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Early intervention reduces future community & financial costs (Individual advocacy)

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Submission 507

24-May-26

TO: Senate Community Affairs Legislation Committee

RE: National Disability Insurance Scheme Amendment Bill 2026

Dear Committee Members

INTRODUCTION

I write as a paediatric and mental health occupational therapist with 33 years’ experience in the disability sector, and as someone who has worked alongside children, adults, families, and carers whose lives depend on the stability, fairness, and integrity of the NDIS.

I support reform that improves scheme sustainability, but I do not support reform that shifts the Scheme away from individualised, evidence-based decision-making and toward blunt administrative controls that reduce supports without adequate due process or regard to actual need.

The NDIS was established to provide reasonable and necessary supports based on disability related functional impact, not to ration assistance by formula or category.

THE VALUE OF THE NDIS

The NDIS should be understood as an investment with returns to participants, families, communities, and the economy. Publicly cited economic analyses have estimated that every $1 invested in NDIS support returns about $2.50 to the Australian economy, underscoring that support is not simply a cost line but part of the nation’s social and economic infrastructure.

This matters when considering legislative changes that may reduce support funding, because cuts that appear fiscally efficient in the short term, will increase downstream costs in health, crisis care, unpaid caregiving, and lost workforce participation – of both the participants themselves and their family.

EARLY INTERVENTION REDUCES FUTURE COMMUNITY & FINANCIAL COSTS

The evidence for early intervention is clear and should be protected in any reform agenda. The NDIA’s evidence review on early intervention for children with autism found positive outcomes across several intervention types. Benefits of early intervention have been shown to compound, so the cost to the Australian taxpayer is less as these participants’ capacity improves. Research on psychosocial disability also supports early intervention to improve function and reduce longer-term costs, rather than delaying support until needs become more complex and expensive.

Early intervention is particularly important because children do not grow out of unmet developmental need; they grow into it. When timely support is reduced or delayed, the result is often increased family stress, school difficulty, behavioural escalation, and later dependence on more intensive and costly services. For that reason, the Bill should be amended or interpreted in a way that protects early intervention as a core scheme principle rather than treating it as an optional discretionary extra. Cuts to the NDIS ECEI program cannot be reasonably made before new State run programs are clearly defined and in place.

Submission 507

DECISION MAKING & MINISTERIAL POWER

I am concerned about any legislative change that expands ministerial or administrative power to alter supports for groups of participants, or categories of supports, without full procedural fairness, transparent evidence, and meaningful review rights.

Where supports have already been assessed as reasonable and necessary, any system that allows broad reductions by policy instrument, formula, or administrative direction risks undermining the rights of participants and replacing individual assessment with budget management.

The Committee should be wary of any mechanism that can cut supports without a demonstrated individual reassessment process and without safeguards against unintended harm.

CLINICAL JUDGEMENT & DEFINING FUNCTIONAL CAPACITY

I am also concerned about the growing reliance on automated or overly standardised functional capacity processes that appear to discount the training, experience, and advanced clinical reasoning of occupational therapists and other health professionals.

Functional capacity cannot be validly reduced to a narrow data point or a generic algorithm when it should reflect the interaction between diagnosis, environment, cognition, mental health, executive functioning, motor skills, sensory needs, communication, and daily life demands.

Further, functional capacity cannot be reduced to a set of markers specific to one disability – this is often impacted by the interplay between two or more diagnoses and there is complexity in addressing these individualised needs that require expertise and experience. As highly regulated allied health professionals with high annual continuing education requirements, occupational therapists are uniquely placed to consider functional capacity and to provide assessment of this across the NDIS functional domains.

Likewise, the diagnostic contributions of paediatricians, psychiatrists, psychologists, speech pathologists, and other specialists should not be diluted merely because their findings are inconvenient to a funding reduction model.

SOCIAL AND COMMUNITY PARTICPATION & CAPACITY BUILDING SUPPORTS

The proposed reduction of supports such as social and community participation, and capacity-building supports, raises serious concerns about safety, mental health, and inclusion.

NDIA research on social inclusion shows that community access is linked to belonging, confidence, safety, and participation in ordinary life, including pathways to education and employment.

Arbitrary percentage cuts to supports that have already been measured as reasonable and necessary risk pushing participants into isolation, regression, crisis presentations, and

Submission 507

greater dependency on family members and service systems. In the long run, it is likely this will cost the Australian taxpayer more, leading to greater social costs around family breakdown as well as increased mental ill-health for both participants and their families.

