Paediatric occupational therapy practice concerns regarding NDIS bill (Provider experience)

Submission 332

Email: info@outcomestherapy.com.au PO Box 1403 North lakes, QLD 4509 www.outcomestherapy.com.au

Phone: 0466 994 500 ABN: 15 636 676 956

Submission to the Senate Community Affairs Legislation Committee

Date: 26/05/2026

This submission is made from the perspective of a private paediatric occupational therapy practice supporting children, young people and families who rely on the NDIS, and from the perspective of a business owner who is also a disabled person, carer, plan nominee, and parent of three disabled children. Our central concern is that the Bill treats many supports as if they can be reduced, delayed, administratively narrowed or standardised without immediate consequence. In practice, the consequence does not disappear. It is transferred to disabled people, unpaid carers, already overloaded mainstream systems, and the small allied health businesses that currently hold much of the early-intervention, family-capacity and functional-support infrastructure together.

Executive summary We support the need for Scheme integrity, fraud prevention and long-term sustainability. We do not support reforms that achieve apparent savings by reducing access to evidence-based disability supports, weakening individualised decision making, or increasing reliance on unpaid carers and overstretched private providers. Sustainability cannot be achieved by making participants, carers, clinicians and small businesses less sustainable. As a paediatric occupational therapy practice, we see every day that NDIS-funded allied health is not a luxury. It supports children to eat, sleep, dress, toilet, communicate, regulate, play, attend childcare or school, participate safely in family life, and develop skills that reduce long-term reliance on more intensive systems. It also supports parents and carers to understand disability-related needs, reduce crisis escalation, and remain in employment. The Bill creates significant risk through broad funding-reduction powers, changes to functional capacity, narrower links between impairment and support needs, tighter reassessment pathways, increased administrative enforcement, potential automation, and future changes to provider registration, claim timeframes and pricing. Individually, each measure may be framed as administrative reform. In combination, they create a real risk that children and families will be pushed out of timely, relational and preventative support and into crisis-driven systems. The most important question for Parliament is not only whether the NDIS spends less in the short term. It is whether children, families and high-support participants remain safe, supported and able to participate in ordinary life. A reform that reduces an NDIS line item but increases hospital presentations, mental health crises, school exclusion, carer burnout, workforce withdrawal, homelessness risk or state care involvement is not a saving. It is cost-shifting.

Recommendations sought

1. That the Bill not pass in its current form, and that progression of the Bill through Parliament be paused until meaningful consultation has occurred with disabled people, families, carers, nominees, allied health providers, support workers, plan managers, advocates and disability representative organisations.

2. That proposed section 34A, or any equivalent power allowing broad percentage reductions to support categories without individual reassessment, be withdrawn in its entirety.

3. That any reduction to a participant budget or support category require individualised consideration of safety, functional impact, family/carer capacity, risk of deterioration, and likely downstream cost to health, education, housing, justice and child-protection systems.

4. That the current 21-day timeframe for responding to valid reassessment requests be retained, with a triage mechanism for non-urgent requests rather than a blanket extension to 90 days.

5. That proposed revocation powers for non-contactability be removed or substantially narrowed, with suspension only as a last resort and with strong safeguards, nominee contact, multiple contact methods and staged warnings.

Submission 332

6. That the proposed functional capacity definition be removed or amended so that functional capacity is not artificially separated from environment, support relationships, assistive technology, fluctuating presentation, trauma, communication needs, informal supports and the real-world context in which disability is lived.

7. That fully automated eligibility, reassessment or funding decisions be prohibited, and that any automated administrative process be subject to transparency, human review, independent oversight and accessible appeal rights.

8. That independent allied health evidence remain a meaningful component of planning, reassessment and review decisions, especially for children, participants with complex or fluctuating disability, and participants whose needs cannot be captured by a single standardised tool.

9. That any increased provider regulation, registration, record-keeping and compliance burden be proportionate, staged and supported, so that small ethical allied health practices are not pushed out of NDIS service delivery.

10. That foundational supports be properly designed, funded, available, geographically accessible and operational before NDIS eligibility or capacity-building supports are narrowed.

