Submission 2017
To the Senate Community Affairs Legislation Committee, Re: Submission regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Please accept the below submission regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.
I am an Occupational Therapist with a background in psychosocial rehabilitation, complex disability support, and community-based practice, working with people experiencing severe psychiatric illness, psychosocial disability, physical disability, neurodivergence, trauma-related conditions, chronic illness, ageing, and complex functional impairment.
Across my career, I have worked extensively with people whose disabilities are often not immediately visible within standardised systems, despite profoundly impacting their ability to sustain employment, housing, self-management, relationships, community participation, and long-term independence. Many of the people I support live very close to the surface vulnerability of losing economic participation, stable housing, health, or community connection, despite appearing superficially “functional” .
I am deeply concerned that the proposed reforms move disability support further toward standardised, administrative, and financially driven systems that do not adequately reflect the complexity of real-world functioning, particularly for people with fluctuating, invisible, or multi-layered disabilities.
This is particularly relevant to the Bill’s proposed increased use of standardised tools and automation in decision-making, restrictions on reassessment and review, and reductions to capacity building and participation supports.
Occupational Therapy is fundamentally concerned with functionality across whole-of-life domains. Our role is not simply to identify impairment, but to understand how a person actually lives, functions, copes, participates, and sustains themselves within contemporary life and systems. This includes understanding the interaction between disability, psychiatric illness, trauma, ageing, cognition, executive functioning, housing, employment, relationships, financial stress, social exclusion, physical health, and environmental demands.
Much of our work involves designing practical, sustainable systems around a person’s actual functional capacity - not an idealised version of independence. This requires significant clinical reasoning, advocacy, research, education, problem-solving, environmental modification, team coordination, and capacity building to create supports that are realistic, sustainable, and responsive to changing life circumstances.
For example, in a recent Functional Capacity Assessment, I worked with a woman with Cerebral Palsy, significant visual impairment, chronic pain, fatigue, gastrointestinal conditions, and increasing age-related functional decline, who was simultaneously attempting to maintain employment, independent housing, caregiving responsibilities,
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and community participation. A standardised assessment may identify that she can technically shower, dress, work, travel independently, and manage her finances. However, Occupational Therapy assessment identified that these activities were occurring at enormous physical and cognitive cost, with cumulative fatigue, overuse injuries, falls risk, employment fragility, and significant risk of long-term functional decline.
The assessment process required analysis not only of physical impairment, but of energy expenditure, sustainability of functioning over time, accessibility of environments, transport limitations, cognitive load, housing stability, employment demands, social isolation, sleep disruption, ageing, and the interaction between multiple health conditions. Recommendations were therefore designed not simply around “care needs†, but around preserving long-term social and economic participation, reducing future system burden, preventing avoidable deterioration, and maintaining sustainable independence.
Capacity building and participation supports should not be understood as optional or secondary supports within the NDIS. In my clinical experience, they are often the very supports that prevent significant downstream deterioration, both for participants and for broader systems.
When people with complex disability do not receive appropriate therapeutic intervention, practical supports, environmental modifications, transport assistance, community participation supports, and ongoing capacity building, the consequences are rarely neutral. Instead, we frequently see escalating functional decline, worsening psychiatric symptoms, increased social withdrawal and isolation, loss of employment, housing instability and homelessness, increased reliance on government pensions, carer burnout, family system breakdown, addiction and maladaptive coping strategies, repeated presentations to emergency departments and acute mental health systems, and, at times, suicidality.
Many of the people I work with are already operating at the edge of their functional capacity. Their independence is often maintained through carefully developed systems, routines, supports, and environmental adaptations that allow them to sustain employment, manage daily living, remain connected to community, and participate meaningfully in society. Without ongoing support, these systems frequently collapse, resulting in significantly higher long-term human and economic costs.
Importantly, these outcomes are often not immediate or obvious within standardised systems. A participant may appear superficially “functional†while privately exhausting all available physical, emotional, cognitive, and financial resources simply to maintain basic stability. By the time deterioration becomes visible to acute systems, tervention is often occurring far later, at significantly greater personal and economic cost.
This level of functional reasoning cannot be meaningfully replicated through narrow assessment tools, automated decision-making, or broad funding categories. Functional
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Capacity is dynamic, contextual, and deeply influenced by a person’s environment, support systems, cumulative life demands, and fluctuating health.
Without these considerations, we risk losing the very best and original aspiration of the NDIS - the expectation that people with disability can live ordinary lives characterised by social and economic participation, choice and control, dignity, and citizenship. Occupational Therapists play a critical role in translating this aspiration into real-world, sustainable functioning, and without this level of functional understanding and capacity building support, these outcomes become significantly less achievable for many of the people the Scheme was designed to support.
I strongly urge Parliament to ensure that functional capacity assessments remain clinician-led and grounded in real-world functional understanding; that reassessment pathways remain flexible for people with fluctuating needs; and that capacity building and participation supports are protected as essential foundations for sustainable independence, economic participation, and meaningful community life.
Kind regards,
Catherine Phan
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Catherine Phan
Occupational Therapist | Co - Founder Phone: Address: Website: www.gyft.online
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