Concerns regarding NDIS definition of permanent disability and pricing oversight (Provider experience)

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

Submission 2185 Rose Maskill, Occupational Therapist canberra development clinic DEVELOPMENT & BEHAVIOURAL PAEDIATRICS

Senate Inquiry Submission Re: Securing the NDIS for Future Generations Bill 2026

To whom it may concern, I am writing in my capacity as a paediatric occupational therapist working with children and young people who access the National Disability Insurance Scheme (NDIS). I support participants with varying diagnoses such as Autism Spectrum Disorder, Developmental Delays, Intellectual Disabilities and complex developmental needs across a range of settings including home, school, community and clinic environments. I acknowledge and support the Government’s intention to improve the sustainability, consistency and integrity of the NDIS. Ensuring the scheme remains available for future generations is an important objective. However, I hold significant concerns regarding several proposed reforms and their potential impact on participants, families, service providers and the broader disability sector. Based on my clinical experience supporting children and families accessing the NDIS, I wish to highlight several key concerns regarding the proposed legislation and its potential implications for participants, families and the broader disability sector.

Tightening the Definition of “Permanent” Disability The Bill proposes that impairments may not be considered permanent unless all ‘appropriate treatment’ has been undertaken and further treatment is unlikely to materially improve the impairment. The legislation further suggests that treatment may still be considered ‘appropriate’ even if a participant cannot realistically access it due to financial circumstances or geographic location.I am deeply concerned by the requirement for participants to have exhausted all

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

Submission 2185 Rose Maskill, Occupational Therapist canberra development clinic DEVELOPMENT & BEHAVIOURAL PAEDIATRICS

Increased Reliance on Informal Supports and Parents

The Bill strengthens the presumption that parents are responsible for providing supervision personal care behavioural support emotional support transport and daily assistance for their children It proposes these should generally be considered responsibility based ordinary reasonably expected parent caring similar age regardless additional impacts disability. In my expert clinical experience while may undertake broad parenting responsibilities other families intensity frequency complexity of tasks often substantially greater For example monitoring manage significant safety risks escalation across multiple environments overnight care requirements management absconding behaviours or highly complex emotional sensory regulation needs I am concerned proposed wording oversimplifying realities caregiving fails adequately recognise demands placed supporting with complex needs increased reliance informal supports place at risk carer burnout mental physical exhaustion workforce participation financial strain family breakdown reduced capacity to siblings maintain overall functioning From a perspective sustainable formal critical not participant but preserving wellbeing stability long-term function entire family unit Concerns Regarding NDIS Pricing Oversight Independence The Bill proposes pricing arrangements Minister Agency advice legislative instrument under section This differs Recommendation Review which proposed by Independent Health Aged Care Pricing Authority IHACPA independent body within hospital aged sectors Amended approach reduces independence transparency decisions within NDIS increases budgetary pressures political priorities rather than determined through independent evidence-based assessment service delivery costs sustainability participants Sustainable appropriately structured providers continue delivering safe high-quality services If pricing does accurately reflect true cost there is significant provider attrition longer waitlists access particularly regional underserviced communities Suite 4,1st Floor Napier Close Deakin ACT Tel: +61251050890 Fax: +61261470286 www.canberradevelopmentclinic.com.au reception@canberradevelopmentclinic.com.au

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

Submission 2185 Rose Maskill, Occupational Therapist

In paediatric practice, continuity and consistency of therapeutic support are essential. Inadequate pricing structures may reduce providers’ capacity to deliver services involving travel, collaboration collaboration teachers and schools. schools with complex needs. participants with school teachers and parents. families report writing multidisciplinary consultation and support for participants complex needs. writing, multidisciplinary consultations and support for children or adults with complex needs. involving travel, collaborative work between professionals in different fields such as doctors, nurses, social workers etc., and providing information about a patient’s condition that is needed across multiple settings like hospitals, clinics, homes where they live, workplaces at which their job takes place, community groups where people gather together outside home life. The importance cannot be overstated: without these kinds of supports it would not just make things harder but impossible sometimes even dangerous when trying treat someone who has severe disabilities requiring constant care from many experts all working towards same goal helping them get better faster than possible otherwise alone by one person only. I am concerned that placing pricing powers primarily within ministerial discretion may reduce confidence in the transparency and independence of pricing decisions across the sector.

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

Submission 2185 Rose Maskill, Occupational Therapist Canberra DEVELOPMENT & BEHAVIOURAL PAEDIATRICS CLINIC

I urge the Senate, and government to carefully consider the practical implications of these reforms or participants, families, clinicians and the broader disability sector, and to ensure that future changes remain grounded in clinical evidence, transparency and the core principles of the NDIS. Thank you for the opportunity to provide this submission. Yours sincerely,, r redacted: s22(1)(a)(ii) Rose Maskill Paediatric Occupational Therapist Canberra Development Clinic