Impact of NDIS reforms on access to therapy supports (Individual advocacy) | External submission

Submission 2646

Submission to the Senate Community Affairs Legislation Committee

Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future

Generations) Bill 2026

Author Background

I make this submission from three perspectives:

as a professional working within the disability sector;
as an NDIS participant; and
as a parent of children with disability, including a child with high support needs. These combined experiences provide me with a unique perspective on the strengths and shortcomings of the current system. I have observed the NDIS as a participant, as a parent navigating supports for children with disability, and as a professional working alongside participants, families, therapists, support coordinators and providers.

While my lived experience informs many of the observations contained within this submission, this submission is primarily focused on systemic issues, administrative processes, workforce challenges, service gaps and sustainability considerations observed through my professional experience.

I intend to provide a separate submission outlining my personal experiences as an NDIS participant and as the parent of children with disability, including a child with high support needs. I believe both perspectives are important and should be considered independently.

I would also be happy to be contacted to discuss these issues further, as there is significantly more I could provide beyond what I have included in this submission.

Introduction

I acknowledge that the current trajectory of NDIS expenditure is unsustainable and that reform is necessary to ensure the Scheme remains viable for future generations of Australians with disability.

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

2026 has been referred to the Senate Community Affairs Legislation Committee, and the Committee has stated that submissions must directly address the provisions of the Bill. The Bill is described by the Parliamentary Library as being primarily aimed at reducing projected growth in NDIS expenditure and participant numbers, while also strengthening fraud controls, provider regulation and governance arrangements.

I support the objective of securing the NDIS for future generations. However, I am concerned that many of the proposed reforms appear focused on reducing NDIS expenditure rather than addressing the underlying drivers of demand, inefficiency, workforce shortages, poor coordination, inadequate mainstream services and administrative burden.

Submission 2646

Reducing participant access may lower NDIS expenditure in the short term, but this does not necessarily reduce overall government expenditure. There is a significant risk that costs will simply be transferred to:

public health services;
mental health services;
education systems;
housing and homelessness services;
income support programs;
carers and families;
child protection systems; and
crisis services. Many participants rely on therapy and disability supports to remain employed, participate in education, maintain independence, care for their families, build capacity and reduce reliance on other government systems.

If these supports become inaccessible, the likely result will be increased unemployment, greater reliance on income support payments, increased mental health presentations, increased hospital admissions, increased family breakdown and greater long-term costs to government.

There is also a risk that increasingly unaffordable mainstream allied health services will reduce workforce participation. Individuals who lose access to supports may be unable to maintain employment, while those who do not qualify for the NDIS may be unable to afford private therapy without a concession card or other government assistance. This creates unintended incentives that may increase, rather than decrease, reliance on government support.

A reduction in NDIS expenditure should not be considered a success if it simply transfers costs elsewhere.

The NDIS should not only be measured by what it costs. It should also be measured by what costs it prevents. Every participant who remains employed, avoids hospitalisation, maintains independence, prevents family breakdown, delays entry into supported accommodation or reduces reliance on other government services represents a saving elsewhere in the system.

The Parliamentary Library’s Bills Digest identifies that Schedule 1 of the Bill contains access and planning amendments, including a new definition of functional capacity; Schedule 2 contains fraud, compliance and provider regulation amendments; and Schedule 3 contains governance amendments, including changes relating to pricing and automated administrative actions.

My recommendations relate directly to these themes.

Submission 2646

Recommendation 1: Strengthen Mainstream Services Before Restricting NDIS Access

Relevant Bill areas

This recommendation relates to:

Schedule 1: access and planning amendments;
the proposed focus on functional capacity;
consideration of access to other service systems;
the Bill’s broader sustainability objectives. One of the largest drivers of increasing NDIS demand is the weakening of mainstream allied health, education and health systems.

The NDIS is increasingly becoming the “only lifeboat” because mainstream systems are not adequately funded, accessible or equipped to support people early. If mainstream services are not strengthened before NDIS access is restricted, people will simply be left without support until their needs become more complex and more expensive.

One practical way to address this demand is to require allied health professionals to complete a minimum of three to five years working within mainstream, public, community or supervised service settings before becoming eligible to provide NDIS-funded services independently.

