Impacts of reforms on access to orthotic/prosthetic supports (Provider advocacy) | External submission

Submission 283

Australian Orthotic Prosthetic Association (AOPA) Submission

Committee Secretary

Senate Community Affairs Legislation Committee

Parliament House

Canberra ACT 2600

Dear Committee Secretary,

The Australian Orthotic Prosthetic Association (AOPA) welcomes the opportunity to provide a submission regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

The Australian Orthotic Prosthetic Association (AOPA) is the peak professional body for certified orthotist/prosthetists. AOPA is responsible for regulating the profession and is a founding member of the National Alliance of Self Regulating Health Professions (NASRHP). AOPA is recognised by the Commonwealth Government as the assessing authority responsible for conducting migration skill assessments for orthotists/prosthetists.

Orthotic and prosthetic services are clinically prescribed, highly specialised assistive technology interventions that directly interface with the body. As such, they represent a high-risk category of supports where inappropriate provision can result in significant harm to participant safety, mobility, physical health and independence.

AOPA’s submission focuses on the impacts of the proposed reforms on access to safe, individualised and clinically appropriate orthotic/prosthetic supports within the NDIS. AOPA’s submission emphasises the need to preserve participant-centred planning, clinical oversight, equitable access and funding approaches that appropriately reflect the complexity and ongoing management requirements of orthotic/prosthetic provision.

Ten recommendations are provided within the submission. AOPA would welcome the opportunity to provide further information or appear before the Committee if invited.

Please contact, Jessica Landers, for further information or questions arising from the following submission.

Yours sincerely,

Jessica Landers

Chief Executive Officer

Australian Orthotic Prosthetic Association

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1.0 Introduction

The National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations)

Bill 2026 proposes significant changes to participant access, planning, funding, administration and Scheme governance. Collectively, these reforms will influence how participants access orthotic and prosthetic services and how decisions regarding assistive technology supports are made within the NDIS.

Orthoses and prostheses are highly specialised, body-worn assistive technologies that directly influence mobility, safety, independence, participation and long-term health outcomes. Unlike many other supports, orthotic and prosthetic interventions require ongoing clinical assessment, technical expertise, customisation, fitting, review and lifecycle management. Participant outcomes

are  highly dependent on access  to  appropriately  qualified  practitioners and  responsive,

individualised service delivery.

AOPA supports the long-term sustainability and integrity of the NDIS. However, sustainability measures must be implemented in a manner that preserves participant safety, equitable access and clinically appropriate care. Reforms that rely on standardised planning methodologies, capped funding arrangements, reduced reassessment opportunities or automated decision-making may have unintended consequences for participants who require orthotic and prosthetic services.

This submission examines the implications of the Bill for orthotic/prosthetic provision, with particular focus on:

functional capacity assessment;
access to reassessment and review;
permanence and treatment requirements;
funding reductions, pricing caps and support intensity limits;
framework planning and standardised funding methodologies;
alternative support pathways;
integrity and provider regulation; and
automation of administrative decision-making. AOPA’s recommendations are directed toward ensuring the NDIS remains responsive to participant needs and continues to support safe, effective and person-centred orthotic/prosthetic service provision.

1.1 About Certified Orthotist/Prosthetists

Certified orthotists/prosthetists are tertiary-qualified allied health professionals (minimum AQF Level 7) who provide orthotic, prosthetic and assistive technology services to Australians, including

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NDIS  participants. They assess  participants’ physical  abilities, functional capacity, goals,

environment and broader health context, and support informed decision-making about appropriate orthotic, prosthetic or assistive product supports, balancing safety, function, durability and long term outcomes. Care extends beyond product selection/prescription to encompass assessment, prescription, custom design, coordinating fabrication, fitting, training, education and lifecycle review, with orthoses and prostheses routinely modified in response to growth, ageing, clinical change or environmental demands. Orthotists/prosthetists work across public, community and private settings, including rural and remote areas, and within multidisciplinary teams to deliver person-centred care that supports independence, participation and quality of life.

2.0 Recommendations

AOPA recommends that the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 be amended as per the provisions listed below.

No. Relevant Bill Provision Recommendation

1  Schedule 1 Part 1 –     Amend proposed section 9B to ensure functional capacity

proposed section 9B assessments consider real-world functioning, including the role of orthoses, prostheses, assistive technology, environmental supports and contextual factors in enabling participation and safety.

