Submission 3219 — Mrs Emily-Kate McNamara — NDIS Future Generations Bill

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Submission to the Senate Community Affairs Committee

Inquiry into the National Disability Insurance Scheme Amendment (Securing

the NDIS for Future Generations) Bill 2026

Protecting Early Support and Regional Access for Children and Families

Date: May 2026

I am the owner and lead occupational therapist of Grow Curious Occupational Therapy, a small community-based paediatric occupational therapy service operating across the Blue Mountains, Lithgow and surrounding regional communities of New South Wales.

For more than six years, I have worked directly with children, families, schools, preschools and community services across these regions. My work focuses on supporting children to participate in everyday life through early intervention, parent coaching, educator collaboration and occupational therapy services delivered in homes, schools and community settings. I recognise the importance of ensuring the long-term sustainability of the NDIS. However, I am concerned that several measures proposed in the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 may create unintended consequences for children and families, particularly those living in regional communities.

Functional Capacity and Access to Support

The proposed changes introduce a new definition of functional capacity that focuses on a person’s abilities without assistance, supports, assistive technology or environmental modifications. While consistency in decision-making is important, many children achieve participation only because appropriate supports are already in place. Assessing children without considering the impact of those supports risks underestimating the challenges they experience in daily life. This concern is particularly relevant for neurodivergent children and children with developmental delays. Many of these children may appear capable in structured or supported environments while continuing to experience substantial difficulties in learning, emotional regulation, social participation, communication and independence. There is a risk that children who would benefit significantly from early intervention may be unable to access support until difficulties become more severe and entrenched.

Restrictions on Plan Reassessments

The proposed limitations on participant-requested reassessments are also concerning. Children’s development is not linear. Support needs can change rapidly due to transitions into school, increasing curriculum demands, behavioural challenges, mental health concerns, family circumstances or changing levels of informal support. While it is reasonable to discourage unnecessary reassessment requests, the proposed threshold of demonstrating significant and ongoing change

may create barriers for families seeking timely responses to genuine emerging needs. In practice, many families already struggle to navigate complex systems and provide the evidence required to justify support changes. Additional barriers may result in children going without appropriate supports for extended periods. The extension of decision-making timeframes may further delay access to necessary interventions during critical developmental periods.

Impact on Early Intervention

As a paediatric occupational therapist, one of my greatest concerns is the potential impact on early intervention. Effective early intervention often prevents more significant support needs later in life. It can improve participation, school engagement, family wellbeing and long-term independence. Many children present with emerging challenges that may not yet meet strict thresholds for significant functional impairment but are nevertheless experiencing genuine difficulties that affect their daily lives. If access pathways become narrower and reassessments become more difficult, there is a risk that support will shift from prevention to crisis response. This approach may ultimately increase long-term costs across health, education, disability and social service systems.

Regional and Rural Impacts

The practical realities of regional service delivery should be carefully considered. Families in regional communities already experience significant barriers, including workforce shortages, travel distances and long waiting lists for assessment and intervention services. Many families wait months or years to access specialist services. Delays associated with reassessments, access decisions or transitions between systems may leave children without support for extended periods. When support is unavailable, responsibility does not disappear. Instead, it is often transferred to families, educators and schools that are already under considerable pressure. Regional communities have fewer alternative services available when gaps emerge.

Impacts on Small Providers and Workforce Sustainability

Small private practices play a critical role in delivering services across regional Australia. The uncertainty associated with ongoing reforms, changing eligibility requirements and increased administrative complexity may place additional pressure on already stretched providers. Many small businesses operate with limited workforce capacity and significant travel demands. Further administrative burden reduces time available for direct clinical work and may contribute to workforce attrition. If providers reduce services or close, existing waitlists are likely to increase further, creating additional barriers for children and families.

Interaction with Foundational Supports and Thriving Kids

The Bill anticipates broader reforms and the future implementation of Thriving Kids and Foundational Supports. These reforms have the potential to improve access to

support for many children. However, there remains considerable uncertainty regarding service scope, funding arrangements, workforce availability and implementation timelines. It is critical that children do not lose access to existing supports before alternative systems are fully operational and capable of meeting demand. Any transition must be carefully staged and accompanied by clear communication for families and providers.

Conclusion

The long-term sustainability of the NDIS is important and necessary. However, sustainability should not be achieved by creating barriers that delay access to support for children who would benefit from early intervention or by shifting increasing responsibility onto families, schools and already stretched community services. Children’s developmental trajectories are shaped by the support they receive early. Delays in access often result in more complex needs and higher costs in the future.

Recommendations

  1. Ensure functional capacity assessments consider real-world participation and the role of existing supports rather than focusing solely on unsupported performance.

  2. Retain flexible pathways for plan reassessments where children experience emerging developmental, educational or family-related changes.

  3. Monitor the impact of access and reassessment changes on neurodivergent children and children with developmental delays.

  4. Undertake specific regional impact assessments before implementing significant access changes.

  5. Reduce administrative burden on participants, families and providers wherever possible.

  6. Ensure Thriving Kids and Foundational Supports are fully operational and adequately resourced before any reduction in existing support pathways.

  7. Continue meaningful consultation with families, clinicians, educators and small regional providers throughout implementation.

Thank you for the opportunity to provide this submission. I welcome continued consultation with families, clinicians, educators and regional service providers as these reforms progress.

Emily-Kate McNamara