This could include work in:

public health;
community health;
schools;
early intervention services;
hospitals;
child development services;
mental health services;
low-cost community-based therapy settings. The benefits would include:
increased workforce capacity within mainstream services;
improved access to early intervention;
reduced pressure on the NDIS as the default pathway for support;
greater clinical experience among NDIS providers;
improved affordability for families who do not qualify for NDIS funding;

Submission 2646

better professional understanding of mainstream systems before clinicians move into NDIS- funded practice;
improved quality and consistency of supports delivered to NDIS participants;
reduced risk of inexperienced clinicians working beyond their capability;
stronger justification for higher NDIS rates where the work involves greater complexity and responsibility.

At present, many clinicians are drawn directly into NDIS-funded work due to significantly higher remuneration. In some cases, they may move into NDIS service delivery with very limited practical experience beyond their qualification, registration requirements and business setup. This has reduced workforce capacity within mainstream services and limited access for people who do not qualify for NDIS funding.

This is not sustainable. If the government wants fewer people relying on the NDIS, then people must be able to access meaningful support outside the NDIS.

People who gain access to the NDIS generally do so because they have complex, significant and lifelong support needs. This is not comparable to general mainstream service delivery. NDIS participants often require support that involves complex disability-related functional impacts, behavioural needs, communication needs, psychosocial factors, family systems, risk management, multidisciplinary collaboration and long-term capacity building.

It is therefore reasonable to expect that allied health professionals delivering NDIS-funded supports have a sufficient level of practical experience before working independently within the Scheme.

A newly graduated allied health professional may have strong theoretical knowledge, but they cannot reasonably be expected to have the same practical skills, clinical judgement or disability-sector experience as a practitioner who has spent several years working with diverse clients in mainstream or public systems.

This is not a criticism of new graduates. It is recognition that complex disability support requires experience, supervision and professional development.

Other professions already recognise this principle. Doctors, for example, do not move directly from university into independent specialist practice. They complete internship, residency and further specialist training before working independently in complex areas of medicine. A similar principle should apply to allied health professionals who wish to provide NDIS-funded services to participants with complex and lifelong support needs.

If NDIS participants are accepted into the Scheme because their needs are significant, complex and lifelong, then the workforce supporting them should be appropriately experienced and trained.

This would also help restore confidence in NDIS pricing. Higher NDIS rates are easier to justify when they reflect higher complexity, greater responsibility and a more experienced workforce.

Submission 2646

Recommendation 2: Restore Affordable Mainstream Allied Health Services

Relevant Bill areas

This recommendation relates to:

Schedule 1: access and planning;
sustainability;
consideration of other service systems;
Schedule 3: pricing mechanisms. Following concerns regarding NDIS pricing and allegations of price gouging, many providers increased their fees across all clients to align with NDIS rates.

While this may have been intended to address inconsistent pricing, it has had the unintended consequence of making mainstream allied health services increasingly unaffordable for many Australians.

This may have increased reliance on the NDIS rather than reducing it.

NDIS-funded work generally requires:

more complex interventions;
greater reporting obligations;
increased documentation;
higher compliance requirements;
more multidisciplinary collaboration;
more time spent liaising with families, support coordinators, schools and other professionals;
additional administrative responsibilities. It is reasonable that NDIS-funded services attract higher fees than mainstream services, because NDIS participants often have more complex support needs. That is why they are on the NDIS in the first place.

The problem is not that providers charge more for genuinely more complex work. The problem is that mainstream/private rates have increased to match NDIS rates, making non-NDIS services unaffordable for many families.

This creates a cycle where people become more reliant on the NDIS because mainstream supports are no longer accessible.

Restoring a clear distinction between mainstream pricing and NDIS pricing would improve affordability outside the Scheme while recognising the additional responsibilities associated with NDIS service delivery.

Submission 2646

Recommendation 3: Reform Provider Travel Funding

Relevant Bill areas

This recommendation relates to:

Schedule 2: provider regulation and compliance;
Schedule 3: pricing;
sustainability and efficient use of participant funding. Provider travel is one of the most significant areas where participant funding is lost before direct support is delivered.

For example, an occupational therapist travelling from Geelong to Colac and returning can incur approximately $344 in travel costs before any therapy is delivered.

