SUBMISSION TO THE
Community Affairs
Legislation Committee
INQUIRY INTO THE
NDIS amendment (Securing the NDIS for Future Generations)
Bill 2026
Suzi Goodger
Access OT Services
1 June 2026
website: www.accessotservices.com ABN: 97 368 442 347 email: info@accessotservices.com
NDIS Provider Number: 4050008133
The development of the NDIS has been one of the most important social reforms, and has resulted in lives being changed, persons with disability being able to live with dignity, independence and greater inclusion both with their activities of daily living at home and importantly in the community.
Yet the changes proposed in the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026, risks transforming the Scheme away from participant centered principles towards a system that prioritized administrative controls and fiscal constraint over individual choice and person centered outcomes.
I am making this submission to the Community Affairs Legislation Committee as a registered NDIS provider of occupational therapy services delivered under Capacity Building Supports.
In formulating this submission, consideration has been given to the Bill, the accompanying Explanatory Memorandum, and issues and concerns raised in submissions by the Occupational Therapy Society Independent (OTSi) and The Growing Space.
The concerns raised in this submission reflect the experiences of both the Occupational Therapists working within our organisation and the participants we support on a daily basis. Participants have expressed profound concern regarding the proposed reforms, with many fearing that the changes will reduce access to the supports and services they rely upon to maintain their independence, participate in their communities, and achieve their goals.
Access OT Services (AOTS) was founded by Suzi Goodger, Occupational Therapist with 25 years of clinical experience in complex disability, functional capacity evaluation, assistive technology, and medicolegal assessment across the compensable/insurance and NDIS sectors. Suzi has extensive experience undertaking comprehensive assessments and preparing reports for individuals with neurological conditions, intellectual disability, autism, mental health conditions, dementia, and progressive neurological disorders.
The team at Access OT Services undertakes assessments of functional capacity and support needs, together with the prescription of assistive technology, including complex seating and mobility equipment, pressure care solutions, manual handling equipment, and environmental modifications. Our practice is focused on promoting independence, safety, and meaningful participation in daily life. Through early intervention, risk mitigation, and capacity-building approaches, we seek to reduce disability-related barriers, prevent avoidable deterioration in function, and support participants to engage in their homes, communities, and broader society.
We maintain current professional registration and ongoing professional development, in accordance with AHPRA registration requirements to ensure our practice remains aligned with contemporary evidence, legislative requirements, and best practice standards.
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website: www.accessotservices.com ABN: 97 368 442 347 email: info@accessotservices.com
NDIS Provider Number: 4050008133
Introduction
The National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
presents as the most significant restructure of the scheme since its inception. And whilst this has been pitched to the community as a reform to ensure financial sustainability, the overarching amendments threaten the core fundamentals that made the NDIS so unique, forward visionary and participant focused to a potentially one sized fits all, standardized and fiscally managed administrative system.
There is no doubt by those that live with the supports provided by NDIS and those that work within the system to support participants live ordinary lives, that reform is required, yet the proposed changes threaten to take away individualized support and participant choice and control. And risks failing the most vulnerable in our community.
We know that the scheme must be financially sustainable. Yet the blanket removal of participants from the scheme who genuinely need the support, threatens their Human Rights, quality of life, sustainability of families and other informal supports. Financial sustainability must be achieved through efficiency and not exclusion.
These reforms do not eliminate the need for support; it risks transferring costs to other sectors. Examples provided by the AOTS team, cite potential participants developing pressure wounds and without access to community based clinicians to manage the initial clinical care and possibly halt further progression, the lack of management of these injuries can lead to more significant risks, complications and ultimately hospitalization and we know that unmanaged wounds can lead to sepsis and increased mortality rates.
This submission address concerns expressed by both participants and AOTS, as a registered provider. I urge the Committee to consider what these reforms would mean for the disability community, as well as for someone you know - a family member, friend or even yourself- should you ever require the services and supports provided by the NDIS.
