Submission 465
Committee Secretary
Senate Community Affairs Legislation Committee
Parliament House
Canberra ACT 2600
To the Senators of the Australian Senate,
Submission to the Senate Community Affairs Legislation Committee
On behalf of NAPA Centre, a paediatric neurorehabilitation allied health service supporting thousands of children and families across Australia, we welcome the opportunity to provide feedback on the proposed National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.
NAPA has been operational in Australia for over 10 years and has operated prior to the National NDIS rollout. We are a multidisciplinary company consisting of occupational therapists, physiotherapists and speech pathologists. We specialise in working with children with complex disabilities, physical disabilities, neurodevelopmental conditions, genetic conditions, developmental delay, complex feeding needs and communication disorders.
As specialised allied health clinicians working closely with children with disability, we recognise the importance of ensuring the long-term sustainability of the NDIS. However, we hold serious concerns regarding several proposed reforms and their likely unintended consequences for children, families, carers, clinicians, and vulnerable Australians.
The NDIS was founded on the principles of individualisation, choice and control, inclusion, evidence-based supports and functional capacity building. These principles are particularly critical in paediatric disability, where developmental trajectories are dynamic, time-sensitive, and highly responsive to early intervention and highly skilled allied health support.
Any reforms to the scheme must preserve these foundational principles and ensure participants continue to receive timely, clinically appropriate, individualised supports delivered by qualified professionals.
Concerns Regarding Proposed Legislative Changes
Section 21 – Changes to Access and Eligibility Pathways We are deeply concerned about amendments affecting participant access pathways and eligibility thresholds under proposed changes to Section 21 and related framework provisions.
Submission 465
The proposed tightening of access requirements appears likely to occur before foundational supports, alternative systems, and community-based pathways are adequately developed, operational, funded, tested, and most importantly proven to be effective.
Restricting access to the NDIS without ensuring meaningful, appropriate and accessible supports exist outside the scheme risks leaving children and families without critical intervention during key developmental periods. This is particularly concerning for children with developmental delay, autism, genetic syndromes, neurological conditions, feeding disorders, communication impairments, sensory processing difficulties, complex physical disabilities, and complex functional support needs.
In paediatric practice, developmental windows matter. Delays in accessing clinically indicated therapy can result in:
- loss of critical developmental opportunities
- worsening functional outcomes
- increased long-term support needs
- preventable deterioration in communication, mobility, feeding, and participation
- increased strain on families, schools, health systems, and community services There is significant risk that families may be forced to spend months or years pursuing “alternative” pathways that are either unavailable, waitlisted, inappropriate, or insufficient, despite clear evidence that the recognised and clinically appropriate pathway is timely engagement with skilled allied health intervention.
For many children, particularly in the early years, therapy is not optional or supplementary – it is foundational to development, participation, communication, safety, emotional regulation, feeding, and long-term independence.
We urge the Committee to ensure that any changes to eligibility or access thresholds are not implemented until foundational supports are fully operational, independently evaluated, and demonstrated to be accessible across metropolitan, regional, rural, and remote Australia.
Sections Relating to Support Needs Assessments and Framework Planning Processes
The proposed introduction of support needs assessments raises significant concern, particularly where assessments will not be conducted by appropriately qualified allied health professionals with discipline-specific expertise in determining participant needs.
Children and adults with disabilities present with highly individual and complex functional needs that cannot be accurately understood through standardised or generic assessment processes alone.
Functional impact, participation restrictions, communication challenges, sensory needs, developmental progression, caregiver burden, environmental barriers, emotional regulation, feeding safety, mobility, and educational participation all require nuanced clinical interpretation by experienced allied health professionals.
This is particularly critical in paediatric disability, where children’s needs evolve rapidly over time and supports must remain responsive to developmental change.
There is substantial risk that assessments conducted outside appropriately qualified allied health frameworks may:
- underestimate support needs
- fail to recognise complexity
- reduce participant safety
Submission 465
- create inequitable outcomes
- disproportionately impact participants with less visible disabilities
- fail to identify emerging developmental concerns early
- restrict access to evidence-based intervention Support needs assessments must remain multidisciplinary, clinically informed, and individualised.
Importantly, the proposed framework appears to place insufficient value on the role of highly skilled, AHPRA and SPA registered allied health professionals – including speech pathologists, occupational therapists, physiotherapists, and psychologists – in delivering evidence-based supports that improve long-term functional outcomes and reduce future system costs.
The legislation must explicitly preserve the role of treating clinicians and specialist allied health expertise in assessment, planning, and review processes.
Sections Relating to Funding Frameworks, Budgeting and “Reasonable and Necessary” Supports We are deeply concerned that proposed framework changes relating to budgeting mechanisms, block funding, standardised allocations, and the narrowing interpretation of “reasonable and necessary” supports risk fundamentally undermining the individualisation that is central to effective disability support.
Disability is not a one-size-fits-all experience. Two children with the same diagnosis may have vastly different functional presentations, personal goals, environmental barriers, family circumstances, communication needs, educational participation challenges, and developmental trajectories.
Rigid funding structures risk:
- limiTng responsiveness to changing needs
- reducing parTcipant choice and control
- restricTng innovaTon and evidence-based intervenTon approaches
- prevenTng Tmely increases in support when clinically required
- creaTng barriers to interdisciplinary collaboraTon
- reducing access to intensive therapy during criTcal developmental windows Importantly, many evidence-based paediatric approaches rely on tailored, individualised, intensive, and interdisciplinary models of care. These approaches cannot always be delivered within inflexible or standardised funding frameworks.
The Bill appears to insufficiently recognise the importance of innovative and individualised allied health approaches that are responsive to each child’s goals, developmental stage, family context, and functional capacity.
