Submission Regarding Proposed NDIS Reforms and the Use of

Generic Assessments Conducted by Non-Allied Health Practitioners

Submitted by: Occupational Therapist Paediatric Occupational Therapist, Australia

I am writing to express my significant concerns regarding proposed NDIS reforms involving the increased use of generic assessments completed by individuals who are not qualified allied health practitioners.

As a paediatric occupational therapist (OT) (for over 32 years in paediatri csand40 as an OT ) working extensivelywithchildrenfamiliesacross clinic, home,preschool ,daycare,school,and telehealth environments,I strongly believe thatcomplex functionalassessments must remain withinthe scopeof appropriately trainedallied he alth professionals wit discipline-specific expertise . Children accessing then DIS often present with highly complex developmental sensory behavioural emotionalmotorcommunication anda ndfunctionalparticipation needs.Thesedifficultiesarenot always immediatelyvisibleinabrieforstandardisedgeneric assessment process.Meaningfulassessmentrequiresclinicalreason ingobservation across contextsunderstanding child developmenta n dinterpretation o fhowfunc tionalimpairment simpact daily participationover time. Myconcernsregarding th eproposedreformsincludethefollowing:

Risk of Inaccurate Functional Assessment Generic assessm ents completedby non-alliedhealhpractitionersrisk oversimplifyingcom plexdevelopmentalpresentations Many childrenp resentwit h: - sens oryprocessingdiffic ulti es- em otionalegulationchallenges motorplanningdeficits fine andgrossmotori mpairmen ts executivefunctioningdif ficultie ssocial particip at ionbarriers trauma-relatedbehaviours autismrelateddifferences

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

Submission 1931

• intellectual disability,
• developmental delay,
• feeding and self-care difficulties. These areas require specialised clinical interpretation. Functional impairments may fluctuate across environments and are often masked in unfamiliar settings or short assessment interactions. Without allied health training, there is a substantial risk that:

• developmental needs may be underestimated,
• support needs may be inaccurately categorised,
• functional impact may not be fully identified,
• early intervention opportunities may be missed,
• children may lose access to essential supports.

Lack of Discipline-Specific Clinical Expertise

Occupational therapists undertake extensive university and clinical training in:child development,nervological and sensory processing,functional capacity assessment,environental analysis,paticipation-based assessmen,t adaptive functioning,motor skill developement,assistive technology,eotional regulation,play based asessment,school readiness annd participatian.This expertise cannot be replaced by a generic screening process.Assesment quality relies heavily on:clinical observation,intepretation ot subtle devlopmental indicators,integration oof caregiver nd educator reports,stdaridased assessemt intrepretion,understanding funcitonal partipication over time.

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

Submission 1931

Reduced Individualisation of Supports

The NDIS was designed to provide individualised, person-centred support. A generic assessment framework risks:

• creating “one-size-fits-all” recommendations,
• reducing flexibility,
• overlooking environmental and contextual factors,
• limiting participant choice and control,
• reducing the ability to tailor supports to the child’s real-world functioning. Children do not exist in isolation. Their needs vary significantly across:• home.• daycare.• preschool.• school.• community.• social environments.Allied health practitioners are trained to assess participation across these settings and provide practical recommendations that support inclusion and long-term outcomes.

Concerns Regarding Early Childhood OutcomesEarly intervention is critically important in paediatric practice.Failure to identify functional concerns accurately during early childhood may result in:- worsening developmental gaps,- increased behavioural distress,- school participation difficulties,- mental health impacts,- family stress and burnout,- increased long-term support costs.

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

Submission 1931

High-quality allied health assessment is not an unnecessary expense; it is a preventative investment that reduces future disability burden and depends long-term independence and participation.

Potential Increase in Administrative Burden and Appeals

If assessments are conducted by individuals without adequate alliedhealthexpertise thereisariskof:

• increased reassessments,
• increased review requests ,
• increased appeals,
• delaysinaccessingsupport, -duplicationassessmentprocessesandsysteminefficiency .FamiliesalreadyexperiencesignificantstressnavigationgtheNDIS system.Reforms should reduce barriers rather than create additional confusionandinconsistency.

Impact on Families and Vulnerable Children

Familysfrequentlyreportfeelingoverwhelmedunheardwithinthecurrentsystem.Introducinggenericassessmentsmayfurtherreduce familyconfidencethattheirchild’sneedsarebeingaccurately understood.Parents often relyonalliedhealhcliniciansbecause:• we observe children longitudinally, • understand developmental progression, • collaborate with schoolseducators, • identify subtle functional concerns. We provide practical participatibased recommendations.Removingorreducingtherole of alliehd health expertise maydisproportionatelvadantage vulnerablechildrenwhose needs ar complexsubtle or variable.

Recommendations

I respectfully recommend the NDIS:

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

Submission 1931

• Retain allied health practitioners as central contributors to functional assessment processes.
• Ensure paediatric assessments are completed or reviewed by appropriately qualified clinicians with expertise in child development and disability.
• Recognise the importance of discipline-specific assessment in determining functional capacity and support needs.
• Avoid over-reliance on generic assessment models that may not adequately capture complex paediatric presentations.
• Continue to value evidence-based allied health reports and longitudinal clinical observations within planning processes.
• Engage meaningfully with frontline allied health clinicians during reform implementation.

Conclusion While I acknowledge the need for reform, consistency,

sustainability\ndeserve accurate clinically informed assessmenand individualised participant support. Children with disabilityparticipation long-term outcomes childrenfamilies. I strongly encouragethe NDIS continueclinical expertiseprioritisingindividualisedassessmentparticipant centricpractice. Sincerely, occupational therapist