The issue is not providers claiming funding that the NDIS permits them to claim. Any business can reasonably be expected to utilise the funding arrangements available to it.

The issue is whether those funding arrangements represent the best use of participant funding and taxpayer resources.

Participants in rural and regional areas are particularly disadvantaged. They may already have limited provider choice, long waitlists and few alternatives. When travel costs are deducted from participant plans, the result is fewer hours of actual therapeutic support.

I recommend:

retaining payment for reasonable travel time;
removing participant-funded kilometre charging;
allowing vehicle expenses to be managed through standard taxation arrangements, as occurs in most professions;
providing targeted incentives or annual bonuses for providers who regularly service rural and regional communities;
developing regional provider hubs or outreach models that reduce repeated individual travel costs;
requiring transparent travel cost-sharing arrangements where multiple participants are seen in one regional area.

This would direct more participant funding toward actual support while still maintaining service availability in rural and regional communities.

Submission 2646

Recommendation 4: Stop Calling Provider Travel “Agreement” When There Is No Genuine Choice

Relevant Bill areas

This recommendation relates to:

Schedule 2: provider regulation and compliance;
participant protections;
pricing and administrative fairness. The NDIS frequently describes travel charges and other separately claimed line items as being subject to agreement between providers and participants.

In reality, this is rarely a genuine agreement.

Participants often have little or no negotiating power. Their options are often reduced to:

accept the provider’s conditions; or
go without support. This is particularly evident in rural and regional areas where provider availability is limited.

If the NDIS allows providers to claim a line item, many providers will claim it. That does not necessarily mean the provider is doing anything wrong. The issue is that the system permits funding to be used in a way that reduces the participant’s actual support.

Participants are left with reduced budgets and fewer appointments, while the system continues to describe the arrangement as though it was freely negotiated.

This is not genuine choice and control.

Where a provider has agreed to see multiple participants in a regional area and one participant cancels, the remaining participants should not be required to absorb increased travel costs through no fault of their own.

Nationally consistent travel and cancellation arrangements should be introduced to improve fairness, reduce disputes and prevent participant plans being drained by administrative and travel costs.

Submission 2646

Recommendation 5: Mandatory Parent and Carer Training as Part of Therapy

Relevant Bill areas

This recommendation relates to:

Schedule 1: reasonable and necessary supports;
functional capacity;
improved outcomes;
sustainability through more effective use of funding. Parent and carer training should be a mandatory component of therapy supports involving children.

In practice, many parents do not know:

what goals therapists are working on;
what strategies are being implemented;
what progress is expected;
how to practise skills between appointments;
how to respond consistently to behaviours;
how to support skill generalisation at home, school and in the community. This is a major problem.

A child may attend speech therapy, occupational therapy, psychology or behaviour support once a week, fortnightly or monthly. If the family does not understand what is being worked on, those strategies are not practised between appointments. This means skills take longer to develop, are less likely to generalise and may not stick at all.

Therapy should not be treated as something that happens only in a clinic room classroom or home. It should be a holistic approach across all of a child’s environments.

Therapy should include practical parent and carer coaching so that strategies are embedded into daily life.

This could include:

therapists clearly explaining current goals;
written home strategies after each session;
modelling strategies for parents and carers;
coaching parents during real-life routines;
showing families how to use visual supports, sensory strategies, communication tools and behaviour support strategies;

Submission 2646

checking whether strategies are actually practical for the family;
reviewing whether strategies are being implemented between sessions;
ensuring parents understand what progress should look like. For example, if an occupational therapist is working on emotional regulation, the parent should know what regulation strategies are being used, when to use them, how to prompt them and how to practise them during everyday moments.

If a speech therapist is working on functional communication, the parent should know how to model language, use visuals or communication devices, and create opportunities for communication at home.

If a psychologist or behaviour practitioner is working on reducing distress behaviours, parents and carers need to understand the underlying function of the behaviour and how to respond consistently.

Without this, therapy becomes less effective and more expensive over time.

Mandatory parent and carer training would improve outcomes and reduce long-term costs by ensuring that therapy is carried over into everyday environments. The PCIT (Parent Child Interaction Therapy) is a perfect example of the types of parenting training that should be included under the NDIS.

