National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 250 www.growinggentlypsychology.com.au
admin(§Jgrowinggentlypsychology.com.au
0450012 252
02 82115275
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Growing Gently Psychology
3 Tayter Road, Valley Heights, NSW, 2777
ABN 21 336 429 164
A gB-ntfe approach to parenting and chifd development in the early years
24 May 2026
Re: Concerns regarding proposed changes to the NDIS
My name is Rebecca Cefai. I am a psychologist who works with neurodivergent and disabled parents and children. I am currently self-employed and working in the Blue Mountains region of New South Wales.
Prior to self-employment, I worked as a psychologist within the Nepean Blue Mountains team involved in the pilot of the NDIS Early Childhood Early Intervention approach. I was also one of the first psychologists to work within the NDIS following its rollout as a service provider. I later became a Team Manager for an Early Childhood Partner organisation until 2020. During this time, I contributed clinical input to round table discussions with the NDIA regarding the co-design of the early childhood approach. Hence, I am highly familiar with the legislation, principles, and foundational ideals that originally underpinned both the NDIS and the Early Childhood Approach, including the intended focus on individualised, capacity- building, family-centred, and evidence-informed support.
My submission is informed by both my professional experience within the disability and early childhood sectors, as well as my lived experience as a parent of autistic children and as an autistic and ADHD person myself.
My overall position is that I strongly oppose the proposed Bill in its current form and believe it will be harmful for disabled people, families, clinicians, and the broader community. Please find below a summary of my primary concerns regarding the proposed changes and their likely impacts on disabled individuals, families, service systems, and long-term community outcomes.
- Consultation processes and timeframes do not adequately support disabled participation and reflect broader systemic, political, and economic structures that exclude, silence, and reduce the representation of disabled voices in policy and legislative decision-making.
The timeframe provided for consultation has not allowed disabled people, families, carers, and professionals adequate time to meaningfully engage with changes of this scale and significance. This has impacted the depth and quality of my submission, which I had hoped would be more comprehensively supported by the substantial body of research and evidence that exists in this area. However, due to the limited consultation timeframe and competing professional and caregiving responsibilities, my capacity to adequately review and reference this literature has been significantly constrained.
I believe the limited consultation timeframe itself reflects either an inadequate understanding of, or a disregard for, the everyday realities experienced by many disabled people and families. Disability, caregiving responsibilities, chronic stress, executive functioning difficulties, fatigue, communication barriers, financial strain, and difficulties accessing appropriate support can all significantly increase the time, energy, organisation, and resources required to engage in political and policy consultation processes. For many disabled people and carers, preparing a submission of this nature may require coordinating support workers, interpreters, therapists, advocates, assistive technology, childcare, or substantial recovery time. These barriers are compounded when consultation periods are brief and inaccessible. As a result, the voices of disabled people and their families are less likely to be meaningfully represented and heard within policy processes that directly impact their lives.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 250 www.growinggentlypsychology.com.au
admin(§Jgrowinggentlypsychology.com.au
0450012 252
02 82115275
@growinggenttypsychology
Growing Gently Psychology
3 Tayter Road, Valley Heights, NSW, 2777
ABN 21 336 429 164
A gB-ntfe approach to parenting and chifd development in the early years
Government consultation processes should operate in ways that systematically support disabled people to participate in all aspects of social, political, and economic decision-making, particularly in relation to legislation and reforms concerning disability supports and human rights.
- The proposed changes to the eligibility requirements moves away from utilising pre-existing, well-researched diagnostic criterion, to incorrect and undefined functional capacity labels.
I am concerned about the increasing creation of additional functional categories, thresholds, and administrative labels for funding purposes rather than appropriately recognising existing diagnostic frameworks and clinical assessments already used within healthcare systems.
Diagnoses such as Autism Spectrum Disorder are not provided lightly or based solely on the presence of traits. They are only diagnosed where there is clinically significant impact on functioning, participation, development, wellbeing, or daily life. Diagnostic processes already involve comprehensive assessment of functional impact across multiple environments and are conducted by qualified health professionals using established diagnostic criteria.
Creating additional layers of administrative interpretation beyond existing diagnoses risks increasing duplication, inconsistency, delays, financial burden, and subjective decision-making within the NDIS access process. It also places families in the position of repeatedly having to “prove” disability and impairment despite already completing extensive diagnostic assessments through recognised clinical systems.
A more effective and sustainable approach would involve greater trust in existing diagnostic and clinical expertise while allowing flexibility to consider individual variation in support needs and functioning.
- Foundational Supports will place further burden on the early education and school system and will also stop many neurodivergent children from accessing any support at all.
Thriving Kids proposes expanded “Foundational Supports” delivered through schools and early childhood services with funding pooled rather than allocated to individual participants, support intensity determined at the service or site level, and individual statutory plans not provided for some cohorts.
