmaystillhavelifelondisabilitandy ongoing support needsdespite engage ninthetryformany years.Similarly a participant with psychosocial disability macontinuingpsychology medicationmanagement and allied health interventio ndefinitely Theirpresentationmymay fluctuateovertimeandperiodsofstabil my onlyoccurbecausesubstantial treatmentandsuppportsystemsarealready inplace Ongoingtreatmentdoesnotmeanthe psycchosocialdisabilityistemporary In manycases the treatmen istwhat prevents significant deteriorationorcrisis Anotherexampleisaparticipantwi th adegenerativenervous condition such as multiple sclerosisorparkinsonsdisease These participantsmaingengageinongoing

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

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 onl yaccess 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 exhauste d appropriate treatment options,due despite only being able to access those interventi ons through the Scheme itself. This concern becomes particularly significant for participants experiencing:financial disadvantageregional or rural workforce shortageslong public waitliststrau ma historiesmedication side effectscultural barriersor limited access to specialist services.For example,I work with participants in regional areas wh o may wait many months or yearsto access psychiatry,p sychology or specialist medical service s.Others simply cannotafford private interven tion outside t he ND IS.Som e particip ants m ay al so decline particulart reatment pathways becauseof previous trauma,adverse si de effec ts ora lacko f clinicallymeaningful benefit.These realities do n ot make th edisability any less permanent.I am concernedthatthe proposed approach risks creatinga systemwherepermanenc ebecomesincreasingly difficultto establish ,particularlyforparticipantswith: autism,

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

Submission 1749

• psychosocial disability,
• fluctuating conditions,
• acquired brain injury,
• chronic illness, or complex behavioural presentations. The risk may exist such as: is financially unsustainable, clinically inappropriate, poorly evidenced, inaccessible, o unlikely result in meaningful functional improvement,simply demonstrating all “appropriate treatments” have been exhausted.In practice,many disabilities always need continuous management and care.The existence does not mean temporary disablement.I am also concerned about unintentionally penalizing participants actively engaging with therapies and rehabilitative services.Participants who proactively maintain function through active engagement shouldn’t face disadvantages compared those unable access any service.From clinical perspective,presence doesn’t solely indicate permanency but considers likelihood of significant change,long-term nature,the participant’s lived experience,intervention sustainability,and ongoing supports despite treatment.My view: legislation should clearly recognize that many permanent disabilities still require continued therapy,rehabilitation.Ongoing support must be accessible regardless purpose is maintenance,prevention,effective regulation or slowing deterioration rather than cure.

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

Submission 1749

Area of Concern - Tightening Reasonable and Necessary

I am deeply concerned that several proposed amendments within the Bill significantly narrows 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“ofthe supportneed Fromaclinicalperspectivethisfundamentallymisunderstandshowdisabilitypresentsin real-world environments Disablityrelatedsupportneedsrarelyaarisefromimpairmientalone Inpractice,support needsemergethroughinteractionbetween:
  • Impairment environment housing transport accessibility fatigue sensory processing trauma communication barriers behavioural regulation , anda vailabilityo fsuppo ts.

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

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, socialinteractionandemotionaldysregulationthattheyareunabletosafelycompletetheactivitywithoutsupport.Ifthenvironmentandcontextualfactorsareintentionallystrippedawayfromconsideration,t hereisrisk that thparticipant’ssupporthneedsmayno longerbe recognised as directly disability-related.Similarly,a participantwithpsychosocialdisabilitymayrequire suppor ttoattendappointments,m anage shopp ingorengagewit h them comm unitybecause anxiety ,paranoia,trau ma responsesorem otional d ys regul ation significantly impair participation.Thesupport needs are real andrehability-relat ed,even if they ar e influencedby environmentalan dinterpersonal factors.Anotherexample isparticipantsrequiringSpecialistDisabilityAccommodationorhome modifications.Oftenthesuppon needdoesnotarisepurel y fromt he impairmentitself,b ut fr omthead tionbetweenimpair mentandan inaccessibleunsafe environment.Aparticipant with mobilityim pair m entmaybe abletomobil ise shortdistancesindoorsbut be unabletot safelyaccesstheirbathroom,negotiatestairs orevacuate duringane mergencyw ithi n their current home environmen .Theproposedwordingrisks oversimplifyingthesesituations anddisconnectingsabilit yfr omm theenvironmentsinwhichpeopleactuallylive.I am also concerned aboutthe strengthened “value for money” provisions,particularlytheparticularly increasedemphasisonlower-cost“comparablesupports” butwithe removalof“sameoutcome”.Inpractice,supporths not truly comparable simply becausetheyarecheaper or appear superficially similar. Occupational Therapy recommendations a re based on:

• safety, -functional participa t ion -sustainability, prevention

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

Submission 1749

• 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,and/or long-term functional sustainability.Similarly,reducing support worker hours might initially reduce plan expenditure yet significantly increase:family burnout,behavioural escalation,mental health deterioration,social isolation,safeguarding risk,hospitalisationor crisis-driven intervention.I am concerned that 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 generalisable evidence above participant-specific evidence lived experience.This creates significant concerns participants with:rare conditionshighly individualised support needs.

