Submission 3249 — Speech Ease Therapy Services — NDIS Future Generations Bill

SUBMISSION TO THE SENATE COMMUNITY AFFAIRS LEGISLATION COMMITTEE

Inquiry into the National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026

Submitted by: Cheryl Ye, Director

Organisation: Speech Ease Therapy Services

Location: Melbourne, Victoria

Date: May 2026

Contact:

1. About this submission This submission is made by Speech Ease Therapy Services, an established paediatric speech pathology practice based in Melbourne, Victoria. We are a private allied health provider delivering assessment and therapy services to children and families, the majority of whom are aged eight years and under and a significant proportion of whom currently access supports through the National Disability Insurance Scheme (NDIS) Early Childhood Approach.

Our team comprises speech pathologists at varying career stages, supported by senior clinical leadership, a Practice Principal, an Operations Manager, a Client Experience Manager and a Client Experience Team. Our average clinician tenure is around three years, which directly supports continuity of care for the families we work with. We deliver clinical placements in partnership with universities, run supervision and mentoring structures for early-career clinicians, and maintain partnerships with kinders, childcares and schools across our catchment.

We make this submission in good faith and in support of a sustainable NDIS. We share the Government’s stated objective of protecting the Scheme for people with permanent and significant disability and for future generations. Our concerns relate to specific provisions of the Bill and to the practical implementation realities that, in our considered view, are not adequately addressed in the legislation as drafted and which, if not addressed, will produce significant unintended consequences for children, families, clinicians, providers and the broader allied health workforce on which the success of these reforms depends.

We acknowledge the very compressed inquiry timeframe and submit this evidence with the request that the Committee weigh operational provider perspectives carefully, given the short window for sector input on legislation of this scale.

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2. Summary of position Speech Ease supports the underlying objectives of the Bill but holds serious concerns about the following provisions and the way they interact with the wider reform program, particularly the rollout of Thriving Kids:

• The legislated pathway transitioning children aged 0-8 with low-to-moderate developmental delay and/or autism out of NDIS eligibility and into Thriving Kids, in the absence of operational certainty about how Thriving Kids will be delivered in each State and Territory, and which providers will deliver it.

• The shift to a new functional capacity eligibility assessment for new applicants from 2028 and the phased reassessment of existing participants over three years, without sufficient transitional protections for children mid-way through evidence-based early intervention.

• The provisions enabling Ministerial determinations to progressively reduce participant budgets for social, civic and community participation supports and capacity-building daily activities from October 2026, which affect cohorts our clinicians work with daily, including children and young people whose communication, social participation and self-regulation goals are directly supported by these funding categories.

• The commissioning, pricing and registration changes for providers, including the move toward block funding and panel arrangements, and the implications for small and medium private allied health practices that currently deliver the majority of paediatric therapy in this country.

Our overarching recommendation is that the Bill should not be passed in its current form without amendments and supplementary commitments that secure: (a) genuine continuity of care for children in active therapy during transition; (b) a legislated role for experienced private allied health providers in the delivery of Thriving Kids and successor programs; (c) transparent transitional arrangements for affected cohorts; and (d) realistic implementation timelines that reflect workforce and operational reality.

3. Specific concerns relating to provisions of the Bill 3.1 Transition of children aged 0-8 out of the NDIS into Thriving Kids

The Bill, together with the Government’s published reform timeline, establishes a pathway under which children aged eight and under with developmental delay and/or autism with low-to-moderate support needs will, from January 2028, be supported through Thriving Kids instead of the NDIS. We make the following observations from the perspective of a paediatric provider delivering services to this exact cohort every day.

Operational reality: Thriving Kids procurement is currently underway in NSW (Expression of Interest open until 29 May 2026) and is at varying earlier stages in Victoria and other jurisdictions. The NSW EOI structure channels services primarily through NSW Government agencies and commissioned non government organisations (NGOs), with private providers engaged only “where required.” This is

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significant because the existing paediatric allied health workforce delivering services to children in this cohort is overwhelmingly in private practice, not in NGOs or government services. The Bill legislates the transition before the delivery model that will replace NDIS-funded supports has demonstrated workforce capacity to meet demand.

Risk: If the legislated transition proceeds on the current timeline and Thriving Kids is delivered through a model that excludes or significantly reduces the role of experienced private allied health providers, there will be a service capacity gap at the precise moment the cohort exits NDIS funding. Children currently receiving evidence-based early intervention through private clinicians risk losing continuity of care. New referrals will face extended waitlists while NGO and government capacity is built. These are exactly the developmental windows in which early intervention yields the highest return.

Workforce risk: Paediatric private practices like ours have built our workforce, supervision structures, university placement programs and clinical capability over many years. A significant proportion of our funded caseload is children aged eight and under the NDIS. If that cohort transitions out of NDIS funding and into a Thriving Kids model that excludes us, our financial viability is materially affected. The consequence is not just the loss of services for the under-eight cohort; it is the loss of whole practices, which means children aged 9 and over, including those with complex presentations who remain on the NDIS, lose their therapists too. This second-order workforce contraction does not appear to have been modelled in the design of the design.

