Parent's concerns regarding functional capacity assessments for autistic daughter

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Submission 2340

NDIS Bill Submission

Submission to the Senate Community Affairs Legislation Committee

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

About Me I am the parent of a 14-year-old girl with a diagnosis of Autism Spectrum Disorder (ASD) Level 2.

My daughter has been an NDIS participant since she was 11 years old. Through the NDIS she receives funding for core supports, occupational therapy and psychology. These supports are essential to her daily functioning, emotional wellbeing, independence and ability to participate in her community.

Without NDIS funding, our family would be required to personally fund these supports, which would place significant financial pressure on us and reduce her access to services that are critical to her development and wellbeing.

I am concerned that several provisions within the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 may unintentionally disadvantage participants with lifelong disabilities such as autism.

Functional Capacity Assessments Do Not Adequately Capture Lifelong Support Needs

The Bill introduces a framework for determining access to the NDIS based on substantially reduced functional capacity and proposes a more standardised approach to assessing eligibility.

While consistency in decision-making is important, I am concerned that functional capacity assessments may not adequately reflect the lived reality of autistic people, particularly children and adolescents whose support needs change significantly across different stages of life.

My daughter entered the NDIS at age 11 and has since received plan rollovers with no changes to her budget. However, her needs today are very different from when she first entered the Scheme.

The transition to high school brought increased demands in areas including executive functioning, organisation, social interaction, emotional regulation and anxiety management. These challenges were not fully apparent when she first entered the NDIS.

A functional assessment conducted at age 14 cannot accurately predict the support needs she may have at ages 18, 25 or 40. Autism is a lifelong disability, but the way it impacts a person’s

Submission 2340

functioning changes over time and in response to different environments and life transitions.

I am concerned that standardised assessments may create an overly d narrow snapshot of functioning that does not capture the complexity and evolving nature of autism across a person’s lifespan.

Recommendation

Participants with recognised lifelong disabilities such as Autism Spectrum Disorder should not be required to repeatedly prove that they continue to have a disability. Assessments should focus on identifying changing support needs rather than reassessing the existence of a permanent condition.

Progress Should Not Be Used as Evidence That Supports Are No Longer Needed My daughter has developed skills and independence because she has had access to supports funded through the NDIS.

There is a risk that functional assessments may interpret improvements in functioning as evidence that support is no longer required. In reality, many gains achieved by autistic participants are maintained only because ongoing therapy and support remain available.

Occupational therapy and psychology have helped my daughter develop strategies to manage daily challenges, regulate emotions and participate more successfully in school and community settings. Removing or reducing these supports because she appears to be functioning better would undermine the very progress those supports helped create.

Recommendation

The legislation should require decision-makers to consider whether a participant’s current functioning is dependent on existing supports and interventions when assessing eligibility and support needs.

Concerns Regarding the Definition of Permanence The Bill proposes changes to how permanence is considered, including the introduction of the concept of “all appropriate treatment” when determining whether an impairment is permanent.

I am concerned about how this provision may be applied to autistic participants.

Autism is not a condition that can be cured or resolved through treatment. Therapies can improve skills, participation and quality of life, but they do not remove the underlying disability.

Families should not be placed in a position where participation in therapies is used to argue that a disability is no longer permanent or significant.

Submission 2340

Recommendation

The legislation should clearly recognise that participation in therapy or intervention does not alter the lifelong nature of autism and should not be used as grounds to question permanence.

Increased Administrative Burden on Families

Families of children with disability already spend considerable time coordinating therapies, attending appointments, supporting education and navigating NDIS processes.

Additional requirements for reassessments, reports and evidence create further financial and emotional strain.

Specialist assessments are expensive and often involve lengthy waitlists. Requiring repeated evidence for lifelong disabilities places unnecessary burdens on families without improving participant outcomes.

Recommendation

Administrative requirements should be reduced for participants with established lifelong disabilities. Resources should be directed toward delivering supports rather than repeatedly reassessing eligibility.

Protecting Access to Essential Supports

My daughter’s occupational therapy, psychology and community participation supports are essential supports, not optional services.

These supports help her build independence, develop coping strategies, participate in everyday life and maintain her mental health.

I am concerned that tighter interpretations of what constitutes reasonable and necessary supports may reduce access to therapies that have demonstrated long-term benefits.

Early and ongoing intervention often prevents greater support needs later in life. Restricting access to these supports risks increasing pressure on health, education and mental health systems in the future.

Recommendation

The Bill should protect access to evidence-based supports that improve functional capacity, independence, participation and long- term outcomes for participants.

Conclusion

The NDIS has had a significant positive impact on my daughter’s life. It has enabled her to access supports that help her participate in her community, build independence and prepare for adulthood.

Submission 2340

I support measures that improve the sustainability of the NDIS and address fraud within the Scheme. However, sustainability should not be achieved by creating additional barriers for people with lifelong disabilities who genuinely require support.

I urge the Committee to ensure that the Bill recognises the lifelong nature of autism, avoids unnecessary reassessment processes, protects access to essential therapies and acknowledges that support needs evolve across a participant’s lifespan.

Thank you for considering my submission.