Submission 2150

Submission: NDIS Future Generations Bill 2026

Prepared by , Paediatric Occupational Therapist, Melbourne, Victoria

29 May 2026

About the Submitter

I am a paediatric Occupational Therapist with five years of experience working within the National Disability Insurance Scheme (NDIS). I work in private practice in Melbourne, supporting children and teenagers with complex neurodevelopmental profiles, including autistic young people with Pathological Demand Avoidance (PDA) profiles. PDA is a highly complex presentation of autism spectrum disorder, characterised by severe functional difficulties driven by an overwhelming and persistent neurological response to everyday demands.

In my clinical practice, I work daily with young people for whom routine expectations including basic self-care, transitions, communication requests, and participation in learning, are experienced as highly distressing and threatening. The avoidance, shutdown, or escalation I observe in these children is not voluntary or oppositional. It reflects a genuine impaired capacity to tolerate perceived demands, and it requires individualised, specialist support that cannot be easily replicated in a mainstream or community-based setting.

Section 1: Concerns About the Proposed Legislative Changes

1.1 Eligibility Tightening

I am concerned that the proposed changes to eligibility thresholds will disproportionately affect the young people I support. The children and teenagers with complex, co-occurring neurodevelopmental conditions whose disability is invisible, but whose support needs are profound.

Many of my clients are not able to leave their homes. Some have not attended school for months or years. I have supported young people who are experiencing what is increasingly understood as “school can’t”, a state of burnout and neurological overwhelm so severe that participation in daily life has become genuinely impossible. These children are not refusing. They are unable.

The Thriving Kids and Foundational Supports package is being positioned as an appropriate alternative for many of these children. In my clinical experience, this is not accurate. These supports are primarily designed for delivery through schools, early childhood settings, and community-based services. For the children I work with, many of whom cannot access any of these environments, this is not an alternative pathway. They are simply unavailable.

I am also concerned about how these young people present in assessment contexts. In my experience completing and reviewing Functional Capacity Assessments, a young person with a PDA profile may present as regulated and capable in a structured, one-off clinic environment, while being entirely unable to function in their home, their school, or their community. I have documented this pattern repeatedly in my clinical reports. This is not inconsistency; it is a core and well-evidenced feature of their disability profile. Assessors without allied health training and specific expertise in complex neurodevelopmental presentations are very likely to underestimate need in this cohort.

Submission 2150

1.2 Restrictions on Provider Choice

I am concerned about proposed restrictions on provider choice and control. In my practice, I work with families who have spent years finding clinicians they trust, practitioners with specific expertise in PDA, trauma-informed care, sensory processing, and complex neurodivergent presentations. These clinicians are frequently unavailable through large organisations or registered provider lists. The therapeutic relationships my clients have built with their providers are not incidental to their outcomes; they are central to them.

I have seen firsthand what happens when a child loses access to a trusted clinician due to funding or provider restrictions. Engagement breaks down. Dysregulation increases. Families are back to square one. Choice and control have allowed the families I work with to access the right support for their child’s specific needs, and I am concerned that restricting this will reduce safety and increase harm for the most complex participants.

1.3 Increased Administrative Burden on Families and Clinicians

Over the course of my five years in NDIS practice, the administrative load associated with maintaining participant funding has increased substantially. I regularly spend significant portions of my clinical week completing reports, reassessment documentation, and funding justifications. Time that is not available for direct therapeutic work with children.

I have also watched families I support navigate this system with extraordinary effort. Parents who are already managing a child in crisis, managing their own exhaustion, and often managing their own neurodivergence, are being required to repeatedly prove the existence of lifelong disabilities. Several families I work with have described the NDIS administrative process as a second full-time job. The proposed changes risk increasing this burden further, at precisely the point when many of these families have the least capacity to absorb it.

1.4 Concerns Regarding Foundational Supports

While Foundational Supports are being presented as an alternative pathway, I have significant concerns about whether these supports will be practically accessible to the children I work with. In my clinical experience, existing systems including schools, public mental health services and paediatric health services, are already chronically under- resourced and frequently unable to meet the needs of neurodivergent children with complex presentations.

I have worked with clients who have been referred across multiple systems, only to be told that their needs are too complex, that waitlists are too long, or that the service does not have the expertise required. I have supported families through the experience of their child being turned away from every available service. The risk that participants who lose NDIS access will simply not receive meaningful support elsewhere is not hypothetical, it is something I have observed, and it has serious consequences: crisis presentations, family breakdown, worsening mental health, and years of lost developmental progress.

1.5 Human Rights Concerns

I believe aspects of the proposed legislative changes raise serious human rights concerns, especially in relation to the children and young people I work with.

The United Nations Convention on the Rights of Persons with Disabilities (CRPD) affirms the rights of disabled people to access the supports required to participate fully in society and to

Submission 2150

exercise genuine choice and control over their lives. In my clinical practice, the NDS has been the mechanism that has made this possible for many of my clients. I have seen children who were housebound begin to engage with learning. I have seen families move from crisis to stability. Policies that reduce flexibility, narrow eligibility, or limit access to equitable supports risk undermining these rights. Particularly for participants with communication differences, psychosocial disabilities, and complex neurodevelopmental profiles who require non-traditional approaches to care.

Section 2: Recommendations

I strongly urge the government to reconsider aspects of the proposed legislation and to meaningfully consult with disabled people, families, clinicians, and advocacy organisations before implementing further reforms.

In particular:

• Preserving participant choice and control, including access to specialised providers of their choice.
• Reducing unnecessary administrative burdens on families and clinicians.
• Ensuring Foundational Supports are fully funded, evidence-based, and genuinely capable of meeting participant needs before any reduction in NDIS access occurs.
• Embedding disability rights and the principles of the CRPD at the centre of all NDIS reforms.
• Ensuring that access to supports and funding decisions are determined by appropriate assessments conducted by qualified professionals with relevant expertise in the disability profiles being assessed.

The NDS has been life-changing for many of the children and families I support. I have witnessed this directly in the day-to-day lives of real children who are now safer, more regulated, and more able to participate in their own lives because of the supports their plans have made possible.

I am deeply concerned that the proposed changes risk reversing this progress and leaving some of the most vulnerable young people in our community without the supports they need to live safely and meaningfully.

Paediatric Occupational Therapist

Melbourne, Victoria