Paediatric speech pathology provider's concerns regarding early intervention access (Provider experience)

Submission 459

Submission from a paediatric speech pathology provider: protecting early intervention, service access and continuity of care under the NDIS Amendment Bill 2026

To the Senate Community Affairs Legislation Committee

Thank you for the opportunity to provide feedback on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

I am the owner and speech pathologist with 30 years experience at Talking Together Speech Pathology, a small paediatric speech pathology practice based in Geelong, Victoria. Our practice supports children up to 10 years of age, with a strong focus on early intervention, developmental delay, autism, speech and language delays and disorders, and family-centred support. We work with children and families in clinic, home, kindergarten, childcare and school settings where appropriate. Our work is practical, developmental and relationship-based.

I understand and support the need for the NDIS to be sustainable, fair and protected from fraud. The NDIS is an essential scheme, and it needs to remain available for people with significant and permanent disability now and into the future. The Government has described the Bill as focusing on clarifying eligibility and supports, addressing fraud, and updating governance and administrative arrangements.

My concern is that some of the proposed changes, if implemented without careful safeguards, will have serious unintended consequences for children, families, providers, schools and communities. These impacts will be particularly felt in early childhood, where delays or disruptions in support can affect communication, participation, emotional wellbeing and school engagement during important developmental years.

1. Early intervention must not become harder to access The Bill proposes changes to functional capacity, eligibility, permanence and the link between a person’s impairment and funded supports. I understand the intent is to improve consistency and clarify what the NDIS should fund. However, for young children, development is rarely simple, fixed or easy to describe in narrow categories.

In paediatric practice, children often present with overlapping developmental needs. A child may have communication delay, sensory processing differences, social communication differences, anxiety, motor planning difficulties, learning vulnerabilities and regulation needs. These areas are interconnected. It can be difficult, and at times artificial, to separate which support need arises directly from which impairment.

For young autistic children and children with developmental delay, support often needs to focus on everyday participation: communicating needs, joining play, managing transitions, understanding routines, participating in kinder or school, and supporting families to understand their child. If the Bill is interpreted too narrowly, there is a risk that children will lose access to supports that are essential in real life because they do not fit neatly into one diagnostic or impairment category.

Submission 459

Early intervention works best when it is timely, flexible and responsive. Most of us small allied health providers practice in a multidisciplinary way that is best evidence-based practice for the children we support If families are required to gather more reports, prove thresholds repeatedly, or wait for reassessments while their child is struggling, children may miss support during critical developmental windows.

2. Restrictions on plan reassessments may create practical barriers for families The Bill proposes limits on unscheduled plan reassessments, including who may request them and when they may occur. I understand the concern about reassessments being used inappropriately or without participant knowledge. However, the practical reality is that many families need help to identify, document and explain changes in their child’s needs as child development can fluctuate.

Parents of young children are often exhausted, overwhelmed and still learning how to navigate the NDIS, health, education and therapy systems. Some families have literacy, language, cultural, disability or mental health barriers. Others are managing multiple children, work demands, financial stress or complex care needs. In these situations, therapists and support coordinators often help families understand what has changed and what information may be needed.

If reassessment pathways become too narrow or administratively difficult, families who are already under pressure may simply not be able to pursue them. Children whose needs have genuinely changed may then remain on plans that no longer reflect their circumstances.

The Bill’s explanatory material recognises the need for careful design so that people with communication and decision-support needs can still access help to navigate NDIS processes. This is particularly important for families of young children, Aboriginal families, culturally and linguistically diverse families, and families in regional areas where advocacy and support options may be limited.

3. Reduced flexibility may increase pressure on schools and families In early childhood and primary school, therapy support is often not just about the individual session. It includes parent coaching, educator consultation and teaching, observation in natural settings, communication strategies, transition planning, visual supports, social communication support and practical problem solving.

If funding becomes too restricted, or if reasonable and necessary supports are interpreted in a way that does not reflect real developmental needs, families may lose access to the supports that help children participate in everyday life. Schools and kindergartens will then be left to manage increased complexity without enough specialist support around them.

This will not reduce need. It will shift need onto parents, educators, schools, health services and community settings who already report that they are challenged to keep up with support needs.