I have significant concerns that this model fails to adequately consider several important factors. I. Schools, early childhood services, and community organisations are already significantly under- resourced. Teachers, educators, and community-based staff are experiencing high levels of workload stress, burnout, workforce attrition, and insufficient staffing support. Expanding responsibility for disability supports within systems that are already overwhelmed risks further reducing the quality and accessibility of support for disabled children. II. Neurodivergent children often require smaller group environments, individualised approaches, high levels of co-regulation with trusted adults, sensory accommodations, flexibility, and highly responsive relational support. These needs are frequently difficult to sustainably provide within current mainstream education and community systems due to staffing ratios, time constraints, environmental demands, and limited specialist knowledge. So unless the educational system
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 250 www.growinggentlypsychology.com.au
admin(§Jgrowinggentlypsychology.com.au
0450012 252
02 82115275
@growinggenttypsychology
Growing Gently Psychology
3 Tayter Road, Valley Heights, NSW, 2777
ABN 21 336 429 164
A gB-ntfe approach to parenting and chifd development in the early years
undergoes significant reform, support in mainstream educational settings will continue to be insufficient for neurodivergent children. III. Teacher and educator training is primarily designed around supporting neurotypical child development, learning, and behaviour. Many educators report feeling underprepared and overwhelmed when supporting neurodivergent children with complex behavioural, sensory, communication, emotional regulation, and learning needs, particularly where capacity fluctuates significantly. While professional development is valuable and essential, short-term training models cannot replace the years of specialised education, supervised practice, clinical reasoning, and multidisciplinary experience held by allied health professionals working within disability and neurodevelopmental fields. IV. Neurodivergent children are already overrepresented in poor school attendance rates, school refusal, school trauma, and complete school withdrawal. The mainstream education system is often not designed to adequately meet their needs and can contribute to chronic stress, burnout, trauma, exclusion, and mental health deterioration. This results in children being to stressed to attend school, families choosing to home-school, or early childhood centres and schools sending children home when this is not align with the family’s wishes. Children who are unable to consistently attend school due to disability-related barriers may become effectively excluded from accessing disability supports if those supports are primarily embedded within school-based systems. Reducing access to the NDIS or making supports harder to obtain will likely worsen these outcomes.
- Removal of disabled children from the NDIS and redirection toward mainstream health and mental health systems that are not currently equipped to meet their needs risks leaving many children and families without any effective support at all.
The primary healthcare system and public mental health system are not adequately resourced, structured, or trained to support many neurodivergent children with complex developmental, behavioural, sensory, communication, and mental health needs. Many mainstream systems continue to operate within narrow eligibility criteria, limited session models, workforce shortages, long waitlists, and service frameworks that are not designed to adequately support neurodevelopmental disability.
As a psychologist, I have repeatedly experienced situations where disabled children have been declined access to mainstream health and mental health services, including CAMHS and community health teams, even when families are experiencing acute distress or crisis. Families are frequently redirected elsewhere or left without meaningful support options. Shifting disabled children away from the NDIS without first establishing adequately funded, accessible, neuroaffirming, and disability-informed alternative systems risks leaving many children and families without any effective support at all.
- Generic parenting programs are not replacements for disability supports
I am concerned by increasing assumptions that mainstream parenting programs can replace disability- specific and individualised supports for neurodivergent children and families. While programs such as Triple P may provide some foundational parenting knowledge, they are not designed specifically for neurodivergent children or neurodivergent parents. They often lack the nuance, flexibility, sensory understanding, communication knowledge, and relational approaches required to adequately support autistic children, ADHD children, and families with complex support needs.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 250 www.growinggentlypsychology.com.au
admin(§Jgrowinggentlypsychology.com.au
0450012 252
02 82115275
@growinggenttypsychology
Growing Gently Psychology
3 Tayter Road, Valley Heights, NSW, 2777
ABN 21 336 429 164
A gB-ntfe approach to parenting and chifd development in the early years
In my clinical practice, it is very common for families to seek diagnostic assessments, individualised therapy, and NDIS support only after they have already attempted mainstream parenting programs without meaningful improvement in their child’s development, wellbeing, regulation, functioning, or family stress. Many parents accessing the NDIS are not seeking “basic parenting advice.” They are seeking specialised support because mainstream systems and generic interventions have already failed to adequately understand or support their child. Neurodivergent children often require highly individualised, multidisciplinary, and neuroaffirming approaches that consider sensory needs, communication differences, emotional regulation, executive functioning, learning profiles, trauma, participation barriers, and environmental accommodations. These needs cannot be adequately addressed through one-size-fits- all parenting programs alone.
