National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2455
Occupational Therapist P:-E:
Submission to the Senate Community Affairs Committee:
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
I welcome the opportunity to provide feedback regarding the proposed NDIS reforms and their potential impact on participants, families, carers, and service providers.
As an occupational therapist with over 10 years of experience working with children and young people with disability, I am concerned that some aspects of the proposed reforms may unintentionally reduce access to necessary supports. I am also concerned that proposed distinctions between registered and unregistered provider payment arrangements may be impractical tor sole practitioners and small allied health practices, potentially limiting participant choice, reducing market capacity, and creating barriers to accessing services.
While I acknowledge the need to improve the sustainability and effectiveness of the NDIS, it is essential that reforms preserve participant access to appropriate supports, maintain a skilled disability workforce, and recognise the realities faced by people with disability and their families.
Parental Responsibility Must Not Replace Disability Supports
I am particularly concerned about the increasing emphasis on parental responsibility when determining support needs tor children with disability.
While parents are expected to provide care and support to their children, disability-related support needs are fundamentally different from ordinary parenting responsibilities. Children with disability often require significantly greater levels of supervision, emotional regulation support, physical assistance, prompting, behaviour support, and assistance with daily living activities than their non-disabled peers.
For example, a child may require: • Continuous support to regulate emotions and behaviours. • Physical assistance to complete routine daily activities. • Additional supervision to maintain safety. • Support with transitions and participation in community activities. • Ongoing assistance that exceeds age-appropriate expectations.
These supports are required because of the child’s disability, not because of ordinary parenting responsibilities.
Applying broad assumptions about parental responsibility risks reducing support hours and increasing reliance on unpaid family care. This places significant pressure on families and fails to recognise the intensity, complexity, and sustainability challenges associated with providing disability-related supports.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2455
Occupational Therapist P:-E:
Many parents are already providing extensive unpaid care, often at the expense of their own health, employment, financial stability, and wellbeing. Reducing funded supports on the basis that parents should absorb these responsibilities risks increasing tam ily burnout and may ultimately result in poorer outcomes tor both the child and their family.
The NDIS was established to support people with disability to participate in everyday life and reduce the inequities created by disability. Funding decisions must clearly distinguish disability-related support needs from ordinary parental responsibilities and accurately reflect the additional care requirements arising from disability.
Needs Assessments Must Be Conducted by Appropriately Qualified Professionals
I have significant concerns regarding the proposed needs assessment processes and the potential tor assessments to be conducted by NOIA employees who may not have the relevant clinical expertise to fully understand a participant’s disability and support needs.
Assessment outcomes have a direct impact on access to supports, participant wellbeing, safety, independence, and quality of lite. Given the importance of these decisions, assessments should be conducted or overseen by experienced allied health professionals with expertise relevant to the participant’s disability and circumstances.
A qualified allied health professional is better positioned to understand:
• Functional capacity across different environments. • The impact of fluctuating or episodic conditions. • Hidden disabilities and complex support needs. • The difference between functioning with adequate supports and functioning without supports. • The long-term consequences of inadequate supports. • The cumulative burden placed on families and informal supports.
A person’s disability cannot always be accurately measured through a brief assessment or standardised process. Many participants present differently depending on their environment, stress levels, available supports, fatigue, pain levels, sensory demands, or mental health status.
There is a significant risk that assessments may capture a participant’s best day rather than their typical day.
Assessments should take a whole-person approach and consider the participant ‘s lived experience over time, including periods where supports are insufficient or unavailable. Support needs should not be underestimated because a participant has developed coping mechanisms or because family members are compensating tor gaps in support. The legislation should include stronger safeguards to ensure assessment s are evidence-based, clinically informed, and reflective of participants’ actual support requirements.
Concerns Regarding Broad Ministerial Powers
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2455
Occupational Therapist P:-E:
I am concerned about the extent of powers being delegated to the Minister through the proposed reforms.
The NDIS exists to provide certainty, consistency, and support based on individual needs. Changes that allow significant aspects of participant supports to be determined through ministerial rules or future decisions may create uncertainty tor participants, families, and providers.
Many participants are concerned that important decisions about what supports can be funded may increasingly occur outside primary legislation and with limited parliamentary scrutiny. Given the importance of the NDIS to the lives of people with disability, there should be strong safeguards to ensure future changes are transparent, subject to appropriate oversight, and developed through genuine consultation with people with disability.
