Submission 243
Submission to the Committee
Inquiry into the National Disability Insurance Scheme Amendment (Securing the
NDIS for Future Generations) Bill 2026
Submitted by: Light Occupational Therapy (Not-for-Profit Service)
Date: 29 May 2026
Confidentiality Statement
Light Occupational Therapy consents to this submission being published. No personal contact details are included in the body of this submission. Contact details and return address have been provided separately in accordance with submission guidelines.
Response to Terms of Reference
This submission addresses key elements of the Terms of Reference relating to reforms proposed in the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026, including:
- The definition and use of functional capacity
- Changes to reasonable and necessary supports
- Requirements that supports be directly related to eligible impairments
- The introduction of plan end dates and reassessment limits
- Consideration of alternative service systems
- Use of automation and compliance mechanisms
Executive Summary
Light Occupational Therapy is a not-for-profit provider supporting Autistic children, adolescents, and young adults.
While we recognise the intent of the Bill to improve sustainability and integrity of the NDIS, we are concerned that several measures may unintentionally reduce equitable access for Autistic participants.
Key risks arising from the Bill include:
-
Increased difficulty demonstrating support needs under a stricter functional capacity framework
-
Reduced access to supports for co-occurring conditions (e.g., anxiety, ADHD)
-
Decreased flexibility in responding to changing or crisis needs
-
Narrower interpretation of “reasonable and necessary” supports
-
Greater reliance on under-resourced mainstream systems
-
Increased administrative burden on families
-
Oversimplification of complex needs through automation
Light Occupational Therapy
Submission 243
These risks are likely to disproportionately affect Autistic individuals whose needs are dynamic, context-dependent, or less visible.
We note that the NDIS is underpinned by the principles set out in section 4 of the National Disability Insurance Scheme Act 2013, including that people with disability should be supported to exercise choice and control, participate in the community, and achieve their full potential.
In our clinical experience, the proposed changes, if not carefully implemented, risk undermining these principles by narrowing access to supports that are essential for meaningful participation and long-term outcomes.
About Light Occupational Therapy
Light Occupational Therapy is a not-for-profit organisation providing occupational therapy to Autistic children, adolescents, and young adults.
We support individuals with diverse presentations, including those who:
- Experience fluctuating functional capacity
- Have co-occurring mental health conditions
- Mask or compensate in structured environments Our approach is neurodiversity-affirming and focused on participation, independence, and long-term wellbeing.
Key Concerns in Relation to the Bill
Light Occupational Therapy notes that the proposed amendments must be interpreted consistently with the objects and principles of the NDIS Act, including:
- Supporting people with disability to participate in economic and social life
- Enabling choice and control in the pursuit of individual goals
- Providing supports that are reasonable and necessary to achieve these outcomes
We are concerned that several elements of the Bill, as currently framed, may unintentionally constrain the achievement of these objectives.
- Functional Capacity Definition May Exclude or Undervalue Need The Bill’s introduction of a clearer definition of functional capacity shifts access and funding toward observable, measurable impairments.
Risk:
Autistic individuals often present with:
Light Occupational Therapy
Submission 243
-
Context-specific difficulty
-
Fluctuating performance
-
High masking in assessments As a result, functional limitations in real-world environments may be under-recognised, leading to:
-
Reduced supports
-
Ineligibility for some participants
- Requirement for Supports to Be Directly Related to Autism The Bill clarifies that funded supports must be directly linked to a participant’s eligible impairment.
Risk:
Autism frequently co-occurs with:
-
Anxiety
-
Depression
-
ADHD
-
among other conditions These conditions are deeply interconnected with functional capacity. Restricting supports to those deemed “directly related” risks:
-
Fragmented care
-
Reduced effectiveness of intervention
-
Increased long-term reliance on services
- Reduced Flexibility Through Plan Reassessment Restrictions The Bill limits unscheduled plan reassessments and introduces more structured plan cycles.
