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

Submission 2224 30 May 2026 Committee Secretary Senate Standing Committees on Community Affairs PO Box 6100 Parliament House, Canberra ACT 2600 Re: Submission – National Disability Insurance Scheme Amendment (Securing the NDIS) Bill 2026 dear Committee Secretary, I write to you as a practising Occupational Therapist with eight years experience working directly within the National Disability Insurance Scheme(NDIS). Throughout my career I have worked extensively children families navigating NDIs access early intervention supports It is professional vantage point grounded daily practice evidenced based assessment profound respect serve that wish raise serious concerns regarding proposal National Disability Insurance Scheme Amendment Securing future generations)Bill. ##The Proposed ‘Thrving kids’ Pathway Fails Meet Needs Children Developmental Delays Autism One most significant concern bill transition children developmental delays autism diagnoses out of NDis into Thriving Kids pathway move fundamentally misrepresents severity complexity conditions doing so risks causing long term irreversible harm Australia’s vulnerable children Science early childhood development unambiguous early child life represent critical window neuroplasticity during which brain uniquely receptive therapeutic intervention precisely period targeted evidence-based individually tailored supports can produce most profound lasting gains in functional capacity communication social participation independence remove dilute these supports this window not cost-saving measure false economy devastating consequences In daily practice witness extraordinary effort required therapy teams, families and themselves achieve meaningful progress. Children autism delay do follow standardised trajectory each presents unique profile strengths challenges requiring kind individualised clinically informed support general early childhood cannot provide Best clinical guidelines including Speech Pathology Australia Occupational Therapy Australia Autism CRC clear effective early must be intensive evidenced based tailor to individual proposed Thriving Kids does meet this standard.

National Disability Insurance Scheme Amendment Submission

Section: Long-Term Fiscal Cost of Inadequate Early Intervention

I respectfully ask the Committee to consider the broader economic calculus of this policy decision. While the Bill appears to be motivated by a desire to contain NDIS expenditure, it does not reduce cost; it displaces those onto other systems over time. The lack of early intervention increases risk:

• Poor educational outcomes & school engagement;
• Mental health challenges including anxiety/depression/co-existing conditions;
• Employment/economic capacity as adults;
• Reliance on disability services/social welfare throughout life. Downstream healthcare/mental infrastructure/welfare/supported living will exceed savings from reduced funding. Investing adequately is fiscally responsible for children/families.

Burden On Families And Impact Of Workforce Participation

It’s incomplete without acknowledging its effect on families supporting disabled kids currently enabled through funded therapies and supports, enabling parents (especially mothers) meaningful workforce participation when professional support isn’t adequate they step into roles like primary therapists/carers unsustainably. Many parents are already stretched beyond limits—weekly therapy sessions, home programs implementation, navigating complex bureaucratic processes managing emotional weight raising poorly understood needs. Without skilled allied professionals’ guidance these families manage increasingly complex needs with inadequate clinical knowledge/resources effectively leading to lower parental workparticipation increased carer burnout higher family breakdown systemic costs all carry their own impact.

Real Source Of NDIS Cost Overruns Is Being Ignored

Over my eight years in this sector I’ve reviewed Functional Capacity Assessment reports internal review documentation Assistive Technology recommendation processes confidently stating the genuine sources financial strain within not being properly identified or addressed by Bill.

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

Submission 2224

Allied health professionals — occupational therapists, speech pathologists, physiotherapists, and others — are routinely subjected to an unnecessarily adversarial review and approval process. Reports are rejected on technical grounds despite meeting the ‘reasonable and necessary’ criteria. Assistive technology recommendations that would improve a participant’s independence and quality of life denied; overturned upon appeal; The NDIS Appeals Tribunal data tells compelling story: extraordinary proportion found favourable against participants yet Agency continues expending substantial resources including significant legal fees fighting qualified clinicians acting good faith.

Allied Health Professionals complete minimum four years university-level education regulated national professional bodies with strict standards practice ethical accountability do not make recommendations lightly nor recommend supports unnecessary Treating our clinical judgement suspicion while simultaneously proposing shift children onto under-resourced community pathways professionally disrespectful counter-productive goals NDLS.

Regulatory Reform Should Target Actual Source Rorting If Committee genuinely concerned about financial integrity within ndis should be evidence points clearly area requiring urgent regulatory attention support worker sector Unlike allied health professions governed by registration mandatory continuing professional development obligations many enter workforce minimal qualification single certificate course few weeks duration Lack consistent regulation creates conditions in which mismanagement inappropriate billing substandard service delivery more likely occur Sector seen well-publicised cases fraud exploitation rorting none attributable registered Allied Health Professions Bill intent protect long-term sustainability ndis benefit enormously directing reform energy meaningful regulation work rather than restricting access evidenced-based therapy for children need most.

