Submission 2722
Submission to the Senate Community Affairs Legislation Committee
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill
2026
Submitted by: Director and Principal Paediatric Physiotherapist
Introduction
I am the Director and Principal Paediatric Physiotherapist of a small paediatric allied health practice supporting children and young people with disability and developmental differences in Sydney NSW.
Our team of four senior paediatric physiotherapists provide physiotherapy and allied health support to children with a wide range of support needs. We work closely with families, educators, medical professionals and community services to improve participation, independence, wellbeing and quality of life. Our approach is family-centred, developmental, neuroaffirming and focused on meaningful participation in everyday life.
I support the need for a sustainable National Disability Insurance Scheme that remains available for future generations. I also support efforts to reduce fraud, improve accountability and ensure public funds are used responsibly.
However, I have significant concerns that several proposed measures within this Bill may create unintended consequences for participants, families, clinicians and small providers while not necessarily achieving the intended objectives.
Mandatory Registration of Providers
The proposal for mandatory registration of providers is presented as a measure to reduce fraud and improve quality and safety. While these are important goals, mandatory registration alone is unlikely to address fraud effectively.
Fraud has already occurred within registered organisations operating under existing regulatory frameworks. Registration does not automatically prevent fraudulent behaviour. Instead, it risks creating additional administrative and financial burdens for compliant providers while failing to address the underlying causes of fraud.
For small businesses already facing increasing operating costs, workforce shortages, compliance obligations and frozen NDIS pricing, the cost of registration, auditing and ongoing compliance may become unsustainable.
There is a risk that experienced small providers may leave the sector, reducing participant choice and access to specialised services, particularly in regional and underserved communities.
Reduced Claim Timeframes
The proposal to reduce claim timeframes raises significant operational concerns.
Submission 2722
Many small allied health providers operate with limited administrative resources. Reduced claiming periods increase the risk of administrative errors leading to unrecoverable losses. They also create additional administrative workload that diverts resources away from direct participant support.
Cash flow remains a significant challenge for small businesses delivering NDIS services. Shorter claiming windows may increase financial instability and reduce the viability of smaller providers who are already managing rising costs without corresponding increases in pricing.
NDIS Pricing and Conflict of Interest
I am concerned about the increasing concentration of responsibility within government for both determining NDIS pricing and managing scheme sustainability.
There is an inherent tension between controlling expenditure and ensuring pricing adequately reflects the true cost of delivering high-quality services.
Pricing decisions should be transparent, evidence-based and informed by independent economic analysis. If pricing is primarily driven by budgetary considerations, there is a risk that providers will be unable to maintain quality services, invest in workforce development or remain financially viable.
Ultimately, participants experience the consequences when providers reduce services, limit availability or leave the sector entirely.
Reduction of Community Participation and Capacity Building Supports
The proposed reduction of social, civil and community participation budgets by 50% and capacity building daily activity budgets by 10% is particularly concerning.
For many participants, these supports are not discretionary extras. They are essential components of building independence, developing skills, maintaining community connections and preventing social isolation.
Participation in community activities often provides opportunities to develop communication, mobility, self-regulation, social skills and confidence. These experiences contribute directly to long-term independence and reduced reliance on paid supports.
Reducing these supports may create short-term savings but increase long-term costs through reduced participation, poorer outcomes and increased demand for higher levels of support in the future.
These reductions also threaten the sustainability of many small providers whose services focus on skill development, participation and early intervention.
Maximum Funding Levels and Group-Based Funding Approaches
The proposal to establish maximum funding levels or support allocations for particular groups of participants is inconsistent with the principles of individualised support that underpin the NDIS.
People with the same diagnosis often have vastly different strengths, needs, goals, environmental circumstances and support requirements.
Submission 2722
Funding decisions should continue to be based on the individual rather than broad diagnostic categories or population groups. Standardised funding approaches risk failing to meet the needs of those whose circumstances fall outside expected patterns.
Limitations on Unscheduled Plan Reassessments
Disability and family circumstances do not always follow predictable timelines.
Children grow, developmental demands change, family circumstances evolve, and health conditions can fluctuate. Participants need access to timely plan reassessment processes when genuine changes in circumstances occur.
