To whom it may concern,

I am writing to express concern regarding several proposed changes contained within the NDIS Future Generations Bill and the likely impact these changes will have on participants, families, and the sustainability of high-quality allied health services.

As a private practitioner working with NDIS participants, I support reforms that improve consistency, transparency and long-term sustainability of the Scheme. It has been a concern for many years regarding the functioning and application of the NDIS and as such although I agree we need reforms, I have significant concerns that several aspects of the Bill risk reducing participant access to essential supports and limiting the capacity of clinicians to provide safe, individualised and evidence-based care.

Consequently, I anticipate the proposed reforms will not provide any meaningful or long term benefits for our society or vulnerable individuals and will lead to more government spending in future years as a result of getting this wrong now.

I am particularly concerned about the proposed changes/reductions to:

• capacity building daily activity supports,

• social, civic and community participation supports

• Early intervention and Thriving Kids

These supports are not optional extras. Early intervention is the most imperative initiative to ensure a reduction in future needs. They are fundamental to helping participants develop independence, obtain quality of life, reduce future diagnosis, increase mental health impacts, maintain routines, build functional capacity and participate meaningfully in community life.

In practice, these supports often prevent greater long-term costs by reducing deterioration, supporting carers, maintaining community connection and increasing independence over time. Reducing these supports risks increasing isolation, family stress, hospitalisation, crisis presentations and reliance on more intensive services later. Ultimately, we are already in a silent mental health epidemic and the current reforms are clearly going to exacerbate this.

For many participants, capacity building supports are what allow therapy recommendations to translate into meaningful real-world outcomes.

Importance of Professional Judgement and Functional Assessment

I am concerned that the proposed changes may shift decision-making away from detailed functional assessment and toward standardised frameworks, automated systems or rule-based determinations. This is at odds with viewing each and every person as an individual who have individual dreams, capacity, challenges and goals.

Tick-a-Box Approaches to Delivering Health Services

Tick a box approaches to delivering health services to humans should never be a consideration.

Functional capacity cannot be accurately captured through tick-box assessments or standardised tools alone. Many participants present with fluctuating, multi-faceted, complex or layered needs that require clinical judgement and nuanced understanding. Something which a screening tool cannot determine. Clearly the short term cost cutting exercise will come at a significant cost to individuals and ultimately a greater cost to society and government.

Professional assessments conducted by appropriately qualified clinicians are essential because they consider:

• the interaction between challenges, disability and environment specific to the individual,
• psychosocial and family circumstances,
• functional variability over time,
• and the practical realities of daily living for that individual and their family/carers

When decisions do not adequately reflect real-world functioning, participants risk being under-supported, unsafe, or excluded from meaningful participation and opportunities for growth and development.

Risks Associated with Automation and Standardised Decision-Making

I am concerned about increased reliance on automation or algorithmic approaches within assessment and planning processes. AI cannot and should not replace the clinical nuances of human to human connection and decision making.

While consistency is important, disability support planning requires human judgement. A heavily standardised system risks overlooking complexity, cultural context, episodic conditions and invisible disability.

Participants should not lose essential supports because their disability is difficult to quantify within a standardised framework.

Impact on Children and Early Intervention

I am significantly and mostly concerned that the proposed eligibility and assessment changes may unintentionally narrow access to early supports for children and families before alternative systems such as Thriving Kids or Foundational Supports are fully established and operational.

Our society is already far too reliant on late stage reactive programs and services. For example our justice systems, out of home care systems - the amount of money spent on

these instead of proactive early life, early intervention is an inherent flaw in our social systems. Early intervention and spending is the only evidence based and sensible method for reducing long term damage, system cycles, generational trauma and a never ending increase in government spending on later stages containment.

Early intervention is most effective when support is timely, flexible and responsive. Delays or increased barriers to access will result in children requiring more intensive support later, form a wider range of systems. Essentially children and families are losing the ability to hope for a brighter future.

Families are already experiencing uncertainty regarding future access pathways. We have personally experienced an increase in parental anxiety and mental health struggles as a sole result of these proposed changes. Introducing tighter eligibility thresholds before replacement systems are fully funded and accessible risks creating gap during critical developmental periods.

Restrictions on Reassessment and Review

The proposal to limit unscheduled reassessments to “exceptional circumstances” is also concerning.

Participant needs can change rapidly due to health deterioration, developmental transitions, mental health fluctuations, family breakdown, housing instability or changes in informal support networks.

Flexible review processes are essential to ensure plans remain safe and appropriate. Restricting reassessment risks leaving participants without adequate supports during periods of significant need.

Governance, Ministerial Powers and Transparency

I am concerned about the expansion of ministerial powers to reduce or restrict categories of supports at a system-wide level.

NDIS supports should remain grounded in individual functional need and evidence- based assessment rather than broad funding limitations. Greater transparency, independent oversight and consultation with disability professionals and participants are essential to maintain trust in the Scheme.

I am also highly concerned that ongoing pricing constraints will inevitably undermine the sustainability of private allied health services, particularly for providers delivering complex supports, rural services, supervision, report writing and multidisciplinary collaboration. This result will ensure that our society experiences an even larger dwindling of confidence in our government. If you lose private practices it has a devastating impact on not only our participants and most vulnerable but our society

and communities as whole. Our workforce will crumble. Unemployment will rise. The list of catastrophic consequences goes on.

If pricing structures do not reflect the real cost of delivering safe and qualified services, participants will experience reduced access to experienced clinicians and longer wait times. Or not have access at all.

Conclusion

I support efforts to improve the long-term sustainability of the NDIS, I have been working within the NDIS Scheme since its inception. However, sustainability should not come at the expense of participant safety, functional outcomes, independence and community participation. And it should not come at the cost of trained professionals livelihood.

I urge the Committee to carefully consider:

• the impact of reducing capacity building and participation supports,

• the importance of professional clinical judgement,

• the risks associated with automated and standardised decision-making,

• the need for flexible reassessment processes,

• and the importance of maintaining transparent, evidence-based governance arrangements.

People with disability require systems that are responsive, individualised and grounded in real-world functional outcomes. I encourage the Committee to ensure these principles remain central to any future reforms. I also encourage the Committee to include peak bodies such as OT Australia to be an integral party in decisions regarding health care and reform.