Concerns regarding evidence requirements and therapy access for individuals with severe intellectual disability and autism (Provider experience) | External submission

Submission 260

SUBMISSION TO THE SENATE COMMUNITY AFFAIRS LEGISLATION

COMMITTEE

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill

2026

Submitted by: Emily Healy

Tailored Developmental Therapies

South Australia

26 May 2026

I am writing to express serious concerns about the proposed NDIS Amendment Bill and its impact on disability service delivery, workforce sustainability, access to evidence-based supports, and the protection of people with high and complex support needs.

CONTEXT: PROFESSIONAL ROLE AND EXPERTISE

I operate a 12-year-established disability support practice (Tailored Developmental Therapies) delivering specialised therapeutic services to clients with developmental and neurological conditions, including autism, ADHD, and associated support needs. Our team includes trained support workers, DIR Floortime practitioners, and therapeutic specialists. We work with some of the most complex and vulnerable clients in the disability sector—particularly non-speaking autistic children and adults, people with profound intellectual disability, and those with severe behaviours of concern requiring intensive therapeutic intervention. Our evidence-based therapies target:

Speech and communication development in non-verbal and minimally verbal autistic individuals
Nervous system regulation—calming over- and under-responsive neurological responses
Long-term neural pathway development and motor planning
Visual and auditory processing improvement
Reduction of violent and self-injurious behaviours through therapeutic intervention I also supervise support workers and manage client planning. Most critically, I was recently diagnosed with ASD and ADHD while in burnout, after decades of medical professionals dismissing my needs. I am speaking from both professional expertise and lived experience.

SPECIFIC CONCERNS

THE “GENERALISABLE EVIDENCE” PROBLEM: EXCLUDING HIGH-NEED

POPULATIONS FROM THERAPY ACCESS

The Bill introduces a critical gatekeeping mechanism that will deny evidence-based therapies to people who need them most. The legislation states that the CEO must give the greatest weight to evidence that is ‘published, peer reviewed and generalisable.’ Further, the CEO may refuse funding if there is ‘limited or no research or evidence of the kind mentioned’ — even when evidence specific to the participant exists.

Submission 260

This is catastrophic for non-verbal autistic children, people with profound intellectual disability, and those with severe support needs. These populations are systematically absent from generalised research. The very individuals for whom specialised, intensive therapies are most critical are the ones most likely to be excluded by this evidence standard. I have already experienced this. Clients with non-speaking autism, severe intellectual disability, and complex behaviours requiring intensive intervention have been denied access to our evidence-based therapies because the NDIA has decided the research base is ‘insufficient’—not because our therapies are ineffective, but because adequately representative research does not exist. The Bill relies on generic meta-analyses (such as Sandbank et al., 2024, JAMA Pediatrics) that do not represent minimally verbal autistic children or those with severe intellectual disability. The authors themselves caution practitioners to be especially careful when determining intensity for high support-needs populations at risk of injury if unsupported. This Bill ignores that caution and provides no protection for people who will be harmed by insufficient therapy.

THE 50% CUT TO SOCIAL, CIVIC AND COMMUNITY PARTICIPATION

SUPPORTS

This proposed cut will directly harm the viability of person-centred, evidence-based disability services. Our therapeutic tabletop gameplay, and mentored support workers all sit within this category. These are not frivolous activities—they are structured therapeutic interventions that build capacity, support nervous system regulation, and create genuine community connection for people with autism and developmental differences. For our non-verbal clients and those with profound support needs, group-based community activities are often impossible. A 50% budget cut forces a false choice: close services or reduce quality. Our practice has spent 12 years building trust-based relationships with clients and families who have often been failed or rejected by mainstream services. We cannot absorb a 50% revenue reduction while maintaining the supervision, training, and quality that make our services safe and effective. Clients who need support to attend therapy are at risk of not being able to attend.

MAXIMUM THERAPY INTENSITY CAPS: RISK OF HARM FROM INSUFFICIENT

INTERVENTION

The Explanatory Memorandum states the Bill may ‘specify a maximum intensity for a particular therapy support if research shows that any more than that intensity does not add any benefit for an individual.’ The example given is ‘12 hours per year of a particular kind of therapy support.’ For a non-speaking autistic child or a person with severe intellectual disability requiring intensive speech, motor, and nervous system support, 12 hours per year is not intervention—it is abandonment. This approach provides no protection for participants at risk of harm due to insufficient intensity. Our clients with severe behaviours of concern, self-injurious behaviours, or profound speech and motor delays require sustained, intensive therapeutic intervention. Arbitrary caps based on generic research will not reflect their actual needs. The Bill provides no mechanism to protect people who require more intensive support to prevent harm.

