Concerns regarding NDIS support for children and adults with complex needs

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To Whom It May Concern,

I am writing to raise serious concerns regarding the proposed NDIS Future Generations Bill and its potential impact on the clients I currently support. As an allied health professional working closely with NDIS participants, I have both professional and ethical obligations to advocate for the people whose lives depend on this scheme.

Children with Autism and Other Disabilities

Children with autism and other disabilities require consistent, adequate, and appropriately tailored support to develop and thrive. Occupational therapy plays a vital role in supporting children across physical, cognitive, and emotional domains — benefiting not only the child but the entire family unit. Insufficient access to therapy sessions or support workers places an unacceptable burden on families and risks long-term harm to the child’s development and wellbeing.

I am particularly concerned that the Bill may raise eligibility thresholds in practice, limiting access for children aged 0–8 before adequate alternatives such as Thriving Kids or Foundational Supports are in place. Early intervention is not optional — it is essential for outcomes, and delays or gaps in support at this stage carry lifelong consequences.

The Domino Effect on Families and Communities

It is critical that decision-makers understand that a child with a disability, complex health needs, or challenging behaviours does not exist in isolation. The impact of inadequate support extends far beyond the child themselves. Parents and caregivers carry an immense physical, emotional, and financial burden when their child does not receive sufficient support. This burden contributes to carer burnout, mental health deterioration, relationship breakdown, and reduced capacity to participate in the workforce.

Siblings are also profoundly affected — growing up in a household under significant stress, often with reduced parental attention and emotional resources available to them. The ripple effect extends into schools, where teachers and classroom peers are impacted by behaviours and needs that could have been better managed through adequate therapeutic and community support.

When a child is not supported appropriately, the consequences do not stop at the front door. They flow through every environment that child occupies — the home, the classroom, the community. This is a sequential, compounding consequence: one gap in support creates another, and another, until the entire ecosystem around that child is

Adults with Disabilities

Adults living with disability often present as capable of performing some activities of daily living independently, yet still require substantial support with essential tasks including eating, dressing, bathing, and other personal care. The complexity of their needs is frequently underestimated. Many participants also rely on home modifications to live safely; however, modifications alone are insufficient without ongoing support services. Failure to provide adequate, person-centred support for adults with complex needs can lead to serious health decline and, in the most critical cases, risk to life.

Impact on the Hospital System

Delays in NDIS support do not occur in isolation — they have direct and serious consequences for the broader health system. When participants do not receive timely, adequate support in the community, their conditions deteriorate. This leads to increased rates of hospitalisation that are otherwise preventable. As hospitalisations rise, the demand placed on an already strained health system intensifies, reducing the quality of care available to all patients. For people with disability, hospitalisation itself carries elevated risks — including increased exposure to infection, functional decline, medication complications, and reduced capacity to recover safely without appropriate post-discharge support. In the most serious cases, these cascading consequences can result in death. Adequate, timely NDIS funding is therefore not only a disability services issue — it is a critical public health issue.

Functional Capacity and Assessment Design

High-quality, individualised assessments conducted by appropriately qualified professionals are fundamental to the integrity of the NDIS. I am concerned that the Bill may allow funding decisions to be shaped by rules and frameworks rather than professional judgement. Assessments must reflect real-world needs — not standardised tools that fail to capture the complexity of a person’s daily life. The risks associated with automated or algorithm-driven decisions, as recently highlighted in the aged care sector, must not be replicated in the NDIS.

Use of Automation and Algorithms

The Bill permits greater use of automated tools and systems in decision-making. I strongly oppose fully automated eligibility or funding decisions for NDIS participants. Human oversight by qualified professionals is essential when assessing complex, fluctuating, or nuanced support needs. No algorithm can replace the clinical reasoning of an occupational therapist or other allied health professional who understands a participant’s full context.

Ministerial Powers and System-Wide Funding Reductions

The expanded ministerial powers proposed in the Bill — including the ability to limit or reduce whole categories of supports — risk removing the individual, needs-based approach that underpins the NDIS. Funding decisions must remain grounded in individual assessment and clinical evidence, not broad policy instruments. I urge that any such powers be substantially constrained, with full transparency and accountability built into any decision-making process.

Restrictions on Reassessment and Review

Limiting unscheduled plan reassessments to “exceptional circumstances” is of significant concern. Participant needs change — sometimes rapidly — due to health deterioration, life events, or changing environments. Barriers to timely reassessment create real risks to safety and dignity. Flexible, accessible pathways for review must be retained.

Capacity Building and Participation Supports

Proposed cuts to capacity building and participation supports would have far-reaching consequences for independence, community inclusion, and family wellbeing. These supports uphold the human rights of participants and contribute to long-term outcomes. Removing or reducing them is counterproductive to the stated aims of the scheme.

Pricing and Allied Health Workforce Sustainability

Sustainable pricing is essential to maintaining a qualified, clinically governed allied health workforce. Without appropriate pricing structures, access to occupational therapists and other allied health professionals will diminish, particularly in regional and underserved areas. I also note that existing AHPRA regulation of occupational

Summary of Asks

I respectfully urge the Parliament to:

  1. Ensure that functional capacity and support needs assessments are conducted by appropriately qualified allied health professionals, including occupational therapists.

  2. Prohibit fully automated eligibility or funding decisions and require human oversight of any assessment tools or algorithms.

  3. Remove or substantially constrain ministerial powers to impose broad, class-wide funding reductions, ensuring all decisions remain based on individual need and transparent, clinically informed processes.

  4. Ensure the Bill does not narrow access to the Scheme, particularly for children and people with complex or fluctuating needs.

  5. Retain practical and timely pathways for reassessment and review.

  6. Reverse proposed reductions to capacity building and participation supports.

  7. Ensure pricing and integrity reforms support a sustainable, clinically governed allied health workforce.

  8. Recognise existing AHPRA regulation of occupational therapists to avoid duplicative compliance requirements.

I would welcome the opportunity to contribute further to any consultation process and am available to discuss these concerns at your convenience.