Submission 2237

Submission to the Senate Community Affairs Legislation Committee

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

I am an Occupational Therapist working with NDIS participants across community in Brisbane. I am writing to express concern regarding some of the proposals within the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

Firstly, I support the need for sustainability, fraud prevention and accountability within the NDIS. However, I am concerned that many of the proposed changes will reduce access to required and safe supports for participants with complex and/or psychosocial disability, while also restricting the input of qualified allied health professionals, who are the most suited to determine the needs of these individuals in complex and fluctuating scenarios.

In particular, I urge the Committee to consider the following concerns:

• The reliance on standardised assessment approaches without recognition of context, which is hugely important and the reason disability exists. Without the environment itself creating barriers, many individuals would not be disabled at all! The environment is part of who we are, and it influences everything about us. If it is so freezing cold that I cannot take my mittens off, I cannot do a puzzle or tie my shoelaces. The environment is everything with disability, and it creates or minimises it.
• The risk that participants with fluctuating, psychosocial, neurodevelopmental or complex functional impairments may not be appropriately assessed through the proposal of the I-CAN. I have a client who has around 20 different diagnoses, some of which are recognised, and some not. However, they all are interconnected and impact on each other, her well-being, and level of disability. Again, this is hugely impacted by her environment, with the Australian heat causing her to be unable to go outside (even for a few seconds to get to her car) without collapsing. This cannot be captured in a standard assessment, and can only be considered by a person making nuanced decisions.
• I am concerned about the introduction of the “all appropriate treatments” test for NDIS eligibility. Firstly, many treatments may take years to enact, and in this time the person is at serious risk and financial burden while in reality privately paying for disability supports. For many, access is impossible, and this does not mean they do not wish to access treatment! Treatment may cost tens of thousands of dollars and not covered under Medicare, this can be impossible, making disability permanent. This unfairly disadvantages the already disadvantaged, where those with the means can access all treatments, and then get disability supports, and those without cannot

Submission 2237

receive either. It also creates unrealistic expectations that participants must continually pursue treatment in order to prove disability, rather than recognising that treatment and disability support often work alongside each other, and are needed together to ensure safety and continued living of life!

• Plan reassessments being just another I-CAN assessment means that it will be impossible for these clients to be fairly considered.
• This unintentionally by powerfully impacts on participant choice and control.
• I am extremely concerned about the powers of the minister to reduce funding for a type of support across all participants’ plans. This means that, those who have been considered safe with a certain level of support (this may only be a couple of hours of community participation a week to take them to their Physiotherapy appointment, which is the only thing maintaining their strength to walk), can have this reduced without warning or appeal (suddenly, they cannot get to their appointments, significantly impacting on safety). I am extremely concerned about the safety impact this will have on participants, who have otherwise been considered to have reasonable and necessary support in their plan.

Occupational Therapists assess functional capacity within the real environments where people live, work and participate. This is what we are trained for, and uniquely can determine how the client, their daily activities, and their environment interact to create barriers, limitations and possibilities. Effective assessment cannot be replaced by merely a checklist. It requires clinical reasoning, environmental observation, experience, training, understanding of risk, sensory processing, executive functioning, fatigue, mental health, informal support breakdown, and the cumulative impact of disability over time.

I am particularly concerned about any movement toward overly standardised assessment systems replacing nuanced professional judgement. A standardised or brief office-based assessment cannot possibly understand the nuance of the human experience. Without appropriate assessment by trained OTs, participants will be at risk of crisis, hospital presentations, homelessness and serious injury.

While I understand the efficiency, this reform would prioritise budgetary and administrative ease over the safety of Australians with disabilities.

I respectfully recommend that the Committee consider amendments that would:

1. Preserve the role of qualified allied health professionals in functional assessment and planning.
2. Ensure participants continue to have access to individualised, evidence-based assessments conducted in their natural environments.
3. Require transparency regarding how assessment outcomes inform funding decisions and budgets.
4. Maintain strong review and appeal rights, including meaningful access to independent review.
5. Ensure any new assessment tools are independently validated across diverse disability cohorts before implementation.

I urge the Committee to carefully consider the real life consequences of these reforms for participants with complex support needs and for the families who live alongside them.

Submission 2237

Thank you for the opportunity to provide this submission.

Yours sincerely,

Occupational Therapist

Brisbane