2  Schedule 1 Part 2 –     Amend proposed sections 48 and 48A to ensure participants

proposed sections 48 requiring orthotic/prosthetic services retain access to timely and 48A reassessment pathways that support preventative and responsive intervention and rely on clinical evidence from treating orthotist/prosthetists.

3  Schedule 1 Part 4 –     Amend proposed section 34A, section 45C and subsections

proposed section 34A; 33(2EA)–(2EB) to exclude orthotic and prosthetic supports from Schedule 1 Part 6 – broad percentage-based funding reduction mechanisms, proposed subsections maximum funding caps and standardised support intensity limits 33(2EA) and 33(2EB); that would compromise access to clinically appropriate and safe Schedule 3 Part 1 – supports. proposed section 45C

4  Schedule 1 Part 8 –     Amend proposed subsections 24(5), 25(1B) and section 25A to

proposed subsections clarify that participants may access orthotic/prosthetic supports 24(5), 25(1B) and section while treatment, rehabilitation or recovery pathways continue, 25A and that ongoing treatment should not delay access to essential mobility and functional supports.

5  Schedule 1 Part 9 –     Amend proposed section 25B to ensure orthotic/prosthetic

proposed section 25B supports are not excluded from the NDIS on the basis that they are considered to be funded elsewhere, recognising that no

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equivalent alternative funding system currently exists for orthotic/prosthetic supports and associated clinical services.

6  Schedule 2 – proposed   Amend Schedule 2 to recognise existing professional regulatory

sections 10C, 45B and arrangements, including AOPA certification and professional proposed Part 3C standards, and ensure integrity measures support clinically integrated orthotic/prosthetic service delivery by appropriately qualified practitioners.

7 Schedule 2 – compliance, Ensure implementation of Schedule 2 integrity reforms includes complaints and formal engagement and information-sharing mechanisms enforcement framework between the NDIA and AOPA regarding profession-specific complaints, safety concerns and emerging integrity risks relating to orthotic/prosthetic provision.

8  Schedule 3 Part 2 –     Amend proposed sections 59B–59E to ensure orthotic/prosthetic

proposed sections 59B– support determinations are not subject to fully automated 59E decision-making and continue to require appropriately qualified human review.

9  Schedule 4 – proposed   Amend proposed subsections 32K(3B)–(3E) to ensure

subsections 32K(3B)–(3E) orthotic/prosthetic supports are not reduced to simplified “levels of need”, standardised funding methodologies or maximum funding amounts that do not reflect individual clinical requirements.

10 Schedule 4 – proposed Amend proposed section 32L to ensure needs assessments and section 32L and related planning decisions continue to give appropriate weight to needs assessment evidence from treating orthotist/prosthetists and are not based provisions solely on prescribed assessment tools, standardised methodologies or administrative benchmarks.

3.0 Schedule 1 Part 1. Defining Functional Capacity

Proposed section 9B, Schedule 1 Part 1 of the Bill, defines functional capacity as a person’s ability to undertake an activity without assistance from assistive technology, other people or modifications, and excluding environmental and personal circumstances as far as possible. This approach is inconsistent with contemporary disability frameworks, including the World Health Organization’s International Classification of Functioning, Disability and Health (ICF), and fails to reflect the lived reality of orthotic/prosthetic users. The Bill requires functional capacity to be assessed:

without assistance from other people, assistive technology or modifications; and
in a context that excludes, as far as possible, the impact of environmental and personal circumstances.

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For many people who use orthoses or prostheses, functional capacity cannot be meaningfully understood separately from their orthotic/prosthetic use, as it enables standing, walking,

balance, joint  stability, limb protection, transfers, mobility and participation in daily  life.

Assessing a person’s functional ability without their orthosis or prosthesis creates an artificial representation of disability that risks significantly distorting support needs and clinical risk.

For example:

•  a lower limb prosthesis user may demonstrate independent mobility with  their

prosthesis, but be unable to safely mobilise or participate in the community without it;

a person using a custom ankle-foot orthosis relies on it to prevent falls, reduce fatigue, stabilise gait and maintain employment participation;
a spinal orthosis may enable sitting tolerance, pain management or respiratory function;
upper limb orthoses and prostheses may be essential for activities of daily living, workplace participation and injury prevention.