Restricting access to unscheduled reassessments may leave participants without appropriate supports during critical periods, potentially leading to worsening outcomes and increased risks.
Increased Reliance on Families and Informal Supports
The expectation that families and informal supports will absorb a greater share of support responsibilities raises significant concerns.
Many families already provide extensive unpaid care well beyond what would be expected in the general community.
Increasing reliance on informal supports may contribute to caregiver burnout, reduced workforce participation, financial hardship and declining family wellbeing.
In paediatric practice, the wellbeing of parents and caregivers directly influences outcomes for children. Policy settings should recognise the limits of unpaid care and the economic contribution families already make through their support roles.
Value for Money Considerations
Value for money is an important principle, but it must be applied carefully.
There is a risk that value for money may become synonymous with selecting the lowest-cost option rather than the most appropriate or effective support.
Participants should not be placed in situations where they are encouraged to choose less experienced or less suitable providers solely because they are cheaper.
Quality, effectiveness, safety, participant outcomes and long-term benefits must remain central considerations when assessing value.
Poor-quality supports often generate greater costs over time through reduced progress, increased support needs and poorer participant outcomes.
Supports Linked Only to Eligible Impairments
The proposal that supports must be directly linked to an eligible impairment represents a narrow understanding of disability.
Submission 2722
Disability does not exist solely within an individual’s impairment. Outcomes are shaped by the interaction between the person, their environment, available supports and societal barriers.
This proposal appears inconsistent with the internationally recognised International Classification of Functioning, Disability and Health (ICF), which acknowledges that participation and functioning are influenced by personal, environmental and contextual factors.
A person-centred approach should consider the whole individual and their participation in everyday life, not simply the impairment itself.
Suspension or Cessation of Participant Plans
The ability to suspend or cease participant plans raises concerns regarding procedural fairness and participant safety.
Participants from culturally and linguistically diverse communities, Aboriginal and Torres Strait Islander communities, and those with limited advocacy support may be disproportionately affected.
Any suspension process should include robust safeguards, accessible communication, independent review pathways and mechanisms to ensure participants are not left without essential supports.
Further Reviews of Access and Eligibility
Many participants have already undergone extensive assessment and evidence-gathering processes to establish eligibility.
Repeated reviews of access and eligibility risk creating unnecessary stress, uncertainty and administrative burden for participants and families while generating substantial additional costs for the Scheme itself.
Resources may be more effectively directed toward service quality, workforce development and fraud prevention rather than repeatedly reassessing participants who have already demonstrated permanent and significant disability.
Redefining Impairment
The proposed approach to redefining impairment appears overly focused on diagnosis and impairment characteristics without adequately considering the impact of assistive technology, environmental factors and individual circumstances.
A comprehensive understanding of disability requires consideration of how a person functions in their real-world environments and the barriers they face.
Any definition that separates impairment from context risks producing inaccurate assessments of support needs and reducing access to appropriate supports.
Requirement to Exhaust All Treatments
The proposal that participants with permanent disability must exhaust all treatments before accessing support is deeply concerning.
Submission 2722
Permanent disability should not be viewed through a framework that assumes cure or recovery is achievable.
Many lifelong disabilities have no treatment that will eliminate the condition. While interventions may improve functioning, participation and quality of life, they do not remove the underlying disability.
Requiring individuals to continually pursue treatment before accessing support risks creating unnecessary barriers, delays and distress for participants and families.
Support needs should be assessed based on the realities of living with a permanent disability rather than on hypothetical possibilities of future improvement.
Conclusion
I support efforts to strengthen the sustainability, integrity and accountability of the NDIS. However, sustainability should not be pursued at the expense of participant outcomes, family wellbeing, provider viability or the principles of individualised support.
Many of the proposed measures risk shifting costs and burdens onto participants, families and small providers without adequately addressing the underlying challenges facing the Scheme.
I encourage the Committee to carefully consider the practical impacts of these reforms and to ensure that future changes remain grounded in participant-centred practice, evidence-informed policy and the lived realities of people with disability, their families and the professionals who support them.
The long-term success of the NDIS depends not only on financial sustainability but also on maintaining access to high-quality, individualised supports that enable people with disability to participate fully in their families, communities and society.