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

Submission 3642

Occupational Therapist (Adult Caseload, Qld)

The proposed reforms risk restricting access to appropriate supports for adults with psychosocial, physical and neurodevelopmental disabilities, particularly where impairments are not immediately visible. While improving scheme integrity is necessary, the proposed approaches do not reflect how functional impairment presents in real-world contexts and may result in inaccurate decisions and preventable functional decline requiring higher-cost intervention over time.

Key Issues

Inadequate Functional Assessment at Intake

Access decisions will rely heavily on: - Self-report - Standardised tools - Assessments by non-allied health staff without discipline-specific training

Resulting with reduced corroboration of functioning within the home or community.

Clinical reality: Functional capacity cannot be accurately determined without: - Contextual observation - Clinical reasoning - Allied health input

This creates risk of underestimating need and inappropriate access decisions.

Evidentiary Expectations Do Not Reflect Clinical Practice

Reforms are pushing for increased objective evidence, however:

- This evidence often does not exist, particularly for psychosocial disability, executive

dysfunction, and fluctuating conditions - Functional impact is individualised and context dependent

In these cases, lived experience and clinician assessment are the most valid forms of evidence. Proposed redirection risks undervaluing clinical expertise and excluding those whose disability is less easily measured.

Misalignment Between Fraud Measures and Assessment Quality

- Fraud reduction strategies are introducing higher evidentiary thresholds, without
   ensuring assessment quality is clinically robust.
- As a result, participants with legitimate needs are required to repeatedly justify and
  defend their disability, rather than being assessed appropriately from the outset.

Risk to Adults with Non-Visible Disability

Adults with psychosocial disability, ASD, ADHD and chronic conditions often present with: Fluctuating, context-dependent function - Compensatory strategies that mask impairment

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

Submission 3642

• Limited insight into their own difficulties

These presentations can be missed when assessments are conducted by untrained personnel or rely on self-report alone. Without appropriate recognition, individuals are at risk of functional decline, reduced independence, and increased reliance on higher-cost supports.

Narrowing of “Reasonable and Necessary” Proposed changes risk excluding: - Maintenance supports - Low-intensity, ongoing intervention - Environmental and strategy-based approaches

Occupational therapy evidence is clear: maintaining function and preventing decline are clinically necessary and cost-effective.

Recommendations - Embed allied health-led functional assessment, including real-world context and lived experience - Recognise clinical judgement and lived experience as valid evidence - Align fraud measures with clinical reality and limitations of available evidence - Retain a broad interpretation of “reasonable and necessary,” including maintenance - Ensure equitable access for non-visible and complex disability presentations

Conclusion Occupational therapists provide essential expertise in functional capacity and participation. Reform must ensure decisions are:

• Clinically informed
• Contextually grounded
• Inclusive of those with non-visible disability
• Consistent application

Without this, changes risk increasing long-term costs while reducing access to appropriate, effective supports.