Submission 2794

Submission to the Senate Community Affairs Legislation Committee Inquiry into the National Disability Insurance Scheme Amendment (Securing the Scheme) Bill 2024

Submitter: Individual speech pathology clinician and private practice owner

Location: East Perth, Western Australia

Relevant experience:

• Speech pathology provider in NDIS since the scheme’s rollout in Canning Vale, WA
• Private practice owner full-time since 2006 - 2025 (19 years)
• Downsized practice in September 2021 to operate with only myself and an allied health assistant (AHA) due to increasing NDIS pricing and compliance pressures
• Closed my clinical practice in December 2025 because NDIS pricing, compliance burden, and payment delays made solo practice unsustainable
• Now working as an allied health business coach and mentor
• Caseload focused on early childhood and school-aged children
• Supervisor and mentor of rural and remote speech pathology therapists nationally

Contact:

• Name:
• Email:

1. Purpose of this submission

This submission outlines concerns from a clinical speech pathology provider about how the proposed Bill may:

• Reduce access to early intervention and ongoing supports for children and families
• Threaten service sustainability through pricing, travel, and fee settings
• Worsen workforce shortages and loss of experienced therapists

Submission 2794

• Undermine rural and remote access, particularly through reduced telehealth and travel support
• Disrupt early intervention funding and continuity of care
• Exacerbate planner inconsistency and its impact on participants and providers

These concerns are grounded in direct clinical and supervisory experience with NDIS participants in Western Australia, including families in Perth metropolitan areas and rural regions such as Kalgoorlie. As a provider who closed my 19-year practice due to NDIS unsustainability, I speak from both clinical experience and the reality of provider financial pressures.

Early Intervention Pathway And Access Issues

Example: School-Aged Child With Autism, ADHD, And Pathological Demand Avoidance (PDA)

A child already diagnosed with autism, ADHD, and PDA presented with severe school refusal, escalating violence toward parents and siblings, absconding, vandalism at school, and significant family tension.

The child:

• Finds it hard to make friends, have conversations, listen and focus, follow multi-step instructions, and be more independent
• Struggles to communicate wants, needs, thoughts, and feelings and to organise and plan
• Exhibits meltdowns, swearing, and threatening language that frightens peers, contributing to social isolation and difficulty attending school
• Is at risk of self-harming behaviour and deteriorating mental health if behaviour and regulation are not managed

The child’s behaviour, emotional dysregulation, meltdowns, and violent outbursts make leaving the house very difficult. The mother is the primary caregiver and cannot manage the child’s behaviour while also supporting three other siblings. She is physically and psychologically unable to cope and is desperately in need of support such as a Support Worker to provide 1:1 support. She is also socially isolated, does not have a car, and cannot safely take all four children on public transport.

Why this matters for the Bill

If early intervention pathways become more restrictive or funding is reduced, children like this will face:

• Delayed or denied support at a critical developmental window
• Ongoing school refusal, possible exclusion, and loss of educational opportunity
• Escalating violence and risk at home, increasing the likelihood of family breakdown
• Greater risk of self-harm, mental health deterioration, and long-term social isolation
• Increased risk of involvement with the justice system as the child grows older
• Long-term impacts on the ability to work, connect with family, and live independently

These consequences extend far beyond the child and family. They have community-wide implications, including increased pressure on schools, mental health services, youth justice, and adult disability supports. The long-term costs of delaying or denying early intervention are likely to be far higher than the short-term savings from reduced funding.

Research links adverse childhood experiences, including maltreatment and family stress, to increased adolescent offending and poorer adult outcomes. Early intervention is not just about therapy hours; it is about preventing long-term harm to the child, family, and community.

Example: sibling on the autism waitlist in an already-known family

A family already in the NDIS system has:

• A 7-year-3-month-old child diagnosed with autism is receiving supports
• A 4-year-old sibling on the waitlist for diagnosis and assessment

Under tighter funding and cost growth caps, the 4-year-old may be unable to access the funding and support needed. This child is already known to the family’s therapists, who understand their context, strengths, challenges, and family dynamics.

The sibling requires 1:1 therapy focusing on:

• Language and communication
• Perspective-taking
• Executive functioning skills

When services are already known to the family, the cost of services typically decreases over time because:

• Therapists know what works and what does not
• Therapy can be targeted and coordinated
• Families can plan toward successful independence from services more efficiently

If funding is reduced or access is delayed, the sibling may:

• Not receive the support they actually need when it is most effective
• Receive funding for therapy that is not well targeted, leading to longer overall intervention
• Experience worsening skills, school problems, behaviour concerns, and family stress
• Face difficulty with literacy acquisition, homework completion, and consolidating learning
• Require more intensive, longer-term therapy later, increasing overall system costs

Submission 2794

This demonstrates the false economy of reducing access for children who are already showing functional need. Delaying targeted early intervention is likely to increase long-term costs rather than contain them.

4. Rural and remote access: Kalgoorlie and regional WA

As a supervisor and mentor of rural and remote speech pathology therapists nationally, I hear weekly about the lack of services in areas such as Kalgoorlie. Returning to Perth for weekly therapy is not possible for many families.

Key issues include:

• Insufficient travel remuneration: The 50% reduction in travel fees has significantly hurt families living in rural and remote areas. Therapists based in the region face disincentives to travel to smaller communities when fees are reduced so substantially.

• Telehealth limitations: Telehealth is not an optional extra; for many families, it is the only service they receive. However, not all children or diagnoses are suitable for telehealth. Some require in-person support, school-based therapy, or the presence of an education assistant.

