National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 2716
Hi
I am an occupational therapist and recently retired provider of clinical services to NDIS participants. I have 40 years clinical experience working with people with disability of all ages and various diagnoses. My areas of expertise are prescribing assistive technology, functional capacity assessment and intervention, sensory processing and executive functioning.
I have concerns about several parts of the “Securing the NDIS for Future Generations) Bill 2026”. These are:
Functional Capacity Assessment and Design
I have extensive experience completing functional capacity assessments with adult and adolescent NDIS participants. To accurately determine a person’s functional capacity, you must do more than complete a standardized assessment as these do not capture the level of effort, time taken, and degree of support needed by a participant to function. Skilled observations of people in their natural environment often reveal different and vital information about function that is not captured in an interview or questionnaire. There is a wide range of diagnosis and impact in the disability sector therefore you need a qualified and experienced health professional to complete a functional capacity assessment.
Example:
I recently completed an FCA on a participant with multiple disabilities that impacted her physical, cognitive, visual and emotional function. The assessment took several visits because the participant’s fatigue, limited concentration, impaired memory and verbal comprehension and level of distraction. I used a wide range of skills acquired over many years as an occupational therapist, to engage the client, observe her skills and gather relevant information about her function. In addition to 9 standardized assessments, I assessed her home environment using my clinical observations and knowledge, observed her completing specific personal care tasks (e.g. showering), cooking, mobility (e.g. balance, bed transfer) and uusing technology You cannot gain a thorough picture of a person’s functional capacity and determine the support they need using a single assessment tool. You risk a tick a box, inflexible and therefore inaccurate approach to assessment to determine a person’s support needs and funding.
I want Parliament to change the Bill to ensure that functional capacity and support need assessment are conducted by appropriate qualified allied health professionals including occupational therapists.
Use of Automation, Algorithm and Standardised Tools
I am concerned that using automation or algorithm to assess a participant could place participants at risk of serious harm. A person’s level of function and risk varies enormously within any single diagnosis group. One tool or algorithm cannot cover the range of presentation or assess complex needs of participants. An effective assessment must be tailored to the individual and take into consideration their age, personality, social context (including carer capacity and family system) and physical environment (including access, space and assistive technology) and combination of disability and health conditions. To assess accurately and thoroughly you must have professional oversight from relevant healthcare professionals.
Example:
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 2716
I have completed many functional capacity assessments with adults with ASD, Complex PTSD and ADHD. Their presentation and functional capacity can be very different. I had two clients with partners with these diagnoses. One had severe limitations to their mobility, personal care and household tasks. They required a manual wheelchair with power assist and weekly support for household tasks. The other had severe and highly unusual sensory processing difficulties, impaired executive function and communication and significant mental health difficulties. They required weekly support, capacity building and transport. Same diagnosis and family system very different impact, need and support required.
I want Parliament to prohibit fully automated eligibility or funding decisions and require human oversight of any assessment tool or algorithms.
Restrictions on Reassessment and Review
Participants need to access reassessment and review of their plans in a timely fashion. Their needs or circumstances can suddenly change and, with that, their level of support. Delays in the review process can increase the person’s risk of injury or lead to more rapid deterioration of their functional capacity. In the latter situation, more intervention and more cost may be needed than if intervention occurred earlier. If their condition deteriorates significantly, it may be more costly and harder to find suitable services for their needs. Quicker access to review or reassessment will be cheaper for the government and better for the participant.
Example:
A client’s weight increased and this meant the seating on their power wheelchair was no longer supportive and risked creating pressure injuries. Their weight changes also stopped them driving their modified vehicle. These changes increased the risk of pressure injury and drastically reduced their independent mobility. A timely plan review could enable vital funding for changes to their assistive technology.
A client had completed Year 12 in a supported learning environment. Their goals and social network post school will be very different. When the person turns 18 y services move to adult instead of paediatric services. The role of their parents change significantly as the person is preparing to be an independent adult and possibly move to independent living. A plan review and assessment are essential. I have known families where a review has not occurred and there is no funding for day programs for clients with high physical and cognitive needs. Instead, the family is suddenly required to provide high level specialised care to their adult child.
I want Parliament to retain practical pathways for reassessment and review.
Yours truly