Submission 251
Submission regarding practical impacts of the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 on regional Early Childhood Intervention services
Senate Inquiry Submission
We are writing from the perspective of a regional provider delivering Coordinated Early Childhood Intervention Supports to children aged 0–7 years through the NDIS Early Childhood Approach.
Our service provides multidisciplinary developmental supports including Speech Pathology, Occupational Therapy, Physiotherapy and Educator services using a coordinated family-centred model. We work with children with developmental delay, disability and complex developmental needs during the critical early years, when timely intervention can significantly influence communication, participation, mobility, school readiness and long-term developmental outcomes.
The stated aim of improving sustainability and consistency in the NDIS is understandable. However, several provisions in this Bill raise significant concerns about how these changes may impact children in the early years, families in regional communities and services providing coordinated developmental intervention.
- Section 9B: Functional Capacity Definition
Concern
The Bill introduces a legal definition of functional capacity based on a person’s ability to perform activities without supports, environmental modifications or assistance.
While this may create administrative consistency, this approach creates concern in early childhood developmental practice.
Young children often function very differently depending on:
Submission 251
- caregiver support
- environmental structure
- sensory demands
- communication supports
- preschool context
- family capacity A child may demonstrate a skill in a familiar and safe setting but still be unable to function effectively in everyday environments without significant support.
Likely real-world impact
For children aged 0–7:
- developmental concerns may be underestimated
- participation difficulties may not be captured
- children with emerging developmental delay may miss access to support
- children with neurodevelopmental differences may not fit a rigid threshold despite clear functional vulnerability
This is particularly concerning for children with:
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autism
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developmental language disorder
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ADHD with functional impacts
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global developmental delay
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complex neurodevelopmental presentations where support needs vary across contexts
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complex and or rare genetic conditions Early childhood disability is often context dependent. Functional assessment that removes context risks reducing accuracy in this age group.
- Access Criteria Changes: “Substantially Reduced Functional Capacity”
Threshold
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Concern
The Bill appears to tighten eligibility by requiring a significant and ongoing reduction in functional capacity.
In early childhood, many developmental concerns are:
- emerging
- not yet stable
- variable across settings
- not fully diagnostically clear Children may benefit from intervention before functional impairment becomes significant.
Likely real-world impact
This may result in:
- delayed access to early intervention
- children entering support later, after developmental gaps widen
- increased behavioural and emotional consequences
- reduced opportunity for prevention In practice, children may need to “fail more” before receiving support and this is a deficit based approach.
This creates concern because early intervention works precisely because it occurs when neuroplasticity is most effective.
- Section 48A: Stricter Reassessment Thresholds
Concern
The Bill appears to require a significant and ongoing change in support needs before a reassessment can occur.
This may not reflect childhood development.
Young children’s support needs change because of:
- developmental progression
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- school transition
- preschool/early leaning education and care setting participation demands
- communication demands increasing with age
- mobility changes
- changes in family support
- emerging behavioural or sensory needs These changes are often gradual but developmentally and functionally important.
Likely real-world impact
This may result in:
- children remaining on outdated plans
- delayed access to appropriate supports
- practitioners needing to document deterioration rather than developmental need
- missed developmental windows
- families reaching crisis before reassessment thresholds are met For children in the early years, waiting for significant decline may undermine impact of early intervention in their everyday lives now and into the future.
- Section 34 Changes: Support Must Arise Directly from an Eligible Impairment
Concern
The Bill appears to narrow funding so supports must arise directly from the impairment meeting access criteria.
In early childhood developmental practice, children rarely present with isolated impairments as each child’s developmental profile is unique.
Children often have overlapping needs involving:
- communication
- sensory regulation
- motor skills (gross & Fine)
- behaviour
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- cognition
- social & emotional skills and development
- play
- family capacity and environmental support needs These domains are interconnected in everyday life and impact significantly on inclusion and participation.
Likely real-world impact
This may create:
- artificial separation of developmental needs
- inaccuracy over causation
- fragmented therapy planning
- reduced flexibility in multidisciplinary intervention
- increased administrative burden For coordinated developmental services, this may make it harder to deliver integrated whole-child support.
Children do not develop in isolated legislative categories.