• FIFO and fly-in models: Metropolitan therapists who do not understand the nuances of regional living may provide supports and strategies that do not work because they do not know what they do not know. Trust is harder to establish, and retention in FIFO/fly-in services is poor, leading to frequent therapist rotation.

• Regional therapists: A therapist based in the region knows the town, the people, the needs, and the resources. They can build trust and rapport, leading to more successful therapy. They can service multiple schools and clients in a region in a single day, making service delivery more efficient.

• School and clinic-based therapy: The clinicians I support can deliver both school and clinic-based therapy. Recruitment of therapists is difficult, and even when therapists are employed, travelling to smaller communities is hard when there is such a significant reduction in fees.

Over-reliance on visiting services can stifle the development of well-resourced, funded, and staffed local primary healthcare systems, creating a dependency cycle rather than a sustainable solution.

Submission 2794

Resident health professionals are more attuned to local community needs, leading to better patient outcomes through consistent, continuous care. Resident models support the long-term stability of rural health infrastructure, whereas FIFO is often viewed as a “necessary evil” or interim solution rather than a remedy.

Telehealth must remain funded and accessible, with flexibility for families to purchase necessary supports such as:

• Headsets with microphones for speech sound work
• Support persons attending with the child
• Therapy at school with an education assistant for children not ideal for telehealth

5. Registration and compliance burden

I am currently an unregistered provider. I closed my clinical practice in December 2025 after downsizing in September 2021 due to NDIS pressures. The client examples in this submission are from 2024 and 2025.

The average price for NDIS registration audits varies significantly based on service risk level and organisation size:

• Verification audits (lower-risk services): typically $900–$3,000
• Certification audits (higher-risk services): typically $3,000–$15,000+

These costs, combined with the paperwork and time required to understand and get support to truly understand what NDIS audits and registration entail, are unsustainable for solo practitioners.

The benefits of solo practitioners include:

• Long-term continuity: I had been in my practice for 19+ years
• Deep knowledge of the local community and families
• Higher retention and trust compared to high-turnover corporate or FIFO models

Submission 2794

I agree with more oversight and stronger safeguards, including severe penalties for breaches (bans, fines, criminal sanctions for fraud). However, compliance settings must be streamlined and proportionate to provider type:

• A support worker who is unregistered, does not have a governing body, and has limited admin expectations needs more oversight than a speech pathologist who already has professional registration, supervision, documentation expectations, and quality systems

• Solo practitioners need simpler, more proportionate audits and reporting requirements

Stronger safeguards with better streamlining, and more oversight, but less red tape, depending on the provider type, is the appropriate approach.

6. Planner inconsistency and decision-making

I have seen plans for self-managed participants that remove all choice and control, stating exactly:

• The funding amount allocated for each therapy type
• The name of the therapist they can access

Some plans are 12 months, some 2 years, and some 5 years. Some participants have not had their plan reviewed for 5+ years. Some clients get a plan rollover, and then, 3–6 months later, their funding is cancelled.

This affects:

• Therapy success and client progress
• Participant and family stress
• Provider’s ability to plan and deliver consistent services

I have seen an example where:

• A single-parent family had two children on the NDIS; plans were reviewed in December, but new plans in January did not have enough funding

• Their mother took the plan to the tribunal, requiring lawyers, adding extra family stress
• No therapy could be accessed during this time
• Children’s skills deteriorated, with massive behavioural issues emerging -18 months later, funding was restored, but the therapy team then had so many behaviours of concern and issues to deal with -Fortnightly therapy moved to weekly, but with two children, this created a huge burden on the mother -School stress built up, school refusal became significant, the mother experienced burnout and could not do home practice

All of this occurred because it took 18 months for the tribunal to reverse the decision and provide the funding that was requested. If the new plans had been correct initially, none of this would have happened. The children were both making good progress and, in 12–18 months, would have needed minimal intervention.

Inconsistent planning decisions generate avoidable distress, higher later support needs, and inefficient use of public resources.

7. Recommendations

The committee should consider the following recommendations:

1.Do not implement an 8% cost growth cap that restricts access for children and families who already demonstrate functional need, particularly in families already known to services.

2.Maintain current early intervention criteria and ensure that complex children with autism, PDA, and co-occurring behavioural and mental health risks are not excluded due to rigid pathway separation.

3.Protect telehealth access and funding, including flexibility for families to purchase necessary equipment (e.g., headsets with microphones) and supports (e.g., support persons, school-based therapy with education assistants).

Submission 2794

• Review travel fee settings for rural and remote areas to ensure therapists can sustainably travel to regions such as Kalgoorlie and that families can access both in-person and telehealth services.

• Standardise planner decision-making and reduce inconsistency across regions and planners, including clearer guidance on funding levels, provider choice, and review periods.

• Streamline registration and compliance for solo practitioners and experienced professionals, with proportionate audits and reporting based on provider type and risk.

• Support regionally based therapists over FIFO/fly-in models to build sustainable local health infrastructure, trust, and continuity of care.

Submission 2794

Conclusion

These concerns are grounded in direct clinical and supervisory experience with NDIS participants in Western Australia. The proposed changes risk reducing access to timely, targeted early intervention, undermining service sustainability, and worsening outcomes for children, families, and the broader community.

Early intervention is not just about therapy hours; it is about preventing long-term harm to the child, family, and community. Reducing funding or access now may appear to save money in the short term, but is likely to increase long-term costs through higher support needs, increased system use, and poorer life outcomes.

This submission respectfully requests that the committee consider these concerns and recommendations when reporting on the Bill.