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

deeply concerned regarding the proposed National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

1. The Proposed ‘Thriving Kids’ Pathway Fails to Meet the Needs of Children with Developmental Delays and Autism

One of my most significant concerns with this Bill is the proposal to transition children with developmental delays and autism diagnoses out of the NDIS and into the ‘Thriving Kids’ early childhood pathway. This move fundamentally misrepresents the severity and complexity of these conditions and, in doing so, risks causing long-term and irreversible harm to some of Australia’s most vulnerable children.

The science of early childhood development is unambiguous: the early years of a child’s life represent a critical window of neuroplasticity during which the brain is uniquely receptive to therapeutic intervention. It is precisely during this period that targeted, evidence-based, and individually tailored supports can produce the most profound and lasting gains in a child’s functional capacity, communication, social participation, and independence. To remove or dilute access to these supports during this window is not a cost-saving measure — it is a false economy with devastating consequences.

In my daily practice, I witness the extraordinary effort required - from therapy teams, families, and the children themselves - to achieve meaningful developmental progress. Children with autism and developmental delay do not follow a standardised trajectory. Each child presents with a unique profile of strengths and challenges, requiring the kind of individualised, clinically informed support that a general early childhood pathway simply cannot provide. Best practice clinical guidelines, including those from Speech Pathology Australia, Occupational Therapy Australia, and the Autism CRC, are clear: effective early intervention must be intensive, evidence-based, and tailored to the individual. The proposed Thriving Kids pathway does not meet this standard.

Submission 2224

The 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, the removal of adequate early intervention supports will not reduce costs — it will displace them onto other systems across a much longer timeframe.

Children who do not receive appropriate early intervention are at substantially elevated risk of:

• Poorer educational outcomes and reduced school participation
• Significant mental health challenges including anxiety, depression, and co-occurring psychiatric conditions
• Limited capacity for employment and economic participation in adulthood
• Greater reliance on supported accommodation, disability services, and social welfare over their lifetime

The downstream costs to the healthcare system, mental health infrastructure, welfare payments, and supported living arrangements will far exceed any short-term savings achieved by reducing early intervention funding. Investing adequately in early intervention is not just the right thing to do for children and families — it is the fiscally responsible course of action.

The Burden on Families and the Impact on Workforce Participation

It would be incomplete to discuss the impact of this Bill without acknowledging its likely effect on the families of children with disability. Currently, NDIS-funded therapies and supports enable parents — particularly mothers — to maintain meaningful workforce participation. When professional support is withdrawn or made inadequate, families do not simply absorb the difference; they are forced to step into the role of primary therapist and carer in ways that are unsustainable.

I have sat with many parents who are already stretched beyond capacity — attending weekly therapy sessions, implementing home programs, navigating complex bureaucratic processes, and managing the emotional weight of raising a child whose needs are poorly understood by the systems designed to support them. Without the guidance of skilled allied health professionals, these families will be left to manage increasingly complex needs without the clinical knowledge or resources to do so effectively. The economic consequence is reduced workforce participation for parents, increased carer burnout, and higher rates of family breakdown — all of which carry their own systemic costs.

The Real Source of NDIS Cost Overruns Is Being Ignored

Over my eight years working in this sector, I have had cause to review Functional Capacity Assessment reports, internal review documentation, and Assistive Technology (AT) recommendation processes. I can state with confidence that the genuine sources of financial strain within the NDIS are not being properly identified or addressed by this Bill.

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 are denied, only to be overturned on appeal. The NDIS Appeals Tribunal data tells a compelling story: an extraordinary proportion of contested decisions are found in favour of the participant, and yet the Agency continues to expend substantial resources — including significant legal fees — fighting recommendations made by qualified clinicians acting in good faith.

Allied health professionals complete a minimum of four years of university-level education and are regulated by national professional bodies with strict standards of practice and ethical accountability. We do not make recommendations lightly, nor do we recommend supports that are unnecessary. Treating our clinical judgement with suspicion while simultaneously proposing to shift children onto under-resourced community pathways is both professionally disrespectful and counter-productive to the goals of the NDIS.

5. Regulatory Reform Should Target the Actual Source of Rorting

If the Committee is genuinely concerned about financial integrity within the NDIS — and it should be — the evidence points clearly to the area requiring urgent regulatory attention: the support worker sector. Unlike allied health professionals, who are governed by national registration, mandatory continuing professional development, and professional indemnity obligations, many support workers enter the NDIS workforce with minimal qualification — in some cases completing a single certificate course of a few weeks’ duration.

