Submission 2674
Submission to the Senate Community Affairs Legislation Committee
Inquiry into the National Disability Insurance Scheme Amendment (Securing
the NDIS for Future Generations) Bill 2026
Occupational Therapist, Illawarra NSW
Executive Summary
This submission reflects my experience as an Occupational Therapist working with adults with complex physical, neurological, psychosocial and less visible disabilities in the Illawarra.
I understand the importance of ensuring the NDIS remains sustainable. However, the proposed reforms shift the Scheme away from a model that is grounded in how disability actually presents in daily life. Instead, the direction appears to move toward more standardised, administratively driven decision-making.
In practice, this has real consequences.
Assessment approaches that do not take into account environment, fatigue, or the role of existing supports are likely to overestimate what people can actually manage on a day-to-day basis. When supports are reduced on that basis, the result is not independence. It is increased risk and gradual decline.
The impact is rarely contained within the participant alone. Families take on more responsibility, often at significant personal cost. Over time, that becomes unsustainable. When those informal supports break down, people enter crisis systems, including hospitals, at a much higher cost.
There is also a flow-on effect in how services are delivered. Increased pressure on providers and greater standardisation are likely to affect continuity, clinical input, and ultimately the quality of support people receive.
The key issue is that these changes do not remove need. They delay it and shift it elsewhere, usually into systems that are already under strain.
A sustainable scheme is one that prevents escalation by getting supports right early, not one that withdraws support and responds later when things have deteriorated.
Introduction
I am an Occupational Therapist providing in-home services to adults across the Illawarra.
My work focuses on understanding how people function in their everyday lives. That includes how they manage over the course of a full day, not just what they are able
Submission 2674
to demonstrate in a single assessment. I look at safety in the home, access to the community, the impact of fatigue and pain, and the interaction between physical, cognitive and psychosocial factors.
A large part of my role is identifying risk early and putting supports in place to prevent things from getting worse.
In practice, many of the people I work with are maintaining a level of stability that relies heavily on the supports currently in place. When those supports change, even slightly, the effects can be quite significant.
Many of the participants I work with also present with multiple interacting conditions and ongoing risk factors. This means relatively minor changes to support can have disproportionate impacts on safety, health, and overall functioning.
What I am describing in this submission is based on that experience. It reflects what happens when supports are appropriate and effective, and what tends to happen when they are reduced or misaligned with actual need.
From a clinical perspective, the current direction presents a high level of risk, particularly for people with complex, fluctuating or less visible disabilities.
A shift away from real-world functioning
One of the main concerns with the Bill is the move toward assessing people in a more abstract way, separated from their environment and usual supports.
The proposed approach to functional capacity, particularly under section 9B, focuses on what a person can do in isolation. From a clinical perspective, this does not reflect how disability presents in real life.
People’s ability to function depends on a range of factors. That includes their home environment, the supports they have in place, how fatigued they are, and what else they need to do throughout the day. These factors interact and change over time.
Someone may be able to complete a task once in a controlled situation. That does not mean they can do it safely every day, or without consequences.
When those broader factors are not considered, assessments tend to present a more capable picture than what is actually sustainable. Decisions are then made based on that picture, and supports are reduced accordingly. I see this regularly.
There is also concern that increasing reliance on standardised tools and automated processes may reduce the role of clinical judgement in decision-making, particularly for people with complex or non-linear presentations.
Submission 2674
This particularly affects people with less visible or fluctuating disabilities, who may appear capable in brief or structured assessments but are not able to sustain function safely in daily life.
People often try to present as capable. Sometimes that is because they want to appear independent. Sometimes it is because they are worried about losing supports. What is not picked up is what it costs them to maintain that appearance, or what other areas of their life are being compromised as a result.
For example, someone may say they are able to prepare meals. In practice, they may be relying on food that is expired or not nutritionally adequate, or they may be using appliances in an unsafe way. The task is technically being completed, but not in a way that maintains health or safety.
