Submission to the Inquiry into the NDIS Future Generations Bill 2026
My name is . I am an occupational therapist with 27 years’ experience working with people with disability, their families and carers, services, and service providers across rural, regional and metropolitan Queensland. My experience spans government and non-government roles, including both clinical and management positions.
Throughout my career, I have worked predominantly with children and families in their natural environments. I have seen first-hand the daily realities of disability, developmental delay, psychosocial complexity, family stress, rural and regional service gaps, and the impact of systems that either enable people to thrive or place them at further risk. I have significant knowledge and experience of the current needs of NDIS participants, their families and carers, and the allied health professionals who support them. I make this submission because I hold serious concerns about the NDIS Future Generations Bill 2026. Due to the short timeframe for submissions, my comments are necessarily focused. I also wish to express my support for the submissions and recommendations made by Occupational Therapy Australia and OTsi — the Occupational Therapy Society for Invisible Disability.
I support a sustainable, effective and accountable NDIS. Publicly funded services must be well-governed, evidence-informed and financially responsible. However, sustainability cannot be achieved by reducing access to essential supports, narrowing eligibility, disregarding professional assessment and evidence, or shifting costs onto families, carers, state systems and other areas of government. A sustainable Scheme must invest early, respond to functional need, and support people to participate safely and meaningfully in everyday life.
Core concerns The proposed changes to NDIS eligibility, planning, funding and governance risk restricting access to essential supports and services for people with disability. In my view, the Bill is likely to cause harm to participants and their families, particularly children, people with psychosocial disability, people with complex or fluctuating conditions, and people whose needs are not easily captured by narrow or standardised assessment processes. I am concerned that the Bill may result in short-term reductions in Scheme expenditure while increasing long-term costs across other systems, including health, education, early childhood education, child protection, housing, family support and justice. When people with disability do not receive timely and appropriate support, their needs do not disappear. They often escalate. Families experience crisis. Children may lose developmental opportunities. Carers burn out. Health presentations increase. Educational participation reduces. In some cases, risks emerge that could have been prevented with appropriate early intervention and capacity-building support.
The NDIS was established to support people with disability to build capacity, independence, social and economic participation, and quality of life. Any reform should
strengthen those goals. It should not reduce access to the very supports that make those goals achievable. I am particularly concerned that legislative change is being pursued before key problems in the current administration of the NDIS, including issues within the NDIA, have been adequately addressed. I note that the NDIS Review Report recommendations have not yet been implemented. Many existing issues relate not to participant need, but to governance, bureaucracy, inconsistent decision-making, delays, poor communication, inadequate understanding of functional capacity, and variable consideration of professional evidence (all within the NDIA). These issues require careful reform. They should not be used to justify measures that reduce access to supports for people with disability.
Social, civic and community participation Supports for social, civic and community participation are not optional extras. For many people with disability, they are essential supports that enable routine, connection, communication, safety, independence, emotional wellbeing and participation in ordinary life. Reducing these supports risks increasing isolation, reducing functional skill development, and placing greater pressure on families and carers. For children and young people, participation in natural environments is often where meaningful development occurs. For adults, community participation may be central to maintaining mental health, preventing deterioration, and reducing reliance on crisis services. A narrow view of these supports as discretionary fails to understand their functional purpose. Participation is not a luxury. It is part of health, development, dignity and citizenship.
Capacity-building supports and therapy Capacity-building supports, including occupational therapy and other allied health supports, are foundational to the NDIS. These supports assist people to develop skills, adapt environments, build independence, reduce risk, and participate more fully in family, education, community and daily life. They are essential.
Any reduction in capacity-building supports must be approached with extreme caution. Therapy is not simply a service cost. When appropriately delivered, it is an investment in function, independence, safety and long-term sustainability. Removing or reducing these supports may produce short-term savings but can lead to higher long-term costs through increased dependence, carer strain, hospitalisation, school exclusion, family crisis and loss of participation. As an occupational therapist, I have repeatedly seen timely, evidence-informed support prevent escalation. I have also seen the harm caused when children and families are left without appropriate intervention until crisis occurs.
Functional capacity and assessment design I am deeply concerned about any proposal that enables decisions about people’s functional capacity and supports to be shaped primarily by new rules, administrative frameworks, automated tools, tick-box processes or staff without appropriate
qualifications, skill and expertise, rather than by high-quality, objective, evidence informed assessment undertaken by suitably qualified professionals.
Functional capacity is complex. It is not simply a checklist of what a person can or cannot do in isolation. It must be understood in context, including the person’s physical, social, cultural, developmental, psychological, sensory, communication and environmental circumstances. Environment is not peripheral to functional capacity. It is central to it. Occupational therapists are specifically trained to assess the interaction between the person, the environment and the occupation or activity being performed. This requires university-level training, clinical reasoning, knowledge of disability and development, understanding of physical and mental health, trauma-informed practice, neuroaffirming practice, family-centred practice, risk assessment, and skilled communication with participants, families and support networks. Qualified health professionals are also accountable to professional standards, regulatory bodies and codes of conduct. These safeguards exist to protect the public. Decision-making processes that rely on unqualified staff, narrow assessment tools or automated systems risk unsafe, inconsistent and inaccurate outcomes.
The Bill should ensure that assessment of functional capacity is evidence-informed, contextually grounded and undertaken by appropriately qualified professionals. It should also ensure that professional reports are meaningfully considered in planning and review decisions.