11. Who we are and why this business submission matters This submission is written from the perspective of a small private occupational therapy business in Queensland, providing paediatric allied health services to NDIS participants and their families. Our work includes assessment, functional capacity reporting, therapy, parent coaching, school and kindy transition support, assistive technology recommendations, sensory and emotional regulation support, self-care intervention, developmental skill building, and practical strategies for daily participation. We are not simply providing appointments. We are part of the functional support system around children and families. Our work often prevents deterioration. We help families understand why a child cannot cope with certain demands, why everyday routines are breaking down, why a child is being excluded from learning or community settings, and what practical supports can improve safety, participation and development. In a functioning private practice, clinical work and business viability are inseparable. A practice cannot support children and families if it cannot retain staff, comply with regulations, fund supervision and continuing professional development, write high-quality reports, cover administrative demands, purchase resources, and remain financially viable under the pricing and claiming framework. Reforms that appear to affect “providers” therefore flow directly to participants. If providers are destabilised, families lose access. If families lose access, unmet need does not vanish. It becomes distress, exclusion, carer burnout, school refusal, emergency presentations, family breakdown and more expensive interventions later. This submission also draws on lived experience. The business owner is a carer and plan nominee for an adult sibling with complex disability, and a parent of disabled children with their own NDIS plans. That personal context matters because it demonstrates the same issue from both sides: as a provider, we see how reform affects access to services; as a family, we live what happens when formal supports are delayed, reduced or destabilised.

12. The personal reality behind the professional concern The risk in this Bill is not theoretical. In our family, one adult participant requires 24/7 supported living and stable routines, relationships and community access to remain safe and regulated. When supports are disrupted, functional capacity does not remain static. Distress increases. Psychosocial wellbeing deteriorates. Community access reduces. Behavioural escalation and crisis risk increase. These outcomes are foreseeable, because they have already occurred during periods of service disruption and restricted community access. At the same time, the business owner is also parenting three disabled children with competing developmental, sensory, physical, mental health and neurodevelopmental needs. Like many carers, she is already providing substantial unpaid coordination, advocacy, emotional labour and day-to-day support while also remaining in the workforce and employing other people. There is no hidden reserve of family capacity waiting to absorb reduced formal support. This matters for a business submission because private allied health practices are often owned, staffed and accessed by people who are also part of the disability community. Many small providers exist because families needed flexible work and because clinicians saw unmet need. When reforms increase unpaid carer load, reduce funded therapy, make reporting harder to obtain, or destabilise small providers, the effects are multiplied. The same people are hit as participants, carers, employees, employers and service providers. The Government are aware of this impact, the Explanatory memorandum states

“Reforms that reduce the demand for NDIS services in the market will disproportionately affect women who make up approximately 68 per cent of the care and support workforce.165 The magnitude of impact on providers is dependent on which supports are reduced and the percentage those supports represent of provider revenue and the extent to

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which the current demand for effected NDIA supports is currently met through market supply. All things being equal, providers with smaller revenue streams will be more significantly impacted by reductions in supply. Tightening the definition of reasonable and necessary supports will also reduce NDIS funding and demand for services across all support categories. Collectively, if reforms result in increased stress on provider viability, then governments may need to prevent market failure and ensure essential services continue.” (p.239)

From our practice perspective, the families we support will experience the same pattern. If a child’s plan is reduced, if a reassessment is delayed, if evidence is discounted, if capacity-building funds are cut, or if access becomes dependent on a narrow snapshot of “functional capacity”, the gap will land on parents. Most often, it will land on mothers. It will reduce workforc e participation, increase stress, reduce siblings’ wellbeing, and increase the likelihood that the child’s needs escalate rathe r than reduce.

The Explanatory Memorandum for the Bill acknowledges this disparity:

“Changes may increase expectations of informal supports. The option includes a more vigorous consideration of what informal supports are reasonable for delegates to consider. This is likely to have direct flow on impacts to family members and kin (particularly of younger people) and may impact on the role of informal support under

Australia’s Disability Strategy.154

Given most carers are female, these impacts may be disproportionately experienced by women.155

Changes also have the potential to affect certain Closing the Gap outcomes.156” (p. 236)

Recommendation: That the progression of the Bill through Parliament be paused until meaningful consultation has occurred with disabled people, families, carers, nominees, allied health providers, support workers, plan managers, advocates and disability representative organisations. A focus point must be that the maintenance of individualised reassessment, safety analysis, carer-capacity analysis, clinical evidence consideration, and review rights before any reductions take effect.

