Submission 2710
Dear Committee Members,
I am a paediatric speech pathologist and director of a small private practice supporting children with developmental delay and neurodivergence. I work closely with families, schools and other providers across the Central Coast and surrounding regions.
I support the goal of ensuring the long-term sustainability of the NDIS. However, based on day-to-day clinical experience, there are aspects of this Bill that are likely to create practical challenges for children, families and frontline services. Many of these risks relate to how the changes will operate in real-world settings, particularly in early intervention.
- Reduced flexibility and responsiveness in plans: The Bill introduces tighter rules around plan reassessments and requires a “significant and ongoing” change before a reassessment can occur.
In practice, children’s needs often change quickly, but not always in ways that meet a strict threshold. For example:
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a child starting school may need different supports within weeks
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a regression in communication or behaviour may require short-term increases
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therapy intensity may need to increase or decrease based on progress Under the proposed changes, these situations may not qualify for reassessment. This shifts pressure onto:
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families to “wait it out”
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therapists to work within unsuitable plans
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schools to manage increased needs without support The likely outcome is delayed intervention and less effective therapy.
- Barriers to reassessment and increased administrative load: The Bill requires formal processes, documentation and specific conditions to be met before reassessment requests are considered.
In practice this means:
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more time gathering reports instead of delivering therapy
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longer delays before changes are approved
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increased frustration for families who already find the system hard to navigate For small practices, this creates a real sustainability issue:
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clinicians spend more unpaid time on reports
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fewer therapy hours are available
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overheads increase without increased funding Over time, this contributes to provider burnout and reduced availability of services.
- Impact on early intervention: The Bill tightens eligibility, including requiring that impairments persist after “all appropriate treatment” before access is confirmed.
Submission 2710
From a clinical perspective, this creates several risks:
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Early supports may be delayed while families are expected to try other systems
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Children may only qualify once difficulties are more entrenched
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Opportunities for prevention and skill development may be lost
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Parents may have difficulty accessing alternative treatments for example due to financial reasons In early childhood, timing matters. Delays of even 6–12 months can:
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increase support needs long term
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affect school readiness
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impact behaviour and participation These changes risk shifting the system away from early intervention and towards later, more intensive and costly support.
- Narrower definition of what supports can be funded: The Bill strengthens the requirement that supports must arise directly from a qualifying impairment.
In practice, many children present with overlapping needs:
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communication difficulties affecting behaviour
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sensory needs affecting learning
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co-occurring diagnoses Separating needs strictly by impairment is often not clinically meaningful. It may result in:
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supports being declined despite clear functional need
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fragmented care
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increased pressure on families and schools This risks reducing access to supports that are functionally necessary but harder to categorise.
- Reduced plan value and funding constraints: The introduction of funding caps, support determinations and potential reductions to support budgets creates uncertainty about what families will actually receive.
In practice, this may lead to:
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lower therapy frequency
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shorter intervention periods
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limited access to multidisciplinary supports For children, this directly affects:
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progress in communication and daily living skills
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participation in education
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long-term independence It also places greater pressure on:
Submission 2710
- parents to fill gaps
- teachers to manage complex needs without adequate support
- Increased reliance on parents and informal supports: The Bill strengthens expectations that parents should provide substantial care and support.
While families already play a central role, many are already stretched. In practice:
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both parents may be working
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families may be managing multiple children or additional needs
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informal supports may not be available Reducing funded supports on this basis risks:
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increasing burnout
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reducing engagement with therapy
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widening inequities between families
- Risk of longer waitlists and reduced service availability: Combined pressures from:
- increased administration
- reduced funding certainty
- tighter compliance requirements are likely to impact provider capacity.
For small paediatric services, this may result in:
- limiting NDIS caseloads
- closing books or increasing waitlists
- leaving the NDIS entirely In regional areas, where services are already limited, this could significantly reduce access.
- Impacts on children’s long-term outcomes: Many of the proposed changes aim to reduce short-term costs. However, in practice they may increase long term costs by:
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delaying early intervention
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reducing therapy effectiveness
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increasing reliance on education and health systems For children, this translates to:
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poorer school participation
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ongoing communication challenges
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reduced independence and employment outcomes later in life
Submission 2710
The intent of this Bill is understood and supported. However, the practical impact on children and families requires careful consideration.
Based on frontline experience, I recommend:
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Maintain flexibility in planning and reassessment Ensure plans can be adjusted in response to functional change, not just major thresholds
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Protect timely access to early intervention Avoid delays linked to eligibility tightening or “appropriate treatment” requirements
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Simplify reassessment processes Reduce administrative burden on families and clinicians
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Allow funding decisions to reflect functional needs Avoid overly narrow interpretations of impairment-based eligibility
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Monitor impacts on small providers and regional services Ensure reforms do not reduce service availability
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Recognise the limits of informal supports Avoid shifting unsustainable responsibility onto families
A sustainable NDIS needs to support children early, respond flexibly, and remain workable for the providers delivering care on the ground.
Thank you for considering this submission.
Yours sincerely,