WORKFORCE VIABILITY AND JOB LOSSES The combined impact of 50% support cuts and maximum intensity caps will force the closure of specialist services. Our practice employs mentored support workers—people who are themselves neurodivergent or from disability backgrounds, who have been trained into skilled roles. These workers have family obligations and depend on stable employment.

Submission 260

A 50% cut to social and community supports, combined with evidence-based caps that exclude high need populations, means we cannot maintain our workforce. Support workers will lose jobs. The expertise and training they represent will be lost. The disability sector is already struggling with workforce recruitment and retention; this bill makes it worse. Our two support work trainees (in a government-supported traineeship) are at risk of losing their positions.

ACCESS AND ELIGIBILITY: EXCLUDING PEOPLE WHO MOST NEED SUPPORT As someone recently diagnosed with ASD and ADHD, I have lived experience of the gatekeeping that this bill will formalise and worsen. I was repeatedly told by medical professionals that I couldn’t have autism, that my difficulties were psychological. I had no family support beyond my husband—no parental advocacy, no siblings to bridge gaps. The proposed new eligibility framework, with tighter functional capacity assessment and ‘generalisable evidence’ requirements, will exclude people like me—people with late diagnoses, complex trauma histories, and masked presentations. It will also exclude people without family support systems to navigate complex assessment processes. More critically, it will exclude precisely the people I serve: non-speaking autistic individuals, people with severe intellectual disability, and those with complex behavioural needs. The bill claims to clarify eligibility. In practice, it narrows access for people with genuine, significant support needs.
SYSTEMIC RISK: CASCADE EFFECTS When specialist disability services close, the burden shifts to emergency services, mental health systems, and hospitals. When people lose access to the therapeutic supports they depend on, their capacity decreases. Crisis presentations increase. For our non-verbal clients and those with severe behaviours, loss of intensive therapeutic support will lead to increased self-injury, aggression, and hospitalisation. The costs will shift to emergency departments, not disappear. This is not sustainability. It is cost-shifting.
LACK OF CONSULTATION AND EVIDENCE The disability sector—particularly therapists and services supporting high-need populations—was not meaningfully consulted. Advocates and service providers are expressing serious concerns that remain unaddressed. Where is the evidence that ‘generalisable evidence’ standards improve outcomes for non-speaking autistic children or people with severe intellectual disability? Where is the modelling of workforce impact? Where is the cost accounting showing that shifting costs to emergency services actually saves money? This bill is being rushed through Parliament without adequate scrutiny.

WHAT NEEDS TO HAPPEN

I am asking the Senate Committee to:

Remove or substantially revise the ‘generalisable evidence’ standard to protect access for underrepresented populations (non-speaking autistic people, those with severe intellectual disability, high-support-needs individuals). Require that individualised evidence and participant-specific outcomes are given equal weight.
Add explicit protections for maximum-intensity caps: any maximum must include a carve-out for participants at risk of harm from insufficient support, with demonstrable harm prevention requirements.

Submission 260

Require the government to provide whole-of-government cost accounting, including impacts on Centrelink, Medicare, mental health, hospitals, and emergency services.
Commission an independent evidence review on the impact of support reductions on non- verbal autistic people and those with severe support needs.
Require meaningful consultation with therapists, disability service providers, and advocates for high-support-needs populations before the bill passes.
Delay the 50% cut to social and community supports and intensity cap provisions pending this evidence and consultation.
Require an impact assessment on disability sector workforce viability and small disability service providers.

CONCLUSION

I have spent 12 years building a service that changes lives for people with developmental and neurological differences—particularly those who have been failed by mainstream services. This work is only possible because the NDIS supports made it viable. But more importantly, this bill threatens the people I serve—non-speaking autistic individuals, people with severe intellectual disability, and those with complex needs who have finally found services that understand them, that are person-centred and evidence-based, that support genuine capacity building. The ‘generalisable evidence’ standard will deny these people access to evidence-based therapies simply because research representing their cohorts does not exist, not because our therapies are ineffective. Maximum intensity caps will restrict support to unsafe levels. This is harm. I am asking the Senate to scrutinise this bill properly, to require evidence, to consult genuinely with the disability sector and therapists, and to pause implementation of the most damaging measures pending that scrutiny. The future of the NDIS should be secured by protecting access for people with genuine, significant support needs—not by narrowing eligibility and cutting supports to viable, person-centred services, and not by adopting evidence standards that systematically exclude the people most in need.

Respectfully submitted,