Example from practice The risks of poor decision-making are not theoretical. In one recent matter, a multidisciplinary team of experienced medical and allied health professionals provided assessments for a family with three children who were NDIS participants. The children’s mother was also an NDIS participant. The assessments considered each child’s disability and developmental needs, functional capacity, environmental context, family circumstances, and the mother’s capacity as the primary carer. Despite the depth of multidisciplinary evidence, NDIS funding and supports were reduced. The decision-making process appeared to give insufficient weight to the professional evidence provided. In the course of the matter, comments were made about one child’s eating that, if followed, could have placed the child at serious risk. The issue was not merely administrative disagreement; it reflected a lack of appropriate clinical understanding of disability, functional capacity, risk and family context. The impact on the family was significant, including trauma for the mother and subsequent hospital admission. This example demonstrates the real-world consequences of decision-making that does not adequately consider professional evidence or the complexity of disability in context. It also raises a broader governance concern. When decisions with serious clinical and functional consequences are made by people who are not appropriately qualified or professionally regulated, participants and families are left exposed. There must be stronger safeguards within the NDIA itself, not weaker ones.
Risk of narrowing access to the Scheme I am concerned that although the Bill may move away from diagnosis-based access, it may raise eligibility thresholds in practice. This is particularly concerning for:
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children aged 0–8 years;
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people with psychosocial disability;
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people with fluctuating, episodic, degenerative or complex conditions;
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people with invisible disability;
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people in rural and regional areas with limited access to assessment and services;
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families experiencing multiple and interacting vulnerabilities; and
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people whose functional needs are not easily captured by standardised tools. If functional capacity is used as an eligibility threshold but is defined narrowly or without adequate consideration of environment, many people with genuine and significant support needs may be excluded from the Scheme or receive insufficient supports.
This is particularly concerning for young children. Early childhood is a critical period for development. Delays in support can have lifelong consequences. Moving children into an alternative pathway, such as Thriving Kids, before that pathway is fully designed, implemented, resourced and evaluated creates significant risk. Children with needs described as “mild” or “moderate” may still require skilled, evidence-informed allied health support. Many children’s needs are complex, emerging or not yet fully understood at the time of initial presentation.
Families should not be left to navigate an underdeveloped alternative system while their child’s developmental window narrows. Reform should ensure continuity of support, clear pathways, qualified assessment and intervention, and no gap in services.
Impact on families and carers Families and carers are already carrying significant responsibility. Many provide extensive unpaid support, coordinate services, advocate across multiple systems, manage risk, and respond to daily disability-related needs. When NDIS supports are reduced or removed, this work does not vanish. It is transferred to families, often without recognition or support. This can lead to carer burnout, reduced workforce participation, financial stress, mental health impacts, family breakdown and increased reliance on crisis services. For children, reduced family capacity can directly affect safety, development and participation. For adults, it can increase isolation, health risks and dependence. A fair and sustainable NDIS must recognise that supporting participants also supports families and carers. Ignoring this reality simply shifts costs from one part of the system to another.
Ethical and human rights considerations The NDIS is not merely a funding mechanism. It is a key national commitment to inclusion, participation, dignity and the rights of people with disability.
Reform must be consistent with Australia’s obligations to people with disability and must be guided by principles of fairness, transparency, evidence, safety, participation and non-discrimination. People with disability should not be treated primarily as a cost pressure. They are citizens with rights, goals, relationships, responsibilities and contributions.
Any changes to eligibility, planning or funding must be carefully tested against the likely impact on people’s lives, not just on Scheme expenditure.
Recommendations
I recommend that the Committee:
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Do not proceed with changes that narrow access to essential NDIS supports without clear evidence that participants will not be harmed.
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Ensure functional capacity is defined in a way that reflects established occupational therapy and allied health evidence, including the interaction between the person, their environment and their daily activities.
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Require functional capacity assessments to be undertaken or meaningfully informed by appropriately qualified health professionals, including occupational therapists.
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Ensure professional reports and multidisciplinary evidence are given appropriate weight in access, planning and review decisions.
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Reject automated, tick-box or overly standardised decision-making processes where they fail to capture the complexity of disability, development, psychosocial need, family context and environmental barriers.
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Protect access to capacity-building supports, including allied health therapy, recognising their role in improving independence, safety, participation and long term Scheme sustainability.
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Protect social, civic and community participation supports where they are reasonable and necessary to maintain function, wellbeing, routines, relationships and community inclusion.
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Ensure children aged 0–8 are not moved into alternative pathways unless those pathways are fully developed, adequately funded, evidence-informed, nationally consistent, and able to provide timely access to qualified allied health support.
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Implement stronger safeguards for decision-making, including accountability where decisions disregard professional evidence and result in foreseeable harm.
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Meaningfully consult with people with disability, families, carers, First Nations communities, rural and regional communities, and allied health professionals (included allied health peak bodies) before implementing reforms that affect eligibility, planning or funding.
Conclusion
I support reform that makes the NDIS fairer, more consistent, more evidence-informed and more sustainable. However, reform must not be achieved by reducing access to essential supports, disregarding professional evidence, or transferring costs and risks to participants, families, carers and already stretched state systems.
The NDIS should build capacity, prevent crisis, support participation and uphold the rights and dignity of people with disability. The proposed Bill, in its current direction, risks doing the opposite. I urge the Committee to ensure that any legislative change is careful, evidence informed, clinically sound, ethically defensible and centred on the lives of people with disability and the families and professionals who support them.