For children, the risks include poorer communication outcomes, reduced school participation, increased distress, reduced peer engagement, family stress and missed opportunities to build independence. Over time, reduced access to early support can increase the need for more intensive

Submission 459

support later. The basis of early intervention in communication is grounded in neuroscience. During the first three years of life, the brain produces synaptic connections at a remarkable rate, and this period of peak neuroplasticity creates a critical window where targeted input can establish strong, durable neural networks for language. As the brain matures and specialises, it becomes progressively less adaptable; attempting to build communication skills on a poorly established foundation requires substantially greater effort and resources later. (https:// developingchild.harvard.edu/wp-content/uploads/2025/02/ From_Best_Practices_to_Breakthrough_Impacts-4.pdf).

4. Provider sustainability and workforce impacts need to be considered Small paediatric providers are a significant part of the current early intervention and disability support system. In many communities, families rely on private speech pathologists, occupational therapists, psychologists, physiotherapists, allied health assistants and administrative staff to access timely support.

If the reforms reduce access to funded therapy too quickly, or create uncertainty around what can be funded, many small providers will become financially less stable. Some may reduce services, stop taking NDIS clients, or close. This would worsen waitlists and reduce access, particularly in regional and underserviced areas. As a therapist who prior to opening a private practice, worked for early intervention organisations before NDIS, I have experienced this before and the families and children often missed the early intervention window while waiting on waitlists.

Once experienced clinicians leave paediatric practice, they are not easily replaced. The workforce is already under pressure. Provider closures would not only affect business owners. They would affect employees, families, schools and communities who rely on those services.

5. Administrative and compliance changes must be proportionate I support stronger action against fraud and poor-quality services. Families and ethical providers want the NDIS to be safe and accountable.

However, compliance requirements need to be proportionate and workable for small allied health practices. Small providers do not have large compliance teams. If registration, record keeping, claims processes or audit requirements become too complex or costly, ethical small providers may leave the market. This would reduce choice and access for families, while not necessarily targeting the providers causing the most harm. Additionally, our professional bodies already ensure we meet strict criteria that is accepted by Medicare as robust to provide services, surely this should be recognised for NDIS funded services also.

The Bill includes fraud and integrity measures, including provider regulation, record keeping and claims timeframes. These changes should be implemented with clear guidance, realistic transition periods and practical support for small providers.

Submission 459

6. Transition to Thriving Kids and foundational supports must be safe and realistic

The Bill links some access changes to the commencement of Thriving Kids from 1 January 2028. This is a major concern if foundational supports are not fully available, funded, staffed and accessible before children lose or are diverted from NDIS supports.

Families cannot be asked to move from one system to another if the new system is not ready. This is especially important for young children with developmental delay, autism and neurodivergent needs. If children are found ineligible for the NDIS but the alternative supports are not available, they will simply go without.

Any transition must include clear service pathways, adequate workforce planning, regional access planning, safeguards for children already receiving support, and genuine consultation with families and providers.

Conclusion and practical recommendations

I respectfully ask the Committee to consider the real-world impact of this Bill on children and families who rely on early, practical and consistent support.

I recommend that the Bill and its implementation be strengthened by:

1. Ensuring children do not lose access to early intervention before foundational supports are fully available and functioning.

2. Making sure functional capacity and eligibility rules reflect the developmental reality of young children, including children with autism, developmental delay and overlapping needs.

3. Protecting access to support for families who need help to request reassessments or explain changes in their child’s circumstances.

4. Keeping enough flexibility in planning so that supports can address communication, participation, regulation, school engagement and family capacity in real-life settings.

5. Ensuring compliance and registration requirements are proportionate for small, ethical allied health providers.

6. Consulting directly with frontline paediatric providers, families, educators and regional communities before major changes are implemented. Allowing private allied health providers to be part of the Thriving kids supports.

7. Monitoring provider closures, workforce loss, waitlists and service gaps as part of implementation.

The goal of reform should be a stronger and more sustainable NDIS. That goal will not be achieved if children miss early intervention, families lose trusted supports, schools are placed under greater pressure, or experienced clinicians leave the sector. A sustainable scheme must also be a practical, accessible and human scheme.