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

Submission 1749

• autism,

pyschosocial 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” recommend a highly individualized sensory strategy environmental modification or assistive technology solution based detailed functiona lassessment observed partici pantoutcomes The intervention significantly reduce distress improve participation redu ce escalation that individ ualparticipant despite limited largescale publis hed research evidenc e specific exactintervention Similarly man ydisabilitysupports are designed improvecapacity measurable way Their purpose instead maintainfunctionreducedeclineimprovesafetysupportemotionalregulationpreserveparticipationor preventfuture deterioration I am concerned proposed hierarchy risks reducing weighting given: * ticipantspecific clinicalreasoning,*lived experience,and observable functional outcomes Finally deeplyconcern regarding strengthening assumptions surrounding informal suppor ts parental responsibility Parents children with disabilit often perform same broad categories tasks other parents However intensity duration complexity those may vastly different Forexample many families provide:constant supervision,

• National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
• Submission 1749 •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 describing how they prevent harm Another family may sleep shifts because their child requires constant overnight monitoring due to seizures absconding or behaviour concerns While these supports broadly fall under categories such as: supervision , emotion supportor behavioral support but intensity cumulative burden extends far what would typically be expected typical parenting roles .I’m concerned about wording focuses heavily on type provided while failing adequately consider: •intensity frequency sustainability emotion burden sleep disruption workforce participation impacts long-term functioning Reducing formal does not eliminate disability-related need In many cases it simply transferring that onto families already operating beyond capacity Taken together proposed amendments risk creating significantly narrower interpretation of within NDIs I am this result in :

• National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
• 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 Area from a clinical perspective, disability support decision-making must continue recognising complexity real-world functioning environmental interaction & individualised need Oversimplifying into narrow legislative definitions risks fundamentally misunderstanding realities living with disability providing related care.

Funding Cuts Pricing Powers Ministerial Powers

• reduce by specified percentages;
• impose caps or limits categories supported;
• apply restrictions groups participants;
• & create benchmark-style arrangements based types cohorts.

• 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 anothermayrequire substantial daily assistance tom anage routines regulate emotions maintain safety participateincommunity environments.Funding caps orbenchmarkedsupportmodelsrisk flattening these differences creating systemswhereparticipantsarefundedaccordingto generalisedassumptionsratherthanactual functional need.Similarly part icipants with psychosocialdisabilitymaybeexperiencelfluctuatingsupportneeds thatdonotfitneatlyinto standardized funding categories.Someparticipanstomay functionrelatively independently during periodsof stability while requiring significant supportduring periodsofdeterioration trauma activation or mental health decline.Benchmarksyle funding models a poorly equipped to respond this complexity.I am also deeply concerned by proposed powers relating pricing controlspricing determinations within disability market.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 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 \nworkforce. Occupational Therapy service delivery within the NDIS involves substantial work that\nextends well beyond face-to-face appointments. Clinicians regularly undertake:

• complex report writing,
• risk assessment, 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 shortagesalready significantly impact access to allied health services If pricing structures becomeincreasingly restrictive Thereissubstantial riskthata experienced cliniciansmay leave thedisability sector entirelyor reducethe complexit yof participants theyare willingora bleto support.Inpractice thism aydisproportionatelyimpact:participantswithcom plexsupportneedsparticipan tsinregionalormot remareas part icipantsrequiringintensivereportwritingoradvocacy,and particip ants wit hbehavioural psychosocialorsa fegu ardingcomp lexity.

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

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,
• community participation,* assistive technology,or preventative. 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 but contribute social isolation** mental health deterioration**** crisis presentation***** hospital admission****** housing instability******* increased interaction emergency justice systems*. Similarly, reducing therapy supports for child autism may early intervention emotional regulation sensory regulation family capacity building potentially resulting greater long term dependence and increased breakdown* Another major concern is that proposed powers appear creating distance between individual functional assessment final funding outcomes A participant still demonstrate clear need yet policy settings pricing determination ultimately limit what can actually be funded This represents significant philosophical shift within scheme.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 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 capsor pricing structures through Rules or determinations creates significant uncertainty for:participants,familiesprovidersand the broader disability workforce.From a clinical perspective, disability support should not be viewed solely through a shortterm financial lens. Many supports that appear costly upfront ultimately reducethospitalisationfamily breakdownsafeguarding concernshomelessnesscarer burnoutand long-term dependence on crisis systems.Reducing funding does not reduce disability-related need.In many cases it simply transfers cost and burden onto:

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

Submission 1749

• 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 awayfromwhole-of-person assessment and toward increasingly narrow, fragmented anda impairment-specific interpretations of disability and support need.In Occupational Therapy practice, people are not assessed as isolated diagnoses orindividual impairments.We assess how the person functions as a whole within their actuallife circumstances.This includes understanding how:

