Concerns about standardised assessments for children with complex developmental needs

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

Submission 3766

Dear Committee Members,

I am writing as a paediatric occupational therapist working with children and families who access the NDIS.

I am concerned that aspects of the proposed reforms may unintentionally disadvantage many of the children they are intended to support.

In particular, I am concerned about the apparent move towards greater reliance on standardised assessments and alithrogram driven decision-making processes when determining support needs. While standardised tools have an important place, many of the children I work with have developmental presentations that are not easily captured through formal assessment alone.

Their challenges often emerge across time, settings and relationships. A child may appear capable in one environment but struggle significantly in another and the how this presents can also vary markedly. Difficulties with social participation, emotional regulation, executive functioning, sensory processing, motor planning and adaptive functioning are often highly dependent on context and may not be fully reflected in standardised assessment results.

Understanding these children requires more than measuring performance on a particular day. It requires specialised knowledge of child development and disability, along with the ability to integrate information from families, educators and other professionals to understand how a child’s difficulties affect their everyday life.

My concern is that the proposed reforms appear to place greater weight on what can be measured and standardised, while reducing the importance of the expertise required to understand more complex developmental presentations.

I am also concerned by proposals that may restrict opportunities for reassessment and review. Children’s needs change quickly at times and review processes are an important safeguard that allow new information to emerge and ensure supports continue to reflect a child’s actual needs. If a child’s difficulties are not adequately captured during an assessment process, be that human error or alithrogram based error, it is unclear how those unmet needs will be identified and addressed if opportunities for review become more limited.

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

Submission 3766

Another concern is that the reforms may underestimate how much expertise currently sits outside government services. Much of the specialist knowledge, mentoring, workforce development, clinical supervision and innovation in paediatric services occurs within private practice settings. This expertise has developed over many years and plays a significant role in supporting children and families across Australia. I am concerned that the reforms do not appear to recognise the importance of maintaining and drawing upon this expertise when designing future assessment and decision- making processes.

I am also struggling to understand the rationale for reducing capacity-building and participation supports. These supports exist to help children develop skills, increase independence and participate more fully in their homes, schools and communities. The intention is to reduce future dependence, not increase it. If these supports are reduced, it is difficult to see how the long-term costs to families, schools, health systems and other services will be avoided. The challenges do not disappear; they are simply shifted elsewhere.

The question I would like the Committee to consider is:

What evidence supports the assumption that children with complex, developmental and often context-dependent disabilities can be adequately understood through increasingly standardised assessment and decision-making processes, particularly when opportunities for reassessment and review are also being reduced?

I believe decisions about support needs should continue to be informed by people with specialised expertise in child development and disability, and that the Scheme should retain the flexibility needed to respond to the complexity and variability that characterises many children’s lives.

Thank you for considering my submission.