The same applies to personal care. A person may report that they can shower independently, but on closer observation there may be poor hygiene, high risk of falls, or difficulty managing temperature safely.
This kind of detail only becomes clear with time, observation, and clinical reasoning. Without that, there is a real risk that capacity is overestimated and support needs are reduced on that basis.
Delays, reassessment and deterioration
A related concern is the impact of delays across the system.
Delays in accessing supports, reassessment, or decision-making are not neutral. In practice, they often result in deterioration in function, increased risk, and more complex support needs over time.
If supports cannot be adjusted when circumstances change, people continue to manage without what they need until something breaks down. By the time the system responds, needs are often significantly higher.
Administrative complexity and fairness
There is also increasing reliance on administrative processes, discretionary decision making, and systems that are not always transparent.
Many aspects of how these reforms will operate in practice are not yet clearly defined and appear likely to be determined through future rules, tools or administrative processes. This creates uncertainty about how decisions will actually be made and how consistently the system will be applied.
There is also concern that decisions affecting support availability may increasingly be made at a system level, rather than being based on individual need.
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At the same time, many participants already experience significant barriers navigating the Scheme. This includes people with cognitive impairment, psychosocial disability, communication difficulties, or reduced capacity to manage complex information and processes.
There are also points within the proposed reforms where elements appear to operate in tension with each other. For example, assessing functional capacity without considering existing supports, while subsequently relying on informal or environmental supports within funding decisions, creates a disconnect between how need is identified and how it is responded to in practice.
Increasing complexity in this environment raises concerns about fairness. People who are less able to advocate for themselves or navigate systems are at greater risk of being under-supported.
What happens when supports are reduced
When supports are reduced, the impact is usually immediate.
The tasks themselves do not disappear. Personal care still needs to happen. Meals still need to be prepared. Safety still needs to be monitored. The difference is that the responsibility shifts.
In most cases, it shifts to family members.
Initially, families will take this on. They adjust their routines, reduce work hours, and step in to fill the gaps.
Over time, the impact accumulates. Caring becomes physically demanding and emotionally exhausting. There is little opportunity for rest or recovery.
I often see carers developing their own health issues in this context.
Eventually, there is a point where the current arrangement can no longer be sustained. When that happens, the change tends to be sudden rather than gradual.
This is where people enter crisis.
This is not a theoretical risk. It is a pattern I see consistently.
Community access and gradual decline
Supports that enable people to get out into the community play an important role in maintaining function.
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Supports that build capacity and enable participation are not optional in practice. They are often essential to maintaining function, preventing isolation, and reducing long-term support needs.
When these supports are reduced, people engage less, routine declines, and isolation increases. Over time, this leads to deterioration in mental health, reduced motivation, and a decline in overall functioning.
Once this pattern is established, it can be very difficult to reverse.
Impact on the broader system
Reducing supports does not remove need. It redistributes it.
When supports are reduced, function declines, risk increases, and eventually a higher level of response is required.
This often results in hospital admission, acute mental health support, or other crisis responses.
From a clinical and service delivery perspective, this is a predictable outcome when supports are not aligned with actual need.
It is more accurate to understand these changes as redistributing cost across systems, rather than reducing it.
Workforce and service delivery
There are also likely impacts on how services are delivered.
Increased administrative burden and standardisation reduce the time available for clinical work and limit flexibility. Over time, this affects the quality and effectiveness of supports, particularly for people with complex needs.
Conclusion
The NDIS has made a significant difference in allowing people to live more safely and independently.
A key part of that has been its ability to respond early and prevent escalation.
The concern with the current direction is that it moves away from that approach.
In its current form, this Bill does not align with how disability presents in practice and is likely to result in poorer outcomes for participants, along with increased long-term cost across the broader system.
Submission 2674
For these reasons, I do not consider it appropriate for the Bill to proceed without substantial revision.
A sustainable NDIS requires reforms that reflect real-world functioning, support early intervention, and maintain the capacity to respond to change.