Submission 2646

Recommendation 6: Mandatory Provider Collaboration and Care Team Communication

Relevant Bill areas

This recommendation relates to:

Schedule 1: planning and reasonable and necessary supports;
Schedule 2: provider obligations;
administrative efficiency;
reduction of duplication. There should be mandatory requirements for provider collaboration.

This could include:

bi-monthly care team meetings; or
a free NDIA-managed communication platform allowing providers to coordinate goals, interventions and progress updates.

The amount of duplicated work, conflicting recommendations and lack of communication occurring across provider teams is concerning.

Providers frequently work in isolation despite supporting the same participant.

For example, a child may have:

an occupational therapist;
a speech pathologist;
a psychologist;
a behaviour support practitioner;
a support coordinator;
school staff;
therapy assistants;
support workers. If these people are not communicating, the participant may receive conflicting strategies. One provider may recommend one approach while another recommends something completely different. Parents and teachers are then left trying to work out which advice to follow.

This is inefficient, confusing and often harmful to progress.

Lack of collaboration can result in:

duplicated assessments;

Submission 2646

duplicated goals;
inconsistent language;
conflicting behaviour strategies;
increased parental stress;
slower participant progress;
unnecessary spending;
poor accountability. A free national platform could allow providers to upload:
current goals;
strategies being used;
progress updates;
recommendations;
risk alerts;
school implementation notes;
family implementation notes. This would allow all providers to work toward the same outcomes and reduce duplication.

Submission 2646

Recommendation 7: Improve Teacher Training and Disability Education in Mainstream Schools

Relevant Bill areas

This recommendation relates to:

Schedule 1: access and planning;
consideration of mainstream services;
functional capacity;
sustainability;
reducing future demand on the NDIS. One of the most overlooked areas of early intervention is the education system.

Schools are increasingly supporting children with neurodevelopmental disabilities, including Autism Spectrum Disorder, ADHD and PDA profiles. However, many teachers receive limited practical training in how to understand and support these students in mainstream classrooms.

This is a major gap.

In 2022, 12.1% of Australians aged 0–24 had disability, and the rate for children aged 0–14 was 11.0%. Among children and young people with disability, mental and behavioural disorders were the most common main condition group, and for children aged 0–14 with disability, ADHD and autism were among the most commonly reported main conditions.

Autism is also increasingly common in school-aged children. ABS data shows that 4.3% of children aged 5–14 were autistic in 2022, up from 3.2% in 2018.

ADHD is also highly prevalent. The Australian evidence-based clinical practice guideline for ADHD states that ADHD occurs in approximately 6–10% of Australian children and adolescents.

Given these figures, disability education should not be treated as a specialist optional area of teacher training. It should be a core competency for all teachers.

A full mandatory unit should be included in teaching degrees, particularly focusing on:

Autism Spectrum Disorder;
ADHD;
PDA profiles;
sensory processing differences;
executive functioning difficulties;
emotional regulation;
trauma-informed practice;

Submission 2646

behaviour as communication;
school refusal;
masking;
burnout;
co-regulation;
reasonable adjustments;
inclusive classroom design;
communication differences;
supporting students without escalating distress. Teachers are often expected to manage complex disability-related needs without being given adequate training.

This contributes to:

increased behavioural incidents;
increased suspensions and exclusions;
school refusal;
family stress;
mental health deterioration;
increased demand for therapy;
increased applications to the NDIS;
increased reliance on external behaviour support. Many behaviours seen in classrooms are not deliberate defiance. They may reflect anxiety, sensory overload, communication difficulties, executive functioning challenges, demand avoidance, trauma responses or a lack of appropriate adjustment.

This is particularly important for PDA profiles. Children with PDA often respond poorly to traditional behaviour management approaches based on rewards, consequences and direct demands. These approaches can escalate distress rather than reduce it. Teachers need training in low-demand approaches, collaborative problem-solving, nervous system regulation and flexible support.

Similarly, students with ADHD may not be able to simply “try harder” to focus, sit still, remember instructions or manage impulses. They may require structured supports, movement breaks, visual reminders, reduced cognitive load, chunked instructions and positive regulation strategies.

Autistic students may require sensory adjustments, predictable routines, communication supports, reduced social demands and explicit teaching of expectations.

Submission 2646

Without this training, schools unintentionally increase distress and disability-related functional impacts. Families then turn to the NDIS for support that should have been partly addressed through a better equipped mainstream education system.

