National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2359
Submission Regarding Proposed NDIS Legislative Changes
Submitted by:
Occupational Therapist Whitsundays Region, Queensland
Introduction
I am an Occupational Therapist working with children, families, schools, disability providers, and community organisations throughout the Whitsundays and Mackay regions of North Queensland.
I support many children with complex developmental, behavioural, communication, sensory, physical, and psychosocial support needs. My work places me in a unique position to observe the practical realities of disability support in regional Australia and the significant role that the National Disability Insurance Scheme (NDIS) plays in enabling participation, safety, development, education, and family wellbeing.
While I acknowledge the importance of maintaining a sustainable NDIS, I am concerned that aspects of the proposed legislative changes may unintentionally increase inequity, reduce access to support, place greater pressure on families and carers, and disproportionately affect people living in rural and regional communities.
Functional Capacity Must Be Considered in Context
I am concerned that the proposed changes to the definition and assessment of functional capacity may result in assessments that do not adequately consider environmental supports, family capacity, therapeutic intervention, assistive technology, educational adjustments, and community context.
As Occupational Therapists, we understand that disability cannot be separated from the environments in which people live.
A child’s ability to attend school may only be possible because of years of therapy, extensive educational adjustments, support workers, family advocacy, and emotional regulation supports.
An adult’s ability to maintain employment may only be possible because of workplace accommodations, assistive technology, and ongoing support.
The appearance of functioning often reflects the presence of support, not the absence of disability.
I am concerned that assessment processes which focus primarily on observable performance may underestimate the true impact of disability and overestimate an individual’s level of independence.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2359
The success of support should not be used as evidence that support is no longer required.
Rural and Regional Queensland Experiences Disability Differently
I am concerned that the proposed legislative changes do not sufficiently recognise the impact of geographical disadvantage on disability and participation.
Families living in regional communities such as Proserpine, Airlie Beach, Cannonvale, Bowen, Collinsville, Sarina, and Mackay face additional barriers that are often not experienced in metropolitan areas.
These barriers include:
• Limited provider availability • Workforce shortages • Reduced specialist access • Long waiting lists • Significant travel requirements • Limited respite opportunities • Reduced community supports • Fewer educational and therapeutic resources
For many families, attending a single appointment may require several hours of travel, time away from work, time away from school, fuel costs, accommodation costs, and complex planning.
The functional impact of disability is often amplified by these environmental barriers.
A child living in Brisbane and a child living in Collinsville may have the same diagnosis but vastly different opportunities to access support and participate in everyday life.
I believe geographical disadvantage should be explicitly considered when determining eligibility, support needs, and functional capacity.
Reduced Supports Do Not Remove Need
One of my greatest concerns is that reducing eligibility or reducing support levels does not eliminate disability-related need.
Instead, it transfers responsibility elsewhere.
When disability supports are reduced, disability-related needs do not reduce at the same rate.
The need remains.
The risks remain.
The disability remains.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2359
What changes is who carries the burden.
In many cases that burden shifts onto:
• Parents and carers • Schools • Health services • Mental health services • Community organisations • Emergency departments • Child protection systems
In regional communities, many of these systems are already stretched beyond capacity.
Families often become the system of last resort.
A family’s ability to compensate for service gaps should not be mistaken for reduced need.
Examples from Clinical Practice
The following de-identified examples reflect circumstances commonly encountered within my practice.
Child with Complex Needs in Mackay
I support a young child with Autism Spectrum Disorder and Global Developmental Delay who requires significant support across communication, emotional regulation, self-care, feeding, and participation.
The child’s primary caregiver has reduced workforce participation to coordinate appointments, implement therapeutic recommendations, and meet daily support needs.
While the child has made meaningful progress, that progress reflects years of intervention, family commitment, and coordinated support.
Without those supports, participation would be significantly reduced.
Child with Complex Disability in Collinsville
I support a child living in Collinsville with significant developmental and physical disabilities.
The family faces long travel distances, limited access to specialists, reduced respite opportunities, and significant workforce shortages.
The child’s school has implemented substantial adjustments to support participation and safety.
One parent has reduced workforce participation due to caregiving responsibilities.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2359
This example demonstrates how disability-related disadvantage can be compounded by geographical disadvantage.
Child with Profound Needs in the Whitsundays
I support a young child diagnosed with Autism Spectrum Disorder Level 3, Global Developmental Delay, significant communication impairment, and substantial safety concerns.
The child is non-verbal and requires constant one-to-one supervision due to elopement, pica, self-injurious behaviours, and a lack of danger awareness.
The child’s mother is the sole caregiver for three children with significant additional needs.
Recently, all allied health supports were significantly reduced. Services that had previously been delivered weekly were reduced to fortnightly, while services previously delivered fortnightly were reduced to monthly.
The child’s disability-related needs did not reduce when support levels were reduced.
The communication challenges remain.
The safety risks remain.
The developmental needs remain.
What changed was the amount of professional support available to assist the child and family.
The reduction in services increased pressure on a sole parent who is already unable to participate in employment due to intensive caregiving responsibilities.
This example illustrates that reducing support does not remove need.
It transfers responsibility onto families.
The Importance of Telehealth and Flexible Service Delivery
I also support families who rely heavily on telehealth and remote service delivery.
For many regional families, telehealth is not simply an alternative service model.
It is the only available option.
Remote Occupational Therapy, Behaviour Support, Support Coordination, and educational consultation often enable continuity of care when local services are unavailable.
Any future reforms should recognise the critical role flexible service delivery plays in ensuring equitable access for regional Australians.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2359
Workforce and Service Sustainability
I am concerned that the proposed legislative changes may affect the viability of regional disability services.
Across North Queensland, workforce shortages already impact Occupational Therapy, Speech Pathology, Psychology, Behaviour Support, and disability support services.
Families frequently wait months to access services.
Providers often operate at capacity.
Recruitment and retention remain ongoing challenges.
If access to funding becomes more restricted, there is a risk that regional providers may become financially unsustainable.
In metropolitan areas, participants may have alternative providers available.
In regional communities, the loss of a single service may mean losing access to an entire profession.
Recommendations
I respectfully recommend that the Government:
- Retain a holistic and contextual understanding of functional capacity.
- Ensure assessments consider environmental supports, assistive technology, family supports, educational adjustments, and community context.
- Explicitly consider geographical disadvantage when determining eligibility and support needs.
- Protect access to early intervention and capacity-building supports.
- Recognise the importance of telehealth and flexible service delivery models.
- Consider the impact of workforce shortages on regional service access.
- Evaluate the broader costs associated with transferring responsibility onto families and mainstream systems.
- Undertake meaningful consultation with participants, families, carers, allied health professionals, and regional communities before implementing legislative changes.
Conclusion
The NDIS has enabled many children and families within my community to access opportunities that would otherwise have been unavailable.
I am concerned that some of the proposed legislative changes may unintentionally increase barriers for those who already face significant disadvantage.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2359
For regional Australians, disability cannot be separated from geography, workforce availability, service access, and family capacity.
The success of the NDIS should not be measured by how much support can be removed. It should be measured by how effectively people with disability are able to participate in education, employment, relationships, community life, and the activities that matter to them.
I respectfully urge policymakers to ensure that any reforms continue to uphold the principles of equity, inclusion, participation, dignity, and choice for all Australians with disability, regardless of where they live.
Occupational Therapist Whitsundays Region, Queensland
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