National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 246
Submission to the Senate Community Affairs Legislation Committee National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
A Speech Pathology and Early Childhood Perspective from Hartful Therapies
Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submitted by: Hartful Therapies Author: Joy-Ann Hart Qualifications: M.Ed (ABA), BSpPath, CPSP Role: Speech Pathologist and Director, Hartful Therapies Date: 26th of May 2026
Language statement
In this submission I have used identity-first and person-first language where appropriate and acknowledge that language preferences differ across individuals and communities. I recognise that people may identify as autistic, a person with autism, disabled, a person with disability, or use other preferred terminology. References throughout this submission are intended to be respectful and inclusive of diverse perspectives.
I have also used terms consistent with current legislation and policy documents where required for clarity.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 246
Executive Summary
I am a Speech Pathologist and Director of Hartful Therapies, a Queensland-based private practice supporting children and families. I hold a Master of Education (Applied Behaviour Analysis), Bachelor of Speech Pathology and Certified Practising Speech Pathologist (CPSP) credentials.
I have extensive experience working across early intervention, disability and educational settings, including previous leadership experience within specialist autism and early childhood services. My experience spans direct clinical practice, multidisciplinary collaboration, family coaching, service leadership and supporting children with developmental and communication needs across home, educational and community environments.
I support efforts to improve the sustainability, integrity and long-term viability of the National Disability Insurance Scheme (NDIS). However, I am concerned that aspects of the proposed amendments may create unintended consequences for children and families, particularly within early childhood and developmental disability contexts.
My primary concerns relate to:
• The interpretation of functional capacity in children • Potential expectations regarding treatment pathways prior to support access • Expansion of what may be considered parental responsibility • Interaction between NDIS supports and mainstream systems • Consultation and accessibility of reform processes • Provider sustainability and continuity of care
Early intervention relies on timely access, continuity of relationships and coordinated support. Delays or unintended barriers can have lifelong impacts on children’s communication, participation and development. Proposed Bill provisions relevant to this submission
This submission primarily responds to proposed amendments relating to participant access and eligibility, assessment of functional capacity, expectations regarding
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 246
treatment pathways, parental responsibility and informal supports, interaction with mainstream systems, and processes that may affect participant decision-making and continuity of supports.
My comments focus specifically on how these proposed changes may affect children and families accessing early intervention and disability services. The observations outlined within this submission are informed by my experience as a Speech Pathologist and service provider working directly with children and families across clinical, educational and disability settings.
While I acknowledge the importance of strengthening the long-term sustainability and integrity of the NDIS, I encourage careful consideration of potential unintended impacts on developmental outcomes, family wellbeing, continuity of care and service access.
- Functional capacity and children’s developmental needs
The proposed amendments place increased emphasis on functional impacts and assessments of need.
Children with communication difficulties, developmental delay and neurodevelopmental conditions frequently present differently across environments. A child may demonstrate isolated skills during structured assessments while experiencing significant challenges in everyday participation across home, school and community settings.
Communication disability is particularly vulnerable to under-identification if assessment processes become overly standardised or rely heavily on isolated functional observations.
For example, a child may:
• use single words in a structured environment • answer simple questions with familiar adults • appear socially engaged during brief interactions
However, that same child may:
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 246
• struggle to communicate needs independently • experience distress due to communication breakdown • have difficulty participating in educational environments • require significant support across multiple settings
Assessments for children should consider participation and function across environments rather than isolated observations.
Recommendation:
Clarify that functional capacity assessments for children incorporate participation across multiple environments and recognise developmental variability. 2. Treatment pathways and access to support
I am concerned regarding potential interpretations requiring treatment pathways to be explored or exhausted before support eligibility decisions are made.
For many developmental conditions, including autism, intellectual disability and communication disorders, intervention does not aim to cure impairment. Instead, intervention aims to increase communication, participation, independence and quality of life.
Early intervention is time sensitive.
Delaying access to support while treatment pathways are explored risks missing critical developmental periods where intervention may have the greatest impact.
As Speech Pathologists, we frequently observe improved communication, participation and reduced long-term support needs when intervention occurs early.
Recommendation:
Clarify that access decisions should not require exhaustion of treatment pathways where delay may negatively affect developmental outcomes.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 246
- Parental responsibility and informal supports
Parents naturally provide care and support for their children. However, there is an important distinction between ordinary parenting responsibilities and disability-specific support requirements.