3. Our clients will experience this as reduced safety, reduced participation and increased crisis The language of the Bill is administrative. Families will experience it as practical harm. A reduction in capacity-building funding is not a spreadsheet adjustment; it is fewer therapy sessions, delayed assessment, a missed assistive technology application, a parent left without coaching, a school without functional recommendations, or a family unable to obtain evidence for a reassessment until the situation is already unsafe. Our clients include children whose disability-related needs affect toileting, eating, sleeping, dressing, sensory regulation, mobility, play, social participation, emotional regulation, school readiness and family routines. For these children, occupational therapy is often the bridge between “the child is not coping” and “the adults understand what support is required”. Removing or reducing that bridge does not make the need smaller. It makes the child more likely to be labelled non-compliant, difficult, anxious, unsafe, lazy, naughty or not ready, when the underlying issue is disability-related functional need. The Bill must be assessed against these real-life consequences. A child who loses access to therapy may not immediately appear in an NDIS cost line. They may instead appear as a school exclusion, a parent leaving employment, a mental health referral, a paediatrician waitlist, a family violence stressor, a child protection concern, or a hospital presentation. Those systems are already under pressure. Shifting cost to them is not reform.

4. Proposed broad support reductions and capping are unsafe and inconsistent with individualised support The most serious concern proposed in the Bill includes Ministerial power that would allow support categories to be capped at certain amounts or subsequently reduced by broad percentage determinations without individual reassessment of reasonable and necessary needs, safety risk, functional impact or carer capacity. In practical terms, this risks converting the NDIS from an individualised disability-support scheme into a capped category-management scheme. For our clients, a percentage reduction does not fall evenly. A 10% reduction to a capacity-building budget may be the difference between a child receiving an assessment of needs to inform best-practice intervention and not receiving one, between a therapist attending a school transition meeting to support the move into formalised educational environments and being unable to, between a family receiving parent coaching and being left to manage escalating behaviours alone. A

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50% reduction to social and community participation may be the difference between supported access and isolation for participants who cannot safely access community life without assistance. For example, consider a young adult with an intellectual disability who relies on a support worker to attend a weekly community sports group and visit the local library. If their funding is halved, they might only be able to attend these activities once a month instead of every week, or not at all. This loss of regular engagement could lead to increased loneliness, a decline in mental health, and regression in social skills—effects that extend beyond the individual to their family and broader community. The families most harmed by broad reductions will not be those with the most discretionary use of funds. They will be those already rationing. They will be children whose parents delay reports because therapy must come first, participants whose plans are already underfunded, families in regional areas paying travel costs, participants with complex communication needs, and carers who are too exhausted to contest decisions. From a private practice perspective, these cuts also make ethical and effective service delivery harder. Families may ask us to compress complex assessments into inadequate timeframes, write shorter reports than clinically required, reduce intervention frequency below a meaningful therapeutic dose, or prioritise evidence production over actual capacity building. Clinicians are then placed in the position of trying to maintain professional standards within funding settings that no longer support safe or effective work. From a professional registration standpoint, this blurs the line between competent, ethical practice and working outside of the bounds of our AHPRA registration and Professional Code of Conduct, which may result in disciplinary action from the registration board. The Bill should not allow financial sustainability to override individualised assessment. If savings are required, they should be pursued through fraud prevention, pricing integrity, better evidence-based planning, improved mainstream interface arrangements and genuine co-designed reform. They should not be pursued by blunt reductions that make disabled people and carers absorb risk. Recommendation: Proposed section 34A, or any equivalent broad support-determination power, should be withdrawn. If any support reduction mechanism remains, it must require individualised reassessment, safety analysis, carer-capacity analysis, clinical evidence consideration, and review rights before any reduction takes effect.