The disability community should have confidence that major decisions affecting access to supports will not be made without meaningful engagement and accountability.
The Importance of a Whole-Person Approach
One of the strongest concerns emerging from the disability community is the risk that participants become reduced to scores, assessment tools, or narrow definitions of functional impairment.
People with disability are individuals with unique circumstances, strengths, challenges, goals, and support needs. Effective planning requires understanding the whole person, including their family circumstances, informal supports, community participation, health needs, developmental needs, and long-term outcomes.
The NDIS should continue to operate as a person-centred scheme that recognises the complexity of disability and the reality that support needs cannot always be captured through standardised assessment processes alone.
Maintaining a Sustainable Allied Health Workforce
A strong and sustainable disability workforce is essential to achieving the objectives of the NDIS. Participants cannot exercise genuine choice and control if appropriately qualified providers are unavailable or unwilling to remain within the scheme.
As an occupational therapist, I have observed increasing workforce pressures across the disability sector. Therapists are managing growing administrative requirements, increasing reporting demands, complex participant presentations, and significant complia nee obligations while also attempting to maintain high-quality clinical care.
The work involved in supporting NDIS participants extends well beyond direct therapy sessions.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2455
Occupational Therapist P:-E:
It includes assessment, report writing, collaboration with families and support teams, communication with schools and healthcare providers, risk assessment, documentation, planning, and ongoing clinical reasoning.
Supporting people with disability is highly specialised work that requires extensive professional knowledge, clinical expertise, and significant time investment. Participants often present with complex and overlapping needs that require careful assessment and ongoing adjustment of supports.
In addition, many services must be delivered across multiple environments including homes, schools, childcare centres, workplaces, and community settings. Travel is not an optional component of service delivery but an essential part of ensuring participants can access supports within their natural environments.
I am concerned that reductions to therapy rates, travel funding, or other pricing arrangements may unintentionally destabilise the disability service market. Lower remuneration and reduced recognition of travel requirements may make it increasingly difficult for providers to recruit and retain experienced clinicians.
This could result in:
• Increased workforce attrition. • Reduced provider capacity. • Longer waiting lists. • Reduced access to services for participants with complex needs. • Reduced service availability in regional and outer metropolitan areas. • Increased pressure on families and informal supports.
A sustainable NDIS requires a sustainable workforce. Funding arrangements should recognise the complexity, expertise, administrative burden, and travel requirements associated with delivering high-quality disability services.
Protecting therapist remuneration and maintaining reasonable travel funding is not simply a provider issue; it is a participant access issue. Without a stable workforce, participants cannot access the supports required to achieve their goals, maintain independence, and participate fully in their communities.
Recommendations
I respectfully recommend that the Committee:
- Ensure parental responsibility is not used as a substitute for necessary disability supports.
- Require needs assessments to be conducted or overseen by suitably qualified allied health professionals with relevant expertise.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2455
Occupational Therapist P:-E:
- Introduce stronger safeguards to ensure assessments consider fluctuating needs, support gaps, and whole-of-person circumstances.
- Strengthen transparency, accountability, and parliamentary oversight regarding ministerial powers.
- Ensure people with disability, families, carers, and representative organisations remain central to the design and implementation of NDIS reforms.
- Ensure NDIS pricing arrangements appropriately reflect the complexity, expertise, clinical responsibilities, and administrative requirements associated with delivering allied health services.
- Maintain sustainable therapist remuneration to support workforce recruitment, retention, and market stability.
- Preserve reasonable travel funding arrangements to enable therapists to provide services across homes, schools, childcare settings, workplaces, community settings, and regional areas.
- Recognise that investment in a sustainable allied health workforce is essential to maintaining participant choice and control, reducing waiting lists, and ensuring equitable access to disability supports.
Conclusion
The NDIS has transformed the lives of many Australians with disability and their families. Any reforms should preserve the principles of fairness, individualised support, choice and control, and genuine recognition of the realities faced by participants.
Reforms must also recognise that participants rely upon a skilled and sustainable workforce to access those supports. Policies that reduce support availability, increase reliance on unpaid family care, or undermine workforce sustainability risk creating unintended consequences that ultimately reduce participant outcomes.
I urge the Committee to ensure that reforms strengthen participant outcomes, protect access to necessary supports, support family sustainability, and maintain a stable allied health workforce capable of meeting the needs of people with disability now and into the future. Thank you for the opportunity to provide this submission.
Occupational Therapist-