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

I am a senior OT and director of Our Children’s Occupational Therapy, a family-run mobile occupational therapy service supporting children, teens and families across the Gold Coast.

• We provide our therapy within children’s everyday environments including homes, schools,, kindergartens and community settings.- as-a-mobile-community-based-service,-we-seefirsthand-how-disability-participation-and-wellbeing-are-shaped-by-environmental-factors-family-capacity-school-systems-financial-stress-transport-access-and-social-supports-we- arereally-concerned-that-many-of-the-proposed-changes-within-the-National-DisabilityInsurance-Scheme-Amendment-(SecuringtheNDISforFutureGenerations)-Bill-2026fail-torecognise-these-realities.

*We acknowledge the importance of ensuring long-term sustainability of the NDIS.*However,sustainability-cannot-cometathe-expenseofchildrenlosingaccess to essential supports,families experiencing further crisis-or providers being unableto continue delivering safeand effective services-tovulnerable members -ofthecommunity.\nOur practice stronglysupports many concerns raisedwithinOccupationalTherapySocietyHiddenInvisible Disability (OTSi Discussion Paper) wishes highlight several issues will significantly impact childrenfamilies we support Concerns Regarding Functional Capacity Assessments One most significant concern relates proposed definition functional capacity which assesses what person can do without assistance, supports environmental modifications or contextual considerations This approach does not reflect lived reality our children families supported Occupational therapy fundamentally grounded understanding how child functions within their real-world environments Achild’s participation cannot be separated from sensory emotional social educational and relational contexts they navigate every day Many Children present differently across settings over time Child may appear capable during brief assessment but experience overwhelming dysregulation exhaustion anxietyfunctional shutdown at school home Snapshot assessments risk underestimating support needs particularly neurodivergent children who mask difficulties formal interactions Children low moderate support one week high substantial other I am seeing this with Autistic teensunable cope demandshighschool environment schools ineffective supporting leading significantdysregulation distress unfortunately suspensions for child As mobile occupational therapists often observe challenges would never visible clinic-based standardised setting We support in real moments ofdistress,school refusal-emotional-dysregulation unsafebehaviours-sensory overload-executive functioning breakdown daily living complex functional issues that reductionist impairment based models -A-child-or-disabled-person-is disabled context must assessed effectively We are deeply concerned reforms diminish importance treating therapist evidence professional clinical judgement favour administrative potentially automated assessment systems.

National Disability Insurance Scheme Amendment Submission

Concerns Regarding Executive Functioning and Self-Management

The proposed reforms appear to narrow the understanding of disability-related functional capacity by focusing heavily on basic care activities while inadequately recognising\nexecutive functioning difficulties, social skill needs, motor skill development and sensory
processing. Many of the children and adolescents we support experience significant impairments in planning, organisation, emotional regulation, task initiation, self-management, sequencing,flexibility,effective emotion regulation strategies and coping with change.These challenges profoundly affectparticipationin education relationshipsself-carecommunity accessandfamily life.Executivefunctioningdifficultiesareofteninvisiblebuthighlydisabling.Familiesfrequentlyexperience severe burnoutwhileattemptingtocoordinateappointments,school supports,routinesemotionalregulationstrategiesandedailylivingdemandsfortheirchildren.Thesesupportneedsarerealongoingintensive.Theycannotbeaccuratelycapturedthrough simplifiedorstandardisedassessmenttools.

ConcernsRegardingTightenedPermanenceRequirementsWe are extremely concerned aboutthe propoosedrequirementthat participants undertake“all appropriate treatment”before disabilitycan be considered permanent.Manyofthefamilyessuppor t already facesignificantbarriersaccessinghealthcareandtherapy servicesincluding:\n• workforce shortageswaitlists • financial stress impacting families capacity for providing informalsupport or accesstherapyoutside thenDISIS.Increasedcareneds would redusethe workingcapacity offormalsupportswithflowinaffectsimpactingwider communityworkforceandsocialandeconomiccontributiontosociety.\n• transport limitations \n• school attendance difficulties It is also deeply concerning that a child’s eligibilityfordisability support could depend onaccessto servicesthatare financiallyorgographically inaccessible.We arerecerned thatherapyitse may increasinglyb e framed asa prerequisite to proveeligibilityrather than an essential ongoing suppo r requiredto maintainfunctionparticipation andwellbeing.For many childrenoccupational therapyisanotabout “ curing ”disability.Itisa bout supporting emotional safetyindependence participationregulationskill developmentfamily functioninglongterm wellbeing.Therapyaften preventsdeteriorationschool

disengagementmental health crises family breakdown

Concerns Regarding Funding Reductionsand Reduced Access To TherapyOur practice issdeeply concerneda boudproposedpowersallowing broad funding reductions across participant groups.

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

Submission 2080

Children requiring early intervention and capacity-building supports are particularly vulnerable to funding cuts. Early therapeutic support often prevents significantly higher long-term costs associated with school refusal, mental health admissions, family breakdown, crisis services and long-term support dependence. Reducing therapy supports may create short-term financial savings while significantly increasing long-term social and economic costs. Families already report high levels of fear, uncertainty and distress regarding these proposed reforms. Parents are increasingly concerned about losing access to therapies that their children rely upon to participate safely in school, develop independence, regulate emotions and engage in community life. As a small family-run practice, we are also concerned about the impact of pricing restrictions and reduced funding on workforce sustainability within community-based paediatric occupational therapy. Mobile therapy services involve significant demands including travel, collaboration with schools and support teams, report writing, care coordination and family communication. These elements are essential to safe and effective therapy outcomes but are increasingly difficult to sustain under ongoing funding pressures.

Concerns Regarding Automated Decision-Making

We strongly oppose the use of fully automated systems for eligibility determination, functional assessment or funding allocation. Disability is nuanced, relational and contextual. Children’s functioning fluctuates significantly depending on sensory environments, emotional safety, trauma history, communication supports, family circumstances and educational settings. No automated or algorithmic system can adequately interpret the complexity of human functioning, family stress, environmental barriers or neurodivergent presentation. The children and families we support deserve decisions made with compassion, professional judgement, procedural fairness and genuine understanding of their lived experiences.

Concerns Regarding Increased Reliance on Informal Supports

We are deeply concerned that many proposed reforms appear to rely more heavily on unpaid family care. Parents and caregivers of disabled children are already under enormous pressure. Many families reduce work hours, leave employment entirely, manage ongoing advocacy demands and experience chronic emotional, physical and financial strain. In our work, we regularly see the impact of caregiver burnout, mental health deterioration, relationship breakdown and financial stress associated with inadequate formal supports. The NDIS was designed to reduce these inequities, not increase them, enabling choice and control for participants and their families, accessing individualised and high quality care. We are deeply concerned that NDIS participants, likely children, will be removed from the scheme with this new legislation, without effective and accessible systems actually in place where the children and families deserve to access the high-quality experienced OTS from private sector for long-term support.

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

Submission 2080

Recommendations

As an experienced OT working with children for over ten years, I would like to make these recommendations:

• Delay implementation pending meaningful consultation.
• Retain environmental factors during assessments;
• Protect treating therapist’s role;
• Prohibit fully automated decisions on eligibility or funding;
• Ensure access remains protected,
• Remove broad Ministerial powers reducing participant groups’ funds;
• Establish foundational community systems before restricting NDIsS access;
• Protect participants’ right not losing disability supports without treatment refusal ; Strengthen safeguards around reassessment processes.