Functional impact assessment concerns

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Submission 2303

Submission to the Senate Community Affairs Legislation Committee

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

I am writing to provide a submission regarding the proposed amendments to the National Disability Insurance Scheme (NDIS) under the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

I provide this submission as both a clinician working directly with NDIS participants across a wide range of disabilities and functional impairments, and as someone with lived experience navigating disability support systems within Australia.

Through my work supporting both children and adults living with disability, I have observed the significant role the NDIS plays in promoting safety, participation, independence, communication, mobility, emotional wellbeing, education, community access, and overall quality of life. I have also observed the serious consequences that can occur when supports are delayed, reduced, inconsistent, or difficult to access.

Many participants living with disability experience complex and highly individual functional challenges that cannot be adequately understood through rigid funding models, standardised assessment frameworks, or simplified decision-making processes. Functional capacity is often influenced by multiple interacting factors, such as physical ability, neurological function, sensory processing, communication, cognition, fatigue, behavioural regulation, mental health, environmental demands, and access to appropriate support.

For many individuals, functional presentation may vary significantly across environments and throughout the day. A participant may appear capable within a brief or structured assessment setting, while experiencing substantial difficulty maintaining safety, regulation, independence, orientation, mobility, communication, or participation within everyday life.

These complexities require careful and individualised consideration.

I am concerned about proposed changes that may increase reliance on broad funding categories, standardised processes, or automated decision-making systems in ways that reduce the ability to adequately recognise the real-world functional impact of disability.

Disability support planning should remain individualised and based on a participant’s actual functional needs, rather than assumptions regarding diagnosis, appearance, presentation during short assessments, or perceived family capacity.

I am also concerned about increasing reliance on repeated reassessment processes to establish ongoing eligibility and functional impact. While intervention, therapy, and

Submission 2303

Support services can improve participation, wellbeing, safety, and functional capacity, many disabilities remain permanent in nature despite appropriate treatment and support.

The presence of ongoing therapy or intervention should not be interpreted as evidence that a person’s disability is temporary or expected to resolve. In many cases, supports are necessary to maintain stability, reduce deterioration, maximise independence, and support safe participation across daily life.

Repeated requests for extensive evidence, reassessment, and justification may place significant emotional, financial, and administrative burden on participants, families, carers, and treating professionals, particularly where long-term functional impairment has already been clearly established.

I am further concerned about increasing reliance on informal and unpaid supports. Many families and carers are already providing substantial levels of care and supervision, often over extended periods of time and with limited respite or external support. This can include assistance with mobility, communication, emotional regulation, personal care, transport, behavioural support, therapy implementation, environmental safety, appointments, and daily living tasks.

The assumption that families can continue absorbing increasing levels of support responsibility does not reflect the realities experienced by many households supporting a person with disability.

Adults living with disability may also experience significant decline when adequate supports are reduced or unavailable. Reduced access to appropriate support can contribute to increased isolation, reduced community participation, worsening physical and mental health, increased safety risks, loss of independence, and greater long-term pressure on healthcare and crisis systems.

Early intervention and ongoing supports are not optional extras for many participants. Appropriate supports frequently prevent deterioration, reduce crisis escalation, improve participation, and strengthen long-term outcomes across both childhood and adulthood.

While sustainability within the NDIS is important, sustainability should not come at the expense of participant safety, dignity, equity, and meaningful access to support.

The NDIS was established to support Australians living with disability to participate more fully within their communities and access the supports required to live safely and with greater independence. Reforms should strengthen these principles through improved transparency, consistency, accountability, and accessibility, while ensuring that participants remain at the centre of decision-making processes.

I respectfully urge the Committee to:

Submission 2303

  • Preserve genuinely individualised assessment and planning processes;

  • Avoid overreliance on automated or standardised decision-making systems;

  • Protect participant rights to review and appeal decisions;

  • recognise the limits of informal and unpaid support systems;

  • ensure disability is assessed based on real-world functional impact;

  • protect access to early intervention and ongoing specialised supports;

  • continue meaningful consultation with disabled people, families, carers, clinicians, and frontline providers when considering significant reforms to the scheme.

Thank you for the opportunity to provide this submission.

Sincerely,

Orthoptist and Functional Vision Practitioner Perth, Western Australia