3.2 New functional capacity eligibility assessment and transitional arrangements

The Bill enables a new standardised, evidence-based functional capacity assessment to determine eligibility for NDIS access, with implementation to be supported by the Technical Advisory Group. We do not oppose evidence-based functional assessment as a principle. We raise the following implementation concerns.

Children with fluctuating presentations: Many neurodivergent children, including children with autism and developmental language disorder, present with functional capacity that varies significantly across environments, days and developmental stages. A single point-in-time assessment may not accurately capture support needs. The legislation should require that any functional capacity assessment for children explicitly accounts for variability across settings and over time, and that assessments are conducted by clinicians with paediatric expertise.

Reassessment of existing participants: The phased reassessment over three years from 2028 creates significant uncertainty for families currently in active therapy. We routinely work with children on multi-year therapy plans calibrated to developmental trajectory. A reassessment process that may remove eligibility mid-way through a therapy plan, without clear transitional protections to maintain therapeutic continuity, risks undoing the developmental gains the NDIS was funded to support. The Bill should be amended to require clear transitional protections, including a presumption of continuity of care for children with an active, clinically endorsed therapy plan at the time of reassessment.

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3.3 Ministerial determinations reducing social, civic and community participation and capacity-building budgets

The Bill enables the Minister to make determinations progressively, adjusting participant budgets for social, civic and community participation supports and capacity-building daily activities from October

2026. Published policy material indicates intended reductions of approximately 50 per cent for social, civic and community participation and 10 per cent for capacity-building daily activities, with budgets to be reset to approximately 2023 levels.

Why this matters for paediatric speech pathology: While these categories are often discussed in the context of adult participants, they are also relevant to children and young people. Capacity-building daily activities are the funding category through which many of our therapy sessions are claimed. Social and community participation supports the functional generalisation of communication and social skills into real-world environments. For example, the playground, the supermarket, the family event, which is precisely where the evidence base says skills must be practised to consolidate. Reductions to these categories, set by Ministerial determination outside the ordinary parliamentary process, risk eroding the funded basis for delivering evidence-based therapy.

Process concern: Vesting the power to progressively reset participant budget categories in Ministerial determinations, rather than retaining parliamentary oversight, reduces the visibility of changes that will materially affect children, families and providers. The Bill should be amended to require that any such determinations be subject to public consultation, disability community input, sector workforce impact analysis, and disallowance by either House of Parliament.

3.4 Commissioning, pricing and registration changes affecting small and medium private allied health providers

The Bill enables a suite of provider-side changes, including commissioned panels for plan management and support coordination, expanded registration requirements, differentiated pricing for unregistered providers, and broader commissioning of home and living supports. While we support fraud and integrity measures and the principle of quality assurance, we raise the following concerns from the perspective of a small to medium private paediatric practice.

Administrative load on small providers: Paediatric allied health is delivered overwhelmingly by small and medium private practices. Our practice has approximately 17 staff, including clinicians and client experience team members (admin/reception). We do not have dedicated tender-writing teams, compliance departments, or the corporate-scale infrastructure that commissioned panel models are typically designed around. Each additional layer of registration, reporting, panel application, audit, and compliance documentation comes out of clinical capacity — either directly (less time delivering therapy) or indirectly (less time on supervision, professional development, and clinical quality). The cumulative effect of the changes the Bill enables will fall disproportionately on the very providers who deliver the most embedded, continuous, community-trusted paediatric services.

Mixed ecosystem at risk: If the cumulative effect of registration, pricing, commissioning and panel changes is to make participation uneconomic for small and medium private providers, the paediatric

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allied health market consolidates toward larger NGOs and corporate providers. This is bad for choice and control, bad for regional and outer-metro access (where small providers often fill gaps that larger organisations do not), and bad for the workforce, which has historically been trained in and sustained by small-practice clinical environments.

3.5 Implementation timeline

The Bill’s accompanying reform timeline is ambitious. Thriving Kids services commence rollout no later than 1 October 2026; budget resets begin from 1 October 2026; full Thriving Kids rollout by 1 January 2028; access changes for new under-eight applicants from 1 January 2028; phased reassessment of existing participants over three years from 2028. Several of these milestones depend on State and Territory delivery models, workforce mobilisation, and procurement processes that are at very different stages of maturity across jurisdictions.

Our concern is not that reform is happening, but that the timeline is being legislated before the operational components underneath it are in place. Reform implemented at a pace that exceeds workforce and operational capacity does not deliver the outcomes the Bill aspires to. It delivers service gaps, broken therapeutic relationships, clinician attrition and the consolidation of provider markets toward those with the administrative capacity to absorb the change, not necessarily those with the clinical capacity to deliver the outcomes.

4. Real-world consequences if the Bill proceeds unamended Drawing on our daily operational experience as a paediatric provider, we set out below the consequences we anticipate if the Bill proceeds in its current form without the amendments and

   safeguards described in this submission. These are not theoretical risks; they are the lived

implementation realities providers like ours are already planning around.