Please consider whether you want a Bill that promotes the delivery of more sustainable, equitable and effective services that continues to enable people with disabilities to live full and meaningful lives. Without action in response to the concerns outlined in this submission, there is a risk that the NDIS will be undermined by significant service gaps, increasing bureaucracy and AI driven administrative processes that fail to adequately recognize a person’s unique situation, environment and capacity.
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website: www.accessotservices.com ABN: 97 368 442 347 email: info@accessotservices.com
NDIS Provider Number: 4050008133
Functional Capacity Assessment
The Bill proposes a new definition of functional capacity, which assess what a person can do:
- Without assistance from other people
- Without assistive technology or modifications; and
- Excluding, as far as possible, environmental and personal circumstances
Concerns
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Changes in the definition risks disadvantaging people with fluctuating disabilities, for example Multiple Sclerosis, as this snapshot has the potential to underassess their true capacity. These snapshot assessments do not capture genuine support needs when they can fluctuation due to exhaustion, pain, autonomic dysfunction, cognitive function or post exertional deterioration.
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Completion of short administrative assessments can fail to understand the effect of masking, for example for people with Autism, they may appear more capable in a short, structured interview, but the behind the scenes supports such as routine scaffolding, prompting, or shutdowns and severe executive dysfunction cannot be captured.
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These assessments being conducted by persons without clinical qualifications. As Occupational Therapists, using our clinical reasoning, we determine the most appropriate assessment tool to based upon the person’s disability and the clinical evidence base to ensure validity of results. One tool cannot adequately capture the diversity of presentations across the scheme.
Recommendations
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Functional assessments to be conducted in real world conditions, i.e. the places that participants require the implementation of supports.
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Functional assessments to be conducted by trained allied health professionals, Occupational Therapists assess the person, their occupation and their environment. This allows for observations, skilled clinical interviews to break through and understand hidden disabilities, and the impact of supports, both physical, person and environmental.
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Human professional judgement to be retained, and whilst AI and algorithmic tools can be used to support decision making, it must not be used to replace the human element with considering determination, eligibility and planning decisions.
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website: www.accessotservices.com ABN: 97 368 442 347 email: info@accessotservices.com
NDIS Provider Number: 4050008133
Social and Community Participation Funding
The proposed Bill grants the Minister broad powers to reduce funding for specified groups through support determinations. The initial resetting of Social and Community Participation funding by 50% and Capacity Building Daily Activity funding by 10%.
Concerns
The risks associated with these funding resets:
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Fails to acknowledge that participants also require support at home as well as in the community
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It also assumes that participants only access the community for social and lifestyle activities and not for essential life activities such as grocery shopping, attending medical appointments etc.
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Risks of costs being redirected to other systems, reduced supports may contribute to hospital admissions, family breakdown, poorer health outcomes, carer burnout and premature entry into out of home care.
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The $200 million Inclusive Community Program, proposed as a partial replacement to individualized social and community participation, begins to re-enter historical practices of segregation and discrimination and a complete departure away individualized supports that underpin the NDIS.
Recommendations
- This section of the Bill (34A) to be deleted in full
- If the Parliament choose to retain this section, then the recommendation is made that it not proceeds without robust public consultation and opportunities for independent review. Co-Design of the Inclusive Community Program with people with disabilities and be genuine in community inclusion to prevent discrimination.
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website: www.accessotservices.com ABN: 97 368 442 347 email: info@accessotservices.com
NDIS Provider Number: 4050008133
Fraud Measures – Provider Registration
AOTS strongly supports action on fraud; we have previously reported providers that have provided supports alongside our participants to the Commission for investigation into fraudulent billing practices. Maintenance of the integrity within NDIS ensuring appropriation of public funding is critical to the ongoing viability of the scheme.
Concerns
However, as providers whose clinical practice focuses on a participant’s functional capacity, we know for some, their disability can impact their capacity to comply with the Agency’s expectations. This is particularly pertinent for participants with psychosocial disability’s, autism, fatigue related conditions, executive functioning impairments, cognitive and intellectual disabilities as well as those disabilities that can fluctuate. In summation, the concern is, does the administrative burden fall on the right people.
