National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 469
Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submitted by: Ariahne Poggioli Administration Officer and Therapy Assistant The Whole Child Atherton Tablelands, Far North Queensland
Introduction
Thank you for the opportunity to provide this submission.
I work as both an Administration Officer and Therapy Assistant at The Whole Child, a rural paediatric allied health practice based on the Atherton Tablelands in Far North Queensland.
In my role, I support children, families and clinicians across many aspects of service delivery. This includes appointment coordination, communication with families and external services, supporting outreach service delivery, assisting therapists within sessions, preparing resources, supporting therapy implementation and helping maintain continuity of care for children and families.
While I am not involved in policy design or high-level decision making, I see firsthand the practical realities families face when trying to access and maintain supports for their children. I also see the significant amount of coordination, administration and relationship-building required to keep regional therapy services functioning effectively.
I support the need for a sustainable NDIS and improved early supports for children and families. However, I am concerned that current reforms may unintentionally weaken local services and create additional barriers for the children and families who already struggle to access support in regional communities.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 469
Relevance to the Bill
My submission focuses on the practical and operational impacts that changes to funding pathways, access systems and service models may have on children, families and regional allied health services.
From an administration and therapy assistant perspective, I see how important continuity, flexibility and trusted relationships are for families navigating complex developmental, behavioural, emotional regulation and disability-related challenges.
I also see how much invisible work occurs behind the scenes to coordinate services, communicate with families, organise outreach, respond to changing needs and support clinicians to deliver effective intervention.
Many of these tasks are essential to quality care, yet they are often not well recognised within broader discussions around reform and sustainability.
What I See Behind the Scenes
Families accessing therapy services are often already overwhelmed.
Many are managing school difficulties, emotional regulation challenges, medical appointments, behavioural concerns, financial stress, mental health pressures and complex family circumstances alongside trying to navigate NDIS systems and funding requirements.
In administration, we are often the people families contact when they are distressed, confused or struggling to understand processes. We spend significant time helping families navigate appointment changes, service agreements, reports, funding concerns and communication between different services.
There is also a very large amount of administrative work involved in coordinating supports behind the scenes. This includes: • appointment scheduling and rescheduling • coordinating outreach services • communicating with schools, kindergartens and health professionals • preparing therapy resources • managing cancellations and waitlists • supporting report and documentation processes • responding to funding and invoicing questions • organising travel and regional service logistics
I believe many people outside the sector do not fully realise how much coordination is required to keep regional allied health services functioning.
There is also a significant amount of time spent chasing overdue invoices and trying to resolve funding and payment issues, particularly within the NDIS system. In reality, many practices carry a consistent amount of long-term outstanding debt while continuing to provide services to vulnerable families because clinicians do not want children to go without support.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 469
I am particularly concerned about the impact of increasing system complexity on Aboriginal and Torres Strait Islander families within our region. Many families already face significant layers of disadvantage, trauma, limited service access and practical barriers when trying to navigate systems. The NDIS frequently assumes a level of advocacy knowledge, literacy, confidence and administrative capacity that many families simply do not have.
As a result, families who are less able to advocate strongly within the system are often placed at a major disadvantage when trying to access appropriate supports for their children.
I have also observed increasing administrative complexity and report-writing burden placed on clinicians and providers. Therapists are often required to repeatedly rewrite reports using constantly changing wording preferences and terminology in order for participants to access supports that are clinically obvious and reasonable.
Over time, reports have become longer, more deficit-focused and more time-consuming, not because clinicians believe this is best practice, but because providers are attempting to navigate an increasingly bureaucratic system.
Many therapists were trained to write strength-based reports that preserve dignity and focus on empowerment. However, there is often intense pressure to emphasise deficits and functional limitations in extreme detail because families may otherwise be denied essential supports. This can be distressing for both clinicians and families and may negatively impact the self-esteem of participants who later read these reports.
Increasing amounts of funding are being consumed by paperwork, administrative navigation, repeated reassessments and appeals processes rather than direct therapy and meaningful support for children and families.
Therapy Assistant Perspective
As a Therapy Assistant, I see how important consistency, trust and relationships are for children. Many children make progress because they feel safe, understood and connected with the people supporting them. Therapy is often not simply about completing activities. It is about building trust, emotional regulation, confidence, participation and independence over time.
Therapy Assistants can play a very valuable role in reinforcing strategies, supporting participation in meaningful activities and helping children practise skills within everyday situations. However, I am deeply concerned about the growing assumption within reforms that Therapy Assistants or support workers can replace direct occupational therapy intervention for many children.
In reality, paediatric occupational therapy is an extremely skilled area of practice that takes many years to develop competency in. Even children who may initially appear to have only mild or moderate difficulties are often highly complex once the full picture is understood. Therapists are constantly using advanced clinical reasoning throughout sessions, adapting approaches moment by moment based on the child’s regulation, sensory processing, communication, behaviour, trauma background, developmental profile, family dynamics, environmental factors and engagement.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 469
No two children are the same. Even if a therapist has supported many children with similar diagnoses, the approach required for each child may still be completely different.
