Protecting Early Intervention and Community-Based Supports for Children and Families: Submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

I am the Director and Principal Speech Pathologist of I , a small paediatric speech pathology practice based in the Hills District of Sydney. I provide services to children with developmental delay, autism, neurodivergent communication profiles, speech and language disorders, and acquired communication impairments across clinic, home, school, childcare and telehealth settings.

I support the objective of maintaining a sustainable National Disability Insurance Scheme and protecting participants from fraud and exploitation. However, I am concerned that some proposed reforms may have unintended consequences for children, families and frontline service providers if implementation is not carefully considered.

Many of the children and families I work with already experience lengthy waitlists, workforce shortages, funding uncertainty and challenges navigating multiple service systems. For these families, timely access to support during the early years is critical. Delays in assessment, therapy and intervention can have lasting impacts on communication, learning, social participation, mental health and educational outcomes.

The proposed introduction of new functional capacity thresholds and assessments may improve consistency in decision-making, but there is concern that children with developmental delay, autism and other neurodevelopmental differences may face increased barriers to accessing support if assessment processes do not adequately recognise the complexity of child development and the importance of early intervention. Developmental needs often emerge gradually and can fluctuate across settings and stages of development. Many children benefit from support before difficulties become severe. Restricting access until functional impacts are more significant may reduce opportunities for early intervention and increase long-term costs for families, education systems and government.

I am also concerned about proposed restrictions on participant-requested plan reassessments. Children’s needs can change rapidly due to developmental transitions, school entry, changes in family circumstances, health events or emerging support needs. Families often require flexibility to respond to these changes. While safeguards against inappropriate reassessment requests are reasonable, overly restrictive processes may leave families unable to obtain timely adjustments to supports when circumstances genuinely change.

The Bill also proposes stronger links between funded supports and eligible impairments. While accountability is important, there is a risk that this approach may unintentionally reduce access to supports that address functional participation, communication, social engagement and skill development. In paediatric practice, interventions are often preventative and developmental in nature. The benefits may not always fit neatly within a narrow interpretation of impairment-related need, despite being critical to a child’s long-term outcomes.

For families in regional and rural communities, these reforms may present additional challenges. Many areas already face limited access to allied health professionals. Telehealth has improved accessibility, but workforce shortages remain significant. If eligibility becomes more restrictive, reassessment pathways become more difficult, or provider compliance obligations increase substantially, there is a risk that some smaller providers may reduce services or leave the sector altogether. This would further reduce access for families who already have limited options.

Small private practices currently form a significant part of the paediatric allied health workforce across Australia. These services often provide flexible support across homes, schools, childcare centres and community settings while maintaining strong relationships with families and local professionals. Additional regulatory requirements and administrative burdens may be manageable for larger organisations but can place considerable pressure on small providers. Any reduction in workforce participation would likely increase waitlists and reduce service availability.

The Bill notes that future access reforms are intended to align with the commencement of Thriving Kids and broader foundational supports reforms. While improved community-based supports have the potential to benefit many families, successful implementation will depend on retaining and utilising the existing allied health workforce. Private providers, community organisations and multidisciplinary teams already supporting children should be recognised as part of the solution. Excluding or marginalising existing service capacity risks creating further service gaps during a period of significant system transition.

Recommendations

1. Ensure functional capacity assessment frameworks for children are developmentally informed and recognise the value of early intervention before needs become severe.

2. Maintain accessible pathways for genuine participant-requested plan reassessments where children’s circumstances or support needs change.

3. Ensure interpretations of impairment-related supports continue to allow funding for functional, developmental and participation-focused interventions.

4. Undertake detailed impact assessments on rural, regional and workforce- constrained communities before implementing access changes.

5. Minimise unnecessary administrative and compliance burdens on small, allied health providers while maintaining appropriate safeguards.

6. Recognise and incorporate existing community-based allied health providers within future foundational supports and Thriving Kids implementation planning.

Conclusion

The long-term sustainability of the NDIS is important and reform is necessary. However, sustainability should not be achieved at the expense of timely support, early intervention and practical access to services for children and families. The success of these reforms will depend not only on controlling costs, but on preserving the workforce, relationships and local service capacity that children rely upon every day.

A balanced approach that combines financial sustainability with developmental, family-centred and community-based support will provide the best opportunity to improve outcomes for children now and into the future.

Speech Pathologist B App Sc (Speech Pathology) MSPA CPSP