Concerns regarding assessment accuracy and impact on families

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Committee Secretary

Senate Community Affairs Legislation Committee

Parliament House Canberra ACT 2600

To the Senators of the Australian Senate, Submission to the Senate Community Affairs Legislation Committee National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

I am writing a submission with my concerns regarding the proposed National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 and the potential impacts this bill and reforms may have on people with a disability, their families, carers, networks and services that currently provides supports across Australia.

I am a physiotherapist, who has worked for the past 10 years supporting adults and children with a disability; and their families. I have worked across a number of settings, inclusive of being in the community, private therapy and in research. I have worked across multiple funding schemes in the community such as early intervention, Betterstart and HACWA, within school funding and the NDIS.

Ensuring the long-term sustainability of the NDIS is an important and essential topic that must be addressed to ensure our current and future generations are able to access the supports they require to participate and live their lives fully within Australian society. However I do hold some concerns regarding the proposed reform, which are likely to have negative impacts and consequences for all involved within the current system – inclusive of individuals, families, carers, vulnerable Australians and clinicians.

I can appreciate that the sustainability, effectiveness and integrity needs to be addressed, however I do believe these reforms must hear the voices on the ground that it directly impacts and adjust to these before serious unintended consequences occur. And must be done in accordance with NDIS’s key founding principles of individualisation, choice and control, inclusion, evidence-based supports and functional capacity building. Thus I have concerns around the following areas of the bill:

  • Assessments
  • Parental responsibility
  • Evidence based practice
  • Equipment
  • Block and blanket funding amounts
  • Foundational and community supports

Assessments

The Supports Needs Assessments, raises serious concerns around the ability to accurately estimate the actual needs of the participants. Individuals with a disability present with an array of complex and highly individualised needs, that often are not accurately understood by individuals not familiar to the participant or their lives.

We have seen extensive concerns already with planning meetings having inconsistency across clients with similar needs, and within families where multiple children have needs, when planning meetings

Shift from In-Person Assessments

Shifted from in person to over the phone; and also across planners which varied dependent on their experience level within the disability sector.

With the proposed shift for assessments to be generic and not conducted by qualified allied health professionals who have specific expertise in assessing needs for individuals living with a disability, there is a high risk that:

  • Individuals with a disability and their families’ needs will be underestimated and misunderstood
  • Compromise the safety of participants
  • Create undue carer burden and stress
  • Disproportionately affect participations who can mask for the short time of the assessment
  • Failure to identify early developmental concerns

All of these leading to a higher longer term reliance on the NDIS and / or compromised participant outcomes.

This framework also fails to value the role of highly skilled clinicians in the assessment and delivery of supports that improve long term functional outcomes of participants, raising their quality of life, and reducing future system costs. Diminishing the value of skilled allied health professionals, places risks on the sustainability of the skilled workforce.

Parental Responsibility

The proposed changes to the interpretation of parental responsibility and informal supports within the NDIS framework, also poses serious concerns.

Parents and families of individuals with a disability already experience significant social, economical and emotional barriers. They experience significant financial strain, emotional stress, caregiver burden, mental health concerns, relationship breakdowns, social isolation and an inability to access the workforce compared with the general population. Caregiver sustainability needs to be taken into account to ensure the safety and participation of individuals with a disability.

When disability supports are delayed, re-classified or reduced as “ordinary parenting responsibilities”, it shifts the increased burden directly onto already struggling families. These parents are already providing extensive unpaid care, far parents who do not have a child with a disability. Parents wear many hats, but therapy supports, behavioural supports, feeding interventions, communication systems, assistive technology and disability-specific capacity-building supports should not be considered parental responsibilities. These supports are highly specialised, and take clinicians many years to upskill in, and putting these under parental responsibilities undermines the current expertise in the workforce. This may have unintended consequences of a loss of a skilled workforce, leading to access concerns for individuals with a disability.

Evidence Based Practice

The prosed changes emphasis the use of “published, peer-reviewed, and generalisable research” when determining whether a support is likely to be effective and beneficial.

It is important to note that evidence based practice is based of 3 interconnected pillars of best

available research evidence, clinical experience and Participant/individual and family values, preferences, and circumstances. Thus the proposed changes only address one of these pillars.

Progress in assessments, treatments, interventions and assistive technology occur through clinical practice and take significant amounts of time for published, peer-reviewed and generalisable research to be developed. Clinical expertise and family values and preferences remain essential to evidence based practice, and are required to ensure that the current literature is individualised to support participants, particularly those with complex, multiple and rare conditions.

I believe the Bill should recognise all components of Evidenced Based Practice, rather than isolating only one component when determining whether supports are effective and beneficial.

Block and blanket funding amounts

This system used to be in place prior to the NDIS in Victoria, and failed to recognise the diverse and complex needs of each individual. Going back to block and blank funding amounts, will fail to recognise individuals with complex, fluctuating or high-support needs, failing to meet the needs of those who are most vulnerable.

Equipment provision and decisions

Changes are required to ensure the sustainability and cost-effectiveness of equipment and assistive technology within the scheme. However I do believe that decisions around equipment need to be informed by the assessment and recommendation of a qualified allied health professional; as individuals with insufficient knowledge around the equipment and participant needs poses serious safety concerns for individuals with a disability; and a loss of skill within the workforce for complex equipment prescriptions.

I do believe there are several opportunities where this area could be made more sustainable, and have shown to previously work prior to the NDIS rollout.

  • An equipment recycling and reissue program – where families can access second hand equipment, many of which are safe and appropriate to reuse. This would reduce the amount of equipment going to waste, and reduce the purchase of unnecessary brand new equipment.
  • A qualification program from clinicians to ensure there is quality assurance around equipment provision and prescription.

Foundational and Community Supports

Changes to access pathways before foundational and community supports are re-established raise serious concerns for individuals with a disability. Transparency is key here and having systems that are fully operational, funded and accessible are key to ensuring that participants’ needs are met. Early tightening of these pathways and transitions away from current supports risk new participants having delayed or without access during a child’s critical learning years, which can result in:

  • Worse functional outcomes
  • Increased long term support needs
  • Loss of critical developmental opportunities
  • Widening gap between individuals and their typically developing peers
  • Preventable deterioration
  • Increased strain on families, schools, health systems, and community services
  • Individuals and families slipping through the gaps

I urge the committee to ensure that any changes in this domain are only done, once foundational and community supports are operational, funded and demonstrated to support individuals and their families.

Summary

I appreciate the efforts into the long-term sustainability of the NDIS and support emerging services to support individuals with a disability. I urge the committee to consider the on the ground and practical implications that these changes and reforms have on individuals with a disability, families, carers and the workforce involved to support these individuals; as these impacts have a lasting impact on lives and rights of individuals and our citizens of Australia. It is important that amendments and reforms to the NDIS act focus on sustainability that also preserves the

  • Rights, dignity and wellbeing of individuals with a disability and their families
  • Sustainability and retention of specialised allied health workforce
  • Sustainability of specialised services that support participants day to day

So that there is not a worsening risk of inequity and pressure on already stretched healthcare, educational and community systems; and not have unintended consequences that would reduce the quality of life of individuals with a disability and their families and weaken the allied health sector affecting workforce outcomes.

Thank you for considering this submission.