Families of children with disability frequently undertake responsibilities beyond what would reasonably be expected for parents of children of a similar age.
Within paediatric practice, I regularly observe families:
• attending multiple therapy, medical and educational meetings across a week • coordinating communication between providers and services • implementing communication systems and strategies within home environments • supporting behavioural regulation and participation throughout daily routines • transporting children across multiple appointments and locations
I have observed parents spending substantial time coordinating systems that do not naturally connect with one another. Families frequently become the central coordinator between therapists, educational settings, medical professionals and support services.
While family involvement is an essential component of effective intervention, there are practical limits to what families can reasonably absorb.
I have observed families reducing work hours or leaving employment to accommodate appointments and care needs. I have also observed the broader impact on family systems, including siblings spending significant time attending appointments or travelling between services.
Families implementing AAC systems at home frequently require substantial support and coaching. Introducing and maintaining communication systems across multiple environments is not equivalent to ordinary parenting responsibilities and often requires specialist knowledge and ongoing professional guidance.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 246
There is a risk that broadening expectations regarding parental responsibility may unintentionally shift increasing levels of care to unpaid informal supports.
Recommendation:
Clarify within legislation that parental responsibility refers to ordinary parenting expectations and does not include intensive disability-specific support requirements. 4. Interaction with mainstream systems
There appears to be increasing emphasis on determining whether supports should be delivered through alternative systems.
Schools, early childhood services and healthcare systems play important roles. However, they are not designed or resourced to replace specialised disability supports.
I am concerned about potential unintended cost-shifting between systems.
Families often already experience difficulty navigating multiple systems simultaneously and may become caught between systems that each identify another service as responsible.
Clear boundaries are required so that children do not experience delays in support due to uncertainty regarding service responsibility.
Recommendation:
Provide greater clarity regarding the interface between NDIS supports and mainstream services. 5. Provider sustainability and continuity of care
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 246
Provider instability affects more than organisations. It affects children and families through disruption of trusted relationships, increased waiting periods and reduced participant choice.
Recent service closures and restructuring across the disability sector highlight the importance of considering downstream impacts of reform.
Following the closure of specialist autism and early intervention services, including the recent closure of AEIOU Foundation services, I observed families report significant difficulties accessing alternative supports.
Families described:
• joining multiple waitlists • contacting numerous mainstream early childhood services • experiencing challenges locating environments able to appropriately support children with complex needs
One family described contacting approximately fifty early childhood centres before obtaining a placement. Following acceptance, the family was later informed that the child’s support needs could not be accommodated.
While this example represents a single family experience, it illustrates the practical challenges that can occur when specialised services are unavailable and assumptions are made that mainstream systems can absorb additional demand.
The impact of service disruption extends beyond access to therapy. It affects continuity of care, family stress, children’s participation opportunities and the ability to maintain established therapeutic relationships.
Recommendation:
Undertake formal workforce and market sustainability impact assessments prior to implementation of significant reforms. 6. Consultation and accessibility
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 246
Given the scale and complexity of the proposed reforms, consideration should be given to ensuring adequate consultation timeframes with participants, families, clinicians and providers.
Meaningful consultation also requires accessibility.
Many participants and families accessing disability services experience communication barriers, cognitive challenges, literacy demands or significant caring responsibilities that may limit their capacity to review complex legislative documents and prepare submissions within compressed timeframes.
Short consultation periods may unintentionally reduce participation from the individuals and families most affected by the proposed changes.
Recommendation:
Ensure future reforms include accessible information and adequate consultation periods to support meaningful participation. Overall recommendation
Overall, I recommend that the proposed amendments undergo further consultation and refinement to ensure unintended consequences for children, families and disability support systems are appropriately considered prior to implementation. Conclusion
I support efforts to strengthen the long-term sustainability of the NDIS. However, sustainability should not be achieved at the expense of timely access, continuity of care or the developmental needs of children.
The long-term success of the NDIS relies on ensuring that reforms strengthen both financial sustainability and participant outcomes.
I encourage further consultation with participants, families, clinicians and early childhood experts to minimise unintended consequences and ensure reforms achieve their intended purpose.
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