Submission 314
To Whom It May Concern,
I write as an Occupational Therapist working within the disability sector to express grave concerns regarding the proposed changes contained within the National Disability Insurance Scheme (NDIS) “Securing the Future Generation” reforms and associated legislative amendments.
Occupational Therapists work directly with people living with disability across the lifespan and witness firsthand the essential role that the NDIS plays in enabling safety, independence, participation, dignity, and inclusion within the community. The proposed reforms raise significant concerns regarding equity, evidence-based practice, participant safety, and human rights outcomes for people with disability.
Of particular concern are the proposed changes to the interpretation and assessment of functional capacity. Functional Capacity Assessments (FCAs) are comprehensive clinical evaluations completed by trained allied health professionals using recognised assessment frameworks, standardised measures, clinical reasoning, longitudinal observation, and evidence-based methodologies. The proposed replacement of FCAs with “support needs assessments” undertaken by NDIS-employed personnel who may not possess relevant allied health qualifications presents substantial risks to participants. Functional capacity cannot be accurately determined without comprehensive clinical expertise. Allied health clinicians undergo extensive university education, supervised practice, registration requirements, and ongoing professional development specifically to interpret function, participation, environmental barriers, risk, and disability-related support needs. Replacing evidence-based disability assessment with administrative decision-making that lacks clinical rigour risks reducing the accuracy, reliability, and fairness of participant assessments. There are serious concerns that these assessments will fail to adequately capture fluctuating, complex, psychosocial, cognitive, neurological, developmental, and trauma-related disabilities. There is also concern regarding the lack of transparency and procedural fairness where the same body responsible for determining eligibility may also determine budgets and support allocations, with limited opportunity for independent review.
There are also grave concerns regarding proposals suggesting participants must demonstrate that all treatment options have been exhausted before accessing support. This requirement fails to reflect the realities faced by many Australians living with disability and ignores the significant barriers people encounter when attempting to access treatment. Many individuals are unable to access therapies or specialist services due to poverty, workforce shortages, extensive public waitlists, geographical isolation, communication barriers, cultural barriers, transport limitations, trauma histories, or the absence of appropriately trained clinicians. People should not be penalised for systemic failures outside of their control. The expectation that all treatment pathways must be exhausted before supports are considered permanent demonstrates a concerning misunderstanding of disability, rehabilitation, and contemporary allied health practice. Therapy does not “cure” disability. Rather, it supports function, safety, independence, regulation, participation, skill retention, and prevention of deterioration. Many disabilities are lifelong and require ongoing support regardless of treatment engagement.
Submission 314
There is also significant concern regarding the proposed amendments to the “reasonable and necessary” criteria, particularly the increased emphasis on “value for money,” “effective,” and “beneficial” supports. These changes appear to narrow support access through economic reasoning rather than clinical need and risk excluding participants whose progress may be slower, non-linear, or preventative in nature. Occupational therapy interventions frequently prevent hospitalisation, carer breakdown, mental health decline, falls, homelessness, restrictive practices, and premature entry into residential care. While these outcomes may not always produce immediate measurable outputs, they provide enormous long-term social and economic value. Preventative and capacity-building supports should not be denied simply because their benefits are difficult to quantify within narrow economic frameworks. The NDIS was established to support inclusion, participation, dignity, and quality of life, not solely to fund interventions with immediately measurable outcomes.
The proposed changes to budget structures, including increased reliance on flexible and stated funding, also raise serious concerns regarding participant wellbeing and autonomy. Many participants already experience significant financial strain in attempting to meet essential daily support needs. Requiring individuals to effectively choose between personal hygiene assistance, daily living supports, assistive technology, community access, social participation, or therapy interventions creates an unsafe and inequitable system. Capacity-building therapies are not optional luxuries. They are essential supports that maintain function, reduce deterioration, improve safety, increase independence, and reduce long-term support costs. Proposed reductions to therapy budgets and social and community participation funding fundamentally misunderstand the realities of disability support. Community participation often requires substantial supports including transport assistance, support worker assistance, sensory regulation supports, communication supports, supervision, mobility assistance, environmental modifications, and therapeutic intervention. Without these supports, many individuals will become increasingly isolated, dependent, deconditioned, and at risk of declining physical and mental health. If community access is reduced, additional supports within the home environment become necessary. The proposed reforms fail to adequately acknowledge this relationship.
There are also significant concerns regarding proposed barriers to reassessment and review. Disability is not static. Functional needs change due to illness, ageing, environmental changes, trauma, housing instability, carer burnout, mental health decline, equipment failure, changing family circumstances, and progression of conditions. Participants must retain accessible pathways to request reassessment when circumstances change. Reducing opportunities for review increases the likelihood that individuals will remain trapped within inadequate plans that no longer reflect their support needs, placing them at significant risk.
Further concern exists regarding the possibility of differential pricing arrangements and the impact this may have on service accessibility and workforce sustainability. Differential pricing risks reducing service access in rural and regional areas, destabilising the allied health workforce, increasing provider withdrawal from complex cases, worsening workforce shortages, and creating inequitable access based on geography or disability complexity. The disability workforce is already under immense pressure, and policies that undermine sustainability will ultimately reduce participant access to essential services.
Submission 314
Collectively, these reforms risk shifting the NDIS away from its foundational principles of inclusion, dignity, autonomy, and participation. Occupational Therapists are deeply concerned that these proposed changes will unfairly disadvantage people living with disability and expose many individuals to significant harm, neglect, institutionalisation, social isolation, deteriorating health, and reduced quality of life. People with disability deserve the opportunity to live meaningful lives within their communities with the same rights, dignity, and opportunities afforded to all Australians.
The current direction of these reforms creates a perception that disabled people are increasingly viewed as financial burdens rather than valued members of society deserving of support, inclusion, and investment. As clinicians working directly alongside participants and families, we strongly urge the Government to retain comprehensive allied health-led functional capacity assessments, preserve participant rights to independent review and reassessment, protect access to therapy and capacity-building supports, ensure equitable access regardless of socioeconomic status or geography, maintain the integrity of the “reasonable and necessary” framework, and ensure disability support decisions remain evidence-based and clinically informed.
Meaningful consultation with people with disability, families, and frontline allied health professionals must remain central to any future reform of the NDIS.
Yours sincerely,