Improved teacher training would likely:

reduce behavioural escalation;
reduce suspensions and exclusions;
reduce school refusal;
improve mental health outcomes;
improve educational engagement;
reduce family stress;
reduce demand for externally funded behaviour support;
reduce future reliance on the NDIS. If the Bill proposes that other service systems should be considered when determining NDIS supports, then those other service systems must be properly equipped to support children with disability.

At present, many are not.

Submission 2646

Recommendation 8: Improve Education for Schools and Families Around Disability Implementation

Relevant Bill areas

This recommendation relates to:

Schedule 1: access, planning and functional capacity;
mainstream supports;
sustainability. In addition to teacher training at university level, there should be ongoing professional development for current teachers, education support staff, principals and wellbeing teams.

Many families spend enormous emotional energy trying to educate schools about their child’s disability. This should not fall entirely on parents.

Schools should have access to practical training on:

how autism presents differently in different children;
how ADHD affects executive functioning;
how PDA profiles can affect responses to demands;
how anxiety can present as behaviour;
how sensory overload affects learning;
how to implement reasonable adjustments;
how to work with therapists;
how to support communication needs;
how to de-escalate rather than punish disability-related distress. This would reduce the burden on parents and improve consistency between home, therapy and school.

There should also be clearer expectations that schools implement reasonable therapy-informed strategies where appropriate. Too often therapists make recommendations, but schools do not have the training, time or confidence to implement them consistently.

This undermines the effectiveness of therapy and increases NDIS costs.

If a child is learning regulation strategies, communication strategies or social-emotional skills through NDIS-funded therapy, those strategies need to be reinforced at school. Otherwise progress is slower and funding is used less effectively.

A stronger connection between education and therapy would improve outcomes and reduce duplication.

Submission 2646

Recommendation 9: Improve Delegate Training and Decision-Making

Relevant Bill areas

This recommendation relates to:

Schedule 1: planning and access decisions;
Schedule 3: automated administrative actions;
administrative fairness;
decision-making quality. Assessments and professional reports must be properly reviewed and considered during decision making.

Too many decisions appear to be based on assumptions regarding what is considered “typical” rather than the evidence provided by treating professionals.

This contributes to:

internal reviews;
appeals;
Administrative Review Tribunal proceedings;
increased administrative costs;
delays in support;
participant distress;
additional burden on families and providers. The Bills Digest notes that the Bill includes changes relating to access and planning, functional capacity, reasonable and necessary supports, and automated administrative decision-making. It also notes expert concern that any shift to functional assessment depends on the integrity of assessment tools and the professionals using them, and that computational systems used in decision-making must be transparent and able to accommodate individual circumstances.

This is extremely important.

If delegates are not properly trained, functional capacity assessments may become another source of inconsistent and unfair decision-making.

There also appears to be a need for improved delegate training around terminology and professional roles.

For example, I have personally been required to provide evidence that a Level 2 Therapy Assistant is equivalent to what was previously known as an Allied Health Assistant simply because the title changed.

Submission 2646

Situations such as these create unnecessary administrative burden and delays while adding no value to participant outcomes.

Delegates should receive better training in:

allied health roles;
therapy assistant roles;
disability-related terminology;
functional capacity;
neurodevelopmental disability;
psychosocial disability;
developmental delay;
evidence interpretation;
regional service barriers;
the difference between diagnosis and functional impact;
how to read professional reports. Poor decision-making does not save money. It creates internal reviews, appeals, delays and additional administrative costs.

Submission 2646

Recommendation 10: Strengthen Mainstream Health Pathways

Relevant Bill areas

This recommendation relates to:

Schedule 1: consideration of mainstream service systems;
access and planning;
sustainability. The current Chronic Disease Management Plan provides access to only five allied health sessions per year.

For many Australians this is nowhere near sufficient.

Five sessions a year may be helpful for very limited intervention, but it is not enough for people who require ongoing support to build capacity, prevent deterioration or maintain functioning.

This is particularly difficult for working families who do not hold a Health Care Card and therefore receive limited assistance with out-of-pocket costs. For a family with multiple members requiring allied health support, mainstream appointments can result in gap fees of approximately $120 to $250 per appointment after any Medicare or private health rebate.

