Submission 4216 — Name Withheld — NDIS Future Generations Bill

Submission on the NDIS Amendment Bill

Name:

I am a:

☑ Clinician: Paediatric Speech Pathologist and Small Business Owner

1. Introduction / my connection to this issue I am a Speech Pathologist and Director of I Spy Speech, a private practice supporting children and adolescents with disability, developmental delay, communication difficulties, literacy challenges, Autism Spectrum Disorder, and complex communication needs.

As both a frontline clinician and a small business owner, I have observed how policy decisions impact not only participants and families but also the availability of local allied health services within the community.

I work directly with NDIS participants and their families every day. My role involves providing assessment, intervention, parent coaching, school collaboration, report writing, and supporting families to navigate the NDIS system. Through this work I have seen the positive impact that timely, evidence-based supports can have on a child’s communication, participation, education, wellbeing, and long-term outcomes.

I am making this submission because I am concerned about the potential impact of the proposed changes on children with disability, their families, and the clinicians who support them.

2. My overall position on this Bill I have serious concerns.

While I understand the need for sustainability, accountability, and quality assurance within the NDIS, I am concerned that aspects of this Bill may unintentionally reduce access to essential supports for children and families.

Communication support is not optional. It is fundamental to education, social participation, safety, mental health, independence, and future employment opportunities.

Many of the families I support are already experiencing significant stress navigating a complex system. Additional uncertainty, administrative burden, or reduced access to early intervention services may ultimately create greater long-term costs for both individuals and government systems.

3. My key concerns

Communication Access

What the issue is

The proposed reforms create uncertainty around what communication supports may continue to be funded and how decisions regarding access to these supports will be made.

Why it matters

Communication is a basic human right. Children who cannot effectively communicate are at increased risk of social isolation, educational disadvantage, behavioural challenges, mental health difficulties, and vulnerability to abuse or neglect.

Speech pathology supports are often viewed simply as therapy services, but they are also essential disability supports that enable participation in everyday life.

Professional experience

I regularly work with children who require support to communicate their needs, participate in school, build friendships, and engage safely in their communities. Delays or interruptions to therapy can significantly impact progress and may result in increased support needs later in life.

Children and Early Intervention

What the issue is

The Bill creates concern regarding future access to early intervention services and the criteria used to determine eligibility and funding.

Why it matters

The strongest evidence in child development consistently shows that earlier intervention leads to better outcomes. Delaying support until difficulties become more severe is less effective, more costly, and more distressing for families.

Professional experience

I frequently support children whose outcomes have improved significantly because they received intervention early. Families often seek support when concerns first emerge. If access becomes more restricted or delayed, children may miss critical developmental windows where intervention is most effective.

Administrative Burden

What the issue is

The increasing complexity of NDIS processes requires clinicians and families to spend substantial time completing administrative tasks rather than delivering or receiving supports.

Why it matters

Every hour spent on excessive administration is an hour not spent supporting participants.

Small allied health businesses already invest significant unpaid time into compliance activities, report writing, gathering evidence, responding to funding changes, and helping families navigate the system.

Professional experience

As a sole trader, I see firsthand how administrative requirements affect service delivery. Many small providers operate with limited resources. Additional complexity risks reducing clinician capacity, increasing waitlists, and making it harder for families to access services.

Loss of Supports and Funding Uncertainty

What the issue is

Families are increasingly unsure whether supports they currently rely upon will remain available.

Why it matters

Children’s development depends on consistency. Interruptions to support can result in loss of skills, slower progress, increased family stress, and reduced participation.

Professional experience

I have worked with families who delay commencing therapy, reduce the frequency of support, or experience significant anxiety because they are uncertain about future funding decisions. This uncertainty affects not only the child but the entire family system.

4. My lived / professional experience

In my role, I regularly meet families who are already overwhelmed by the challenges of raising a child with disability. Many spend countless hours coordinating services, attending appointments, communicating with schools, gathering evidence, and navigating funding processes.

The NDIS has allowed many children to access supports that have transformed their ability to communicate, learn, build relationships, and participate in everyday life.