5. Capacity-building supports are preventative, not optional Capacity-building daily activity budgets are directly relevant to occupational therapy across the lifespan. These budgets fund the supports that help children develop functional skills and help families build sustainable routines. In our practice, capacity building may look like toileting intervention, mealtime support, sleep routines, sensory modulation strategies, motor planning, fine motor development, self-care skill building, emotional regulation, school readiness, assistive technology trials, parent coaching and functional reporting. These are not extras. They are the supports that reduce long-term dependence and prevent escalation. When capacity building supports are delayed or reduced, children do not simply pause development until the next plan. They miss learning windows. Families become more distressed. Schools and kindergartens receive less guidance. Behaviours of concern may increase. Parents may become less able to work. The eventual support need may become greater, not smaller. Private OT practices also carry substantial non-face-to-face work that is essential to quality service: reviewing reports, liaising with schools, preparing therapy resources, writing functional recommendations, documenting risk, consulting with families, and coordinating with other professionals. If funding reductions pressure families to purchase only face-to-face sessions, the quality and safety of therapy deteriorates. The visible session is only one part of the intervention. The Bill and associated reforms must recognise that evidence-based allied health support often requires assessment, planning, documentation and collaboration. These activities are not administrative waste; they are how safe practice occurs. A system that funds only the visible appointment but not the clinical reasoning around it will produce poorer outcomes and higher risk. Recommendation: Capacity-building supports, including allied health assessment, therapy, parent coaching, report writing and collaboration, must be protected from broad reductions and assessed according to individual need, functional impact and risk of non-provision.

6. Functional capacity cannot be safely assessed outside real-world context The proposed definition of functional capacity is deeply concerning if it requires assessment of what a person can do without assistance, assistive technology, modifications and, as far as possible, without environmental or personal circumstances. Disability does not exist in a vacuum. Function is not a laboratory measure. It is relational, contextual, fluctuating and dependent on the interaction between the person, the task, the environment and available supports.

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For children, this is especially important. A child may appear capable in a quiet one-to-one assessment but be unable to function in a noisy classroom, busy shopping centre, unpredictable playground or morning routine involving siblings, fatigue and time pressure. A child may complete a task once with novelty and adult support but be unable to perform it consistently, safely or independently. A child may mask distress in an assessment and collapse afterwards. A child may have skills that are technically present but not accessible under real-life demands. For participants with psychosocial disability, intellectual disability, autism, communication differences, trauma histories or fluctuating capacity, context is not peripheral. It is the mechanism through which disability becomes manageable or unmanageable. Removing support relationships, routines, environmental scaffolding and informal support from the assessment risks producing an artificial and unsafe picture of function. As occupational therapists, we are trained to assess the person, environment and occupation together. The proposed unskilled approach risks weakening precisely the kind of functional analysis that allows supports to be targeted, proportionate and effective. A narrow tool or snapshot cannot replace nuanced clinical reasoning about capacity, performance, risk, sustainability and support dependence. There is plenty of feedback witnessed from the current undertaking of the Support Needs Assessment Trial to show that agency staff are unable to adequately assess support needs through that process, and that it should be revoked and redesigned with appropriately trained and skilled assessor workforce (Allied Health Professionals). Recommendation: The proposed functional capacity definition should be removed or amended so that assessment must be conducted by a skilled professional such as occupational therapists, and consider real-world performance, supported and unsupported capacity, environmental demands, assistive technology, informal supports, fluctuating presentation, sustainability, safety and risk of deterioration.

7. A stronger impairment-support link must not erase complex disability We understand the policy intention of linking funded supports to the impairment for which a participant meets access. However, this must not be applied in a way that fragments complex disability. Many children and adults have overlapping impairments: autism, intellectual disability, developmental delay, ADHD, anxiety, trauma, motor coordination difficulties, genetic conditions, sensory processing differences, physical disability and psychosocial disability may interact in ways that cannot be clinically separated into neat funding boxes. For example, in paediatric practice, a child’s toileting difficulty may relate to interoception, sensory processing, anxiety, motor planning, communication, cognition, routine dependence and environmental demands. A child’s school participation difficulty may relate to autism, sensory overwhelm, fatigue, executive functioning, motor skills, communication and social vulnerability. If supports are rejected because the need is described as broader than one impairment label, children with complex presentations will be disadvantaged. We agree that the Scheme needs safeguards against inappropriate cost shifting to the NDIS, but it also needs safeguards against inappropriate cost shifting out of the NDIS. A child should not lose access to functional support including 1:1 therapeutic intervention because their disability presentation is too complex to fit a narrow administrative category. Recommendation: Any impairment-support link must allow for interacting impairments and cumulative functional impact, and must not prevent funding where the eligible impairment materially contributes to the support need even if other factors are also present.

