Occupational therapist highlights impact of functional capacity definition on people with complex disabilities (Provider experience)

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National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026

Practitioner Submission to the Senate Inquiry on the Bill

Author: redacted Role: Occupational Therapist – Community Practice Location: Brisbane QLD

Introduction

I am an occupational therapist working in community practice with individuals living with lifelong and complex disabilities. My work focuses on supporting people to remain safe, maintain function, and participate meaningfully in everyday life. Contrary to the narrative often presented about NDIS providers, my current wage is significantly lower than my previous rolein State Parliament. I am not motivated bym financial gain,butby a commitmentto human dignity, inclusion ,and equity . While I recognisethe importanceof ensuringthelong-term sustainabilityo f th eNDIS, I shareconcerns raisedb yOT SiandsuchasOTA Spinal Life Australia disability advocates,and ND ISParticipants themselvesthatthestrong amendmentsprioritise cost reductionover participantwellbeingandriskunderminingthescheme’sfoundational principles . TheBillshouldnotproceedinthescurrentform. Meaningfulconsultationwith disabledpeopleandthesectorisvital prior-to implementation. Thereareanumber ofkey provisionswithinThe B ill thatrequiresubstantial amendment particularly withinSchedule 1 These include ther prop osed repeal o fs ection3 l which underpinsparticipant-centred planning,the introductionofs ec tionA enabling broad fundingreductionpowers, anda nd changes t o functional capacity (section9B), alternative supports(section25B)anda nd permanence requirements(Items88–94). Isharethesame concerns as OTSi and other stakeholders regardingamendments toreassessmentssuspensionprocesses,a s wella se xpanded powersrelating to automation pricing, a n d transitional arrangements across Schedules 2- -5. Across these provisionsthe Billhasbeendevelopedwithout sufficient consultationor impact analysis.

I call for meaningful co-designed engagement with people w ithdisability clinicians a nd the broader sector ,particularly in relationtofunding reductio npowerspricing decisionsautomation, an dinplementationofthenewplanning framework.I agree w i thOT Si an drecommendthat

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

Submission 2310

the Bill be delayed to allow for comprehensive consultation, human rights assessment, and development of appropriate safeguards to mitigate foreseeable risks. Furthermore, rather than adopting broadsystem-wide approaches to reducing participantsupports—an approachthatrisks harmtopeople with disability—greater attentionshouldbe directedtowardthenefficiencieswithinthenDIAitself.Thereis growing concern thatefficient inefficiencies within Agency contribute significant financial loss.Key contributors include administrative complexityand substantial legal cost associatedwith contestingparticipant plans.I recommend thorough independent review auditofNDIAbetakenidentifyinefficenciesensure public funds usedsupportparticipantsensuresafetyenable participationcommunity.

Key Concerns

Shift Away from Individualised Person-Centred CareThe proposed reforms move NDIs away core principle individualisedparticipancentric planning toward standardised fiscally driven model.In practicedisability cannot understood isolation.As occupational therapist assess how individuals function environments including supports home context community barriersRemoving these factors risk inaccurate assessments inappropriate funding decisions.

Narrowing Functional CapacityProposed definition functional capacity excludes assistive technology supportse environmentalcontextThis does not reflect real world functioning underestimates needs people complex fluctuating invisible disabilities.

Permanence Treatment RequirementsRequiringindividual undertake allappropriate treatment before considered eligible raises serious concernsMany person access duecost location system barriersothers make informed decision pursue certain treatmentsThese should excludedfrom support.
Reduction in Therapy SupportsTherapy plays critical role maintainingfunction preventing deterioration reducing longterm costs across health social systemsIn daily work colleagues regularly complete unbillable hours ensure participants receive essentialsupports This reflects committed workforce—notsystem misuseWhile issues of misused be addressed broad narratives suggesting widespread exploitation do reality workforce largely committed working hard to support participants.

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

Submission 2310

Funding Reduction Powers

The introduction of broad powers to reduce funding without individual reassessment risks unsafe and inequitable outcomes. Supports should remain based on individual needs rather than broad fiscal measures.

Safeguarding Risks

Changes to reassessment and suspension processes may result in participants losing supports due to communication barriers or disability-related challenges. this creates significant safety risksand undermines the protective intentofthescheme.`

Workforce Perspective

There is a public narrative suggesting that many providers are exploiting the NDIS.In my experience, is not accurate.I observe clinicians consistently going above beyond often delivering unpaid workto ensureparticipants receive care they need.This narrativerisks damaging trustin workforce deeply committed supporting vulnerable people.

Conclusion

The proposed amendments representa shift away from originalintentNDIS.Sustainability important must come at expense safetynot dignity participation From frontlineperspective reforms risk increasing harm shifting costs other systems reducing quality lifepeople withdisability.Any “cost cutting” NDISshould comprehensive audit itself In addition concerns regarding reductions participantsupports consideration also be given efficiency Agency growing recognition systemic inefficiencies withinAgency including administrative complexity legal associated plan disputes contribute avoidable expenditure independent reviewaudit could assist identifying opportunities improveefficiency ensuring effective usepublic funds.```markdown

Recommendations

  • Delay implementation until meaningful consultation impact assessments completed. An independent review of ndia undertaken identify efficiencies reduce unnecessary expenditures. Retain individualised,participant-centred planning. Ensure functional capacity reflects real-world environments. Protect access therapy andcapacity-building supportss. Limit broad funding reduction powers. Strengthen safeguards procedural fairness. total 3 pages

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

Submission 2310

Thank you for the opportunity to make this submission.

Occupational Therapist (AHPRA registration no:` text redacted`) Brisbane QLD ` text redacted`.