I have witnessed children develop functional communication skills, improve literacy outcomes, increase independence, and participate more successfully in school and community activities because appropriate supports were available.

I am concerned that reforms focused primarily on reducing expenditure may overlook the long-term benefits and cost savings generated when children receive timely, effective intervention. Supporting children early often reduces the intensity and cost of support required later in life.

5. What I believe this Bill gets wrong While I understand the need to improve the sustainability and accountability of the NDIS, I believe this Bill risks placing too much emphasis on system control and cost containment without sufficient consideration of the practical impacts on participants, families, and frontline providers.

In particular, I am concerned that:

• Communication supports may not be adequately recognised as essential disability supports.

• Early intervention may become harder to access despite strong evidence supporting its effectiveness.

• Decision-making powers may become increasingly removed from the lived experiences of participants and families.

• Additional administrative requirements may disproportionately impact small providers and reduce service availability.

• Increased uncertainty may discourage families from accessing support when it is needed most.

Mandatory Registration and Provider Regulation

I support efforts to improve quality, accountability, and participant safety within the NDIS. Participants deserve access to ethical, evidence-based, and high-quality services.

However, I am concerned that mandatory registration requirements may place a disproportionate burden on small providers and sole practitioners who are already operating safely and within existing professional regulatory frameworks.

As a Speech Pathologist, I am already required to maintain professional membership, professional indemnity insurance, ongoing professional development, criminal history screening, child safety clearances, privacy obligations, and compliance with professional standards. Many allied health professionals are similarly regulated through existing professional and legal frameworks.

For small businesses, additional registration requirements may result in significant financial costs, administrative burden, and reduced capacity to provide services. These costs are likely to be felt most strongly by sole traders and small practices, many of whom provide highly personalised services and strong continuity of care for participants and families.

I am concerned that increased compliance requirements may discourage experienced clinicians from remaining within the NDIS sector. At a time when many communities are already experiencing workforce shortages and long waitlists, this could further reduce participant choice and access to services.

At the same time, some of the most publicised examples of misuse of NDIS funding have involved larger organisations with substantial administrative resources. Additional compliance requirements may therefore have the unintended consequence of creating barriers for smaller providers while having limited impact on organisations that already have dedicated compliance teams and extensive administrative support.

Effective regulation is important, but it should be proportionate, risk-based, and targeted toward protecting participants rather than creating unnecessary barriers for ethical providers who are already meeting high professional standards.

6. What needs to change or be protected I ask that the Committee ensure:

7. Communication supports remain clearly recognised as essential disability supports.

8. Access to evidence-based early intervention services is protected and strengthened.

9. Funding decisions remain transparent, consistent, and subject to appropriate review processes.

4. Children and families are not disadvantaged by increased administrative complexity.

5. The voices of people with disability, families, and frontline clinicians continue to inform implementation of reforms.

6. Any changes prioritise long-term outcomes and participation rather than short- term cost reduction alone.

7. Any mandatory registration framework should be proportionate and risk-based, recognising existing professional regulation and avoiding unnecessary barriers for small allied health providers.

8. Existing safeguards already governing registered and regulated health professionals should be considered before introducing additional layers of compliance that may duplicate existing requirements.

9. Reforms should actively support participant choice by ensuring small community-based providers remain able to operate within the NDIS system.

10. Final statement As a Speech Pathologist working directly with NDIS participants and families, I strongly support efforts to improve the sustainability of the Scheme. However, sustainability should not come at the cost of reducing access to essential supports that enable children with disability to communicate, learn, participate, and thrive.

The success of the NDIS should not be measured solely by expenditure, but by the outcomes it achieves for people with disability. Effective communication support, early intervention, participant choice, and access to experienced clinicians are investments that create lifelong benefits for individuals, families, and the broader community.

I encourage the Committee to carefully consider the potential impact of these reforms on children, families, and frontline service providers, and to ensure that communication access, early intervention, and participant choice remain protected within the NDIS.

I ask the Committee to consider my professional experience when reviewing this Bill.