When more than one family member requires one to two appointments per week, the financial burden becomes completely unaffordable.

For example:

one person attending one appointment per week with a $120 gap fee costs approximately $6,240 per year;
one person attending one appointment per week with a $250 gap fee costs approximately $13,000 per year;
two family members each attending one appointment per week could cost between approximately $12,480 and $26,000 per year;
two family members each requiring two appointments per week could cost between approximately $24,960 and $52,000 per year.

These figures are before accounting for travel, time off work, school absences, childcare, reports, assessments, equipment or other disability-related expenses.

For many working families, this creates an impossible situation. They may earn too much to qualify for concession supports, but not enough to afford the level of therapy or intervention required. This can reduce the incentive and ability to remain in employment, particularly where a parent must reduce work hours to attend appointments, manage behaviours, advocate with schools, or provide unpaid support at home.

Submission 2646

This is a clear example of how reducing access to disability supports does not necessarily reduce government costs. It may instead shift costs to families until they reach crisis point, reduce workforce participation, increase reliance on income support, and increase pressure on public health and mental health systems.

Increasing access to mainstream allied health services would:

improve early intervention;
reduce deterioration;
improve workforce participation;
reduce pressure on families;
reduce future demand on the NDIS;
support people who are not eligible for NDIS but still require assistance. Without stronger mainstream pathways, tightening NDIS access risks leaving many Australians without support altogether.

If people cannot afford private therapy and cannot access meaningful mainstream support, their needs may escalate until they require more intensive and expensive intervention.

That is not sustainability. That is delayed cost shifting.

Submission 2646

Recommendation 11: Improve Transparency Around NDIS Expenditure

Relevant Bill areas

This recommendation relates to:

financial sustainability;
public accountability;
Scheme governance;
policy evaluation. Public discussion frequently references NDIS expenditure of approximately $50–52 billion annually.

Greater transparency is required regarding:

approved plan budgets;
actual expenditure;
plan utilisation rates;
underutilised plans;
spending by support category;
spending on direct support compared with administration, travel and non-face-to-face work. In my experience, many plans are not fully utilised.

Understanding the distinction between allocated funding and actual spending is essential when assessing sustainability and determining where reforms should be targeted.

If a plan is approved for a certain amount but only a portion is used, public discussion should not imply that the full approved amount has necessarily been spent.

Better transparency would allow reform to focus on genuine cost drivers rather than assumptions.

Submission 2646

Recommendation 12: Reform Non-Face-to-Face Billing

Relevant Bill areas

This recommendation relates to:

Schedule 2: provider compliance;
Schedule 3: pricing;
sustainability;
efficient use of participant funding. Non-face-to-face work can be necessary. Providers often need time for documentation, reports, communication, resource development and collaboration.

However, non-face-to-face billing should be clearer, more transparent and more outcome-focused.

Participants often do not fully understand what non-face-to-face charges relate to or how they benefit from them. This can create confusion and reduce trust.

There should be clearer requirements that non-face-to-face billing:

is directly linked to participant goals;
is clearly explained to the participant or nominee;
is documented in plain language;
does not duplicate work completed by other providers;
is proportionate to the support delivered;
results in a clear participant benefit. Where non-face-to-face work relates to collaboration, this should connect with the recommendation for mandatory care team communication.

If providers are billing for coordination, planning or strategy development, that work should be visible and useful to the participant, family and broader support team.

Submission 2646

Recommendation 13: Ensure Foundational and Mainstream Supports Exist Before NDIS Access Is

Reduced

Relevant Bill areas

This recommendation relates to:

Schedule 1: access and planning;
consideration of other service systems;
sustainability. The Bills Digest notes that foundational supports are intended to sit outside the NDIS and support people with disability, including those on the NDIS. It also notes that the National Agreement on Foundational Supports involves expected expenditure of around $10 billion over five years, with $4 billion committed to the Thriving Kids program for early intervention for children under 9.

This is important, but foundational supports must exist in practice before NDIS access is reduced.

Families cannot be told they no longer meet NDIS access requirements if the alternative supports are not available, accessible, affordable and effective.

