Submission 526
Submission to the Senate Community Affairs Legislation Committee
National Disability Insurance Scheme Amendment (Securing the NDIS for
Future Generations) Bill 2026
To the Committee,
I am the Director/Practice Manager of a small allied health business based in regional Queensland. Our clinic provides Occupational Therapy and Mental Health services across Townsville, Ingham, Charters Towers and surrounding regional areas. The majority of our clients are NDIS participants, including children and adults with autism, ADHD, psychosocial disabilities, physical disability, intellectual disabilities, trauma backgrounds, neurological conditions and other complex support needs. I am writing to express my concerns regarding several provisions within the National
Disability Insurance Scheme Amendment (Securing the NDIS for Future
Generations) Bill 2026 and the likely impacts these changes will have on small allied health providers, regional service delivery, families and NDIS participants. While I understand the importance of ensuring the long-term sustainability of the NDIS, I am deeply concerned that many of the proposed amendments prioritise cost reduction and administrative control over individualised participant support and real world disability needs. Repeal of Section 31 – Participant Directed and Individualised Planning I am extremely concerned about Item 66 of Schedule 1, which repeals section 31 of the NDIS Act. As a provider working directly with participants every day, I believe this section is fundamental to maintaining genuinely individualised and participant-directed planning. No two participants are the same, even if they share the same diagnosis. In practice, we regularly see participants with identical diagnoses who function differently depending on their emotional regulation, executive functioning capacity, family supports, trauma history, school or home environment, fatigue levels, sensory needs and mental health. The removal of section 31 creates concern that participant plans will become increasingly standardised and financially driven rather than genuinely tailored to the individual. As a small allied health business, we are worried this will reduce clinician input, reduce flexibility and create more rigid support models that fail to account for the complexities we see every day in clinical practice.
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Submission 526
Proposed Section 34A – Ministerial Funding Reduction Powers
I am deeply concerned about proposed section 34A, which would allow broad percentage-based reductions to participant funding categories for reasons relating to “financial sustainability”. From a provider perspective, this creates enormous uncertainty for both businesses and participants. Our clinic already sees families struggling to maintain access to therapy due to limited funding, rising living costs and increasing support needs. If broad reductions are applied to therapy supports, social participation supports or maintenance supports without proper individual reassessment, many participants will simply lose access to services that are keeping them stable and functioning safely. Occupational therapy is not just about improving skills. In many cases it prevents deterioration, supports emotional regulation, assists with school participation, reduces family breakdown and helps participants maintain independence and community engagement. Reducing these supports may appear to reduce NDIS expenditure short term, however it risks increasing long-term pressure on hospitals, mental health systems, schools, child safety systems and unpaid carers. As a small regional provider, sudden funding reductions also threaten workforce stability and service viability. Regional allied health businesses already face workforce shortages, increasing operational costs and difficulty recruiting clinicians. Greater funding instability may result in providers reducing services or being unable to continue servicing regional areas.
Proposed Section 9B – Functional Capacity Assessments
I am also concerned regarding proposed section 9B and the narrowing of how functional capacity is assessed. The proposed model appears to separate a participant from their supports, assistive technology, environmental factors and real-world circumstances. In practice, this is not how disability works. Many participants appear capable within short, structured assessments but cannot sustain that functioning safely across everyday life. We regularly work with participants who mask symptoms during appointments, particularly autistic children, participants with psychosocial disabilities and participants with trauma backgrounds. Others may technically complete a task once in an assessment setting but cannot consistently complete it independently within real-world environments such as school, work or home settings.
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Submission 526
This concern is particularly significant for participants with invisible disabilities, fluctuating conditions, executive functioning impairments and psychosocial disabilities whose difficulties are often underestimated in highly standardised assessment systems. I am worried these proposed changes will result in many participants appearing “not disabled enough” on paper while still struggling significantly in their everyday lives. Permanence and Treatment Requirements – Items 88–94 I have serious concerns regarding Items 88–94 relating to permanence and treatment requirements. As a regional provider, we already see major barriers for participants trying to access specialists, diagnostic services and supporting evidence. Many of our clients wait months or years for paediatricians, psychiatrists or specialist assessments. Some families cannot financially afford repeated specialist appointments, reports or ongoing reassessments. The proposed amendments appear to increase pressure on participants to pursue ongoing treatment or repeatedly prove permanence before they can access support. I worry this will disproportionately disadvantage regional participants, low-income families and participants with complex or invisible disabilities. Some participants also choose not to pursue certain treatments due to trauma history, side effects, previous negative experiences or personal choice. Participants should not risk losing access to support because they decline particular treatments or interventions. This is not allowing participants ‘choice and control’.
