Submission Regarding the Proposed NDIS Bill

My Background

I am an AuDHD Occupational Therapist with 10 years of experience working across disability and community health settings. I have been involved with the NDIS since its initial trial stages while living in Mackay in 2019. I write this submission not only as a clinician, but also as a neurodivergent person with lived experience of disability and chronic health conditions.

I am deeply concerned by the proposed Bill, the direction of the reforms, and the way these changes have been communicated to the public. The current rhetoric surrounding disability, autism, pyschosocial disability, and Scheme sustainability has been distressing, stigmatising, and harmful for many disabled Australians and the professionals supporting them.

The NDIS exists because Australians recognised that disabled people deserve dignity, participation, safety, equality, and the opportunity to live meaningful lives within their communities. Any reform to the Scheme should strengthen those principles – not weaken them.

Key Concerns

Cost Shifting Rather Than Genuine Reform

These reforms do not represent genuine cost reduction. They represent cost shifting. Reducing NDIS supports will not eliminate disability support needs. Instead, costs will be transferred onto:

• state health systems;
• hospitals and emergency departments;
• mental health services;
• unpaid family carers;
• homelessness services;
• aged care systems; and -the broader economy through reduced workforce participation and increased crisis presentations.Cuts to supports may appear financially beneficial on paper in the short term, but the long-term socialand economic consequences will be severe.

Reduction in Community Access & Capacity Building Supports

The proposed reduction of community access and capacity building supports is one of my greatestconcerns. Community participation supports are not “luxury” activities. These supports enable people to:• attend medical appointments; •access pharmacies and essential services; •shop for groceries; -participate in education and employment; -maintain social connection; -reduce isolation; -promote quality of life; -participate in everyday activities that many Australians take for granted; live with dignity and autonomy within their communities; enable people to live a“normal life”, which was a foundational intention of the NDIS;

• build skills and independence;and
• preserve mental health and wellbeing. Reducing thesesupports risks increasing isolation,deterioratingmentalhealth,carerburnout,and preventablehealthcomplicationswhile underminingthecorepurposeoftheNDIS Restrictingsupportsrisks pushingdisabledpeoplebacktowardsisolationandexclusion.Itfeels likeareturntooutdatedandharmfulattitudeswheredisabledpeoplerespectedremain hiddenfrom societyrather than supported to participate within it Similarly,reducingaccesstooccupationaltherapyandotherecapacitybuildingtherapies undermines thvery purpose ofthen DIS.Occupationaltherapistsplayacriticalroleinimprovingdependence safetyfunctionalcapacityquality life.These therapiesareoptional extras-they preventative supportsthat reducelongtermcostsbuidl indepenence quality lifet improve overall outcomes Icurrentlysupport aparticipant who was in tears after her occupational therapy supports wer reduced minimal monthly sessions without travel funding with further reductions planned future years plan As mobile therapistour session occurwithinher home environment where work functional daily living skill (executive functions behind) such as cooking,home organisationcomputer skil These directly assist maintain home care children manage significant limitations caused by disabilities are not goals effectively addressed clinic setting Her needs did disappear simply because changed She will miraculously no longer need support or therapy coming years Considering NDIS access dependent having permanent lifelong conditions people need be supported whole lives Over past year achieved meaningful progress positive outcome together deeply concerned impact these cuts have on long term wellbeing independence Functional capacity and support fluctuate over time participant may appear stable at point later experience burnout deterioration crisis due changing demands stressorsreduced restricting based arbitrary funding decisions means may provide when needed This is best practice creates risk falling through cracks reaching crisis Cutting supportswithout appropriate clinical reasoning consultation treating health professionals dangerous People die that exaggeration again cost saving this a cost shifting create significantly greater costsfuture It creating sustainable Australia’s future 3 Misunderstanding Autism Psychosocial Disabilities Fluctuating Capacity Autistic ADHD woman myself feel profoundly let down government current public narrative surrounding autism psychosocial disability Statements suggesting autistic shouldnotbeontheNDIS ignore reality inadequate foundational available elsewhere Additionally terms mildautism highfunctioningautis outdated inaccurate harmful Functionality factors sensory overload

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

Submission 1776

• stress;
• relationships;
• burnout;
• informal supports;
• environmental demands;
• pain; and
• mental health. This is not an exhaustive list. Some days I am able to function effectively as an Occupational Therapist. Other days, due to burnout, chronic pain, executive functioning difficulties, and overwhelm, I may struggle to sequence basic household tasks or remain present in conversation. Functioning is not static and should not be treated as such.Snapshot-style assessments fail to adequately capture fluctuating capacity, masking, executivefunctioning impairments, trauma history, and the cumulative impact of co-occurring disabilitiesand health conditions.

