Submission 382
Therapy Delayed Is
Development Delayed: A
Paediatric Occupational
Therapy Perspective
Submission to the Senate Community Affairs Committee regarding the National
Disability Insurance Scheme Amendment (Securing the NDIS for Future
Generations) Bill 2026
Submission 382
Introduction
Pouch Kids Therapy is a paediatric Occupational Therapy provider supporting
children and families across metropolitan Sydney through clinic-based,school-based, mobile services.
We support children and adolescents with a wide range of developmental, behavioural, sensory, emotional regulation, social communication and functional participation needs. The families we work with come from diverse cultural, social
and financial backgrounds, including families navigating autism, ADHD,
developmental delay, intellectual disability, school participation challenges,emotional regulation difficulties and complex support needs.
Our work extends beyond therapy rooms. We regularly collaborate with schools, childcare centres, educators, support coordinators and caregivers to help children participate meaningfully in daily life and community environments.
As a small community-based private practice, we understand the importance of maintaining a sustainable and accountable NDIS system for future generations. We support the intent of ensuring long-term sustainability and reducing misuse of funding.
At the same time, we are concerned that some proposed reforms under the
National Disability Insurance Scheme Amendment (Securing the NDIS for Future
Generations) Bill 2026 may unintentionally create barriers for children and families genuinely requiring support during critical developmental years.
This submission reflects practical concerns observed directly through frontline
paediatric service delivery across metropolitan Sydney. It represents the
experiences of families trying to access timely support, clinicians managingincreasing system pressures, and children whose long-term outcomes are closely linked to early and consistent intervention.
Early Intervention Delays Have Long-Term Consequences
One of the strongest concerns from families and clinicians is the potential reduction in access to early intervention supports.
In paediatric practice, delays matter. Children do not simply “pause” development while waiting for reassessments, funding approvals or plan reviews. During these waiting periods, we often see increased emotional dysregulation, school refusal, behavioural escalation, social withdrawal, developmental regression and family stress.
Submission 382
Many children accessing Occupational Therapy are not only working on isolated therapy goals. They are working on the foundations required for participation in
daily life, including communication, emotional regulation, social interaction,
classroom participation, independence, safety awareness and engagement inlearning.
When support is delayed or reduced, schools and families frequently absorb the impact.
Teachers are increasingly expected to manage complex developmental andbehavioural needs within already stretched classrooms. Parents are left trying to coordinate services, advocate for reassessments, manage emotional distress at home and financially absorb therapy gaps where possible.
For many children, particularly neurodivergent children, consistent intervention over time is what prevents larger support needs later in adolescence and adulthood.
Reducing access to flexible and timely early intervention may create greater long-term costs across health, education, mental health and social systems.
Concerns Regarding Reassessments and Administrative Burden
We are concerned about potential increases in reassessment requirements and administrative processes for families and providers.
Families already experience significant stress navigating reports, evidence requests, funding reviews and changing administrative requirements. Many parents describe
feeling like they must repeatedly "prove" their child’s disability or functionalchallenges despite longstanding diagnoses and consistent therapy histories.
From a clinical perspective, excessive reassessment requirements may reduce the amount of actual therapy children receive.
Therapists are already spending increasing amounts of time completing reports, responding to requests for further evidence, writing letters of support and attending administrative meetings. While documentation is important, growing administrative
burden contributes directly to workforce fatigue and reduced appointmentavailability.
This is particularly concerning within paediatric therapy where workforce shortages already exist.
If clinicians spend more time on compliance processes and less time providing therapy, families ultimately experience:
● longer waitlists
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● reduced therapy frequency ● difficulty accessing experienced clinicians ● reduced continuity of care ● higher staff turnover
Smaller private practices may be disproportionately affected because they often lack large administrative teams.
Reduced Flexibility Can Undermine Functional Outcomes
One of the strengths of the NDIS has been the ability for supports to be tailored around the functional needs of each child and family.
In paediatric Occupational Therapy, flexibility is essential.
Children often require support across multiple environments including home,school, childcare and community settings. Progress is rarely linear. Some children
may need increased support during school transitions, emotional regulationchallenges, periods of burnout, family stress, or developmental changes.
Rigid funding structures or limitations around how supports can be used may unintentionally reduce meaningful participation outcomes.
For example, school observations, parent coaching, teacher collaboration and
environmental modifications are often critical components of successfulintervention. However, these supports can sometimes be difficult to justify under increasingly narrow interpretations of “reasonable and necessary” supports despite their significant functional impact.
Families benefit most when clinicians are able to provide responsive, practical and collaborative supports rather than highly restricted service models.
Impact on Neurodivergent Children and Children with Developmental
Delay
Many children supported under the NDIS present with needs that are not always immediately visible.
Neurodivergent children may appear capable in one environment whileexperiencing significant functional challenges in another. We commonly work with children who mask difficulties during short assessments but struggle substantially
with emotional regulation, social interaction, sensory processing, transitions,executive functioning and classroom participation.