8. Longer reassessment timeframes will place families and providers in unsafe positions We are concerned about any proposal to extend the timeframe for responding to valid participant-requested reassessment requests from 21 days to 90 days. We accept that unnecessary reassessments should be discouraged, and understand that they are within the current legislation, only meant to be submitted or considered for significant change in circumstances. However, a blanket 90-day period is unsafe for participants whose circumstances have changed significantly or whose plans were substantially underfunded at onset – a risk of which is heightened with concurrent legislative changes to move the determination of funding towards using algorithmic methods without human oversight (covered elsewhere within this submission). In our practice, reassessment evidence is often requested when a child’s functioning has deteriorated, a school or kindy placement is at risk, a family’s informal support has changed, new equipment is required, therapy needs have increased, behaviours have escalated, or a plan has been exhausted because it did not reflect the child’s functional needs. A 90-day wait for a decision on whether reassessment will occur can be the difference between early response and crisis. The burden also shifts to providers. Families may ask therapists to continue unfunded work, hold places, write urgent letters, discount services or provide crisis advice outside funded arrangements. Ethical providers want to help, but private

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practices cannot operate as an unfunded safety net for systemic delay. When we do, staff burn out and the business becomes less viable; when we do not, families are left unsupported. Recommendation: The 21-day timeframe should be retained for valid reassessment requests, with an option for triaging non-urgent requests rather than delaying all families. Urgent requests involving safety, accommodation, school exclusion, loss of informal support, escalating behaviours or significant functional decline should require faster response.

9. Revocation or suspension for non-contactability is dangerous without strong safeguards Any power to suspend or revoke participant status because a person is not contactable creates serious safeguarding risk. Many NDIS participants are not reliably contactable for disability-related reasons: psychosocial disability, intellectual disability, communication disability, family violence, homelessness, digital exclusion, trauma, cognitive overload, hospitalisation, carer illness, or administrative overwhelm. These are precisely the participants most likely to be harmed if supports are suspended or revoked. As providers, we frequently see families overwhelmed by correspondence, portals, changing rules, plan dates, evidence requests and administrative language. Non-response does not necessarily mean disengagement or absence of need. It may mean the system has become inaccessible. For high-support participants, revocation or prolonged suspension is not an administrative inconvenience. It may destabilise housing, staffing, community access, medication routines, behaviour support, mental health and safety. For children, it may remove therapy and family support at the moment the family is least able to navigate appeal pathways. Recommendation: Revocation powers for non-contactability should be removed. If suspension remains, it must be a last resort after repeated accessible contact attempts, nominee involvement, provider/guardian checks where appropriate, staged warnings, reasonable adjustments, and urgent safeguarding review where the participant has complex or high-risk needs.

10. Automation must never replace human judgement in disability support decisions Automation may have a place in low-risk administrative processes. It should not determine eligibility, reassessment outcomes, support needs or funding allocation without meaningful human judgement. Disability assessment requires interpretation of context, communication, trauma, culture, fluctuating presentation, carer strain, environmental barriers and the difference between technical skill and sustainable real-world function. Families already struggle to challenge decisions that misunderstand disability. If automated or classification-based systems become dominant, the risk is that complex needs will be reduced to scores that appear objective but miss what matters. A child who masks, a parent who underreports because they are exhausted, a participant who performs well on one day, or a person whose needs fluctuate may be under-classified. The result may be a plan that looks fair on paper and fails in real life. Our professional concern is that automation could also discount independent allied health evidence. If reports are treated as secondary to a standardised tool, the system may lose the benefit of clinicians who know the participant, understand functional performance across settings, and can explain risk in practical terms. Recommendation: Fully automated eligibility, reassessment and funding decisions should be prohibited. Any automated process must be transparent, limited, independently overseen, subject to human review, and accompanied by accessible reasons and review rights. Failure to comply with safeguards should affect the validity of the decision.