MENTAL HEALTH & WORKFORCE IMPACTS

The impacts of reduced NDIS supports extend beyond the participant. Research on caregiver burden in Australian mental health contexts shows that families often carry substantial emotional and practical strain when support systems are inadequate, and informal caring research demonstrates the significant economic value of unpaid care that is too often invisible in policy decisions.

When a participant’s support is reduced, families frequently absorb the gap by cutting back paid work, increasing unpaid care, and living with higher stress and poorer mental health outcomes. This has direct consequences for workforce participation, financial security, and the sustainability of family life.

I urge the Committee to consider the safety of participants and their family members when making these changes.

CO-DESIGN & FOUNDATIONAL SUPPORTS

I am deeply concerned about the lack of genuine co-design and consultation in relation to the so-called foundational supports pathway.

Foundational supports are now being positioned as a major part of the broader disability reform architecture, but the Commonwealth’s agreement itself indicates that these supports are still being developed through bilateral agreements and implementation arrangements, including a first phase for “Thriving Kids” for children aged 8 and under with developmental delay and/or autism with low to moderate support needs.

In practical terms, many participants are being told they will be referred into supports that do not exist (yet), are not yet visible in their final form, and may not be available equitably across metropolitan, rural, and regional Australia.

This is especially concerning for people living in regional Victoria, where access to multidisciplinary services is already patchy, travel burdens are high, and workforce shortages are common.

A system that assumes foundational supports will be equally available everywhere, before the service model, workforce, commissioning, and referral pathways are settled, risks shifting people out of the NDIS and into an uncertain gap between systems.

The result will be greater disadvantage for children and families in rural and regional areas, not more choice or better integration. Any gaps will compound to impact costs for care of these individuals over the longer term.

Submission 507

WHAT THE COMMITTEE SHOULD PROTECT

I ask the Committee to recommend that the Bill:

  1. Preserves person-centred, individualised assessments and procedural fairness.

  2. Prevents broad reductions to whole groups or support categories without transparent evidence and review rights.

  3. Considers ongoing due process and with checks and balances in place to prevent ministerial over-reach, and that considers the safety and participation in ordinary daily living of participants at its centre.

  4. Requires that clinical evidence from qualified practitioners be given proper weight, especially around the expertise of occupational therapists that are uniquely positioned to conduct individualised assessment of functional capacity.

  5. Protects reasonable and necessary social, community, and capacity-building supports, considering the cost-benefit of these ($1 spent = $2.50 saved in long term).

  6. Ensures that foundational supports are fully designed, tested, funded, and available before participants are diverted into them. *Any cuts to early childhood early intervention funding must be delayed allowing for community consultation/co design, development and implementation of a nationally defined ‘Thriving Kids Initiative’.

  7. Ensures consultation and co-design with the disabled community that maintains the choice and control the NDIS was designed to enable.

  8. Ensures consultation with the key stakeholders that support them, including occupational therapists and OT Australia’s submissions to the Committee.

  9. Is mindful of equity of access for rural and regional communities, including Victoria.

CONCLUSION

A sustainable NDIS is not achieved by undermining the supports that prevent crisis, enable participation, and keep people and families connected to work and community. It is achieved by funding the right support, at the right time, for the right person, with proper safeguards and fair process. I urge the Committee to ensure this Bill strengthens the scheme without eroding the evidence-based, rights-based foundations on which it was built.

REFERENCES

  1. Australian Government Department of Health and Aged Care, 2026 amendments to the NDIS Act, 2026.

  2. Parliament of Australia, Senate Community Affairs Legislation Committee, National

Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations)

Bill 2026, inquiry page, 2026.

  1. National Disability Insurance Agency, Social inclusion and community access research, 2024.

  2. National Disability Insurance Agency, Evidence review: Early interventions for children with autism, 2024.

  3. Shields et al., Evidence-based early intervention support for psychosocial disability in the NDIS, 2018.

  4. Mental Health Australia, NDIS Capacity Building Project Papers, 2015.

  5. Australian mental health caregiver burden research, 2019.

  6. The economic value of informal mental health caring in Australia, Mind Australia,

Submission 507

  1. Commonwealth of Australia and State/Territory Governments, National Agreement on Foundational Supports, 2026.

  2. NDS, Government commitment to Foundational Supports, 2025.

  3. Rural Health Network / rural disability access material on rural and regional access issues.

  4. OT Australia. Thriving Kids Initiative – OTA Submission. May 2026.

  5. OT Australia. NDIS Rules: Public consultation on New Framework Planning – OTA Submission. March 2026.