For foundational supports to work, they must be:

available in regional and rural areas;
accessible without long waitlists;
affordable;
inclusive of children with complex needs;
connected to schools and early childhood settings;
trauma-informed;
neurodiversity-affirming;
practical for families;
delivered by appropriately trained professionals. If foundational supports are not ready before access changes occur, families will be left with nothing.

That will increase pressure on mental health, education, public health and crisis systems.

Submission 2646

Recommendation 14: Measure Sustainability by Outcomes, Not Only Cost Reduction

Relevant Bill areas

This recommendation relates to:

the Bill’s overall sustainability objective;
governance;
policy evaluation;
financial accountability. The Parliamentary Library states that the Bill is primarily aimed at reducing projected growth in NDIS expenditure and participant numbers.

However, reducing participant numbers should not be treated as a success measure on its own.

The government should also measure whether reforms result in:

increased hospital presentations;
increased mental health presentations;
increased unemployment;
increased reliance on income support;
increased school refusal;
increased family breakdown;
increased carer stress;
increased homelessness risk;
increased child protection involvement;
increased tribunal appeals;
poorer participant outcomes. If NDIS costs decrease but costs increase elsewhere, the reform has not achieved genuine sustainability.

True sustainability should mean:

better outcomes;
better use of funding;
fewer duplicated services;
stronger mainstream systems;
earlier intervention;

Submission 2646

better workforce distribution;
less administrative waste;
reduced crisis intervention;
maintained participation in education, work and community life.

Submission 2646

Recommendation: Improve Delegate Understanding of Provider Roles and Scope of Practice

Relevant Bill areas

This recommendation relates to:

Schedule 1: access and planning decisions;
Schedule 2: provider regulation and compliance;
NDIA administrative efficiency;
decision-making quality;
appropriate funding of reasonable and necessary supports. A further issue requiring attention is the need for NDIA delegates to have a clearer understanding of the different roles providers play within a participant’s support team.

Too often, supports appear to be rejected, reduced or questioned because a delegate does not fully understand the distinction between different professional roles. This can result in incorrect assumptions that one provider can simply replace another, when in reality the supports may serve different purposes and require different qualifications, frameworks and intervention approaches.

A common example is the difference between a Behaviour Support Practitioner and a psychologist.

While there may be some overlap in the participants they support, these roles are not the same and should not be treated as interchangeable.

A psychologist may provide assessment, diagnosis, therapeutic intervention, mental health treatment, emotional regulation support, trauma therapy, counselling, cognitive assessment, behavioural intervention and psychological therapy depending on their qualifications and scope of practice.

A Behaviour Support Practitioner, by contrast, generally focuses on understanding behaviours of concern, identifying their function, reducing restrictive practices, developing behaviour support plans, training support teams, and ensuring strategies are implemented consistently across environments.

Behaviour support is often highly practical and environmental. It may involve examining what happens before, during and after behaviours of concern, identifying triggers, modifying environments, teaching replacement skills, supporting communication, training carers and support workers, and reducing the need for restrictive or reactive responses.

Psychology may be necessary where a participant requires therapeutic support for anxiety, trauma, emotional regulation, mental health, cognitive functioning or psychological wellbeing.

These supports can be complementary, not duplicative.

For example, a participant may require a psychologist to address anxiety, emotional regulation or trauma responses, while also requiring a Behaviour Support Practitioner to develop and monitor a behaviour support plan for behaviours of concern occurring across home, school, community or supported accommodation settings.

Submission 2646

If a delegate assumes that psychology and behaviour support are the same, the participant may be left without one of the supports they require. This can result in poorer outcomes, increased behaviours of concern, greater family or carer stress, increased use of restrictive practices, and higher long-term costs.

Delegates should receive clear training about the roles and scopes of practice of common NDIS providers, including but not limited to:

psychologists;
Behaviour Support Practitioners;
occupational therapists;
speech pathologists;
physiotherapists;
exercise physiologists;
therapy assistants;
support coordinators;
psychosocial recovery coaches;
developmental educators;
social workers;
nurses;
dietitians. This training should include practical examples of when supports are genuinely duplicative and when they are complementary.

Better understanding of provider roles would improve decision-making, reduce unnecessary reviews and appeals, and ensure participants receive the right supports at the right time. It would also reduce administrative waste caused by participants and providers having to repeatedly explain basic distinctions between professional roles.