In these circumstances, the orthosis or prosthesis is central to functioning.

The proposed definition risks encouraging assessments that:

underestimate the importance of orthotic/prosthetic intervention;
overemphasise impairment in isolation from functional outcomes;
fail to recognise the preventative value of orthotic/prosthetic supports;
create inconsistent planning outcomes; and
increase pressure toward simplified or standardised assessment approaches that do not reflect real-world disability experience.

The interaction between proposed section 9B and the broader reforms relating to framework planning, standardised needs assessments and automation of administrative may reduce the

weight given to detailed  clinical assessment by  treating  orthotist/prosthetists and may

oversimplify highly individualised orthotic/prosthetic needs.

Recommendation 1: Amend proposed section 9B to ensure functional capacity assessments consider real-world functioning, including the role of orthoses, prostheses, assistive technology, environmental supports and contextual factors in enabling participation and safety.

4.0 Schedule 1 Part 2. Plan Reassessments

Schedule 1 Part 2 introduces stricter thresholds for unscheduled plan reassessments through proposed amendments to sections 48 and 48A, including requirements for “significant and

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ongoing” changes in functional capacity and “substantial reduction” in daily functioning before reassessment may occur.

These provisions do not adequately reflect the clinical reality of orthotic/prosthetic service provision, where timely review and adjustment are often required before substantial functional decline occurs. Orthotic and prosthetic needs frequently change over time due to:

• growth and developmental change;          •  equipment failure or wear;

• changes in gait, balance or mobility;         •   progression of underlying conditions;

•  pain, skin breakdown or pressure injury;     •  changes in work, education or

community participation demands.

deterioration in device fit or alignment; Early orthotic/prosthetic intervention prevents deterioration, maintains participation and reduces downstream health and disability costs. Restricting access to reassessment until a participant experiences substantial functional decline is inconsistent with preventative, person-centred care.

The proposed extension of reassessment decision timeframes from 21 to 90 days under

amendment subsection 48(3)  will also delay  clinically necessary  interventions. Delays  in

orthotic/prosthetic review can contribute to avoidable falls and injury, skin breakdown and pressure injury, reduced mobility and independence, deterioration in physical function, and increased downstream health and disability system costs.

Recommendation 2

Amend proposed sections 48 and 48A to ensure participants requiring orthotic/prosthetic services retain access to timely reassessment pathways that support preventative and responsive

intervention  and  rely  on  clinical  evidence  from  treating

orthotist/prosthetists.

5.0 Schedule 1 Part 4, Schedule 1 Part 6 and Schedule 3 Part 1. Funding

Reductions,  Pricing Powers and  Sustainability  of  Orthotic/Prosthetic

Services

The proposed funding reduction and pricing provisions contained within proposed sections 34A and 45C create significant risks for orthotic/prosthetic services. These provisions permit:

Schedule 1 Part 4 inserts proposed section 34A, which permits the Minister to apply percentage-based funding reductions to specified groups of supports for the purpose of “ensuring the financial sustainability” of the Scheme; and
Schedule 3 Part 1 inserts proposed section 45C, which permits the Minister to determine maximum amounts payable for supports or classes of supports

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Item 68, Schedule 1 Part 6 inserts proposed subsections 33(2EA) and 33(2EB), which permit the Minister to specify maximum funding amounts, maximum intensity of supports and maximum worker-to-participant ratios for supports or classes of supports.

The NDIS was designed to enable people with disability to pursue their functional, social, educational and vocational goals and to live ordinary lives alongside other Australians. For many participants, access to clinically appropriate orthotic and prosthetic supports is fundamental to achieving those outcomes.

Funding caps and standardised funding limitations are fundamentally incompatible with these objectives. Orthotic and prosthetic needs cannot be reduced to benchmark pricing or simplified funding categories without compromising function, participation and safety. The proposed ability to impose maximum funding amounts and intensity limits is particularly problematic for orthotic/prosthetic services, where clinical needs, review frequency, fitting complexity and

support  intensity  vary  significantly between  participants and  often change  over  time.

Standardised limits are poorly suited to highly customised, body-interfacing interventions that require responsive and individualised clinical management.

