National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2469
Dear Committee Members,
I am an Occupational Therapist and private practice owner working primarily with neurodivergent children, young people, and their families. We also work with children and young people with a variety of other disabilities and developmental needs. I am writing to express significant concerns about the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.
Replacement of Functional Capacity Assessments with Support Needs Assessments
Occupational Therapists are trained to assess functional capacity, support needs, and environmental fit — not in isolation, but as an integrated picture of a person’s daily life. Our assessments consider sensory processing, executive functioning, communication, emotional regulation, environmental barriers, safety risks, developmental trajectories and the interaction between disability and everyday occupations. This is not a skill that can be replicated by untrained assessors or generic tools.
The Bill’s shift toward Support Needs Assessments conducted by non-clinical staff poses a serious risk. Functional assessment is not a “tick-box” activity. It requires clinical reasoning, observation across settings, and the ability to identify subtle but critical risks — particularly for autistic participants, PDA profiles, children who mask, and individuals with fluctuating or episodic needs.
When assessments do not reflect real-world needs outcomes are compromised and supports become misaligned with lived experience . This is already a challenge under the current system; reducing clinical involvement will magnify these risks dramatically.
Algorithm-Driven Decision Making
The Bill’s intended greater use of automated tools and algorithmic decision-making is also concerning. Automation cannot recognise masking, sensory overload patterns, burnout, executive functioning variability, trauma responses and the difference between “can do once” and “can do consistently and safely”
Neurodivergent participants, in particular, do not fit neatly into algorithmic categories. Their needs are contextual, relational, and often invisible to standardised tools.
Automated decisions will lead to inaccurate budgets, reduced supports, and increased appeals — ultimately increasing system costs and distress for families.
Concerns around Thriving Kids
The proposed Thriving Kids model in NSW assumes that:
• Not-for-profits can absorb thousands of children
• Schools can provide therapeutic support
• Group and parent programs are sufficient
This is not realistic. Not-for-profits do not have the workforce capacity. Many already have year-long waitlists. Our practice particularly ceased offering a waiting list service as it extended over 2 years wait.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2469
Schools do not have the clinical expertise to deliver therapy or assess functional needs. They cannot absorb higher support needs nor can they provide the individualised supports these children need. The proposed changes limit their access to supports in addition to increasing the support needs of students they teach.
Group programs cannot meet the needs of children with complex sensory, behavioural, communication, or developmental profiles.
Children who lose access to individualised supports will experience escalating needs, increased behavioural distress, school disengagement, and mental health decline. Many will ultimately return to the full Scheme with higher support needs — the opposite of sustainability.
This also threatens the viability of private paediatric practices, which currently provide the majority of early intervention services in Australia. Workforce loss in this sector will have long-term consequences for children’s developmental outcomes.
Restrictions on Plan Reviews
The Bill limits unscheduled plan reassessments to “exceptional circumstances” .
As a clinician, I frequently see plans that underestimate support needs, misunderstand neurodiversity, fail to account for fluctuating capacity, omit essential supports or assistive technology and assume high support needs are a parental responsibility.
If families cannot request a review when a plan is insufficient, they will be trapped in unsafe and unworkable plans. This is neither clinically sound nor aligned with the NDIS principles of reasonable and necessary supports. I work with many families experiencing burn out from caring for their children with high behavioural, communication and self-care support needs. These families are suffering and the proposed changes across eligibility, Thriving Kids and restrictions on appeals significantly impacts them.
Funding cuts to Capacity Building and Participation Supports
The proposed cuts including a 10% reduction to capacity building daily activity supports and a 50% reduction to social, civic and community participation supports shows a complete lack of understanding of the need and impact of these supports.
These supports are essential for building independence, maintaining routines, community inclusion, maintaining relationships, preventing crisis and supporting families and carers. These supports are essential for everyday activities people take for granted - visiting the shops, attending doctors appointments, going to the bank, visiting friends for lunch etc.
Reducing these supports will increase long-term costs, not reduce them. Reducing access to community participation supports does not reduce a participant’s overall support needs — it simply shifts them. Many participants cannot safely remain at home without supervision, so if community access hours are cut, they still require equivalent support in the home environment. The cost to the Scheme does not decrease; instead, participants become more isolated, less engaged, and more dependent on higher-intensity supports over time. Community participation is not an optional extra — it is a protective factor that maintains routines, builds skills, prevents behavioural escalation, and reduces long-term reliance on the NDIS. Cutting these supports will not create savings; it will create risk.
Pricing Pressures and Workforce Sustainability
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2469