Submission 1931
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 paediatrics and 40 as an OT) working extensively with children and families across clinic, home, preschool, daycare, school, and telehealth environments, I strongly believe that complex functional assessments must remain within the scope of appropriately trained allied health professionals with discipline-specific expertise.
Children accessing the NDIS often present with highly complex developmental, sensory, behavioural, emotional, motor, communication, and functional participation needs. These difficulties are not always immediately visible in a brief or standardised generic assessment process. Meaningful assessment requires clinical reasoning, observation across contexts, understanding of child development, and interpretation of how functional impairments impact daily participation over time.
My concerns regarding the proposed reforms include the following:
- Risk of Inaccurate Functional Assessment
Generic assessments completed by non–allied health practitioners risk oversimplifying complex developmental presentations.
Many children present with:
- sensory processing difficulties,
- emotional regulation challenges,
- motor planning deficits,
- fine and gross motor impairments,
- executive functioning difficulties,
- social participation barriers,
- trauma-related behaviours,
- autism-related differences,
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- 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,
- neurological and sensory processing,
- functional capacity assessment,
- environmental analysis,
- participation-based assessment,
- adaptive functioning,
- motor skill development,
- assistive technology,
- emotional regulation,
- play-based assessment,
- school readiness and participation.
This expertise cannot be replaced by a generic screening process.
Assessment quality relies heavily on:
- clinical observation,
- interpretation of subtle developmental indicators,
- integration of caregiver and educator reports,
- standardised assessment interpretation,
- understanding functional participation over time.
Submission 1931
Generic assessments may fail to recognise the nuanced presentations commonly seen in paediatric disability.
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 Outcomes
Early 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.
Submission 1931
High-quality allied health assessment is not an unnecessary expense; it is a preventative investment that reduces future disability burden and supports long-term independence and participation.
Potential Increase in Administrative Burden and Appeals
If assessments are conducted by individuals without adequate allied health expertise, there is a risk of:
- increased reassessments,
- increased review requests,
- increased appeals,
- delays in accessing support,
- duplication of assessment processes,
- increased system inefficiency.
Families already experience significant stress navigating the NDIS system. Reforms should reduce barriers rather than create additional confusion and inconsistency.
Impact on Families and Vulnerable Children
Families frequently report feeling overwhelmed and unheard within the current system. Introducing generic assessments may further reduce family confidence that their child’s needs are being accurately understood.
Parents often rely on allied health clinicians because:
- we observe children longitudinally,
- we understand developmental progression,
- we collaborate with schools and educators,
- we identify subtle functional concerns,
- we provide practical participation-based recommendations.
Removing or reducing the role of allied health expertise may proportionally disadvantage vulnerable children whose needs are complex, subtle, or variable.
Recommendations
I respectfully recommend that the NDIS:
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- 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, and sustainability within the NDIS, these goals must not come at the expense of accurate, clinically informed assessment and individualised participant support.
Children with disability deserve assessment processes that recognise the complexity of development and functioning. Allied health professionals play a critical role in identifying needs early, supporting participation, and improving long-term outcomes for children and families.
I strongly encourage the NDIS to ensure that any reform process continues to prioritise clinical expertise, individualised assessment, and participant-centred practice.
Sincerely,
Occupational Therapist