Concerns about restrictive funding impacting supports for participants with complex needs

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Submission to the Senate Inquiry Regarding Proposed Changes to the National Disability Insurance Scheme (NDIS)

Author: Role: Occupational Therapist Location: Queensland, Australia

Dear Committee Members,

Thank you for the opportunity to provide feedback regarding the proposed reforms to the National Disability Insurance Scheme (NDIS).

I am an Occupational Therapist who works extensively with NDIS participants experiencing significant and permanent disabilities, including autism spectrum disorder, intellectual disability, psychosocial disability, physical disability, and complex support needs. Through my clinical practice, I have observed the transformative impact that the NDIS can have when participants receive timely, reasonable, and necessary supports. I am concerned that several proposed reforms may unintentionally reduce participant choice, create additional barriers to accessing supports, and increase uncertainty regarding future funding arrangements.

Impact on Participants with Complex Needs

Many participants I support experience substantial functional impairment and require highly individualised funding arrangements. Participants with intellectual disability, Level 3 autism, communication impairments, and complex behavioural support needs often rely on multidisciplinary assessments and specialist recommendations to access appropriate supports.

The proposed changes may increase uncertainty regarding what supports can be funded and may create delays in accessing essential services. For participants who are unable to advocate for themselves, prolonged delays can lead to deterioration in function, increased behavioural distress, hospital presentations, family breakdown, and housing instability.

Concerns Regarding Restrictive Funding Definitions

While I acknowledge the importance of maintaining scheme sustainability, there is a risk that narrowly defined funding categories may fail to account for the diverse and individual needs of participants.

Disability does not present uniformly. Two participants with the same diagnosis may require vastly different supports to achieve similar outcomes. Restrictive funding approaches may limit participant choice and control, which are foundational principles of the NDIS.

Furthermore, many supports that enable meaningful participation, skill development, independence, and community inclusion do not fit neatly within prescriptive funding categories. Limiting access to these supports may ultimately reduce participant outcomes and increase reliance on more intensive and costly services in the future.

Impact on Housing and High-Support Participants

I am particularly concerned about the potential impact of reforms on participants requiring Specialist Disability Accommodation (SDA) and Supported Independent Living (SIL).

Many individuals with severe autism, intellectual disability, complex behavioural presentations, or significant support needs require specialised housing solutions to ensure their safety and wellbeing. Delays or increased barriers to accessing SDA and SIL funding may place participants at risk of homelessness, inappropriate accommodation, restrictive practices, emergency accommodation use, and avoidable hospital admissions.

This concern is especially relevant for young people transitioning from out-of-home care, child protection systems, or residential care arrangements into adulthood. Without access to appropriate disability-specific housing and support models, these individuals face significant risks of social isolation, service system failure, exploitation, and poor long-term outcomes.

Impact on Allied Health Providers and the Disability Workforce

In addition to the impact on participants

consideration should be given to the effect that the proposed reforms may have on the disability workforce, particularly allied health professionals who play a critical role in delivering assessment, intervention, capacity building, and support planning services.

The viability of many allied health services is closely linked to NDS funding arrangements. Significant funding restrictions, uncertainty regarding support eligibility, or reductions in access to therapeutic services may result in reduced demand for services, workforce attrition, and decreased service availability, particularly in regional and rural communities where workforce shortages already exist.

Occupational therapists, speech pathologists, physiotherapists, psychologists, and other allied health professionals provide essential supports that enable participants to develop independence, reduce long-term support needs, improve community participation, and achieve NDIS goals. Any reforms that inadvertently reduce access to these services may have downstream consequences for both participants and the sustainability of the disability support system.

It is also important to recognise that the allied health workforce is predominantly female. According to workforce data across multiple allied health professions, women comprise the substantial majority of practitioners. As a result, reforms that reduce service utilisation, restrict funding for therapeutic supports, or affect the viability of private practices and community-based providers may disproportionately impact the income, employment opportunities, and economic security of women working within the disability sector.

The Senate should therefore consider not only the impact of proposed reforms on NDIS participants but also the broader implications for workforce sustainability, service accessibility, regional service provision, and gender equity. A stable and adequately resourced allied health workforce is essential to achieving the objectives of the NDS and supporting participants to live meaningful and inclusive lives.

  1. Maintain flexibility within funding frameworks to accommodate individual circumstances.

  2. Protect access to specialist supports, SDA, and SIL for participants with complex needs.

  3. Ensure reforms are informed by meaningful consultation with people with disability, families, advocates, and frontline clinicians.

  4. Monitor the impact of reforms on vulnerable cohorts, including people with intellectual disability, autism, communication impairments, and those transitioning from child protection or institutional settings.

  5. Ensure evidence provided by treating clinicians is appropriately weighted in funding and planning decisions.

Conclusion

The NDIS has significantly improved the lives of many Australians living with disability. While reform may be necessary to ensure long-term sustainability, it is critical that any changes do not unintentionally disadvantage those with the highest support needs.

I urge the Senate to carefully consider the practical consequences of the proposed reforms and ensure that participant wellbeing, human rights, inclusion, equitable access, and evidence-based decision-making remain at the centre of reform implementation.

Thank you for considering this submission.

Yours sincerely,

Occupational Therapist