NDIA Accountability Project

Speech pathologist objects to restrictions on supports for children with disability

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Submission 2098

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

To Whom It May Concern,

I write as a speech pathologist working closely with children with disability, as well as their families and carers, across a range of settings. I strongly object to several proposed amendments within the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

While I acknowledge the importance of protecting the long-term sustainability of the NDIS, many of these proposed changes risk undermining the original intent of the Scheme and will have serious negative consequences for participants, families, carers, and frontline allied health providers. In particular, these amendments place disproportionate emphasis on cost containment over participant wellbeing, functional outcomes, and equitable access to supports.

Objection to the proposed definition of “functional capacity” (Schedule 1, Part 1, section 9B)

The proposed definition of functional capacity under section 9B is deeply concerning because it requires assessment of a person’s ability to undertake activities “without assistance from other people, assistive technology or modifications” and in a context excluding environmental and personal circumstances.

This approach fundamentally misunderstands disability and contradicts contemporary evidence-based practice and the social model of disability. Functional capacity cannot be accurately measured in isolation from the supports, technologies, communication systems, environments, and relationships that enable participation.

As a speech pathologist, I regularly work with individuals whose communication abilities are significantly enhanced through AAC devices, visual supports, environmental modifications, communication partners, and therapy intervention. To artificially exclude these supports from consideration creates an inaccurate and harmful representation of a person’s actual functioning and participation needs.

This amendment risks:

  • reducing access for participants with complex communication needs;
  • disproportionately disadvantaging autistic individuals and people with intellectual disability;
  • ignoring the real-world contexts in which disability is experienced;
  • creating inconsistent and subjective access decisions.

Objection to restrictions on unscheduled plan reassessments (Schedule 1, Part 2)

The proposed changes to sections 48 and 48A significantly limit a participant’s ability to request reassessment of their plan unless they meet strict thresholds relating to “significant and ongoing” changes.

Submission 2098

This fails to recognise the dynamic nature of disability and support needs. Participants often experience changes in communication, behaviour, mental health, education participation, family circumstances, or caregiver capacity that require timely adjustment of supports before a crisis occurs.

Extending decision timelines from 21 days to 90 days will also create substantial delays in access to essential supports.

For many families, speech pathology supports are preventative and capacity-building. Delays in reassessment may lead to:

  • deterioration in communication and behaviour;
  • increased hospitalisation or school refusal;
  • carer burnout;
  • breakdown of placements and informal supports;
  • greater long-term costs to the Scheme.

Objection to strengthened requirement that supports arise “directly” from impairment (Schedule 1, Part 3)

The amendment requiring supports to arise “directly from an impairment or impairments” is concerning because disability impacts are rarely isolated or linear.

Communication difficulties frequently interact with trauma, mental health, sensory needs, educational exclusion, social disadvantage, and family stress. Restricting supports only to needs deemed to arise “directly” from impairment risks excluding participants with complex and intersecting presentations.

This amendment may particularly disadvantage:

  • autistic participants;
  • individuals with psychosocial disability;
  • participants with developmental trauma;
  • children with complex behavioural and communication needs.

Objection to Ministerial powers to reduce funding (Schedule 1, Part 4, section 34A)

The proposed power allowing the Minister to reduce funding percentages for groups of supports is alarming.

Of greatest concern is subsection 34A(5), which explicitly states that funding may be reduced even where it results in funding being less than the actual cost of reasonable and necessary supports.

This creates significant uncertainty and undermines participant confidence in the Scheme. It also risks:

  • arbitrary funding cuts;
  • disruption of therapeutic relationships;
  • workforce instability;

Submission 2098

  • inability for participants to continue clinically necessary supports.

Speech pathology services often rely on continuity, long-term intervention, and therapeutic trust. Sudden reductions in funding can reverse years of progress.

5. Objection to automatic plan renewals without review (Schedule 1, Part 5, section 50A)

The proposal for plans to automatically renew without meaningful reassessment or review is highly problematic.

