Unrealistic assessment of functional capacity impacting neurodiverse individuals (Participant experience)

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Submission 460

Phone: ; Email: admin@exploreempower.com; ABN: 74 101 101 830.

To whom it may concern,

This submission is being provided on the 27th of May 2026 in relation to the NDIS Future Generations Bill 2026. The Bill proposes significant changes to NDIS eligibility, planning, funding, and governance, and I hold extreme concern for the safety and welfare of my participants if the Bill proceeds in its current form.

My name is Stephanie, I am an Occupational Therapist and the founder of Explore & Empower, a small business operating in and around the Goulburn Valley in Victoria. I have an Honours Degree in Occupational Therapy from Deakin University and recently had a journal article published (for which I was Lead Author) relating to Inclusion for individuals living with disability within sport and recreation. My entire career has been in the disability space, and prior to becoming an Occupational Therapist, I also worked as a Disability Support Worker and Allied Health Assistant, so have a variety of experience to draw on as I consider my concerns relating to the Bill. I have countless concerns regarding changes proposed in the Bill. As a small business owner, my time to articulately put these into a submission is limited, so I hope to provide a summary in this submission, but also encourage you to review more in-depth submissions by Occupational Therapy Australia (OTA) and the OT Society for Indivisible Disabilities (OTSi).

I am deeply concerned about the proposed changes to the definition of functional capacity, and about the changes to how one’s functional capacity will be assessed. Explore & Empower currently specialises in providing Functional Capacity Assessments (FCAs), so I feel highly qualified in assessment and can see firsthand how these changes will affect the participants I work with. The Bill proposes that functional capacity be assessed without assistance from others, without assistive technology, and without considering environmental and personal circumstances as much as possible.

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This is an unrealistic way of assessing functioning and does not reflect the realities of the world we live in, of disability, and of the impact an individual’s environment and personal circumstances has onto their functioning. This approach also shifts away from the Social Model of Disability, which deeply concerns me when I consider the rights, dignity, and quality of life of my participants.

I frequently work with neurodiverse individuals and people living with psychosocial disability. This cohort will be heavily impacted by these changes, as their functioning frequently fluctuates, is affected by those around them (informal support), and is impacted in ways that an untrained assessor/observer will not pick up on; a clinical lens and whole-of-person assessment approach is essential. For instance, one cannot accurately assess the functional capacity of a person living with Autism Spectrum Disorder, without considering the impacts of their environment onto their sensory processing needs and associated fluctuations in masking, fatigue, executive functioning abilities, and emotional regulation. To suggest that this can be assessed without considering the environment is misguided and shows a deep misunderstanding of psychosocial disability and neurodiversity.

I also hold grave concerns with the idea that the new Bill will require potential participants to have undertaken “all appropriate treatment” before their impairment can be considered permanent. Of deeper concern again, is the idea that if a person does not undertake such ‘treatment’ due to factors such as financial constraints, environmental barriers, etc, they will therefore be unable to prove ‘permanency’ of their lifelong disabilities. Many individuals I support are unable to drive or work due to their disability, and to suggest that they may privately fund certain treatments to prove permanency is discriminatory and unrealistic; I have numerous participants currently experiencing homelessness due to the current cost-of-living crisis, and many who go without nutritious food (or entire meals) because they cannot afford groceries.

I work in and around the Shepparton region, though regularly travel up to 90 minutes each way to see participants living in rural areas, because they do not have access to any providers geographically closer to them. Of course, telehealth is provided where possible, but this is not always appropriate for the individual or circumstances, for several reasons I won’t go into here. Access to specialists in our geographical area is next-to-none, and long waitlists and out-of-pocket costs frequently apply. Individuals living with disability rurally will be disproportionately impacted by these changes, and it is often not feasible for them to travel to Melbourne to undergo treatment, again due to financial barriers, a lack of public transport, and the impact of their disabilities onto their fatigue, safety, and overall capacity.

The Bill also proposes amendments to parenting and family responsibilities, and will place grave pressure on already burnt-out families who are barely getting by. The Bill appears to place a greater expectation on informal supports to provide disability-related

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Submission 460

parenting assistance that exceeds ordinary parental responsibility, and which will ultimately place child participants and their caregivers at risk. I personally work with several families operating at crisis point, and can say with certainty that many of these children in question would be unable to continue living within the family home if NDIS services were reduced.

In many instances, parents/caregivers and siblings also live with disability, and many families I support live in poverty and have low levels of health literacy, meaning that, despite wanting to, they cannot independently understand and implement disability specific support needs. I regularly assess carer burnout using a standardised assessment tool known as the Zarit Caregiver Burden Scale, and it is extremely rare that families score “none” or “mild,” with “severe” levels of burnout the most common amongst the populations I work with. Should the proposed changes proceed, family breakdowns, Child Protection involvement, and the removal of children from their family homes will occur. It goes without saying that the logistics of this, coupled with the trauma it will cause, will cost other government systems exponentially.

I could write on for pages and have not addressed all the concerns I hold due to time constraints, but I know that my concerns are reflected in other submissions, and the concerns I feel most qualified to address are detailed above. I recognise a need for the NDIS to be sustainable, and as a taxpayer and small business owner, want (and expect) public funding to be used appropriately and efficiently. However, withdrawing supports and tightening guidelines will not reduce the need of people with disability; these needs cannot simply be made to go away or disappear, and the real life impact of the proposed changes cannot be understated.

I strongly believe that individuals living with psychosocial disability, and those in regional and rural areas, will be most impacted by the proposed changes. I also genuinely believe that if these changes are implemented, we will see poor outcomes and numerous suicides in the disability community, including amongst participants and carers. I do not say that lightly- as someone working within the disability sector, I have anecdotal evidence from participants that suggests that this is likely. The changes will also not reduce government spending, it will merely amplify costs and redirect them inappropriately to overexerted education, health, housing, mental health, and child protection services instead. These changes will lead to a crisis that cannot be undone without harm and death to people with disability.

Thank you for your consideration. Please feel free to get in touch via email

(                                  or phone                 for any further information.

Kind regards,

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Stephanie Sorraghan.

Occupational Therapist,

Explore & Empower.

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