Submission regarding the National Disability Insurance
Scheme Amendment (Securing the NDIS for Future
Generations) Bill 2026
Supporting sustainable reform without reducing access to essential early intervention supports
I am writing as a Speech Pathologist with over 35 years experience, working in a small private practice, with children and families accessing early intervention. I work with an Occupational Therapist, providing a transdisciplinaiy approach in a practice called– in the Inner No1thern Suburbs of Melbourne. We are strongly affiliated with many Physiotherapists and Psychologists in the area. My work primai·ily involves Neurodivergent children, children with developmental delay, speech and language differences, social communication challenges, senso1y processing disorders and Global Developmental Delay. I work with families and educators using a play-based therapy approach, pai·ent coaching and functional suppo1t within eve1yday environments. Most of my families are currently suppo1ted through the NDIS.
I suppo1t the need for a sustainable and accountable NDIS. Fraud reduction, clearer processes and consistent decision-making are reasonable goals. However, I am concerned that aspects of the proposed legislation may create unintended consequences for children, families, therapists, schools and community services, paiticulai·ly in eai·ly intervention and developmental disability settings.
Many of the families accessing se1vices ai·e ah-eady under significant pressure. They are navigating long waitlists, school difficulties, behavioural distress, financial strain and ongoing administrative demands. Small changes to access, reassessment or funding flexibility can have substantial real-world impacts.
My concerns ai·e primai·ily related to implementation, access and the practical functioning of the system at community level. Early intervention and developmental delay
Early inte1v ention is time-sensitive. Delays in accessing therapy often lead to increased suppo1t needs later across education, mental health, fainily functioning and community participation.
Many children seen in private practice do not fit neatly into rigid categories. Developmental trajectories can change quickly, paiticulai·ly in younger children. Functional capacity may fluctuate significantly depending on environment, senso1y load, co-occmTing conditions, communication demands and school expectations.
I am concerned that tighter eligibility thresholds or more restrictive inte1pretations of “reasonable and necessaiy” suppo1ts may reduce access for children who do not present with severe impai1m ent in brief assessment settings, but who experience substantial functional challenges across daily life.
There is also concern that reassessment processes may become increasingly difficult, slow or inaccessible for families ah-eady stmggling to navigate the system. If reassessments are delayed or thresholds become harder to meet, children may lose suppo1t during critical developmental periods.
In practice, when supports are withdrawn early, the burden does not disappear. It shifts onto families, schools, emergency systems and unpaid carers. The reality is the burden is simply transferred to the later years and theoretically, as a child ages the supports they require usually increase rather than decrease.
Impact on Neurodivergent Children
Neurodivergent children often require flexible and responsive supports rather than highly standardised service models.
Many children with autism, ADHD, developmental language disorder and sensory processing differences do not demonstrate their support needs consistently across settings. A child who appears regulated in a short assessment may be struggling significantly at school, unable to participate socially, experiencing school refusal, emotional dysregulation or family breakdown at home.
There is concern that increased reliance on standardised functional assessments may fail to capture the complexity of these presentations. In my experience, standardised assessments do not often accurately reflect the communication difficulties of young children. These standardised assessments are not detailed or comprehensive enough, and therefore relying on those would mean that many children would be seen as not requiring support. These are the children that will then present to us again in primary school, when their challenges become obvious in the educational setting.
Children with communication difficulties are particularly vulnerable within systems requiring extensive documentation, self-advocacy or repeated reassessment processes. Families already report difficulty understanding changing requirements, obtaining evidence and coordinating reports across multiple providers.
If access pathways become more restrictive or administratively burdensome, some children are likely to miss support entirely until difficulties escalate further.
Reduced flexibility of supports
In paediatric practice, flexibility is essential.
Children’s needs change rapidly. Therapy often needs to adapt between direct intervention, parent coaching, school collaboration, environmental support, regulation strategies and capacity building within everyday routines.
Overly narrow definitions of funded supports may unintentionally reduce effective intervention. In practice, meaningful progress often occurs through collaborative and relationship-based work that may not fit easily into rigid funding categories.