- Ministerial Support Determinations (Group Funding Reduction Powers)
Concern
The Bill appears to allow broad reductions to categories of supports across groups rather than based on individual need.
While intended as a sustainability mechanism, there is concern about the practical consequences for honouring the individual developmental journey of each child.
Likely real-world impact
If categories relevant to Early Childhood Intervention are reduced:
- families may receive less support than functionally required
- multidisciplinary supports may become harder to structure effectively
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- services may become less responsive to individual developmental trajectories In paediatric practice, children’s developmental needs often require flexible intensity over time.
Broad category-based reductions may not reflect this.
- Plan Renewal Changes and Removal of Fund Flexibility
Concern
The proposed move toward annual renewal and reduced carry-over flexibility raises practical concern for Early Childhood Intervention supports.
Children’s developmental trajectories are not predictable within rigid funding periods.
Some periods require:
- increased therapy
- equipment needs
- transition support
- school readiness focus
- short bursts of focused intervention Other periods may require less intensity.
Likely real-world impact
Reduced flexibility may create:
- inefficient use of supports
- pressure to use funding within arbitrary cycles
- reduced capacity to respond to developmental transitions
- loss of family-centred planning flexibility For children in the early years, support needs often fluctuate as development unfolds.
- Sustainability as a Legislative Principle
Concern
The Bill strengthens sustainability as a formal legislative principle.
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Sustainability is important. However, there is concern if this becomes operationalised in a way that prioritises short-term cost containment over developmental prevention.
Likely real-world impact
Reduced Early Childhood Intervention support may increase downstream costs in:
- education systems
- behavioural and mental health services
- family support systems
- later disability supports
- workforce participation impacts for parents A child who receives timely Early Childhood Intervention support may require less intensive support later.
Sustainability should include long-term developmental and social outcomes, not only immediate scheme expenditure.
- Regional Implementation Concerns Across the Bill
Concern
Across multiple amendments, there is concern that tighter access, reduced flexibility and reassessment restrictions may disproportionately affect regional communities.
Regional families already face:
- practitioner shortages
- limited provider choice
- travel burdens
- service gaps
- fewer specialist alternatives Likely real-world impact
This may lead to:
- increased inequity between metro and regional children
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- longer delays to early intervention
- increased pressure on early learning settings, schools and families
- reduced viability of coordinated multidisciplinary regional services In regional communities, the loss or destabilisation of one service can have broad community consequences.
- Workforce and Service Sustainability Concerns
Concern
Implementation of tighter eligibility, reassessment barriers and more restrictive funding may increase administrative complexity for providers.
Coordinated developmental services require:
- multidisciplinary planning
- family engagement
- reporting
- liaison across settings
- workforce collaboration Likely real-world impact
Potential consequences include:
- increased unpaid practitioner time
- workforce burnout
- reduced efficiency
- reduced intake capacity
- financial pressure on small regional providers
- possible provider withdrawal or closure This may reduce access even where policy intent is to improve sustainability.
Conclusion
There is broad understanding that the NDIS must be sustainable and consistent.
Submission 251
However, several provisions in this Bill raise significant concerns in the Early Childhood Intervention context, particularly regarding:
- Section 9B functional capacity assessment
- tightened access thresholds
- Section 48A reassessment restrictions
- Section 34 narrowing of impairment-support links
- broad funding determination powers
- reduced plan flexibility For young children, Early Childhood Intervention requires a responsive, individual and coordinated approach.
If these changes are implemented without safeguards, there is concern they may:
- delay access to Early Childhood Intervention
- reduce developmental progress and capacity
- increase pressure on families, early learning settings and schools
- worsen regional inequity
- destabilise coordinated multidisciplinary services Children only have one early childhood. Legislative sustainability measures should ensure this developmental window is protected.
Practical Recommendations
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Amend Section 9B to ensure functional capacity assessments for children account for developmental context and participation across everyday environments
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Retain pathways for Early Childhood Intervention where developmental risk is present, before severe functional decline occurs
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Modify Section 48A reassessment criteria to recognise developmental change and childhood transitions
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Ensure Section 34 implementation does not fragment multidisciplinary developmental supports for children with overlapping needs
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Require impact monitoring for regional access, workforce sustainability and provider viability
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- Embed long-term developmental outcomes into sustainability measures and implementation review