• multiple impairments, • psychosocial factors, • trauma, • sensory processing, • fatigue, • communication difficulties, • behavioural regulation, • environmental accessibility, housingtransportrelationships,andsupport systemsinteracttogetherinfluence participation,safetyandindependence.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1749

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 offatigue,sensory overload,electromagnetic dysregulation,trauma responses,cognitive overloadand 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 anxiety that they are unable to safely access the community without support The supportneed does not arise solelyfromone isolatedimpairment It arisesfrotheinteractionbetweentheparticipant’sdisabilitysdndthedemandsofthenvironmentaroundthem.Similarly aparticipantwithpsychosocialdisabletyidintellectual disablemayrequire supportbecausecumulativeinteractions between emotional regulation difficulties cognitive limitations trauma history ndenvironmental stressorscreates substantial safety

National Disability Insurance Scheme Amendment Bill

Submission: Submission-1749

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 due-to-the-interaction-between-impairment-and-inaccessible-environments. A-participant-with-significant-vision- impaired-may require mobility equipment-or-support to safely-access-the-community-not-simply-because-of-the-imperfection-itself-but-because-public-transit-systems-road-crossings-unfamiliar-environments-and-navigation-demands-create-substantial-participation-barriers.Similarly-a-participant-with-mobility-impaired-may technically-beabletoambulateshortdistancesindoors-yetbeunabletosafely-managetheirhomeenvironmentbecauseofstairsbathroomaccessissuesunevensurfacesoremergency-evacuation-concerns.In-practice-Occupational-Therapists-frequently identify thatsupport-needs-arise-throughtheinteractionbetween: • impairment, • environment , task demands risk andparticipationsexpectation. This-is-consistentwithcontemporarydisabilityframeworksincludingthelInternationalClassificationOfFunctioningDisabilityHealth(ICF)whichrecognisesthat-disabilityoccursthroughtheadinteractions between-aperson’shealthconditionandcontextual factors-rather-than-existingpurewithin-individual.I-amconcernced-theproposedlegislative-direction-risksshiftingthenDISIS-towardanarrower biomedicalmodelofdisabilitywheresupportsareincreasinglyassessed throughisolatedimpairmentcategoriesratherthanwhole-personfunctioning. This-creates-significantriskforparticipantswhoseneedsdonotfitneat within:

• single diagnoses, • standardisedimperfection categories or simplified assessment frameworks Italso risksadvantaging participants whose disability-related support needs are heavily influenced by:

• trauma,
• housing stability
• psychosocial complexity sensory processing environmental accessibility cumulative functional burden. From a clinical perspective ,whole -of -person assessment essential for safe accurate understanding Disability related Support need .Without consideration broader context factors influencing Participation function there significant Risk that: •support needs underestimated risk Factors missed Preventative Supports reduced participants more independent everyday Life.I also concerned increasingly narrow assessment approaches encourage fragmented decision making where supports are assessed Isolation rather than considering Participant’s overall functioning sustainability long term wellbeing.For example Reducing support worker hours appears reasonable isolated Carer Burnout Behavioural Escalation Housing Instability Community Participation Fatigue Or Mental Health Deterioration.However When Participant assesses Whole Person becomes clear reducing One support Creates Substantial Increased Risk Across Multiple Areas Of Life.In My View The ndis Must Continue Recognise That Disabilty Complex Contextual Highly IndividualizedAssessment Processes Should Preserve WholeOfPerson Clinical

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

Submission 1749

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, ementhal 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.

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

Submission 1749

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 inhospitalisation,homlessness,safeguarding concernsmental health deteriorationschool disengagementfamily collapseor 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 whosedeteriorationisgradualfluctuatingdifficultto objectively measureor heavily influenced by contextual factors.Many disabilities do not deterioratein neatlinear oreasily measurable ways.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1749

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 behavioral 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,and 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,a 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.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1749

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.Ann 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.

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

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 increasinglyreactive, restrictive and crisis-driven, ultimately shifting costs and burdento:families,humanity systems,emergency services,housing systems,and informal supportsratherthan genuinelyreducingsdisabilityrelatedneed.

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

Submission 1749

Conclusion

The cumulative effect of these reforms risks fundamentally changing the nature of the NDIS. While sustainability of the Scheme is important, sustainability cannot be achieved simply going narrow eligibility restricting access reducing support flexibility Poorly supported disability does not disappear Instead it re-emerges through:

• hospital systems,
• crisis services, homlessness safeguarding concerns family breakdownschool disengage menal health deterioratiorand increased long term socia econo cost I respectfully urge the Committee to carefully consider the real world implications othese proposed amendments nd to ensur that the NDIS rema grounde individua assessmen contextu understandin disabilities participan prevenlong ter sustaiability peopel wih diabiliti an thie famili