Participants’ needs change over time. Children develop, school demands evolve, communication systems require updating, and carers age or experience burnout.

The proposed framework:

  • removes opportunities for collaborative planning;
  • reduces participant voice and choice;
  • risks outdated supports being rolled over;
  • may lock participants into inadequate funding arrangements.

Importantly, subsection 50A(4) states that automatic renewals do not involve a reviewable decision. This significantly weakens procedural fairness and participant rights.

6. Objection to changes prioritising “scheme sustainability” over participant needs (Schedule 1, Part 6)

The amendments repeatedly elevate “financial sustainability” as a guiding principle in determining supports.

While sustainability is important, these amendments risk shifting the Scheme away from its core purpose of enabling participation, inclusion, and quality of life for people with disability.

Of particular concern are:

  • maximum funding caps and intensity limits for supports;
  • increased emphasis on lower-cost supports over clinically appropriate supports;
  • prioritisation of peer-reviewed evidence over participant-specific outcomes and clinician expertise.

Speech pathology intervention is highly individualised. Many effective supports for communication and participation may not yet have extensive large-scale published evidence despite strong clinical effectiveness for an individual participant.

The proposed hierarchy of evidence risks excluding innovative, personalised, and neurodiversity-affirming supports.

7. Objection to increased reliance on families and carers (Schedule 1, Part 6, subsections 34(1G)-(1K))

Submission 2098

The proposed provisions place excessive responsibility on parents, carers, and informal supports, particularly those provided by mothers or women in general.

As a clinician, I regularly witness carer exhaustion, emotional distress, financial hardship, and relationship breakdown resulting from inadequate formal supports.

The proposal that parents are presumed responsible for “substantial care and support” and that supports should not reduce “burdens on parental time” is deeply concerning.

Families are already carrying extraordinary responsibilities. These amendments risk:

  • increasing unpaid care burdens;
  • worsening carer mental health;
  • reducing workforce participation of parents and carers, particularly women;
  • increasing family breakdown and safeguarding concerns.

Objection to tighter permanence requirements and mandatory treatment expectations (Schedule 1, Part 8)

The amendments requiring participants to undertake “all appropriate treatment” before impairments are considered permanent are problematic and potentially discriminatory.

These provisions:

  • fail to account for treatment accessibility;
  • disregard geographic and financial barriers;
  • risk coercing participants into unwanted or unsuitable interventions;
  • create uncertainty for participants with fluctuating or evolving disabilities.

The bill also states that treatment may still be considered “appropriate treatment” regardless of whether a person can realistically access it.

This is inequitable and disconnected from the realities faced by regional, rural, First Nations and disadvantaged Australians.

Objection to exclusion of participants based on access to “alternative supports” (Schedule 1, Part 9)

The proposed “alternative support requirements” create substantial risk that participants will be excluded from the NDIS on the assumption that another system should provide support.

In practice, many mainstream systems are already overstretched and unable to meet disability-related needs adequately.

This amendment risks creating:

  • service gaps;
  • cost-shifting between systems;
  • delays in intervention;
  • poorer outcomes for participants.

Submission 2098

Children and adults with communication disabilities are particularly vulnerable to falling through gaps between health, education, mental health, and disability systems.

In conclusion, the proposed amendments collectively represent a significant shift away from the foundational guiding principles of the NDIS. They prioritise administrative efficiency and cost containment over participant rights, inclusion, early intervention, and person-centred supports.

As a speech pathologist, I see daily the transformative impact that timely, individualised, and adequately funded supports have on communication, safety, independence, participation, and quality of life.

I urge the Government to reconsider these amendments and undertake genuine consultation with people with disability, families, carers, and frontline allied health professionals before proceeding.

The NDIS must remain a scheme that empowers people with disability to participate fully in society, not one that narrows access, shifts burdens onto families, and limits supports through increasingly restrictive criteria.

Yours sincerely,

Speech Pathologist