The introduction of capped funding models risks shifting the Scheme toward a system in which outcomes are determined not by participant need, but by an individual’s capacity to personally fund the gap between capped funding and the actual cost of clinically appropriate supports. This undermines the equity principles underpinning the NDIS and risks recreating the barriers to participation and inclusion the Scheme was designed to remove.

Broad funding reduction powers and capped pricing models will create pressure toward lowest cost orthotic/prosthetic selection, rather than the most appropriate; reduced clinical review and follow-up; and underfunding of clinically complex supports. For many participants, even partial funding reductions will prevent access to clinically appropriate orthotic/prosthetic supports altogether.

Orthotic and prosthetic supports are preventative and cost-effective interventions that reduce downstream expenditure through prevention of falls, hospitalisation, pressure injuries and loss of independence. AOPA also notes that pricing determinations should be informed by transparent evidence and meaningful consultation with the orthotic/prosthetic profession to ensure pricing reflects the true costs of safe and sustainable service delivery.

Recommendation 3

Amend proposed section 34A, section 45C and subsections 33(2EA)– (2EB) to exclude orthotic and prosthetic supports from broad

percentage-based  funding  reduction  mechanisms, maximum

funding caps and standardised support intensity limits that would compromise access to clinically appropriate and safe supports.

6.0 Schedule 1 Part 8. Permanence, Treatment Requirements and Timely

Access to Orthotic/Prosthetic Supports

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Schedule 1 Part 8 introduces proposed subsection 24(5), subsection 25(1B) and section 25A, which require participants to undertake “all appropriate treatment” before an impairment is considered permanent. The proposed permanence and “appropriate treatment” provisions risk delaying access to essential orthotic and prosthetic supports.

The Bill proposes that an impairment will not be considered permanent unless:

the person has undertaken all appropriate treatment; • any further treatment is unlikely to materially improve, reverse or alleviate the

impairment; and

the impairment is likely to persist for the person’s lifetime The Bill additionally states in proposed subsection 25A(2) that treatment may be considered “appropriate treatment” even where a participant’s individual circumstances, including financial circumstances or geographical location, restrict access to that treatment.

These provisions will likely cause delay in access to essential orthotic and prosthetic supports for participants who require immediate intervention to maintain mobility, safety, independence or community participation. Furthermore, orthotic and prosthetic interventions are frequently required concurrently with treatment, rehabilitation or recovery; not only after all possible treatment pathways have been exhausted.

For example:

a participant with neurological impairment may require orthotic intervention to reduce falls risk and maintain safe mobility while their medical treatment continues;
children with developmental or neuromuscular conditions may require ongoing orthotic management despite evolving treatment pathways;
participants with progressive conditions may require orthotic/prosthetic intervention to maintain participation and delay deterioration, even where treatment remains ongoing.

These provisions will disproportionately affect:

people living in rural and remote areas, where access to specialist rehabilitation and medical treatment is often limited;
participants with limited access to specialist rehabilitation services or long public hospital waiting times, who may be unable to complete treatment pathways within reasonable timeframes;

• participants requiring multidisciplinary rehabilitation, where access to

orthotic/prosthetic intervention is often needed concurrently with broader rehabilitation goals; and

people with complex, progressive or fluctuating conditions, where treatment pathways evolve over time and orthotic/prosthetic intervention is required to maintain function and prevent deterioration despite ongoing medical management.

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The orthotic/prosthetic profession frequently works with participants during periods of clinical transition and delaying access to orthotic/prosthetic supports during these periods may contribute to:

avoidable falls and injury;
pressure injuries and skin breakdown;
reduced mobility and participation;
prolonged hospital admissions;
increased carer burden;
deterioration in physical conditioning; and
increased long-term support costs across the health and disability systems. Recommendation 4

Amend proposed subsections 24(5), 25(1B) and section 25A to clarify that participants may access orthotic/prosthetic supports while treatment, rehabilitation or recovery pathways continue, and that ongoing treatment should not delay access to essential mobility and functional supports.

7.0 Schedule 1 Part 9 Alternative Support Systems and Continuity of

Orthotic/Prosthetic Care

The proposed “alternative support requirements” provisions in section 25B risk excluding participants from the NDIS where another system is considered responsible for providing support. The Bill provides that impairments may be treated as “excluded impairments” where support is considered available through:

motor vehicle accident compensation schemes;
workers compensation systems; or
other alternative support systems prescribed through NDIS Rules. These provisions risk excluding participants from the NDIS based on the theoretical existence of another funding pathway, even where equivalent orthotic/prosthetic supports are not genuinely available in practice.

