Concerns regarding functional capacity assessments for children with developmental delay, autism, and neurodivergence (Provider advocacy)

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission 522

Practical Concerns Regarding the National Disability Insurance Scheme Amendment (Securing the

NDIS for Future Generations) Bill 2026

I am writing as the Director of KiddOTherapy, a small paediatric occupational therapy service based in Western Sydney that supports children with developmental delay, autism and neurodivergent needs across clinic, home, preschool, school and community settings.

We understand the need to ensure the long-term sustainability of the NDIS and support measures that improve quality, consistency, safeguarding and reduction of fraud within the system. However, there is significant concern across the paediatric sector regarding the likely practical impacts of the proposed reforms on children, families and frontline services.

The Bill proposes substantial changes relating to eligibility, functional capacity assessments, planning processes and administrative decision-making. (NDIS) While consistency and sustainability are important goals, there is concern that some reforms may unintentionally reduce timely access to supports for children with developmental delay, autism and neurodivergent needs, particularly children with low to moderate functional support needs whose difficulties may fluctuate across environments and developmental stages.

In practice, many children do not present in simple or static ways. Functional capacity can vary significantly depending on sensory demands, communication supports, school expectations, emotional regulation, environmental stressors and family circumstances. There is concern that increasingly rigid eligibility thresholds or standardised assessment processes may not fully capture the day-to-day functional impacts experienced by many children and families. (Health, Disability and

Ageing Australia)

There is also concern regarding the increasing administrative burden on families, clinicians and providers. Many families are already navigating long waitlists, workforce shortages and complex service systems while trying to support their child’s participation, education and wellbeing. Additional reassessment requirements, changing evidence expectations and uncertainty regarding future eligibility may further increase stress and delay access to support.

For small paediatric providers, the current reform environment is creating significant operational uncertainty. Many private practices are already managing rising demand, workforce shortages, clinician burnout and increasing operational costs. Smaller community-based providers often deliver flexible and relationship-based services across homes, schools and early childhood settings, particularly in areas where larger systems have limited capacity.

If experienced private providers reduce services or become financially unsustainable, the impacts are likely to extend beyond individual businesses. Families may lose access to trusted therapeutic relationships and continuity of care. Schools and early childhood services may experience increased pressure supporting children with unmet developmental and behavioural needs. Waitlists across both public and private systems may continue to increase, particularly within regional and underserved communities.

0437 819 147 info@kiddOTherapy.com.au ABN: 45 643 549 482 www.kiddOTherapy.com.au

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission 522

There is also concern regarding the pace and scope of the consultation process. The Senate inquiry submission period is relatively short given the scale of the proposed legislative changes and the potential long-term impacts on people with disability, families and service systems. (Australian Parliament House) Meaningful consultation is particularly important where reforms may significantly alter access pathways, planning processes and future support models.

As a frontline paediatric provider, our concern is not opposition to reform itself. Reform is necessary. However, implementation must carefully consider the practical realities experienced by children, families, clinicians and communities.

Recommendations

We respectfully recommend that the Committee consider:

  1. Ensuring functional capacity assessments remain flexible, developmentally appropriate and capable of recognising the fluctuating and contextual nature of disability and neurodivergence in children.

  2. Maintaining timely access to early intervention and developmental supports during critical developmental periods.

  3. Reducing unnecessary reassessment and administrative burdens on families and clinicians.

  4. Improving consultation timeframes and engagement with people with disability, families, clinicians and community-based providers before implementing large-scale legislative changes.

  5. Considering the potential impacts of reforms on workforce sustainability, provider viability and service accessibility, particularly within regional and underserved communities.

  6. Recognising the importance of continuity of care, therapeutic relationships and flexible community-based supports for children and families.

  7. Monitoring the long-term impacts of reforms on children’s participation, education engagement, mental health, independence and future workforce participation.

Thank you for the opportunity to provide this submission and share concerns from frontline paediatric service delivery experience.

KiddOTherapy

Western Sydney, NSW

0437 819 147 info@kiddOTherapy.com.au ABN: 45 643 549 482 www.kiddOTherapy.com.au