Failure to Consider Holistic & Interconnected Disability Needs & Actual Functional CapacityDiagnoses do not exist in isolation. Disabilities and health conditions interact in complex ways.For example, my hypermobility affects my muscle activation and movement patterns, which impactspelvic function, chronic pain, and my endometriosis symptoms. If only one diagnosis is consideredinisolation, the broader functional impact is missed entirely.The same principle applies across disabilitysupport planning. A narrow impairment-based model doesnot reflect real-world functioning or support needs.Please refer to the All Brains Belong Clinical Guide (2023),which further demonstrates the importanceof holistic healthcare approaches - https://allbrainsbelong.org/clinician-resources

The proposed reforms also significantly narrows the understanding of functionalcapacity.Occupational therapists are specifically trained to assess how individuals’ function within theirenvironments, identify barriers, analyse task demands, determine what supports are required for safe participation.This involves far more than a tick-box assessment For example I currently support: * participant with brain injury whose hearing visionimpairment resulting from thatjury remain unrecognisedwithin his plan leaving him without accessto hearing aids; an * Participant psychosocialdisability who physically unablewalk 10 metreswithout heavily relyingfour-wheel walker yet her physical disabilities continuebeexcluded consideration despite repeated requests several years. These situations not uncommonThe current system already leaves many participants appropriate recognitionor support actualneeds.Narrowing assessments will increase risk people being under- captured:fluctuating device; extensivefunctioning impairments; pyschosocial complexity;

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

Submission 1776

• masking;
• environmental barriers;
• communication differences; or
• nuanced functional limitations. There is a substantial conflict of interest where the same agency responsible for funding decisions is also conducting assessments that directly influence access to funding. Many participants report being “independent” in tasks despite requiring significant prompting, supervision, scaffolding, or informal support. Allied health professionals are trained to identify these nuances through observation, collateral information, and clinical reasoning. delegateswithoutclinicaltrainingarenotequippedtoaccuratelyassessthesecomplexitiesandasaresultpeoplewillnothavetheiractualneedsrecognised.

Excluding Environmental Factors Is Not AppropriateTheproposedchangesare inconsistentwiththeInternationalClassificationofFunctioningDisability

dehalth(ICF),which recognisesthatdisabilityseshapedbyenvironmentalandcontextualfactors.Disabilitydoes notoccurinisolationfrom: housinggeographyfinancessocialsupports culturetrauma; andaaccessibility.For exampleifaparticipantcannot safelymanagestarstairsand theirhomecontains stairs,the environmentdirectlyimpactstheirfunctionalcapacityandsafety.Ignoring environmental factors will no remove therbarriers.Itwillsimplyincrease riskofi njury, derioration,hospitalisation, homelessness,anddeath.This approachisinconsistent withthesize modelodisabilityunderpinningboththenDISAND Australia’sobligationsundertheConventionontherights of PersonsWith Disabilities ,an d the WHO Human Rights Act

Risks Associated With Eligibility Requiring Forced TreatmentTheproposedeligibility requirementsaredeliciousconcerning.Requir ingparticipantsunto undertake“all appropriate treatment”before impairments may be considered permanent fails to account for:poverty; workforce shortages; geographic barriers; inaccessible healthcare systems; rama; c ommunication barriers; i inabilitytotoleratetreatment environments ; and lackofo avaliable specialists.Disabled people must also retain bodily autonomy andreftoreject treat mentwithoutriskin g lossof accesstod is ability supports.

