Submission 2071

Submission 2071

Use of automation, algorithms and standardised tools

I am concerned about the proposed expansion of automated systems, algorithms and standardised tools in decision-making processes. While standardisation may improve administrative efficiency, disability support planning cannot safely or appropriately rely on automated or overly simplified systems. Children with developmental disabilities often have highly individual presentations that do not fit neatly within standardised criteria. There is significant risk that automated decision-making could: - overlook nuanced clinical information - underestimate fluctuating or emerging needs - disadvantage children with complex or rare conditions - reduce opportunities for clinical advocacy - create unfair or inconsistent outcomes. Human clinical judgement and professional oversight must remain central to all eligibility and planning decisions. Recent concerns regarding aged care assessment systems demonstrate the risks of relying too heavily on standardised tools and insufficiently individualised assessments. It is concerning that a similar approach may now be expanded within the NDIS.

Ministerial powers, automation and system-wide funding reductions

I am concerned about the expansion of Ministerial powers to limit or reduce categories of supports at a system-wide level. Disability support needs are highly individual. Broad funding reductions or restrictions risk undermining the core principles of the NDIS by prioritising cost containment over participant need and evidence- based care. As a paediatric physiotherapist, I have concerns that system-level funding decisions may disproportionately impact children requiring therapy supports, early intervention and capacity-building services. Funding decisions should remain: - transparent - evidence-based - independently reviewed - responsive to individual participant needs rather than broad administrative targets. Families and clinicians need confidence that decisions affecting essential supports are made fairly and with appropriate accountability.

Risk of narrowing access to the Scheme

Although the Bill proposes moving away from diagnosis-based access, I am concerned the practical effect may be a narrowing of eligibility criteria and reduced access to supports. This is particularly concerning for: children aged 0-8 requiring early intervention children with developmental delay who have not yet received a diagnosis. I have many children who come onto the scheme and receive vital earlier intervention that they otherwise wouldn’t have been able to afford to later have a diagnosis for cerebral palsy . Missing this opportunity for early intervention would increase their need for support in the future for example due to deformity and lack of ability to gain skills like walking. participants with fluctuating or degenerative conditions participants with psychosocial disability individuals whose needs are difficult to capture through standardised assessments.

Submission 2071

Submission 2071

I am concerned about the increasing concentration of decision-making powers and the potential reduction in transparency surrounding pricing and funding decisions. Sustainable pricing is essential to maintaining access to experienced and appropriately qualified allied health professionals, including paediatric physiotherapists. If pricing structures fail to reflect: -increasing complexity of care -travel requirements -non-face-to-face work -documentation and reporting requirements -workforce shortages, there is significant risk of: -reduced service availability -longer waitlists -workforce attrition -poorer access for rural and complex participants. Independent, evidence-based decision-making processes are essential to maintaining quality and trust within the Scheme.

Recommendations

I respectfully urge the Committee to consider the following recommendations: 1. Ensure functional capacity assessments prioritise comprehensive clinical assessment and professional judgement. 2. Limit reliance on automated decision-making and ensure appropriate human oversight in all eligibility and planning processes. 3. Ensure support decisions remain individualised and not driven by broad system-level funding restrictions. 4. Protect access to early intervention and ongoing therapy supports for children with disability and developmental delay. 5. Ensure no participant loses access to supports before alternative systems are fully operational and accessible. 6. Maintain flexibility for reassessment and review when participant needs change. 7. Preserve capacity-building and participation supports as essential components of disability inclusion and long-term outcomes. 8. Ensure pricing and governance decisions are transparent, evidence-based and support workforce sustainability.

I want Parliament to change the Bill to ensure that there are no reductions to participants access to occupational therapy, capacity building supports or community participation supports

The NDIS has transformed the lives of many children and families I work with. While reform is necessary, it is critical that sustainability measures do not come at the expense of early intervention, individualised care and meaningful participation for people with disability.

Thank you for considering this submission. Kind regards,

Submission 2071

Mondays, Tuesdays and Thursdays

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