There also appears to be a misunderstanding of the role of play within paediatric therapy. To an outside observer, a session may appear to involve “just games” or simple activities. However, play is the language of engagement for children and is often the most effective pathway to therapeutic change. Unlike adults, children are rarely able to directly engage in structured therapeutic conversations about their difficulties. Occupational therapists therefore use play, trust, co-regulation and relationship as highly skilled therapeutic tools to achieve outcomes indirectly. The therapeutic relationship itself is often a major part of the intervention.
While Therapy Assistants and support workers provide excellent and valuable support, they are not substitutes for direct occupational therapy intervention. Positive outcomes will not be maintained by simply reducing therapist involvement and replacing it with lower-cost support roles.
I am already seeing examples of this occurring. One child at our practice recently received only minimal occupational therapy funding, enough for approximately 15 sessions per year, despite having significant support needs. However, she was simultaneously funded for three hours per week of Therapy Assistant support. While additional practical support may be beneficial, this model risks removing the very clinical expertise required to guide effective intervention and achieve long-term outcomes.
Regional Realities
Working in a regional area creates additional challenges that are not always visible in broader policy discussions.
Recruiting and retaining staff in regional communities is difficult. Outreach services require extensive coordination and travel. Small disruptions can have significant impacts on schedules and service delivery.
I have also seen how hard practices work to build and maintain stable teams. New staff require training, support and supervision, and experienced clinicians often carry very large workloads to meet community need.
There can sometimes be assumptions within reform discussions that regional services can easily expand lower-cost workforce models to compensate for reductions in therapist funding. In reality, recruitment and retention challenges affect all levels of the workforce, including Therapy Assistants and support staff.
Training Therapy Assistants within paediatric disability work requires extensive supervision, mentoring and ongoing support from senior clinicians. This investment is significant for small regional practices already operating under workforce shortages and financial pressure.
For example, our primary Therapy Assistant recently commenced 18 months maternity leave. While we considered recruiting a replacement, the practical reality was that the time and financial investment required to recruit and train a new Therapy Assistant for a relatively short-term position was not financially viable for a small regional business.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 469
These realities mean that reforms based on assumptions about easily substituting therapist input with lower-cost workforce models may not reflect what is practically achievable within rural and regional communities.
I am also concerned by public commentary suggesting that allied health clinicians affected by NDIS reforms can simply transition into other practice areas such as aged care, hospital systems or veteran services if paediatric disability work becomes financially unsustainable.
From a frontline perspective, this significantly underestimates the level of specialisation involved within occupational therapy practice.
Occupational therapists often develop highly specialised skill sets early in their careers and continue refining those skills over decades of clinical experience. Paediatric occupational therapy is a specialised field requiring advanced knowledge in child development, sensory processing, emotional regulation, trauma, play-based intervention, family systems, disability, behaviour support, communication and complex developmental presentations.
These skills are not directly interchangeable with other occupational therapy practice areas such as aged care, hand therapy, mental health, acute hospital work, equipment prescription or rehabilitation.
Many highly experienced paediatric clinicians have spent the majority of their careers developing expertise specifically within child and family work. Transitioning into entirely different practice areas later in their careers is often neither simple nor realistic.
There is also growing burnout and distress among experienced clinicians who feel increasingly blamed for systemic pressures while simultaneously trying to navigate escalating administrative burden, workforce shortages and emotionally complex caseloads.
From discussions occurring across the sector, many experienced paediatric clinicians are not considering transition into other occupational therapy fields if services become unviable. Instead, there is significant concern that many may leave clinical practice altogether.
This would represent a major loss of highly specialised workforce capacity that has taken many years to develop, particularly within rural and regional communities where recruitment is already extremely difficult.
Many families in regional areas already have limited service options. If local services reduce or close, there are often few realistic alternatives available nearby.
I am concerned that future reforms may unintentionally weaken continuity of care, reduce access to trusted local providers, increase wait times, reduce outreach availability and place even greater pressure on families already struggling to navigate complex systems. I am also concerned that increasing administrative burden and funding uncertainty may make it increasingly difficult for smaller regional services to remain financially sustainable.
From a frontline perspective, large-scale systems do not always appear able to replace the flexibility, responsiveness and trusted local relationships that smaller community-based regional services provide.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 469
Examples of System Complexity and Inefficiency
I am also concerned by the increasing complexity, inefficiency and apparent lack of common-sense decision making occurring within parts of the NDIS system. From a frontline perspective, significant amounts of funding and clinician time appear to be consumed by repeated reports, reassessments, appeals and administrative processes rather than direct supports for children and families.
One recent example involved a child with Autism Spectrum Disorder whose parent was advised by an NDIS representative that the child’s Functional Capacity Assessment would be viewed more favourably if our occupational therapist completed two very specific assessments. One of these assessments was designed for children with cerebral palsy despite the child not presenting with motor difficulties, let alone cerebral palsy. The second assessment was not routinely used within our practice and would have required substantial expense and training to implement. Situations like this create the impression that clinicians are being asked to jump through increasingly unrealistic and clinically inappropriate hoops in order for families to access support.
