National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 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 standardized 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 individualized functional supports that enable children and young people to participate in all aspects of daily life including home school community settings This includes building communication independence social participation regulation real-world environments Proposed reductions to capacity-building supports Including cited reduction activity supports Reductions significant limit work outcomes operating strong clinical governance structured supervision Occupational therapy Speech Pathology collaborative goal setting with Families stakeholders regular review These processes ensure targeted accountable focused Real-life outcomes also responsive change without overservicing intensity adjusted based function progress need Only possible within flexible Individualised Funding model In practice Capacity Building Supports are discretionary They Underpin child’ ability engage education communicate effectively build relationships Function independently Reduced access will shift costs pressure onto families schools other systems Also concerned about Shift standard assessment tools Automated rules-based Decision making Children neurodivergent complex presentations require nuanced clinically informed Assessment cannot accurately captured tick-box algorithm-driven Processes Additionally Expanding ministerial powers apply broad funding reductions across support categories risks undermining principle should be Based On individual needs professional assessment I ask Parliament amend bill:

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

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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Member 2025

Submission 232