Risk:
Autistic individuals often experience:
-
Burnout
-
Transitional stress
-
Sudden functional decline Reduced flexibility means supports may not adapt in a timely way, resulting in:
-
Escalation of needs
Light Occupational Therapy
Submission 243
- Increased crisis presentations
- Narrowing of “Reasonable and Necessary” Supports Changes to the interpretation of reasonable and necessary supports emphasise clear, measurable outcomes and system sustainability.
Risk:
This may disadvantage supports that are essential but less quantifiable, including:
-
Social participation programs
-
Sensory regulation supports
-
Preventative capacity-building interventions Such supports are critical for maintaining:
-
Mental health
-
Community inclusion
-
Long-term independence
- Ministerial Powers to Restrict Funding Categories The Bill enables the Minister to reduce or limit funding for specified support types.
Risk:
This creates uncertainty and may result in reduced access to:
- Early intervention supports
- Capacity-building therapies
- Community-based supports These supports are particularly important for Autistic children and young people.
- Increased Reliance on Other Service Systems The Bill requires consideration of whether supports should instead be provided by other systems (e.g., health, education).
Risk:
In practice, these systems are often:
- Overstretched
- Difficult to access
- Not equipped for disability-specific needs
Light Occupational Therapy
Submission 243
This creates a significant risk that Autistic individuals will:
- Fall between systems
- Experience unmet support needs
- Increased Administrative Burden The introduction of:
- Plan end dates
- Renewals
- Greater evidentiary requirements places additional strain on families and carers.
Risk:
Participants with less advocacy capacity or resources may:
- Struggle to maintain access
- Experience interruptions in support
- Automation and Compliance Measures May Oversimplify Needs Increased use of automated decision-making and compliance oversight aims to improve efficiency and integrity.
Risk: Autism is highly heterogeneous and not easily captured by standardised or automated processes.
This may result in:
- Oversimplified assessments
- Inaccurate funding decisions
- Reduced responsiveness to individual needs
Conclusion
The NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 represents a significant shift in the legislative and operational framework of the Scheme.
While the objective of ensuring long-term sustainability is important, it must be balanced with the statutory obligation to uphold the rights, participation, and inclusion of people with disability, as set out in the NDIS Act.
Light Occupational Therapy
Submission 243
A scheme that becomes overly restrictive or inflexible risks undermining its core purpose. For Autistic individuals in particular, supports must remain responsive, individualised, and grounded in functional reality, rather than constrained by narrow or overly standardised interpretations.
We urge the Committee to ensure that the implementation of these reforms remains consistent with the foundational principles of the NDIS.
Recommendations
Light Occupational Therapy recommends that the Committee:
-
Ensure that assessments of functional capacity are applied in a manner consistent with section 4 of the NDIS Act, recognising the impact of masking, variability, and environmental context on Autistic individuals. Occupational therapists are well positioned to provide holistic, evidence-based assessments of functional capacity in real-world contexts.
-
Clarify that supports addressing co-occurring and interconnected conditions may still meet the “reasonable and necessary” criteria where they are intrinsically linked to the participant’s functional impairment, consistent with the intent of section 34 of the NDIS Act.
-
Maintain sufficient flexibility within planning frameworks to enable timely plan variations, ensuring supports remain responsive to changes in functional capacity and life circumstances.
-
Ensure that interpretations of “reasonable and necessary” supports continue to reflect the importance of social and economic participation, not solely short term or easily quantifiable outcomes.
-
Avoid cost-shifting to mainstream service systems that are not resourced or designed to meet disability-specific needs, in alignment with the scheme’s objectives under section 3 of the Act.
-
Minimise administrative and evidentiary burden on participants and families to preserve equitable access, particularly for those with limited capacity to navigate complex systems.
-
Ensure that any use of automated decision-making is supported by appropriate clinical oversight, and does not replace nuanced, individualised assessment processes.
Thank you for the opportunity to provide this submission. Light Occupational Therapy would welcome the opportunity to provide further information to assist the Committee.
Light Occupational Therapy.