Another example involves a child with a severe cochlear malformation resulting in deafness, alongside an equally severe vestibular malformation affecting balance and physical functioning. Despite specialist reports and MRI evidence being submitted repeatedly over many years, the NDIS has continued to refuse recognition of her physical impairment. This has resulted in repeated requests for additional reports and ongoing stress for the family and clinicians involved.
The family also reported being advised that funding to support learning Auslan was unnecessary because sign language interpretation is available through the television program Bluey. From a frontline perspective, examples like this are difficult to reconcile with the stated goals of improving participation and functional outcomes for children with complex disabilities.
Another child supported by our practice is six years old with extremely severe disability affecting all areas of functioning. He is unable to move voluntarily, including his eyes, and requires extensive therapy and equipment support. His occupational therapist recently completed a comprehensive report requesting funding for the assessment, trial and prescription of essential equipment including a wheelchair, commode, car seat and hand splints, as his existing plan does not contain sufficient funding for therapy, equipment assessment or equipment provision. His mother currently carries him manually throughout the community and during daily care activities. However, the NDIS approved funding only for ankle-foot orthoses, stating that the justification for the funding for equipment was not sufficient. The plan continues to contain insufficient funding for the assessments and trials for the equipment.
This creates an extremely distressing situation where clinicians must either spend further therapy funding writing increasingly detailed justifications, or the child goes without essential equipment while his condition deteriorates. During these delays, children may develop preventable contractures, lose function and place enormous physical strain on carers.
For many Aboriginal and Torres Strait Islander families already navigating significant disadvantage and systemic barriers, these processes can become completely overwhelming.
From what I observe within the sector, many clinicians feel increasingly discouraged and exhausted by the growing administrative complexity and ongoing pressure associated with the system. Many
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 469
also feel increasingly blamed for cost pressures within a scheme whose complexity and inefficiencies were built into the system itself. While reforms are certainly needed and there are genuine concerns regarding misuse and unsustainable spending within parts of the NDIS, there is also concern that current approaches may unintentionally destabilise the very community-based providers who have devoted their careers to supporting participants and families.
Ultimately, when increasing amounts of funding and clinician time are consumed by repeated reports, reassessments, administrative processes and appeals, there is less funding and less therapist time available for direct intervention with children and families.
Recommendations
I respectfully ask that future reforms carefully consider:
- The importance of stable, trusted relationships for children and families accessing therapy services.
- The realities of delivering allied health services in rural and regional communities, including workforce shortages, travel, outreach and the difficulty of recruiting and retaining staff.
- The large amount of coordination, administration and behind-the-scenes work required to keep regional services functioning effectively.
- The importance of maintaining viable local allied health services so families are not left with even fewer support options.
- The need to reduce unnecessary paperwork, repeated reporting and overly complicated processes that take time and funding away from direct support for children and families.
- The importance of recognising that paediatric occupational therapy is a highly specialised area of practice and that Therapy Assistants and support workers, while valuable, are not replacements for direct occupational therapy intervention.
- The need for systems that are practical, clinically sensible and easier for families to navigate, particularly for Aboriginal and Torres Strait Islander families and families already experiencing significant disadvantage.
- The importance of listening to the experiences of frontline regional staff, clinicians and families when planning future reforms.
- The need to protect and retain experienced paediatric clinicians within the workforce, particularly in regional communities where recruitment is already extremely difficult.
- The importance of ensuring future reforms strengthen rather than unintentionally weaken the community-based services children and families rely on every day.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 469
Concluding Statement
I feel very privileged to work alongside children, families and clinicians within regional allied health services.
Every day I see how important these supports are for families who are often doing their very best under difficult circumstances.
I also see how much effort, coordination and commitment is required behind the scenes to keep these services operating in regional communities.
When the NDIS was introduced into regional areas such as ours, allied health providers were actively encouraged to expand services based on projected participant demand and the recognised shortage of supports available to families. Many practices invested heavily in staff, infrastructure, outreach services and workforce development in response to this need.
Only a relatively short time later, many of these same regional providers are now facing significant uncertainty about whether their services will remain viable under future reforms and funding changes.
The potential closure or destabilisation of small and medium allied health businesses would not only affect participants. It would also impact the many local families employed within these services and further reduce already limited workforce capacity in rural and regional communities.
I am deeply concerned that reforms intended to improve sustainability may unintentionally reduce access to the very relationship-based, flexible and community-connected services that have created meaningful long-term outcomes for children and families.
I respectfully ask that future reforms carefully consider the practical realities faced by children, families and regional providers, and the long-term importance of maintaining stable, relationship- based and community-connected services across rural and regional Australia.
Thank you for considering this submission.
Ariahne Poggioli
Date 26/05/2026
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