Whilst provider registration being rolled out for providers in high-risk settings, such as SDA/SIL homes is welcomed, Allied Health providers are already regulated through the Australian Health Practitioners Regulation Agency (AHPRA). We must meet professional standards, maintain a commitment to continual professional development and operate ethically. Additional registration with the Commission may not improve quality or safety, and it at risk of smaller, practices becoming financially unviable.
Recommendations
- Mandatory registration to be risk-tiered – i.e. where services are provided in high risk or closed settings, such as SIL/SDA. Where providers are already regulated under alternate agency, such as AHPRA for Allied Health providers, this to be recognized and accepted by the Agency.
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website: www.accessotservices.com ABN: 97 368 442 347 email: info@accessotservices.com
NDIS Provider Number: 4050008133
Governance arrangements – Pricing and Allied Health Sustainability The Bill significantly expands Ministerial control over pricing arrangements while reducing the role of independent oversight.
Allied Health provider rates have been frozen for seven years - effectively a decrease in real terms this - is contributing greatly to the wider shortage in workforce.
Concerns
Differentiate pricing for unregistered providers delivering capacity building daily activities creates an environment whereby participants choose providers based on pricing, therapeutic fit, cultural suitability or clinical expertise.
This will create further pressure on service viability and may drive many providers out of the scheme, creating further shortages both in clinical expertise and service delivery, which may impact those participants in regional and rural communities the greatest.
Participants have already been exposed to narrative questioning the cost of occupational therapy services. Differentiated pricing risks exacerbating this perception by making it more difficult for participants to understand why some providers charge higher fees, despite differences in qualifications, compliance obligations, service quality, and clinical expertise.
Recommendations
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Differentiate pricing for Capacity Building Daily Activities not to be implemented. Pricing to remain consistent across providers delivering equivalent supports, to ensure participants can make Choice and Control decisions based upon quality, clinical expertise and therapeutic fit, rather than on pricing differentials.
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The Annual Pricing Review to take into account the sustainability of allied health provider rates. The Committee to seek information from the Minister on the current gap between NDIS Allied Health rates and market rates and how this gap is going to be addressed.
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Recognition of the costs associated with quality and compliance. Allied Health practitioners registered with AHPRA incur costs associated with governance, continuing professional development, quality assurance, supervision and regulatory compliance
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website: www.accessotservices.com ABN: 97 368 442 347 email: info@accessotservices.com
NDIS Provider Number: 4050008133
Conclusion
The NDIS has been truly transformative for many Australians living with disability, as well as for their families and carers. It has enabled the provision of individualised supports that promote independence, community, inclusion to enhance quality of life, and uphold the principles of choice and control.
This submission has highlighted several concerns regarding the proposed Bill. While efforts to improve the sustainability, consistency, and integrity of the Scheme are important, we must not lose sight of the participants at its centre. A person-centred, flexible Scheme that can respond to the diverse and complex needs of participants is crucial.
The Occupational Therapists at Access OT Services work alongside people with significant and pervasive disabilities and are concerned that aspects of the proposed reforms may inadvertently disadvantage some of the most vulnerable members of our community. In particular, there is concern that the barriers to independence experienced by people with invisible, fluctuating, psychosocial, and neurodevelopmental disabilities cannot always be accurately quantified through standardised assessment measures administered remotely.
As Occupational Therapists, we understand that functional capacity is influenced by the interaction between a person’s impairments, their environment, available supports, and the fluctuating nature of many conditions. Assessments that do not adequately consider these factors risk failing to capture the realities of a person’s everyday functioning and support needs.
We respectfully urge the Committee to consider the recommendations made within this submission and ensure that any future planning and assessment framework retains the individualised, evidence-based foundations of the NDIS, values professional clinical judgement alongside standardised assessment tools, and remains responsive to the unique circumstances of each participant. These principles are essential to ensuring that the NDIS continues to support people with disability to live safely, participate meaningfully in their communities, and achieve their goals.
Suzi Goodger
Director
Access OT Services
Blackburn, Victoria
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