To the Community Affairs Legislation Committee,

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

I am an Occupational Therapist and small business owner in a regional town of Western Australia. I work primarily with children, adolescents and families, including children with autism, intellectual disability, developmental delay, psychosocial disability and complex developmental trauma.

I am writing to express my concern regarding several aspects of the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026. While I support the need for a sustainable NDIS, I am concerned that a number of the proposed changes risk undermining the very outcomes the Scheme was designed to achieve. In particular, I am concerned about proposed reductions to capacity building and participation supports, increased reliance on standardised assessment tools and frameworks, restrictions on reassessment processes, and the potential narrowing of access for children and people with complex needs.

As an occupational therapist, I see every day that disability is not simply a diagnosis. Disability is experienced through the interaction between a person’s abilities, their environment, their supports and the demands placed upon them. Functional capacity cannot be accurately understood through diagnosis alone, nor can it be meaningfully captured through a standardised tool or automated process.

Many of the children I support have needs that fluctuate significantly depending on factors such as sensory overload, mental health, family stress, school expectations, developmental stage and environmental supports. Clinical assessment requires observation, collaboration with families and schools, professional reasoning and consideration of the child’s real world functioning. I am deeply concerned about any move toward assessment systems that reduce the role of qualified allied health professionals and place greater reliance on algorithms, standardised tools or administrative frameworks. I am particularly concerned about the impact on children.

The proposed changes may unintentionally create barriers to early intervention and ongoing developmental support. In my clinical practice, occupational therapy is often focused on helping children develop the foundational skills required for lifelong participation. This includes emotional regulation, executive functioning, self-care, social participation, school engagement, independence and community access. These supports are not short-term interventions. Development occurs over years, not weeks or months. Progress is often gradual and non-linear. Children may require increased support during

key developmental transitions such as starting school, entering adolescence or

experiencing significant changes in family circumstances. Restricting reassessments to exceptional circumstances risks preventing families from accessing support when it is most needed.

I am also concerned about the proposed reductions to capacity building and participation supports. In my experience, these supports are often misunderstood as optional or discretionary. In reality, they are the supports that enable participants to build skills, maintain routines, engage in education, develop social connections and participate meaningfully in their communities. For many neurodivergent children, participation supports provide opportunities to practise skills in real-world settings that cannot be replicated in a clinic room. Community participation, social engagement and supported skill development are critical components of long-term independence and wellbeing. Reducing these supports may create immediate budget savings, but risks increasing long- term costs through greater dependence on formal supports, increased family stress, poorer educational outcomes and escalating mental health concerns.

I am particularly concerned about children with complex presentations, including neurodevelopmental conditions, developmental trauma, psychosocial disability and co- occurring mental health challenges. These children often do not fit neatly within standardised assessment frameworks. Their support needs may fluctuate considerably over 时间 and across environments. They are also among the children most likely to experience exclusion from education, social isolation, family breakdown and mental health difficulties if appropriate supports are not available.

The Bill also raises concerns regarding workforce sustainability. Occupational therapists play a critical role within the NDIS. We assess functional capacity, support participant goal attainment, build independence and provide evidence to inform funding decisions. The proposed reforms occur within a context where many regions are already experiencing significant workforce shortages. If pricing reforms, increased administrative burden or reduced funding further undermine the viability of providing NDIS services, participants will experience reduced access to appropriately qualified clinicians. This risk is particularly significant in regional and outer metropolitan communities where workforce availability is already limited significantly.

I respectfully ask Parliament to:

• Ensure functional capacity and support needs assessments are conducted by appropriately qualified allied health professionals, including occupational terapists.
• Prohibit fully automated eligibility and funding decisions and require meaningful human oversight of any assessment tools or algorithms.
• Reverse the proposed reductions to capacity building and participation supports.

• Ensure that children and people with complex, fluctuating or psychosocial disabilities are not disadvantaged by eligibility or assessment changes.
• Retain accessible and flexible pathways for reassessment and review.
• Limit ministerial powers that allow broad reductions to categories of support without transparent evidence-based processes.
• Ensure pricing and integrity reforms support a sustainable allied health workforce and continued participant access to therapy services.

The NDIS was established to support people with disability to live meaningful lives, participate in their communities and achieve greater independence. The children and families I work with demonstrate every day that early, individualised and clinically informed support changes life trajectories. I urge the Committee to carefully consider the potential unintended consequences of these reforms and to adopt Occupational Therapy Australia’s recommendations to ensure the future sustainability of the NDIS does not come at the cost of participant outcomes, access to support or the long-term wellbeing of Australian children and families.

Sincerely,

Tamara Bushell Senior Occupational Therapist Provider Number: 4946015X