Loss of flexibility may also increase fragmentation between health, education and disability systems. Families are already frequently caught between services, with schools expecting health input, health services expecting school adjustments and families left coordinating complex systems alone.
Workforce and provider sustainability
The paediatric therapy workforce is already under significant strain.
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Private practices are managing increasing administrative demands, delayed payments, workforce shortages and growing waitlists. Many small providers operate with limited financial buffer. This certainly applies to myself in my private practice.
If reforms significantly increase compliance requirements, reduce funding certainty or narrow service flexibility without adequate transition support, there is a risk that smaller providers will reduce NDIS work or close altogether.
This risk is particularly significant in regional and outer suburban communities where workforce shortages are already severe.
Reduced provider availability will likely increase waitlists further and place additional pressure on public health services, schools and families. These services will struggle to find the workforce to treat the increased waiting lists. Furthermore, it is a great concern that these services generally employ very few senior clinicians. Clinicians such as myself, who have a wealth of experience and knowledge, that are approaching retirement age, are more likely to simply leave the profession, creating a further gap in the workforce, rather than seeing out there final years reducing their workload but still maintaining a caseload.
Regional, rural and underserved communities
Families outside metropolitan areas already experience reduced access to allied health services, long travel times and difficulty recruiting therapists.
Any reduction in flexibility around telehealth, outreach services or parent capacity-building models may disproportionately affect rural and regional families.
These families are often managing complex care needs with fewer local supports and limited alternatives if providers withdraw from the sector.
Administrative burden on families
Many families report that the NDIS has become increasingly difficult to navigate.
Parents are already spending large amounts of time coordinating reports, responding to reviews, managing funding categories and advocating for supports. For families of children with high support needs, this often occurs alongside sleep disruption, reduced workforce participation and carer burnout.
More restrictive reassessment processes or shortened plan periods may unintentionally increase stress and administrative overload without improving outcomes.
There is also concern that increased system complexity may advantage families with greater financial, educational or advocacy capacity while disadvantaging vulnerable families who are less able to navigate appeals and evidence requirements.
Long-term outcomes
Early and appropriate support reduces long-term costs.
When children receive timely intervention, families are often better able to maintain employment, children are more likely to participate successfully in education and schools experience reduced behavioural and wellbeing pressures.
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Conversely, delayed or reduced access to suppo1is frequently leads to escalating complexity, increased family crisis, school disengagement and higher downstream costs across health, education and social systems.
The sustainability of the NDIS should not be considered separately from the long-tenn social and economic benefits of effective early suppo1i.
Recommendations
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Preserve access to early intervention suppo1is for children with developmental delay and neurodevelopmental conditions.
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Ensure reassessment pathways remain accessible, timely and clinically informed.
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Avoid oveITeliance on standardised functional assessments that may not reflect real-world functioning in children.
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Maintain flexibility within funding categories to allow responsive, family-centred and developmentally appropriate intervention.
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Provide clear transition planning and administrative support for participants and providers before implementing major changes.
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Consider the impact of refonns on workforce retention, small providers and regional service sustainability.
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Unde1iake meaningful consultation with clinicians, families, autistic and disabled people, educators and collllllunity providers before implementing significant operational changes.
Conclusion
There is broad suppo1i for improving the integrity and long-te1m sustainability of the NDIS. However, sustainability cannot be achieved through measures that unintentionally reduce access to effective early suppo1is or destabilise the existing workforce and service system.
Children and families require a system that is practical, flexible and responsive to real-world functioning. Refo1ms should strengthen the scheme without creating additional baITiers for those ah eady experiencing significant challenges.
From a frontline perspective, the success of these refo1ms will ultimately depend not only on legislation, but on whether children and families can still access timely, effective and relationship-based suppo1i within their COllllllunities.
If you have any questions, or would like to discuss this further, please do not hesitate to contact me.
Speech Pathologist
M Ed St, B App Sci (Sp Path), MSPA, CPSP
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