Submission 2185
Rose Maskill, Occupational Therapist
DEVELOPMENT & BEHAVIOURAL PAEOl,t,TRICS
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 “appropriate” treatment before their impairment is recognised as permanent. Many individuals with lifelong disabilities continue to engage in regular therapy and intervention to maintain function, prevent decline, develop skills and improve quality of life. Participation in ongoing therapy does not mean a disability is temporary, nor does it indicate that a person will no longer require disability-related supports.
In paediatric practice particularly, therapy is often focused on supporting functional participation, independence, emotional regulation, communication, sensory processing and safety within daily life activities. These interventions assist individuals to engage meaningfully in their occupations and environments; they do not “cure” disability.
I am concerned that participants who actively engage in therapeutic intervention may be unfairly disadvantaged under the proposed framework and risk being denied access to essential supports despite having permanent and lifelong disabilities.
I also hold serious concerns regarding the inequitable impact this may have on families experiencing financial hardship or living in rural and regional areas with limited access to therapy services. Participants who cannot afford private intervention or who face significant barriers to accessing treatment will be disproportionately disadvantaged, further widening socioeconomic inequities within the disability sector.
Submission 2185
Rose Maskill, Occupational Therapist
DEVELOPMENT & BEHAVIOURAL PAEOl,t,TRICS
2. 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 that these supports should generally be considered the responsibility of parents, on the basis that they would ordinarily and reasonably be expected of a parent caring for a case of a similar age, regardless of the additional impacts of disability.
In my expert clinical experience, while parents of children with disability may undertake many of the same broad parenting responsibilities as other families, the intensity, frequency and complexity of these tasks are often substantially greater.
For example, supervision may involve constant line-of-sight monitoring to manage significant safety risks, behavioural escalation across multiple environments, overnight care requirements, management of absconding behaviours, or support with highly complex emotional and sensory regulation needs.
I am concerned that the proposed wording risks oversimplifying the realities of disability-related caregiving and fails to adequately recognise the significant additional demands placed on families supporting children with complex needs.
Increased reliance on informal supports may place families at greater risk of carer burnout, mental and physical exhaustion, workforce participation impacts, financial strain, family breakdown and reduced capacity to support siblings and maintain overall family functioning.
From a clinical perspective, sustainable formal supports are often critical not only for the participant, but for preserving the wellbeing, stability and long-term functioning of the entire family unit.
3. Concerns Regarding NDIS Pricing Oversight and Independence
The Bill proposes that NDIS pricing arrangements sit with the Minister, based on Agency advice, through legislative instrument under section 45C. This differs from Recommendation 11 of the NDIS Review, which proposed that pricing be overseen by the Independent Health and Aged Care Pricing Authority (IHACPA), the independent body responsible for pricing within the hospital and aged care sectors.
I am concerned that the proposed approach reduces the independence and transparency of pricing decisions within the NDIS and increases the risk that pricing may be influenced by short-term budgetary pressures or shifting political priorities, rather than being determined through an independent, evidence-based assessment of service delivery costs, workforce sustainability and participant needs.
As an allied health clinician, I have observed increasing strain across the disability workforce, including workforce shortages, increasing operational costs and growing complexity of participant presentations. Sustainable and appropriately determined pricing structures are critical to ensuring providers can continue delivering safe, high-quality and evidence-based services.
If pricing decisions do not accurately reflect the true cost of service delivery, there is significant risk of reduced provider sustainability, workforce attrition, longer waitlists and reduced access to supports, particularly in regional and underserviced communities.
Submission 2185
Rose Maskill, Occupational Therapist
DEVELOPMENT & BEHAVIOURAL PAEOl,t,TRICS
In paediatric practice, continuity and consistency of therapeutic support are essential. Inadequate pricing structures may reduce providers’ capacity to deliver services involving travel, collaboration with schools and families, report writing, multidisciplinary consultation and support for participants with complex needs.
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.
4. Concerns Regarding the Transition to the “Thriving Kids” Approach and Reduced Access to Early Intervention
I acknowledge the intention to improve consistency and accessibility of supports for children through the proposed “Thriving Kids” approach. However, I hold significant concerns regarding the potential reduction in access to individualised early intervention supports for children with developmental delays, autism and other disabilities.
There is a substantial body of peer-reviewed evidence demonstrating that early intervention is critical in supporting improved functional, developmental and long-term participation outcomes for children with disability. Early access to occupational therapy, speech pathology, physiotherapy, psychology and multidisciplinary supports has consistently been shown to improve communication, emotional regulation, independence, social participation, school engagement and family functioning.
Importantly, evidence also demonstrates that effective early intervention reduces long-term economic costs by decreasing future reliance on intensive supports, crisis services, educational adjustments, mental health intervention and long-term care systems.
In paediatric practice, early intervention is not simply beneficial — it is often time-critical. Delays in accessing supports during key developmental periods can result in skills becoming more difficult to develop over time, leading to increased functional impairment and greater long-term support needs.
I am concerned that movement away from individualised, participant-centred early intervention funding may reduce families’ ability to access timely and specialised supports tailored to their child’s functional needs. Generic or delayed supports may not adequately meet the needs of children with complex developmental presentations, particularly those requiring multidisciplinary intervention.
From a clinical perspective, investment in evidence-based early intervention should be viewed as both a participant outcome measure and a long-term economic strategy. Reducing access to these supports risks poorer lifelong outcomes for children and increased long-term costs across health, education, disability and social service systems.
As a paediatric occupational therapist, I strongly support the long-term sustainability and integrity of the NDIS. However, as outlined above I am concerned that the proposed reforms within this Bill may unintentionally reduce access to essential supports, increase pressure on families and clinicians, and create greater inequity for participants with disability.
In my expert clinical experience, flexible, evidence-based and participant-centred supports are critical in enabling children with disability to develop functional skills, participate meaningfully in everyday life and achieve improved long-term outcomes. Early intervention, appropriate therapy access and sustainable formal supports not only improve quality of life for participants and families but also reduce long-term social and economic costs.
Submission 2185
Rose Maskill, Occupational Therapist YELOPIIENT CLINI/ DEVELOPMENT & BEHAVIOURAL PAEDIATRICS
I urge the Senate, and government to carefully consider the practical implications of these reforms for 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,
Rose Maskill Paediatric Occupational Therapist Canberra Development Clinic
Suite 4, 1st Floor, 16 Napier Close, Deakin, ACT 2600 www.canberradevelopmentclinic.com.au Tel: +61 2 5105 0890, Fax: +61 2 6147 0286 reception@canberradevelopmentclinic.com.au