Submission 382
There is concern that stricter interpretations of eligibility or functional impairment may unintentionally disadvantage children whose challenges fluctuate or are less outwardly visible.
This may particularly affect:
● autistic children requiring ongoing support for participation and regulation ● children with ADHD and executive functioning challenges ● children with developmental delays requiring early intervention ● children experiencing sensory processing difficulties ● children at risk of school disengagement ● children with significant emotional regulation challenges
Without timely supports, many of these children may later require more intensive interventions through mental health systems, education supports or crisis services.
Regional, Rural and Workforce Concerns
Although our service primarily operates across metropolitan Sydney, we regularly hear concerns from families and clinicians regarding workforce shortages across regional and rural communities.
Any changes that reduce provider sustainability may worsen existing workforce gaps.
The paediatric allied health workforce is already under pressure. Recruitment and retention remain ongoing challenges, particularly for experienced clinicians. Many
small practices are managing increasing operational costs, clinician burnout,administrative demands and rising waitlists simultaneously.
If funding uncertainty, increased compliance burden or restrictive service models continue to grow, there is a genuine risk that some providers may reduce services, stop accepting NDIS participants or close entirely.
This would leave families with even fewer support options.
The impact is often greatest on children who require consistency, routine and long-term therapeutic relationships.
Submission 382
Impact Across Metropolitan Sydney Communities
Across metropolitan Sydney, families are already experiencing increasing difficulty accessing paediatric allied health supports due to growing waitlists, workforce shortages and rising service demand.
Many families are balancing therapy appointments alongside school demands, work
commitments, financial pressures, transport challenges and caregivingresponsibilities. For culturally diverse families, navigating the NDIS system can be even more complex due to language barriers, limited system understanding and difficulties accessing coordinated supports.
We work with families from a broad range of backgrounds and circumstances. Some families are highly resourced and able to privately fund therapy gaps when needed. Many others cannot.
When supports are delayed, reduced or become more difficult to access, the impact is not experienced equally.
Families with fewer financial resources, limited informal supports or lower system literacy are often the most affected. These families may struggle to advocate for reassessments, navigate appeals processes or fund private therapy during lengthy waiting periods.
Children should not experience poorer developmental outcomes simply because their families are less able to navigate increasingly complex systems.
Strong community-based paediatric supports are particularly important within growing metropolitan areas where schools, childcare services and healthcare systems are already under significant pressure.
Protecting accessible early intervention services helps strengthen not onlyindividual children and families, but also broader community participation, school engagement and long-term social outcomes.
The Broader Community Impact
The effects of reduced disability supports extend far beyond therapy sessions.
When children cannot access timely intervention:
● schools experience greater pressure managing complex needs ● parents reduce work participation to care for children ● family stress and burnout increase ● children become more socially isolated
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● behavioural challenges escalate ● mental health concerns increase ● long-term educational and employment participation may decline
Early intervention is not simply about therapy hours.
It is about supporting children to participate meaningfully in family life, education, friendships and community.
Strong early supports help children build independence, emotional regulation, communication and functional skills that can positively shape long-term outcomes.
Recommendations
We respectfully recommend that the Committee consider the following:
1. Preserve timely access to early intervention supports for children with developmental delays and neurodevelopmental conditions. 2. Avoid excessive reassessment requirements for children with established functional needs and long-term diagnoses.
3. Ensure funding frameworks maintain flexibility for school collaboration,parent coaching, environmental supports and functional participation-based interventions. 4. Reduce unnecessary administrative burden on clinicians to protect therapy availability and workforce sustainability. 5. Consult closely with frontline providers, families and disability communities regarding the practical implementation impacts of reforms. 6. Consider the long-term economic and social costs of delayed intervention, provider closures and workforce shortages.
7. Ensure regional and rural communities are not disproportionatelydisadvantaged by future reforms.
Conclusion
As clinicians and providers working directly with children and families every day, we understand the importance of ensuring the NDIS remains sustainable into the future.
However, sustainability should not come at the cost of reducing timely and meaningful support for children during critical developmental years.
The families we support are not asking for unnecessary services. Most are simply trying to help their children participate safely and meaningfully in everyday life, school, relationships and their communities.
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Small moments often matter most.
A child learning to regulate enough to remain in the classroom. A parent finally understanding how to support meltdowns safely at home. A child making their first
friendship. A teenager gaining confidence to participate independently incommunity settings.
These outcomes are not always immediately measurable in short-term funding discussions, but they profoundly shape long-term wellbeing, participation and future independence.
We encourage the Committee to ensure that future reforms remain practical, balanced and informed by the lived realities of children, families, clinicians and communities.
The long-term strength of the NDIS will depend not only on financial sustainability, but also on maintaining accessible, responsive and human-centred supports for the Australians who rely on it most.