Submission 2153
Submission 2153
decision to cease travelling to certain client homes and schools, and turn away new participants. In our region, these clients frequently have zero other options, leaving them entirely without access to intervention. Many of these families do not have capacity or ability to travel to clinics further down the mountain. Some cannot leave their homes generally and need those in home services.
- Income Instability: With a rigid NDIS cancellation policy, maintaining a consistent income has become incredibly difficult, placing me under significant personal and professional stress.
Furthermore, the 2026 Bill introduces frameworks designed to restrict capacity-building funding based on the assumption that support needs will naturally and linearly decrease over time. This fundamentally conflicts with established speech pathology research and my daily clinical reality. For participants with lifelong neurological, developmental, or communication conditions, progress is long-term and highly dynamic. Functional capacity during childhood, adolescence, and early adulthood is not linear; it fluctuates intensely based on:
- Developmental Transitions: Moving from primary school to high school, or transitioning into the workforce, vastly shifts environmental demands, creating a stark mismatch between a participant’s skills and their changing circumstances. These transitions can also occur on a much smaller scale that can have profound impacts on a child/ young person’s life. For example, moving to a new grade with a teacher who does not understand their needs, moving house, needing to do work experience etc.
- Systemic Stresses: Family mental health, home stress, and changing informal support structures directly impact a participant’s ability to maintain functional communication skills.
Classifying therapy under rigid, time-bound structures or viewing “maintenance therapy” as separate from capacity building will cause immediate developmental regression. This rigidity is mirrored in the tightening of NDIA-approved “appropriate tools,” specifically restrictions targeted at technology, games, and engagement devices. In speech pathology, particularly within early childhood, neurodivergent cohorts, and non-verbal AAC users, engagement is the foundation of neurological change. If a clinician cannot establish a solid base of engagement using motivating, contemporary tools, little to no therapeutic progress will follow. Restricting these tools is clinically inappropriate and actively harms outcomes.
If this Bill passes unamended, the human and economic costs will simply shift from the NDIS to other overstretched state systems, such as health, education, and child protection:
- Early Intervention Failure: Children will miss critical neurological windows for speech, language, and literacy development, leading to long-term educational exclusion.
Affinity Therapy Services ❖ ABN: 68 649 854 642 ❖ www.affinitytherapy.com.au 2
Submission 2153
● Family Burnout and Mental Health Crisis: Slashing plan flexibilities and placing rigid limits on capacity building will drastically increase the caregiving burden. We will see a sharp decline in parental mental health, leading to family breakdown. ● Participant Safety: For many clients, communication is a safety mechanism—allowing them to express pain, discomfort, or report abuse. Restricting functional communication and AAC support puts participant safety at direct, immediate risk.
To address these critical flaws, I urge the Senate Committee to consider the following recommendations:
- Mandate Statutory Co-Design: Delay the implementation of any rules defining or restricting “NDIS supports” until genuine, transparent co-design has occurred with allied health peak bodies, such as Speech Pathology Australia and people with disabilities themselves.
- Review Geographic Classifications for Travel: Adjust the travel framework to allow regional pricing exemptions for isolated or topographically challenging pockets (like the Blue Mountains) that are incorrectly classified as metropolitan.
- Establish an Independent Pricing Mechanism: Transfer pricing and annual review responsibilities away from the NDIA to an independent body (such as IHACPA) to ensure sustainable pricing that reflects real-world business inflation.
- Protect Flexible Capacity Building for Lifelong Conditions: Ensure that legislative definitions of “capacity building” explicitly recognise the non-linear, fluctuating nature of developmental progress across childhood and adolescence.
Thank you for considering the vital perspective of small, localised allied health providers who form the true backbone of the NDIS ecosystem.
Abbey Forster BSpHSc MSpchLngPath GCert(Autism) MSPAA Speech Language Pathologist Affinity Therapy Services
Affinity Therapy Services ❖ ABN: 68 649 854 642 ❖ www.affinitytherapy.com.au 3