NDIA Accountability Project

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Submission 3445 — Second Skin — NDIS Future Generations Bill

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission 3445

SECOND SKIN PTY LTD

40 O’Malley Street

OSBORNE PARK WA 6017

P: +61 8 9201 9455 E: perth@secondskin.com.au

June 1, 2026

Dear Sir/Madam

Second Skin response to NDIS Future Generations Bill

Second Skin Pty Ltd is an Australian owned and based company specialising in the design, manufacture, and delivery of custom-made dynamic splints/orthoses and custom made and off the shelf medical compression garments for over 35 years. Second Skin has been a registered provider with the NDIS since 2014.

We employ a therapy team of experienced Occupational Therapists and Physiotherapists to provide our service to NDIS participants . We are fortunate to offer our service across all states and in many regional areas face to face and via telehealth , so we share our perspective from our broad experience across the NDIS service at a national level.

We are particularly concerned about the following aspects of this Bill

  1. The Bill limits unscheduled plan reassessments to “exceptional circumstances”. Our clients with severe neurological conditions are expected to change with age, growth, social and living circumstance and general change in health status over time. They require the ability to request a change in their plan if their circumstance changes in a way that will affect their health status,

    participation and quality of life. Change does not happen in terms of plan dates at key pre-

determined intervals ; deterioration often happens suddenly, so plan review and reassessment needs to reflect the reality of these changes, rather than a prescribed time frame. Many of our clients have memory and cognitive impairment and leave key items off the list in their discussions with planners. Families under stress and most who are sleep deprived in this area also regularly do the same .

We have seen examples of

 parents caught unaware while driving who forget to mention key equipment during a ‘review’ call and then find it is not included when the plan arrives  parents who have separated where only one parent is at the plan review meeting and forgets to mention key items which are then left off a plan,  wheelchair base which was approved without the seat so the plan needed urgent review which was delayed for several months, which increased time in bed and non attendance at school

The definition of ‘exceptional circumstances’ for plan review therefore needs to be considered more broadly to enable these circumstances to be resolved quickly, without additonal participant and caregiver stress and risk.

  1. Use of automation, algorithms and standardised tools Equipment and care needs vary across the life span for those with severe disability and complex needs cannot not be made based on a ‘simple’ formula or generic assessment across this broad client and diagnostic group. It is well known that standardised assessments are not well established or valid or reliable, for those with severe neurological disability, which is often why research in this field is often based on single case study designs.

This client group are best served by experienced trained clinicians in this field of allied health assessing for and recommending suitable supports with assessment tools used which relate

specifically  to each  individual  or diagnostic group  . Prescribers  of equipment and therapy

interventions can be credentialled to ensure costs are controlled. The health risks are high in this group and will be increased without the oversight and expertise that clinicians are able to provide.

A.B.N. 15 009 350 467                    PERTH - SYDNEY - BRISBANE - MELBOURNE - LONDON                www.secondskin.com.au

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission 3445

SECOND SKIN PTY LTD - 2 -

Without human oversight and governance and an understanding of complex clinical reasoning with awareness of quality high levels of comprehension of complex research evidence, mistakes can be made by AI assisted programs, that have real-life consequences for our clients and our families.

We have seen examples of:

  • Clients told that particular interventions have limited research evidence to support their use when this is not the case (eg botulinum toxin treament ).

  • Clients told that therapy input once a week by one provider (hydrotherapy) is enough to prevent progressive postural deterioration that may have serious life altering or life limiting consequences when there is no evidence this is the case.

  1. The Bill expands the Minister’s power to limit or reduce whole categories of supports. We are deeply concerned about the possibility that whole categories of supports could be reduced, without due consideration to individual need. Huge variation in this field of neurological disability can be seen across the country in terms of clinical need and equipment requests.

We have seen examples of

 all Assistive Technology being left off a participants plan therefore denying access to equipment, orthotics, communication devices, wheelchairs  water friendly chairs for disability enabling fishing for indigenous disabled participants  clients who travel long distances from western Qld and regional Tasmania for intensive therapy weeks because they cannot access any services locally  clients who access outdoor motorised equipment to access their family’s rural property with their family members and are unable to do so otherwise  clients who wear our postural splints and use a ‘sit to stand’ wheelchair to participate in church activities or stand up at the pub or shops

Reducing whole categories of supports needs to consider each participant’s circumstance and their lifestyle and goals and cannot be simply reduced by limiting categories.

Structure and governance and power of administrative staff:

There  is a concern that without  full review processes in place by clinicians and health care

professionals, administrators may be given powers that were never intended to be placed in their remit when the original NDIS scheme was drafted by previous administrations.

It is not the job of the administrators at NDIS to make quality of life and clinical decisions that are based on complex knowledge of disability and neurological conditions they have no knowledge of. We are concerned that these funding changes and legislative controls will result in exactly this situation.

Thank you for your attention to this submission.

Yours sincerely

Cathy Harries

Clinical Services Director

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