Submission 295
Practical Concerns Regarding the National Disability Insurance Scheme
Amendment (Securing the NDIS for Future Generations) Bill 2026
I am writing as a paediatric physiotherapy provider working with children and families in South West Sydney. Our practice has provided paediatric physiotherapy services since 2003 for children with developmental delay, cerebral palsy, neurological conditions, genetic syndromes, physical disabilities and complex developmental needs.
We support the need for the NDIS to remain financially sustainable and recognise the importance of reducing fraud, inappropriate claims and inconsistent decision making. However, there are several aspects of the proposed legislation that raise significant practical concerns for children, families and frontline services.
Many of the proposed reforms appear reasonable in principle, but there is concern that the real-world impact on children with disability may be more restrictive than intended, particularly for children with developmental and neurodevelopmental conditions whose needs change over time and do not always fit clear administrative categories.
Functional Capacity and Child Development
The proposed definition of functional capacity appears to place strong emphasis on assessing a person’s intrinsic ability without assistance, assistive technology or environmental supports.
In practice, children do not develop in isolation from their environment. Their participation, regulation, learning and physical functioning are often highly dependent on family support, school supports, therapy input, equipment and consistent routines.
Many children who appear to be functioning reasonably well are only able to do so because significant supports are already in place. Removing those contextual factors from assessment risks underestimating the true impact of disability on daily life.
This is particularly concerning for children with:
- developmental delay
- autism spectrum disorder
- ADHD
- cerebral palsy
- neurological conditions
- genetic syndromes
- complex behavioural and sensory presentations. Children’s needs are also developmental. A child may cope adequately in one stage of life but struggle significantly during school transitions, adolescence or periods of increased educational and social demand. Functional capacity in children is not static.
Submission 295
Early Intervention Concerns
Early intervention is most effective when support can be provided consistently and responsively before problems become entrenched.
There is concern that tighter reassessment thresholds and narrower definitions of disability related support may unintentionally delay intervention until difficulties become more severe and more expensive to manage.
In paediatric practice, therapy is often preventative. Support may help:
- maintain mobility
- prevent secondary complications
- improve participation
- reduce caregiver strain
- support school access
- reduce long-term dependence. These outcomes are not always immediate or easily measurable in short funding cycles, but they are clinically meaningful and often reduce future system costs.
A narrow interpretation of “directly related” supports may also create difficulties for children with overlapping developmental and behavioural presentations where needs cannot be neatly separated into isolated diagnoses.
Reassessments and Changing Family Circumstances
The proposed limitations on unscheduled reassessments are concerning in paediatric settings.
Children’s support needs frequently change due to:
- growth and physical development
- school transitions
- changes in mobility
- increasing academic demands
- puberty
- behavioural escalation
- caregiver burnout
- changes in family circumstances. Many of these changes occur gradually rather than through a single major event.
There is concern that families may struggle to meet the threshold required to demonstrate a “significant and ongoing” change before support can be reconsidered.
Submission 295
In practice, delays in responding to changing needs often result in:
- crisis presentations
- school breakdown
- hospital admissions
- family exhaustion
- increased safeguarding concerns
- loss of community participation.
Impact on Families and Informal Supports
The proposed reforms appear to place increased emphasis on informal supports and family responsibility.
Many families are already under significant pressure. Parents of children with disability are often managing:
- therapy programs from multiple allied health professionals involved in the child’s
care – e.g. Physiotherapy, Occupational Therapy, Speech Pathology, Dietician
- behavioural challenges
- school advocacy
- medical appointments
- sleep disruption
- reduced workforce participation
- financial stress
- hospital admissions
- social isolation There is concern that the reforms may overestimate the long-term sustainability of informal care arrangements, particularly for families with limited social support, separated families, culturally diverse families and rural or outer metropolitan families with fewer services available.
When formal supports are reduced, the burden does not disappear. It is usually absorbed by families, schools, emergency departments and unpaid carers.
Workforce and Service Sustainability
Private allied health practices are already operating in a difficult workforce environment.
Paediatric physiotherapy, occupational therapy and speech pathology services across many areas are experiencing:
- workforce shortages
- long waitlists
- clinician burnout
- rising operating costs
Submission 295
- difficulty recruiting experienced staff. Increased administrative complexity and funding uncertainty may make it harder for smaller private practices to remain viable, particularly in regional and outer metropolitan areas.
If experienced providers reduce services or close, the impact on families can be substantial. Children may wait months for therapy or lose access altogether.
This is particularly concerning because private practices currently provide a large proportion of frontline paediatric disability support across Australia.
Concerns for Neurodivergent Children
There is concern that children with neurodevelopmental conditions may be disproportionately affected by tighter interpretations of functional impairment and support eligibility.
Children with autism, ADHD, developmental coordination disorder and learning difficulties often experience significant participation challenges despite appearing capable in some structured settings.
Their support needs may fluctuate considerably across:
- home
- school
- community settings
- sensory environments
- social demands. Rigid functional thresholds may fail to capture the cumulative impact of these challenges on long-term education, mental health, independence and participation.
Conclusion
The NDIS must remain sustainable, accountable and equitable. However, sustainability should not come at the cost of reducing flexibility and responsiveness for children with disability and their families.
Children develop over time, and effective paediatric intervention relies on flexibility, early support and realistic understanding of family life.
There is a significant risk that overly narrow access criteria, stricter reassessment barriers and reduced funding flexibility may lead to:
- increased waitlists
- delayed intervention
- greater family stress
- higher downstream costs
Submission 295
- reduced educational participation
- reduced long-term independence.
Practical Recommendations
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Ensure paediatric functional assessments recognise environmental and developmental context rather than relying solely on intrinsic ability.
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Maintain flexibility for reassessments where children’s developmental needs, school participation or family circumstances change.
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Ensure early intervention supports remain accessible and responsive for children with developmental delay and neurodevelopmental conditions.
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Include stronger recognition of clinician judgement alongside standardised assessment processes.
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Monitor the impact of reforms on workforce sustainability, especially for small and regional allied health providers.
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Establish safeguards to ensure children do not fall between the NDIS, education, health and community systems.
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Undertake ongoing consultation with frontline paediatric providers, families and disability communities during implementation of the reforms.
These reforms will have significant practical effects on children, families and services. Ongoing consultation with clinicians and providers working directly with children every day will be critical to avoiding unintended consequences.