Orthotic and prosthetic service delivery in Australia is already fragmented across the NDIS, hospital systems, compensable injury schemes, DVA programs and state equipment schemes. These systems frequently involve capped subsidies, restrictive eligibility criteria, long waiting periods, inconsistent device access and significant out-of-pocket costs. The existence of another

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funding pathway does not mean equivalent orthotic/prosthetic supports are available, timely or clinically appropriate.

This issue is particularly significant for orthotic/prosthetic services because workforce shortages are substantial, specialist expertise is limited, and continuity of clinical care is essential. Fragmented responsibility for supports increases the risk of delayed intervention, disrupted care pathways, inconsistent clinical decision-making and poorer long-term outcomes. The risks are

especially pronounced  for participants  transitioning between systems, participants with

progressive or fluctuating conditions, and people living in rural and remote communities with limited provider availability.

Lessons from the Support at Home Program

Similar “funded elsewhere” approaches have already produced exclusionary outcomes within the Support at Home program. Orthoses and prostheses were excluded on the basis that partial funding existed through state equipment schemes or artificial limb programs, despite other assistive technology categories, including wheelchairs and hoists, remaining eligible under comparable subsidy arrangements.

State equipment schemes and artificial limb programs are not comprehensive funding systems. They commonly involve capped subsidies, restrictive eligibility criteria, long replacement cycles and substantial out-of-pocket costs.

The proposed framework risks replicating these outcomes within the NDIS if the existence of another funding pathway is treated as evidence that equivalent supports are genuinely available.

AOPA has already observed the consequences of similar “funded elsewhere” approaches through the Support at Home reforms (see Appendix 1)

Recommendation 5

Amend proposed section 25B to ensure orthotic/prosthetic supports are not excluded from the NDIS on the basis that they are considered to be funded elsewhere, recognising that no equivalent alternative funding system currently exists for orthotic/prosthetic supports and associated clinical services.

8.0 Schedule 2. Integrity Measures, Provider Regulation and Professional

Safeguards

Schedule 2 introduces expanded provider regulation, compliance, investigation and record retention powers, including proposed sections 10C, 45B and proposed Part 3C relating to monitoring, investigation and enforcement functions. AOPA supports measures that strengthen integrity, transparency and public confidence within the NDIS. However, integrity reforms must recognise the specialised clinical and technical nature of orthotic/prosthetic provision and avoid creating administrative frameworks that undermine participant safety or clinically integrated care.

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As a self-regulating profession, certified orthotist/prosthetists already operate within an established

professional  framework  that  includes  certification  requirements, competency  standards,

continuing professional development obligations, professional standards, complaints processes and accredited education pathways. These arrangements provide important safeguards for participant safety, service quality and professional accountability.

Integrity reforms should recognise and build upon these existing arrangements while supporting clinically integrated service delivery. Separating assessment, prescription, fabrication oversight and fitting increases the risk of inappropriate prescription, poor fit, inadequate follow-up and reduced accountability for outcomes. Orthotic/prosthetic services are also vulnerable to integrity

risks recognised across the broader  assistive technology  sector,  including  inappropriate

substitution of products, inadequate customisation, insufficient follow-up and billing practices that do not reflect the level of clinical customisation provided.

Recommendation 6

Amend Schedule 2 to recognise existing professional regulatory

arrangements,  including  AOPA   certification  and  professional

standards, and ensure integrity measures support clinically integrated

orthotic/prosthetic  service  delivery  by  appropriately  qualified

practitioners.

Recommendation 7

Ensure implementation of Schedule 2 integrity reforms includes formal engagement and information-sharing mechanisms between the NDIA and AOPA regarding profession-specific complaints, safety concerns and emerging integrity risks relating to orthotic/prosthetic provision.

9.0 Schedule 3 Part 2. Automation of Administrative Action and Clinical

Decision-Making

Schedule 3 Part 2 introduces proposed sections 59B–59E, which permit computer programs to undertake administrative actions, including evaluative judgements, discretionary decisions and elements of decision-making under designated provisions of the Act.