Reassessment and Suspension Powers
I am also concerned regarding the expanded reassessment and suspension powers within the Bill. Many NDIS participants already struggle navigating complex administrative systems due to cognitive impairments, executive functioning difficulties, mental health challenges, communication barriers or periods of deterioration. Within our clinic we regularly support families who miss emails, struggle completing paperwork, become overwhelmed by administrative requirements or experience periods where simply managing day-to-day life is difficult. The proposed suspension powers create concern that vulnerable participants may lose supports not because they no longer need them, but because they cannot successfully manage increasingly complicated administrative requirements.
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Submission 526
For participants already in crisis, suspension of supports can lead to further deterioration, school refusal, family breakdown, mental health decline or hospitalisation.
Automation and Standardised Planning
I am deeply concerned about the increased use of automation, algorithmic decision making and standardised planning models proposed throughout the Bill. As clinicians, we know disability cannot be properly understood through purely standardised systems. Many of the participants we support have highly complex presentations involving overlapping disabilities, trauma histories, fluctuating mental health, behavioural concerns, sensory regulation difficulties and family stressors that cannot be accurately captured through rigid assessment models or automated systems. I worry that increasing reliance on standardised budgeting and automated processes will reduce clinical discretion, reduce participant voice and lead to more participants falling through the gaps.
Parenting, Informal Supports and Family Sustainability
I am particularly concerned regarding the proposed changes relating to parental responsibility, informal supports and the increasing expectation that families will absorb greater caring responsibilities when funded supports are reduced or unavailable. As an allied health provider with a high percentage of paediatric clients, we already work with families operating well beyond what would reasonably be considered ordinary parenting responsibilities. One example from our clinic involves a single mother caring for a child with Autism Spectrum Disorder Level 3 alongside additional disabilities and highly complex behavioural and support needs. The child requires constant 1:1 supervision for their safety and the safety of others. Within our clinic environment, the child cannot safely be left unsupervised due to significant risks of absconding and unsafe behaviours, including running toward roads and unsafe environments. The local mainstream school has determined that they can only safely accommodate the child for approximately one hour per day, at times selected by the school, and only if the mother remains onsite for the entire duration. The local autistic school is currently at capacity and unable to offer placement but even if they could the family would be unable to afford the exorbitant fees. As a result, this mother is effectively unable to maintain employment due to the level of supervision and care required 24 hours a day.
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Submission 526
Despite the severity of the child’s needs, the family does not receive formal in-home supports and has limited funded supports available. The family carefully spaces Occupational Therapy appointments to fortnightly sessions, not because this meets the child’s therapeutic needs, but because the mother is attempting to stretch inadequate NDIS funding across the full plan period and across multiple required therapies. This family is already functioning at the absolute limit of what is sustainable. The proposed legislative changes create significant concern that increasing reliance on “informal supports” and parental responsibility will place even greater pressure on families already experiencing extreme burnout, financial stress and social isolation. In cases such as this, there is no realistic capacity for the parent to “do more” or absorb further reductions in support. If allied health supports, capacity-building supports or community supports are reduced under broader funding reduction measures, the likely outcome is not increased independence or sustainability. The likely outcome is family collapse, mental health deterioration, increased child protection involvement, crisis presentations and greater long-term reliance on emergency and government systems. As a provider, I am deeply concerned that the proposed reforms fail to recognise the reality that many parents of children with severe disabilities are already providing care far beyond what would normally be expected of a parent, often without respite, without adequate support and without the ability to maintain employment or financial stability. These families are not asking for luxury supports. They are asking for enough support to safely survive day to day.
Conclusion
As a small allied health business working directly with vulnerable participants and families every day, I strongly believe these proposed legislative changes risk moving the NDIS away from its original purpose of providing individualised, participant centred support. While sustainability is important, sustainability should not come at the expense of flexibility, human rights, participant safety and genuine consideration of individual circumstances. The participants we support are not numbers on a spreadsheet. They are children struggling to remain engaged in school, exhausted parents trying to keep their families functioning, adults attempting to maintain independence and vulnerable people relying on these supports to safely participate in their communities.
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Submission 526
I urge the Committee to reconsider these proposed amendments and ensure that any reforms to the NDIS continue to protect individualised supports, participant dignity and access to essential services. Thank you for considering my submission.
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