Sections Relating to Evidence Based Practice
We are significantly concerned that the proposed reforms risk narrowing the definition of evidence-based practice by placing disproportionate emphasis on research evidence alone, without appropriately recognising the equally important roles of clinical expertise and participant-centred decision making.
True evidence-based practice is built upon three essential components:
- the best available research evidence
- clinical expertise
- patient values and circumstances (including the individuals preference, goals and unique needs)
Submission 465
Focusing predominantly on standardised research evidence may reduce the ability of clinicians and participants to access the most appropriate and effective supports for their individual needs.
Clinical expertise remains a critical component of safe, high-quality, and individualised care, particularly for participants with complex presentations, developmental differences, co-occurring conditions, or needs that may not be fully captured within standardised evidence frameworks.
Disability support must remain person-centred and flexible enough to account for the diversity of participant experiences, goals, environments, and functional impacts.
Sections Relating to Parental Responsibility and Informal Supports
We are deeply concerned regarding proposed changes that expand interpretations of parental responsibility and informal supports within the NDIS framework.
We see families of children with disability already experience significantly higher levels of financial strain, emotional stress, caregiving burden, mental health challenges, social isolation, and workforce disruption compared to the general population. In practice, these impacts are profound and ongoing.
When disability-related supports are reduced, delayed, or reclassified as “ordinary parenting responsibilities,” the burden does not disappear – it shifts directly onto families. This has substantial social and economic consequences, including:
- increased caregiver burnout
- worsening parental mental health
- reduced workforce participation
- increased financial insecurity
- reduced family functioning
- increased risk of family breakdown and crisis Parents of children with disability are already providing extensive unpaid care well beyond typical parenting expectations. Therapy supports, assistive technology, behavioural supports, feeding intervention, communication systems, and functional capacity-building supports are not ordinary parenting tasks — they are disability-specific interventions required to support safety, development, participation, and independence.
Reducing these supports is likely to create greater long-term societal and economic costs, not less.
Lack of Individualisation and Cultural Responsiveness
We are concerned that the proposed reforms risk reducing both individualisation and cultural responsiveness within the scheme. Effective disability support requires recognition of:
- cultural background
- family structure
- developmental stage
- communication needs
- geographic location
- community context
- socioeconomic factors
- lived experience
Submission 465
Particularly for Aboriginal and Torres Strait Islander communities, culturally safe and flexible approaches are essential. Standardised assessment and funding models risk failing to account for the diversity of participant experiences across Australia and may further entrench inequity for already marginalised communities. Equitable support does not mean identical support.
The Bill Does Not Adequately Address the Structural Drivers of System Inefficiency
While the Bill is framed as necessary for sustainability, there is insufficient evidence that the proposed reforms meaningfully address the underlying drivers of system inefficiency, escalating costs, or fraud. Reducing direct supports to participants is not the same as improving system integrity.
The Bill does not adequately address broader structural issues including:
- inconsistent decision-making
- excessive administrative burden
- poor transparency
- lengthy review and appeals processes
- escalating tribunal and legal costs
- workforce shortages
- inadequate oversight systems
- gaps in governance and operational accountability
- inefficient planning processes
- delays in approvals and implementation
- poor coordination across systems There is significant concern that the proposed reforms may achieve cost reduction primarily through restricting participant access and reducing supports, rather than through genuine system improvement and better governance.
Sustainability cannot be built by reducing access to clinically necessary intervention for vulnerable children and families.
Conclusion
The NDIS exists to support some of the most vulnerable members of our society. Sustainability is important — but sustainability cannot come at the expense of safety, dignity, development, participation, and access to appropriate supports. Children with disability do not get developmental time back.
Delays to intervention in early childhood can have lifelong consequences for communication, mobility, feeding, emotional well-being, education, independence, and community participation.
Participants and families deserve:
- genuine choice and control
- individualised supports
- timely access to evidence-based intervention
- clinically informed assessment processes
- culturally responsive approaches
- flexibility to respond to changing needs
- access to qualified allied health professionals
- supports that enable meaningful participation in everyday life
Submission 465
We urge the Committee to carefully consider the significant unintended consequences these reforms may have on children, families, carers, allied health services, and the broader Australian community.
Importantly, the sustainability of the NDIS is intrinsically linked to the sustainability of the allied health workforce and the specialist services that support participants every day.
Paediatric disability services across Australia are already operating within an environment of increasing workforce shortages, rising operational costs, escalating administrative burden, and ongoing uncertainty regarding funding frameworks.
Policy settings that increase administrative complexity, reduce flexibility, devalue clinical expertise, or create ongoing instability within the NDIS risk undermining not only participant outcomes, but also the long-term sustainability of the specialist allied health workforce itself.
The long-term economic and social consequences of these reforms must therefore be considered not only through the lens of scheme expenditure, but also through their impact on:
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access to specialised paediatric services
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long-term health, education, and social outcomes for children with disability
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sustainability of small and medium allied health businesses
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retention of skilled clinicians Reforms of this scale should not proceed without:
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clear evidence that foundational supports are adequately funded and operational
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demonstrated accessibility across metropolitan, regional, rural, and remote communities
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safeguards to ensure vulnerable individuals do not fall through service gaps
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transparent evaluation processes prior to implementation Without these protections, there is significant risk of worsening inequity and increasing pressure on already stretched health, education, and community systems.
Australia must continue to uphold the rights, dignity, wellbeing, and inclusion of people with disability – not reduce supports in ways that place greater burden on families, weaken the allied health sector, and diminish opportunities for children to reach their full potential.
Australia needs leadership that protects the rights, dignity, and wellbeing of people with disability. Australians with disability deserve the opportunity to live the lives they want, with the supports they need to participate fully in their communities.