Orthotic and prosthetic assessment and planning involve highly individualised clinical reasoning that cannot be reliably reduced to automated or formulaic processes. Prescription decisions rely on nuanced assessment of biomechanics, gait, skin integrity, pain, falls risk, environmental demands, participant goals and long-term functional outcomes. These factors are dynamic, context-dependent and frequently require trialling, iterative adjustment and ongoing clinical review.

Automated systems risk underestimating the complexity of orthotic/prosthetic needs, privileging lower-cost standardised interventions and reducing responsiveness to individual participant circumstances. The consequences of poorly informed decisions may include falls, pressure

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injuries, device abandonment, reduced mobility and increased long-term health and disability system costs.

The proposed framework also permits future expansion of automation through legislative instruments, creating a pathway for increasingly complex support determinations to become automated over time. Participants may additionally face difficulty understanding or challenging automated decisions where clinical reasoning and contextual factors are not clearly visible within the process.

Orthotic and prosthetic outcomes depend on responsive and iterative clinical management that cannot be fully replicated through automated administrative systems.

Recommendation 8

Amend proposed sections 59B–59E to ensure orthotic/prosthetic support determinations are not subject to fully automated decision making and continue to require appropriately qualified human review.

10.0 Schedule  4. Framework Planning, Standardisation and Risks  to

Individualised Orthotic/Prosthetic Supports

The proposed New Framework Planning provisions would reduce the capacity for individualised orthotic and prosthetic planning within the NDIS. In particular, the proposed reforms allow for:

standardised methods for determining funding amounts;
categorisation of participants into “levels of need”;
maximum funding amounts for supports or classes of supports; and
increasing reliance on prescribed assessment tools and methodologies While AOPA acknowledges the objective of improving consistency and administrative efficiency within the Scheme, orthotic and prosthetic needs are highly individualised and are poorly suited to simplified categorisation or standardised funding methodologies.

Orthotic and prosthetic prescription depends on a complex interaction of factors including:

•   clinical presentation;                       •   transportation requirements;

•  anatomy and biomechanics;                •   cognitive and behavioural

considerations;

skin integrity;
comorbidities;
falls risk;
carer supports; and
pain and fatigue;
long-term functional goals.
environment and terrain;

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occupational and educational demands;

Participants with superficially similar diagnoses may require substantially different

orthotic/prosthetic interventions, clinical time, componentry and follow-up requirements.

For example:

two transtibial amputees may require entirely different prosthetic systems depending on residual limb condition, activity level, occupation, balance, skin tolerance and

environmental demands;

youth with the same neurological diagnosis may require different orthotic management approaches depending on growth, spasticity, contracture development and participation goals;
participants with diabetic foot complications may require highly customised pressure- relieving orthoses to prevent ulceration and hospitalisation.

Framework planning models based on standardised “levels of need” will fail to adequately capture this complexity and variability.

The Bill additionally permits methods that may set funding amounts below the actual cost of supports. If enacted, this will create systemic underfunding for participants requiring complex or customised orthotic/prosthetic interventions, particularly where supports fall outside simplified funding categories or benchmark assumptions.

Provisions  that  allow prescribed assessment methodologies and  specified  information

requirements to shape needs assessments and funding determinations are poorly suited to orthotic/prosthetic supports. Orthotic and prosthetic needs are highly individualised and frequently emerge through detailed clinical observation, trialling, iterative fitting, longitudinal review and real-world functional assessment. These needs cannot be reliably captured through

generic  questionnaires,  standardised  scoring  systems,  decontextualised   functional

assessments or administrative benchmarking methodologies without risking oversimplification of participant needs and inappropriate support determinations.

There is a significant risk that simplified planning approaches will:

privilege standardised or lower-cost device pathways;
reduce clinical flexibility;
discourage customised prescription;
reduce participant choice and control; and
create inequitable outcomes for participants with complex presentations. AOPA highlights the cumulative interaction between standardised planning methodologies, funding caps, value-for-money provisions, reduced access to reassessment, and increasing automation of administrative action. Collectively, these reforms shift the Scheme away from

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responsive, clinically informed and participant-centred planning toward increasingly formulaic administrative models that do not adequately reflect the complexity, variability and ongoing clinical management requirements of orthotic/prosthetic provision.

Recommendation 9

Amend   proposed    subsections    32K(3B)–(3E)    to   ensure

orthotic/prosthetic supports are not reduced to simplified “levels of need”, standardised funding methodologies or maximum funding amounts that do not reflect individual clinical requirements.

