Regarding the NDIS Future Generations Bill 2026

I have several concerns.

• Capacity building supports are often the pillar that families and participants need and want the most to upskill and enable independent living and is a key requirement of choice and control. Already participants have very limited access to capacity building supports with the NDIS planners only funding 1 hour of therapy and not considering the additional costs required with travelling to home or school or other environment (such as assistive technology suppliers for trial of equipment). This significantly impacts on funding available for participants plans for capacity building supports which are frequently their highest priority. Although are some cases where clinic-based sessions may be reasonable, most NDIS participants have complex disabilities which result in needing contextual based supports which is evidence based and most effective in the necessary environment, particularly as occupational therapists working with participants in functional activities to achieve functional outcomes is in most cases most relevant in the environment these activities occur in (eg. School, home, community etc). Further reducing capacity building supports that are already so low only further disadvantages participants and their families and particularly those people who live regionally with limited access to services

• I am greatly concerned that the NDIS memorandum acknowledges the expectation of impact on First Nations people and women as primary care givers and as people who proportionally live regionally and remote and with limited financial access to services for assessment and treatment. The proposed Bill significantly disadvantages our most vulnerable people in our communities who already have limited access to services. By requiring people to have exhausted all treatment options prior to being eligible for NDIS is unfair and discriminatory given there is no allowance for financial or geographical access.

• Occupational therapists and several other health professionals are regulated through AHPRA and provide working with children’s checks and national police clearance documents when required. We have a high level of insurance as part of our compliance requirements with AHPRA and professional development. Currently there are very few sole traders who are registered with the NDIA as the process is expensive and time consuming for auditing and not financially viable for sole traders. NDIA should recognise occupational therapists regulation through AHPRA and not require additional red tape when there are several processes already in place.

• The definition for ‘treatment’ is too broad in the proposed bill and potentially exempts any capacity building interventions as these could be considered ‘treatment’ based on the current language however in reality participants do not have the funds to provide for these supports and they are not one offs but require adaption and different needs throughout the lifetime for people with complex disabilities.

• It is important that an independent body maintains involved in disputes as if all power is given to the NDIA this is incredibly biased and the evidence thus far demonstrates that the NDIA has not managed the NDIS effectively by the extent of issues raised at ART and disputes that NDIA has lost.

• The NDIA has mismanaged the NDIS and are thereby holding participants and providers accountable when it is their errors. The number of participants plans

• that have been extended thereby prolonging the costs for several years
• unnecessarily should be researched and provided feedback on the data for this
• as NDIA is the cause of most of the money lost and this could be saved by
• improving systems of management rather than unnecessarily new Bill.