11. Provider compliance reform must not collapse ethical small providers We support proportionate safeguards, proper record keeping, fraud prevention and high professional standards. Ethical providers want poor practice, exploitation and fraud addressed. However, compliance reform must distinguish between deliberate misconduct and the reality of small allied health practices operating under increasing administrative burden. The Bill and related reforms appear likely to increase expectations around provider definition, registration, records, claim verification, investigation powers, pricing and plan management. These may be reasonable in principle, but they have practical costs: policy development, administration, audits, supervision, systems, staff training, legal review, documentation time and risk management. Large organisations may absorb these costs. Small practices may not.

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If the regulatory response to fraud is designed in a way that pushes small, ethical, relationship-based providers out of the market, participants will lose choice and access. Families may be left with no local services (and therefore longer travel expectations in already tight schedules), longer waitlists, larger providers with top-heavy management systems and less therapist capacity, less relational care, fewer neurodiversity-affirming options, reduced continuity, and less capacity for flexible family-centred service delivery. The proposed 90-day claim period also creates significant operational risk. This expectation, alongside the increased expectation of managing smaller plan funding durations which are often being over-spent by participants (also leaving providers significantly out of pocket since its’ inception, or chasing payments from families who aren’t aware of the plan limitations or who have trouble managing the budget periods). Currently there is no way for providers to tell prior to a session with a client whether there are funds in the correct category, or remaining at all in the plan, as there is no oversight into the budget for a plan – the families, even those who are plan managed, need to be tracking this through the portal. As a small provider, we are able to advise that this is not working for providers or families, and the risks of incurring debt for a family is significant. Allied health work often spans sessions, non-face-to-face activity, reporting, parent feedback, school liaison and plan manager processes. We support timely claiming, but rigid timeframes must allow for legitimate complexity, delayed participant approval, plan-manager issues, administrative error, worker illness and exceptional circumstances. Recommendation: Provider regulation should be proportionate, risk-based and staged. Small allied health providers should receive clear guidance, templates, transition time and administratively realistic requirements. Compliance should improve safety without reducing participant access to ethical providers. Recommendation: That a 90 day claim timeframe is reconsidered in favour of 12 month timeframe for claims. Recommendation: That the 3-monthly budget periods be reconsidered in favour of the 12 month plan periods that were in place prior, as this lessens risks to both participants and nominees, as well as NDIS providers, of unintentional overspent, and personal or business debt creation.

12. Independent allied health evidence must remain meaningful Private occupational therapy reports are sometimes framed as a driver of plan inflation. That framing is incomplete and an unfair characterization of the professional’s highly specialised clinical knowledge, insight and assessment. High-quality allied health evidence also prevents waste. It clarifies actual functional need, identifies lower-cost alternatives, documents why a support is or is not appropriate, prevents inappropriate equipment requests, supports mainstream settings to make adjustments, and helps families understand what will actually improve participation. In our practice, we have regularly declined to recommend supports that are not clinically justified. We support the creation of the ‘in’ and ‘out’ lists (albeit do request to have more clarity/input into the decision for certain inclusions or exclusions), as it helps to clarify the reasonable expectations of parental or individual’s disability-related needs. We have explained and documented when an item is unlikely to meet reasonable and necessary criteria and why. We have recommended lower cost alternatives where appropriate. We have explained to family that certain items may be philanthropically or self-funded as they may have benefit, but are excluded items from the Reasonable and necessary guidelines. We have supported families to use existing resources better, rather than simply asking for more. More often than not, this documentation is completed outside of session times, and is unfunded despite research and clinical reasoning time. This is exactly the kind of professional reasoning the Scheme should value. If private reports are discounted, families with complex children may lose one of the few mechanisms available to explain their child’s day-to-day functioning in detail. Agency-held data and standardised assessments will not accurately capture the lived reality of a child across home, school, community and therapy contexts. Independent evidence is not a threat to sustainability when it is high quality; it is part of sustainability. Recommendation: The Bill and future rules should protect the meaningful role of independent allied health evidence in access, planning, reassessment, review and support determination decisions. The NDIS must not rely only on internal, non-allied health professional staff assessment, as the basis for these decisions, especially if there is to be an element of algorithmic or AI-determined access or funding decisions.