The lack of consistent regulation, quality assurance, and accountability in this sector creates conditions in which financial mismanagement, inappropriate billing, and substandard service delivery are far more likely to occur. The sector has seen well- publicised cases of fraud, exploitation, and rorting — none of which are attributable to regulated allied health professionals. If the Bill’s intent is to protect the long-term sustainability of the NDIS, it would benefit enormously from directing that reform energy toward meaningful regulation of support work, rather than restricting access to evidence-based therapy for children who need it most.

6. The NGO-Funded Thriving Kids Model Will Freeze Out Private Practices and Small Allied Health Businesses

A consequence of the Thriving Kids pathway that has received insufficient public attention is its structural effect on the allied health workforce delivering early childhood services. Under the proposed model, Thriving Kids funding will be channelled through Non-Government Organisations (NGOs) as the primary service delivery mechanism. While NGOs play a valuable role in the disability sector, routing early intervention funding exclusively or predominantly through this channel will have profound and damaging consequences for the private practitioners and small allied health businesses that currently form the backbone of NDIS early childhood service delivery.

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, and clinics of five to twenty therapists who have built their businesses around serving NDS participants. These practices have invested heavily in clinical infrastructure, workforce development, and community relationships. Many operate in areas where no equivalent NGO service exists or could realistically be established at the scale required to absorb current demand.

By funnelling Thriving Kids funding through NGOs, the proposed model effectively excludes private practitioners from accessing this work — not because they are less qualified, less effective, or less committed, but simply because of the structural design of the funding mechanism. This raises several critical concerns:

• Market consolidation and reduced consumer choice: Families who have established trusted relationships with their child’s therapist may find those practitioners are no longer able to provide services under the new model. The therapeutic relationship is not incidental to outcomes — it is central to them, especially for children with autism and developmental delay who often require extended time to build trust and engagement with unfamiliar adults.
• Service gaps in underserved communities: In many regional and rural communities, small private practices are the only source of allied health services. NGOs do not have the infrastructure, staffing, or geographic reach to replace them. Restricting funding to NGO-delivered models in these areas will not reduce costs — it will simply eliminate access to services entirely for the families who need them most.
• Destruction of small businesses and livelihoods: Occupational therapists, speech pathologists, physiotherapists, and other allied health professionals who have built private practices around NDIS early childhood work face the loss of a significant or entire revenue stream without meaningful transition support. These are not large corporations with diversified income — they are small businesses employing local clinicians, often in communities with already fragile health economies.
• Workforce attrition and brain drain: If private practice becomes unviable in the early intervention space, experienced and highly skilled clinicians will leave the sector entirely — moving into areas of practice that remain financially sustainable. The loss of this clinical expertise cannot be quickly or cheaply replaced, and the children currently benefiting from it will bear the cost.
• No evidence that NGO delivery produces better outcomes: The proposal to route funding through NGOs appears to be driven by administrative and cost-containment logic, not by evidence that NGO-delivered early intervention produces superior clinical outcomes. In the absence of such evidence, there is no justification for a structural change that will so profoundly disrupt existing and effective service delivery arrangements.

The Committee should be aware that this element of the Bill does not merely affect the business interests of private practitioners — it undermines the entire ecosystem of early intervention service delivery that families with children with disability currently rely upon. A model that concentrates funding within a narrow subset of

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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 for Future Generations) Bill 2026, as currently drafted, risks doing the opposite of what its title promises. By removing children with developmental delays and autism from individualised NDS supports and placing them into a generalised early childhood pathway, the Bill disregards the clinical evidence on early intervention, underestimates the complexity of these children’s needs, and imposes costs on families, communities, and downstream government systems that will dwarf any short-term savings.

Compounding this, the decision to channel Thriving Kids funding exclusively through NGOs will systematically exclude the private practitioners and small allied health businesses that currently deliver the overwhelming majority of early intervention services — particularly in regional and rural communities where no NGO alternative exists. This is not a reform that will improve service quality or access. It is a structural change that will reduce competition, eliminate consumer choice, drive experienced clinicians out of the sector, and leave many families with no 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 early intervention, and a diverse and competitive service delivery market. I urge the Committee to reject the provisions of this Bill that undermine access to early intervention supports and that threaten the viability of private allied health practice, and to engage in genuine, evidence-driven consultation with the full breadth of the allied health professions before any further amendments are progressed.

I am available to provide further information or to appear before the Committee should that be of assistance. I thank you for your consideration of this submission.

Yours sincerely,

Anonymous Occupational Therapist