The NGO-Funded Thriving Kids Model Will Freeze Out Private Practices Small Allied Health Businesses A consequence the Thriving Kids pathway received insufficient public attention structural effect on allied health workforce delivering early childhood services Under proposed model, funding will channelled through Non-Government Organisations (NGOs) as primary service delivery mechanism While NGOs play valuable role disability sector routing intervention exclusively or predominantly this channel have profound damaging consequences private practitioners small allied businesses currently backbone NDIS early childhood service delivery.

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

Submission 2224

Across Australia—and particularly in regional, rural, and outer suburban areas—the majority of NDIS-funded early intervention therapy is delivered not by large organisations but by small private practices: sole traders partnerships clinics five twenty therapists who have built their businesses around serving NDIS participants These practices invested heavily Clinical infrastructure workforce development community relationships Many operate where equivalent NGO services exist or could realistically established at scale absorb current demand. By funnelling Thriving Kids funding through NGOs proposed model effectively excludes private practitioners from accessing work—not because they are less qualifiedless effectivelesser committedbut simply Because structuraldesignoffundingmechanism This raises several critical concerns:

• Market consolidation reduced consumer choice Families trusted relationship child’s therapist may find those Practitioners no longer able provide under new Model Therapeutic relationship outcomes central themparticularly Children autism developmental delay often require extended time build trust engagement unfamiliar adults Service gaps underserved communities In many regionsrural Communities Small private Practices source allied health Services NGOs do Not Infrastructure staffing geographic reach replace Restricting Funding to NGO-delivered models these Areas will reduce costs it eliminate access entirely families need most Destruction small Businesses livelihoods Occupational therapists speech pathologists physiotherapists other Allied Health professionals Built Private Practices Around NDIS Early childhood Work face loss significant entire revenue stream without meaningful transition support Large corporations diversified income They small Employ local clinicians fragile economies Workforce attrition brain drain If private practice becomes unviable early intervention space experienced highly skilled Clinicians leave sector Entirely moving areas financially sustainable Loss clinical expertise quickly cheaply replaced children currently benefiting cost No evidence that NGO delivery produces better outcomes Proposal route funding through NGOs appears driven administrative and cost-containment logic not by Evidence That NGO delivered early Intervention Produces Superior Clinical Outcomes Absence such evidence justification structural change profoundly disrupt existing effective service delivery arrangements The Committee should aware this element Bill does merely affect business interests of private practitioners undermines ecosystem early intervention service delivery with disability current rely upon A model concentrates within narrow subset

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

Submission 2224

providers, without regard for geographic coverage, clinical continuity, or workforce capacity, is one that will inevitably produce shortages, inequity, and poorer outcomes. If the Government’s goal is a more sustainable and efficient NDIS, the answer is not to dismantle a diverse and functional private allied health market in favour of a centralised NGO model that lacks the capacity to meet demand. It is to work collaboratively with the full range of service providers — including private practitioners and small businesses — to develop a system that is equitable, evidence-based, and genuinely accessible to all families regardless of where they live.

Summary The National Disability Insurance Scheme Amendment (Securing the NDIS forFuture Generations) Bill 2026, as currently drafted, risks doing the opposite of whatits title promises. By removing children with developmental delays and autism fromindividualised NDIS supports and placing them into a generalised early childhoodpathway, the Bill disregards the clinical evidence on early intervention,

derestimates the complexity of these children’s needs, and imposes costs onfamilies, communities, and downstream government systems that will dwarf anyshort-term savings.Compounding this, the decision to channel Thriving Kids funding exclusively throughNGOs will systematically exclude the private practitioners and small allied healthbusinesses that currently deliver the overwhelming majority of early interventionservices – particularly in regional and rural communities where no NGO alternativeexists.This is not a reform that will improve service quality or access.It is astructural change that will reduce competition, eliminate consumer choice,drive experienced clinicians out of the sector,and leave many families without viable pathway to the supports their children urgently need.A scheme that is truly secured for future generations must be built on clinical integrity,genuine trust in qualified professionals,evidence-based investment in earlierevaluation,intervention ,and diverse competitive market.I urge Committee reject provisionsBill undermine access earlyinterventionsupports threaten viability private practice. engagement genuine consultation breadth allied professions before further amendments progressed available provide information appear Committee should assistance thank consideration submission Yours sincerely Anonymous Occupational Therapist 5