Submission 455
27 May 2026
To whom it may concern,
Submission to the Senate Community Affairs Legislation Committee
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill
2026
I am an Occupational Therapist and sole trader working primarily with children, adolescents and young people with disability, including autism, ADHD, developmental trauma, intellectual disability and complex psychosocial and behavioural presentations.
This submission is provided as a supplementary frontline clinical perspective regarding the proposed reforms outlined in the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.
My work occurs directly within family homes, schools and community environments. I support participants and families navigating significant functional, sensory, emotional, behavioural and participation challenges that are often not immediately visible in standardised or clinic-based assessment environments.
While I recognise the importance of ensuring the sustainability and integrity of the NDIS, I hold significant concerns regarding several proposed reforms and the likely unintended consequences for children, young people and their families.
- Concerns Regarding the Proposed Definition of Functional Capacity The proposed definition of functional capacity appears to exclude environmental supports, informal supports, assistive strategies and contextual factors from consideration. This does not reflect contemporary occupational therapy practice or the lived reality of disability.
Children and young people often appear significantly more capable in structured, supported or highly scaffolded environments than they are in everyday life. Many of the children I support rely on constant co-regulation, supervision, prompting, routine management and environmental adaptation simply to participate in ordinary daily activities.
For example, an autistic adolescent may present as articulate and capable during a formal assessment while requiring extensive parental scaffolding at home to manage basic routines, emotional regulation, school attendance, eating, sleep and community participation.
If these contextual supports are removed from assessment consideration, there is substantial risk that support needs will be underestimated and participants will appear “too functional” to qualify for appropriate support.
Submission 455
Occupational therapy assessment is inherently contextual. Function cannot be meaningfully separated from environment, fatigue, sensory load, relational supports and real-world participation demands.
- Concerns Regarding Increased Reliance on Informal Supports The proposed strengthening of expectations regarding parental responsibility is deeply concerning in paediatric practice.
Many disability-related supports can superficially resemble ordinary parenting. However, the intensity, duration, complexity and sustainability of these supports are often vastly beyond what would reasonably be expected for a child of the same age.
Families I work with are frequently managing:
● constant supervision requirements; ● severe emotional dysregulation; ● behavioural escalation; ● school refusal; ● sleep disruption; ● safety risks; ● community avoidance; ● high levels of executive functioning support; and ● extensive coordination across healthcare, education and disability systems.
These supports are not simply “parenting”. They are often highly specialised, relentless and associated with significant caregiver burnout.
There is a serious risk that the proposed wording may further normalise unsustainable levels of unpaid caregiving and reduce access to essential supports that preserve family functioning and participant safety.
- Concerns Regarding Standardised Assessment Processes The proposed movement toward highly standardised assessment methodologies risks reducing clinical discretion and overlooking the complexity of many participants’ presentations.
Children and adolescents with autism, ADHD, PDA profiles, trauma histories, fluctuating regulation and psychosocial disability often demonstrate uneven functional capacity that cannot be accurately captured through brief or standardised assessment processes.
In my clinical experience:
● functioning fluctuates significantly across environments; ● capacity may deteriorate after periods of masking or sustained effort; ● emotional regulation demands impact participation; ● support needs are cumulative and interconnected; and
Submission 455
● risks often emerge over time rather than during isolated assessment interactions.
A purely standardised or benchmarked approach risks overlooking nuanced but clinically significant disability-related impacts.
- Concerns Regarding “Value for Money” Amendments The proposed removal of the requirement for lower-cost alternatives to achieve equivalent outcomes is particularly concerning.
In practice, supports are not interchangeable simply because they are cheaper.
For neurodivergent children especially, therapeutic relationships, consistency, communication style, sensory compatibility and trust are often critical determinants of whether a support is effective.
A lower-cost alternative that disrupts regulation, increases distress or reduces engagement may ultimately result in poorer outcomes, increased family stress and greater long-term system costs.
There is concern that participants may increasingly be expected to accept supports that are merely “adequate” rather than genuinely effective and sustainable.
- Impact on Early Intervention and Prevention Many supports currently funded through the NDIS reduce long-term risk and prevent escalation.
In paediatric practice, therapy and capacity-building supports often:
● prevent family breakdown; ● reduce school disengagement; ● reduce mental health deterioration; ● reduce restrictive practices; ● support community participation; ● build independence; and ● reduce future reliance on crisis systems.
Restricting access to supports until functional decline becomes severe may ultimately increase costs across health, education, mental health and child protection systems.
- Importance of Preserving Clinical Reasoning The proposed reforms appear to increase reliance on generalisable research evidence while reducing the weighting of participant-specific clinical reasoning and observed functional outcomes.
Evidence-based practice should include:
● research evidence; ● clinician expertise; and ● individual participant context and outcomes.
Many participants do not fit neatly within standardised evidence frameworks, particularly where presentations are complex, intersecting or neurodivergent.
Submission 455
Occupational therapists rely heavily on nuanced functional observation and longitudinal understanding of participants and families. This clinical reasoning should not be marginalised within future planning and funding decisions.
Conclusion
As a sole trader Occupational Therapist working directly with children, adolescents and families, I am concerned that several proposed reforms may unintentionally disadvantage participants with complex, fluctuating and context-dependent support needs.
I urge the Committee to ensure that:
● functional capacity continues to be assessed contextually; ● informal caregiving expectations remain reasonable and sustainable; ● participant-specific clinical evidence retains strong weighting; ● reassessment pathways remain accessible during periods of escalating need; and ● reforms do not inadvertently reduce safety, participation and long-term outcomes for children and families.
The sustainability of the NDIS is important. However, sustainability must not come at the expense of accurately understanding disability and adequately supporting those with significant functional needs.
If you have any further questions or would like to clarify any of this information, please feel free to contact me.
Kind regards,