Submission 232

Dear Committee,

I am the director of Functional Focus Therapy, a paediatric allied health service delivering occupational therapy and speech pathology supports to children and families under the NDIS.

I am writing to express concern regarding key elements of the proposed Bill, particularly changes that risk reducing capacity building supports, increasing reliance on standardised or automated decision-making, and expanding system-level control over funding.

Our service does not operate solely through one-to-one therapy. We deliver highly individualised, functional supports that enable children and young people to participate across all aspects of daily life, including home, school, and community settings. This includes building communication, independence, social participation and regulation in real-world environments. Proposed reductions to capacity building supports, including the cited 10% reduction to daily activity supports and 50% reduction to social and community participation supports, would significantly limit this work and its outcomes.

We operate with strong clinical governance, including structured supervision across occupational therapy and speech pathology, collaborative goal setting with families and key stakeholders, and regular goal review. These processes ensure supports are targeted, accountable, and focused on real-life outcomes. They also ensure we are responsive to change without over-servicing, with therapy intensity adjusted based on functional progress and need. This is only possible within a flexible, individualised funding model.

In practice, capacity building supports are not discretionary. They underpin a child’s ability to engage in education, communicate effectively, build relationships, and function independently. Reduced access will shift costs and pressure onto families, schools and other systems.

We are also concerned about the shift toward standardised assessment tools and automated or rules-based decision-making. Children with neurodivergent and complex presentations require nuanced, clinically informed assessment that cannot be accurately captured through “tick-box” or algorithm-driven processes.

Additionally, expanding ministerial powers to apply broad funding reductions across support categories risks undermining the principle that supports should be based on individual need and professional assessment.

I ask that Parliament amend the Bill to:

Submission 232

• Ensure decisions remain based on individualised, clinically informed assessment by qualified allied health professionals
• Remove or limit system-wide funding reductions that impact therapy and capacity building supports
• Prohibit fully automated decision-making in eligibility and funding
• Maintain access to early and ongoing supports for children and individuals with complex needs
• Support a sustainable, clinically governed allied health workforce across both occupational therapy and speech pathology

These changes are critical to ensuring the NDIS continues to deliver meaningful, functional outcomes for participants.

Kind Regards,

Luke Walsh

Occupational Therapist | Functional Focus Therapy

FUnCTIOnRL FOCUSTHERAPY eeee ~••

Web: www.functionalfocustherapy.com.au

Functional Focus Therapy acknowledges the traditional owners of country throughout Australia and their continuing connection to land and community. We pay our respects to Elders both past and present.

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Submission 232