NDIA decision-making should be based on the participant’s functional needs and the specific purpose of each support, rather than assumptions that providers with overlapping areas of practice are interchangeable

Submission 2646

Conclusion

I support the objective of ensuring the NDIS remains sustainable for future generations. I also acknowledge that the current system requires reform.

However, sustainability will not be achieved simply by reducing participant access or shifting responsibility onto mainstream systems that are not currently equipped, funded or accessible enough to meet community need.

If reforms reduce NDIS expenditure while increasing pressure on public health, mental health services, education systems, housing, carers, families and income support, then overall government expenditure may increase rather than decrease.

Cost shifting should not be mistaken for cost saving.

True sustainability requires reform that addresses the underlying causes of demand and inefficiency. This includes:

strengthening mainstream services before restricting NDIS access;
improving access to affordable allied health supports;
better training and supervision requirements for allied health professionals entering NDIS-funded work;
improved understanding by NDIA delegates of provider roles and scope of practice;
better teacher training in disability, particularly ASD, ADHD and PDA profiles;
mandatory parent and carer training so therapy strategies are implemented between appointments;
mandatory provider collaboration to reduce duplication and conflicting strategies;
reform of provider travel, cancellation and non-face-to-face billing arrangements;
improved transparency around actual expenditure compared with approved plan values;
stronger decision-making processes that properly consider professional evidence and functional impact.

The NDIS should not only be measured by what it costs. It should also be measured by what costs it prevents. Every participant who remains employed, avoids hospitalisation, maintains independence, prevents family breakdown, delays entry into supported accommodation, reduces reliance on crisis services or continues participating in education and community life represents a saving elsewhere in the system.

Based on my experience as a disability sector professional, NDIS participant and parent of children with disability, including a child with high support needs, I believe there are many practical reforms that could improve sustainability without removing necessary supports from people who genuinely need them.

Submission 2646

The recommendations outlined in this submission are only some of the issues I observe through my work and lived experience. I would welcome the opportunity to discuss these matters further with the Committee, as there are many additional examples and practical reform ideas I would be happy to share.

Thank you for considering this submission.

Yours sincerely,

NDIS Participant, Parent of Children with Disability, and Disability Sector Professional

Submission 2646

Reference List

Australian Bureau of Statistics. (2024). Children and young people with disability, 2022. Link: https://www.abs.gov.au/articles/children-and-young-people-disability-2022 Used to support statistics that 12.1% of Australians aged 0–24 had disability in 2022, and 11.0% of children aged 0–14 had disability.

Australian Bureau of Statistics. (2024). Autism in Australia, 2022. Link: https://www.abs.gov.au/articles/autism-australia-2022 Used to support the statistic that 4.3% of children aged 5–14 were autistic in 2022.

Australian ADHD Professionals Association. (2024). Australian Evidence-Based Clinical Practice

Guidelines for ADHD: Factsheet for Educators. Link: https://adhdguideline.aadpa.com.au/wp-content/uploads/2024/02/ADHD-Guideline-Factsheet ADHD-Factsheet-For-Educators-C-AADPA.pdf Used to support the statement that ADHD affects approximately 6–10% of children and is one of the most common mental health/neurodevelopmental conditions in childhood.

May, T., Birch, E., Chaves, K., et al. (2023). The Australian evidence-based clinical practice guideline for attention deficit hyperactivity disorder. Link: https://research-repository.griffith.edu.au/bitstreams/6bc71303-11d9-4300-b1f3 9f40e98160a1/download Used to support the statement that ADHD occurs in approximately 6–10% of Australian children and adolescents.

Parliament of Australia. (2026). National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 — Senate Community Affairs Legislation Committee inquiry page. Link: https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Community_Affairs/NDISFutureG enBill Used to identify the inquiry, submission requirements, dates, and committee context.

Parliamentary Library. (2026). Bills Digest No. 65, 2025–26: National Disability Insurance Scheme

Amendment (Securing the NDIS for Future Generations) Bill 2026. Link: https://www.aph.gov.au/Parliamentary_Business/Bills_Legislation/bd/bd2526/26bd065 Used to support references to the Bill’s purpose, schedules, access and planning amendments, provider regulation, pricing, compliance, governance, functional capacity, and automated decision-making provisions.