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

Submission 1776

Practically, these proposed requirements fail to reflect the realities many disabled people face. For example, a single mother living in Alice Springs may be told she must pursue additional treatment options in a metropolitan city before her condition can be considered permanent. However, this may be entirely unrealistic. She may be unable to afford travel and accommodation costs, have no informal supports available to care for her children, pets, or household responsibilities, and be unable to take unpaid leave or lose further income due to already limited workforce participation and time required to undertake treatment. It is unreasonable and inequitable to expect a person to access treatment that is geographically, fiscally, financially, or practically inaccessible to them. There is also insufficient clarity regarding how “appropriate treatment” will be determined and by whom.I am concerned that these decisions may ultimately be made by planners or delegates without relevant clinical qualifications or specialist health knowledge.There is significant risk that treatment options could be identified through generic processes or theoretical availability rather than individualised clinical consideration of whether a treatment is genuinely suitable,safe ,accessible,evidence-basedor appropriateforthatparticularindividual.Theproposedframeworkalsofailsaddresswhathappenswhenparticipantscannotrealisticallyaccessrecommendedtreatment,cannottoleratetreatment oran exhausted reasonableoptionswithoutmeaningfulimprovement.Inthesesituations,personsriskbeingexcludedfrombothhealthcareaccesanddisabilitysupportleavingthemwithnowhereelsetoturn 8.Plan Reassessments,Suspensions & Review ProcessesThe proposed reassessmentandsuspensionpowersarehighlyconcerningandriskcausingsignificant harm.Disabled peoplemayexperience:•suddendeterioration;•homelessness;•familyviolence;•lossofcarers;•hospitalisation;orr•periodsof disengagementrelatedtopsychosocial disability Theproposalallowingplansbe suspendedwheretheAgency“cancontacta participantpresents major safeguarding risks for: •Deaf participants;•blind participants;•autistic participants overwhelmed by administrative communication;•people experiencing homelessness and ;•participantsexperiencing mental health crises.No particiants should losssupportswithout:demonstrated accessiblecommunication attempts; -independent safeguarding review; welfare checks where appropriate; consideration of participantsafety; anda-alternativesupporst being in place.

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

Submission 1776

Workforce & Equity Concerns

Differentiated pricing and funding restrictions risk favouring large corporate providers while undermining smaller, community-based providers and sole practitioners. In my experience, larger organisations often experience:

• higher staff turnover;
• poorer communication; inconsistent training; weaker workplace culture;and executive decision-making disconnected from frontline realities.I have personally chosen to leave larger organisations due to these systemic issues and now work within a small private practice team that prioritises clinical integrity, client-centred care, and quality of support over key performance indicators. This change has enabled me to focus on delivering meaningful individualised outcomes for participants rather than being driven by productivity targets or organisational metrics that do not reflect participant complexity or need.These reforms also create serious equity concerns for rural, regional, and remote Australians where workforce shortages already severely limit access to allied health services Capped pricing without adequate consultation risks destabilising an already overstretched allied health workforce reducing service availability even further.

Ministerial Powers & Lack Of OversightI am deeply concerned by the concentration of power proposed within this Bill.The proposed powers appear highly discretionary capable significantly impacting participant rights operating with limited parliamentary scrutiny independent oversightProposed section which permits broad percentage funding reductions financial sustainability reasons without individual reassessment represents major departure foundational principles NDISSupport should be based upon individual assessment needs arbitrary fiscal target

Lack Transparency & Meaningful Co-Design I extremely disappointed though unfortunately surprised lack transparency surrounding these reforms The previous independent assessment failed part inadequate consultation transparent It concerning see similar issues repeated current consultation process felt rushed inaccessible poorly communicated Information emerged gradually through media releases insider discussions changing minister statementsMeaningful co-design requires genuine engagement disabled people families carers frontline clinicians support workers regional communitiesandpeople from diverse cultural socioeconomic backgrounds.

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

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It cannot simply be consultation or “co-design” in name only.

Recommendations

I urge the Committee to reject this Bill in its current form and undertake genuine consultation with disabled people, families, and frontline professionals before proceeding with reforms. While I recognise the NDIS requires reform to remain sustainable, sustainability cannot be achieved through measures that:

• reduce access to essential supports;
• weaken safeguards;
• increase hardship;
• undermine human rights; or
• shift costs onto disabled people, families, and other systems.

I urge the Committee to:

• Delay implementation pending meaningful consultation and impact assessment,
• Remove or substantially limit Ministerial powers to impose broad funding cuts,
• Retain environmental and personal factors within functional capacity assessments,
• Protect the right to refuse treatment without losing Scheme access,
• Strengthen safeguards surrounding plan suspension and participant contact,
• Prohibit fully automated eligibility and planning decisions and consider evidence from health professionals,
• Protect community participation and capacity building supports,
• Require stronger parliamentary oversight for key definitions and funding powers,
• Conduct comprehensive human rights, gender, First Nations, and socioeconomic impact assessments before any changes are implemented, 10. Ensure foundational supports are fully established before restricting NDIS access.

Final Statement

disabled Australians deserve dignity, autonomy, safety, participation, and access to appropriate support.The proposed Bill risks moving the scheme away from those principles toward a system prioritising administrative efficiency over human wellbeing.I urge the committee carefully consider these reforms’ real-world consequences on participants,families,careers,health professionals,and broader communities.Thank you for your consideration,Occupational TherapistMoreton Bay region QLD