Replacing individualised disability supports with generic parenting interventions risks delaying access to appropriate care, increasing family distress, worsening mental health outcomes, and ultimately creating greater long-term costs across health, education, and social systems.
- Cutting the NDIS budget does not reduce long-term government expenditure unless adequate alternative supports and systems are simultaneously funded, accessible, and appropriately equipped to meet the needs of disabled people.
The government has stated that the NDIS budget has become financially unsustainable and that these proposed changes are necessary to reduce disability-related expenditure. However, when adequate disability supports are unavailable, the burden does not disappear. Instead, it shifts onto other already overstretched systems, including education, emergency healthcare, mental health services, child protection, housing and homelessness services, and the justice system.
Failing to provide timely, individualised, and appropriate supports for disabled children and families creates significantly greater long-term social and economic costs. These costs may include school disengagement, mental health deterioration, caregiver burnout, family breakdown, increased hospital presentations, unemployment, social isolation, and increased future reliance on crisis and tertiary services.
Early and appropriate intervention should be understood not only as a disability support issue, but also as a long-term economic and public health investment.
- The NDIA must acknowledge the role that systemic inefficiencies, administrative burden, inconsistent decision-making, and poor implementation processes have played in contributing to NDIS cost blowouts.
Another significant factor contributing to NDIS budget pressures is the excessive administrative burden placed on health professionals and families through repeated NDIS requests for reports, support needs assessments, and progress reports. As a psychologist, I spend substantial amounts of time writing and often rewriting reports using highly specific NDIS terminology and phrasing to reduce the likelihood of recommendations being misunderstood, rejected, or misinterpreted by NDIA staff who may not have clinical qualifications, disability-specific expertise, or experience interpreting neurodevelopmental presentations.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 250 www.growinggentlypsychology.com.au
admin(§Jgrowinggentlypsychology.com.au
0450012 252
02 82115275
@growinggenttypsychology
Growing Gently Psychology
3 Tayter Road, Valley Heights, NSW, 2777
ABN 21 336 429 164
A gB-ntfe approach to parenting and chifd development in the early years
This process is extremely time-consuming and costly. It often requires clinicians to repeatedly reproduce information already provided in previous reports while shifting away from strengths-based and neuroaffirming frameworks toward deficit-focused medical language in order to justify access to supports. Families are also frequently required to obtain updated assessments and supporting documentation at their own expense simply to maintain existing supports, even where disabilities are lifelong and support needs are well established. This does not represent good use of NDIS funding. This creates unnecessary financial and emotional strain while contributing significantly to administrative waste within the system.
Reducing duplication, streamlining reporting requirements, and increasing reliance on existing clinical evidence would improve both participant outcomes and the long-term sustainability of the NDIS.
- A mandatory registration program for service providers requires a significantly reduced and streamlined registration pathway for sole traders and small businesses who are already registered health professionals.
I acknowledge that the absence of universal mandatory registration for service providers may negatively impact the financial sustainability and integrity of the NDIS and increase the risk of disabled individuals being exploited by unethical or fraudulent providers.
However, I have significant concerns regarding the complexity, administrative burden, and financial cost associated with the current NDIS registration process. As a registered psychologist in private practice who also works part-time, my gross annual income is under $45,000 per year. As such, I cannot reasonably afford the substantial costs associated with becoming an NDIS registered provider, including audit fees, compliance costs, administrative requirements, and the loss of unpaid time required to complete the process. I also do not have the capacity to manage the extensive paperwork and procedural demands involved.
I am concerned that the current registration model disproportionately disadvantages small businesses, sole traders, regional providers, and neurodivergent clinicians, while favouring larger organisations with greater administrative and financial capacity. This risks reducing participant choice and control, limiting access to experienced clinicians, and worsening existing workforce shortages.
I propose that the NDIS introduce a significantly reduced and streamlined registration pathway for sole traders and small businesses who are already registered health professionals and therefore already subject to strict ethical, legal, professional, and regulatory requirements through bodies such as AHPRA. A more proportionate and accessible registration model would improve safeguards and accountability without unnecessarily excluding experienced and appropriately qualified clinicians from the sector.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 250 www.growinggentlypsychology.com.au
admin(§Jgrowinggentlypsychology.com.au
0450012 252
02 82115275
@growinggenttypsychology
Growing Gently Psychology
3 Tayter Road, Valley Heights, NSW, 2777
ABN 21 336 429 164
A gB-ntfe approach to parenting and chifd development in the early years
While the NDIS is not perfect and improvements are needed, the proposed Bill in its current form is harmful and risks creating further barriers, inequity, distress, and exclusion for disabled people and their families. I strongly urge Parliament not to pass this Bill in its current form.
Yours sincerely,
Rebecca Cefai Psychologist PSY0001894898 BA(Psych); PGDipPsy
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