• Many small and medium paediatric private practices will become financially unviable as the under-eight cohort transitions from NDIS funding to a Thriving Kids model that excludes them. Some will close.

• Clinicians and support staff currently employed in private paediatric practices will lose jobs at a time when the allied health workforce is already under pressure. The workforce that the Government has spent years investing in through university placements and graduate development will contract.

• Families currently in trusted, multi-year therapeutic relationships will lose access to their clinicians. Therapeutic relationships are not transferable like consumer goods; for many neurodivergent children, the relationship itself is part of the clinical intervention.

• Waitlists for paediatric allied health services will worsen significantly as NGO and government services are insufficient in current capacity to absorb redirected demand from the private sector.

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• Children will miss critical early developmental windows for speech, language, social

communication and self-regulation skills.

• Regional, rural and outer-metropolitan communities will be disproportionately affected. Private providers, including telehealth-capable practices, currently fill access gaps that NGO and government services have historically struggled to staff.

• Older children, including those aged 9 and over with complex presentations who remain on the NDIS, will lose access when whole practices close as a result of losing the under-eight cohort.

• Reduced access to early and ongoing support will produce poorer long-term outcomes for children: lower school readiness, reduced classroom participation, weaker literacy and social outcomes, increased mental health burden, reduced independence in adolescence, and reduced future workforce participation. The costs of these outcomes accrue to other parts of the public system: education, health, mental health, justice, welfare over decades.

The cost of the Bill, in our view, is not contained to the disability portfolio. It will be paid out across the rest of the public system, by children and families who had no role in its design.

5. Recommendations Speech Ease respectfully recommends that the Committee consider the following amendments and supplementary commitments before the Bill is finalised:

6. Continuity of care protections: Amend the Bill to require that any reassessment process that may result in loss of NDIS eligibility for a child in active, clinically endorsed therapy include explicit transitional protections, including a presumption of continuity of care and a guaranteed funded transition period of no less than twelve months while alternative supports are established.

7. Legislated role for experienced private allied health providers: Amend the Bill (or include in supporting policy and intergovernmental agreements) an explicit commitment that

experienced private allied health providers are a core part of Thriving Kids delivery alongside NGOs and government services, not a fallback engaged “where required.”

3.  Parliamentary  oversight  of  Ministerial  determinations:  Require  that  any  Ministerial

determination progressively adjusting participant budget categories be subject to public consultation, disability community input, independent workforce and outcomes impact analysis, and disallowance by either House of Parliament.

4. Paediatric-specific assessment standards: Amend provisions establishing the new functional capacity assessment to require that any assessment of a child include paediatric clinical expertise, account for variability across environments and developmental stages, and be conducted in a manner consistent with neurodiversity-affirming practice.

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5. Workforce impact analysis: Require, as a condition of commencement of the under-eight access changes from 1 January 2028, that the Government publish a transparent workforce impact analysis modelling the effect of the reforms on the existing paediatric allied health workforce, including small and medium private providers, with the analysis informed by primary data from providers themselves.

6. Tiered procurement pathways for small and medium providers: Commit to supporting policy guidance for Thriving Kids and successor commissioning processes, to tiered or simplified procurement pathways that allow experienced small and medium private practices to participate without bearing administrative overheads designed for large NGO contracts. This may include smaller contract lots, consortium and contracting arrangements, streamlined reporting, or a panel structure that recognises clinical capability and community trust as procurement criteria.

7. Implementation timing aligned with operational reality: Build into the Bill a mechanism whereby the commencement of access changes for the under-eight cohort is contingent on a

   demonstrated, audited level of Thriving Kids workforce and service capacity in each

jurisdiction. The legislated date should be a ceiling, not a floor: where capacity is not in place, transitions for that jurisdiction or cohort should be delayed rather than children left without services.

8. Direct engagement with private allied health providers: Commit to direct engagement with experienced private paediatric allied health providers, not only through peak bodies, in the design of subordinate legislation, rules, and operational guidelines flowing from this Bill, including the Technical Advisory Group’s work on functional capacity assessment.

9. Closing remarks We make this submission because we believe in the NDIS and the broader system of supports that should surround it. We are not opposed to reform. We see, every day, what good early intervention does for children and what its absence costs. We also see, every day, the operational realities of how paediatric services are actually delivered in this country, mainly by small and medium private practices, embedded in their communities, with long-tenured clinicians who know their families.

Legislation that does not reflect those realities will not produce the outcomes it aspires to. Legislation that does will be one of the most consequential and positive reforms this country has made for children with developmental needs and their families. The difference between those two outcomes is in the detail — and in the willingness of this Committee, and of Parliament, to insist that the detail is right before this Bill is passed.

We are grateful for the opportunity to make this submission. We would welcome the opportunity to appear before the Committee or to provide further operational data, case examples and workforce information if that would assist the Committee’s consideration of the Bill.

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Yours sincerely,

Cheryl Ye

Director

Speech Ease Therapy Services Pty Ltd

Melbourne, Victoria

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