13. Foundational supports must exist before NDIS supports are narrowed Much of the reform discussion assumes that supports outside the NDIS will be available. For many families, this is not currently true. Mainstream health, education, community, mental health and family-support systems are already difficult to access, particularly for children with developmental delay, autism, complex behaviour, mental health needs, physical disability or multiple intersecting needs.

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If NDIS access or capacity-building support is tightened before foundational supports are properly funded and available, families will fall into a gap. Additionally, it must be understood that parenting workshops, playgroups or generic programs are not a substitute for skilled disability-informed assessment and intervention where a child has significant functional needs. Foundational supports must not become a rhetorical justification for reducing NDIS support before comprehensive and functioning alternatives actually exists. Recommendation: No narrowing of NDIS eligibility, capacity-building supports or planning evidence should occur until foundational supports are co-designed, funded, operational, accessible, disability-informed and demonstrably able to meet the needs being shifted from the NDIS.

14. The likely downstream impact on our practice and our clients If the Bill proceeds in its current form, we anticipate the following impacts in our practice:

• Families will reduce therapy frequency or stop therapy earlier, not because needs have reduced but because budgets have been reduced.

• Children will present later and in greater distress because families delay support until crisis, or they have only been provided with minimal and generic support through Foundational Supports, until after age 9.

• Parents will request shorter, cheaper assessments and reports that may not be sufficient to understand, plan intervention around or explain complex functional needs.

• Small providers will carry higher compliance costs while facing reduced participant funding and more price control.

• Waitlists will increase as providers reduce NDIS exposure or leave the market.

• Families with the least advocacy capacity will be least able to challenge decisions or obtain comprehensive and appropriate evidence.

• Schools, kindergartens, paediatricians and hospitals will face increased pressure when early disability supports are delayed or reduced.

• Carers, particularly mothers, will absorb increased unpaid labour and may reduce workforce participation.

• Participants with complex, fluctuating or less visible disability will be most likely to be misunderstood by standardised or automated processes. These are not speculative business inconveniences. They are predictable consequences of reducing the capacity of the very services that currently help families remain stable.

Conclusion

The NDIS needs integrity and sustainability. It also needs to remain recognisably the NDIS: an individualised disability support scheme that understands functional need, family context, participation, safety and long-term outcomes. The Bill in its current form risks shifting the Scheme away from individualised support and toward administratively convenient reductions. As a private paediatric occupational therapy practice, we are deeply concerned that these reforms will reduce our ability to support those most in need. Our clients will experience this as fewer services, weaker evidence pathways, delayed reassessments, increased family burden and greater risk of crisis. Our business will experience it as increased compliance pressure, reduced viable service delivery, more ethical tension and a less stable workforce. The broader community will experience it as cost-shifting to carers, schools, hospitals, mental health services, housing systems and income support. The Committee must look beyond the immediate NDIS budget line. Where support is reasonable, necessary and preventative, cutting or delaying it does not remove the need. It only changes who carries it, when crisis occurs, and which part of government ultimately pays. Disabled people, carers, clinicians and small businesses should not be made the shock absorbers for reform that has not been properly consulted, tested or safeguarded. We therefore urge Parliament not to pass the Bill in its current form. The Bill should be paused, redrafted and subject to proper consultation with disabled people, families, carers, nominees, providers, clinicians, advocates and representative bodies. The goal should be a sustainable NDIS that prevents harm, supports participation, preserves choice and control, and keeps ethical providers available to the families who need them.

References and source material used in preparing this submission

• National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 - Parliament of Australia Bill homepage, including Bill text and Explanatory Memorandum.

• Department of Health, Disability and Ageing, NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 fact sheet, published 14 May 2026.

• Department of Health, Disability and Ageing, information page: About the changes to the NDIS, published 14 May 2026. Outcomes Therapy Submission - NDIS Bill 2026 | Page 8

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• Personal submission prepared by Outcomes Therapy Director Kate Hoad regarding the Bill, including lived experience as a disabled person, carer, plan nominee and parent of three disabled children.

• Outcomes Therapy business-risk summary prepared from the Bill and associated explanatory material, including provider registration, claims, record keeping, support determinations, pricing, plan management and support coordination implications.

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