Recommendation 10

Amend proposed section 32L to ensure needs assessments and planning decisions continue to give appropriate weight to evidence from treating orthotist/prosthetists and are not based solely on

prescribed  assessment  tools,  standardised  methodologies  or

administrative benchmarks.

Conclusion Orthotic and prosthetic supports are essential disability supports that enable mobility, safety, independence, participation and social and economic inclusion for many Australians living with disability. For many participants, ongoing access to clinically appropriate orthotic/prosthetic services is fundamental to their ability to live safely, participate in daily life, maintain employment and avoid preventable deterioration.

The National Disability Insurance Scheme Amendment (Securing the NDIS for Future

Generations) Bill 2026 introduces reforms that will significantly affect how participants access orthotic and prosthetic services within the NDIS. While AOPA acknowledges the importance of Scheme sustainability and integrity, these objectives must not be pursued through reforms that reduce access to clinically appropriate, individualised and evidence-informed supports.

Collectively, the proposed reforms shift the Scheme away from responsive, participant-centred and clinically informed decision-making toward increasingly standardised administrative models that do not adequately reflect the complexity, variability and ongoing management requirements of orthotic/prosthetic provision.

Orthotic and prosthetic interventions are highly individualised and require ongoing assessment, technical expertise, fitting, review and long-term management. Delayed access, inappropriate

funding  decisions  or  overly  standardised  planning approaches may  result  in  serious

consequences for participant safety, mobility, physical health, independence and participation.

Importantly,  orthotic and  prosthetic supports  are  also  preventative and  cost-effective

interventions that reduce downstream expenditure across the health, disability and care systems through prevention of falls, injury, pressure injuries, hospitalisation and loss of independence.

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A sustainable NDIS must therefore continue to support:

timely access to orthotic/prosthetic services;
individualised and clinically informed planning;
appropriately qualified professional oversight; and
funding approaches that reflect the true complexity and value of orthotic/prosthetic provision.

AOPA urges the Committee to amend the Bill to ensure orthotic and prosthetic supports remain grounded in participant safety, clinical expertise, equity, functional outcomes and evidence informed practice.

AOPA would be pleased to work collaboratively with the Australian Government and the NDIA and to support implementation of reforms in a manner that preserves participant safety, clinically appropriate care and equitable access to orthotic/prosthetic supports. Ongoing consultation with the orthotic/prosthetic profession will be essential to ensure the Scheme remains responsive to the complexity and lived realities of participants requiring orthotic/prosthetic intervention.

Appendix 1:

Case example from the Support at Home exclusion of most orthotic/prosthetic supports

Gwen has post-polio syndrome. Her condition associated with this diagnosis is impacted by ageing. This has left Gwen with great difficulty in mobilising independently. She relies on her knee ankle foot orthosis (KAFO) to safely move around her house and in the community. Without this KAFO, Gwen would live a sedentary life and rely heavily on care supports. It is most appropriate that Gwen has access to her orthosis and wrap-around clinical services from her home care package. Although Gwen must save her funds up before she has enough to engage an orthotist, she is still able to do so without out-of-pocket expenses. This year Gwen had enough money to replace her decade-old KAFO. She saw certified orthotist/prosthetist Paul, who assessed her changing mobility and functional needs, took a cast of her leg, manufactured the KAFO, provided

the orthosis to Gwen and ensured  it was comfortable and  fit for purpose over several

appointments. Gwen now has a brand new KAFO that is lighter than her previous one, making ambulation and mobility easier. Gwen can no longer afford her orthosis and wrap-around clinical services. This is because Gwen’s only option is to engage with her state equipment program. She lives in Victoria which has one of the more comprehensive state equipment schemes – she would have to pay for her assessment out of pocket, but part of her KAFO would be subsidised (approximately 15% of the cost of the actual device, meaning Gwen now must source approximately $15 000 for the remainder of her KAFO cost). One fitting and one review appointment would also be covered by her state equipment scheme, but Gwen would be forced to pay for ongoing orthotic services out of pocket. Gwen cannot afford this. As a result, she would have to go without her KAFO, forcing her into a sedentary lifestyle with higher care and support needs. These needs would be more costly than her KAFO and orthotic services and would be funded by the Australian Government.

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