Submission 533
Submission to the Senate Community A1airs
Legislation Committee
Inquiry: National Disability Insurance Scheme Amendment (Securing the
NDIS for Future Generations) Bill 2026
Submitted by: Olga Komadina – Speech Pathologist (B Health Sc (Speech Path), CPSP)
Director, Olga Komadina Apraxia Therapy (Albury–Wodonga region)
- Introduction and purpose I am a paediatric speech pathologist with extensive experience supporting children with Childhood Apraxia of Speech (CAS), autism, and complex communication needs. I am making this submission because the proposed legislative changes intended to “secure the NDIS for future generations” must not unintentionally exclude or under support children with severe communication disability, particularly those with CAS, who require specialised, intensive, individualised intervention over extended periods.
The Committee has asked that submissions directly address the provisions of the Bill; I therefore focus on how the Bill’s themes, clarifying eligibility and funded supports, changing administrative arrangements, and related reform settings, could aPect children with severe motor speech disorders, and what safeguards are needed.
- Why CAS must be specifically protected in NDIS legislation and implementation
Childhood Apraxia of Speech (CAS) is not a simple speech delay. It is a complex motor planning disorder that requires intensive, individualised, motor-based therapy delivered by trained speech pathologists with specific expertise.
Olga Komadina | Speech Pathologist | Olga Komadina Apraxia Therapy Albury–Wodonga, VIC | 1Submission 533
Children with CAS cannot participate meaningfully in generic or group-based therapy programs. They require frequent, one to one intervention, often multiple times per week over several years, to achieve functional speech outcomes. This level of support is significantly higher than for many other communication needs and cannot be substituted with lower intensity or generalised approaches.
CAS is also frequently misunderstood in broader systems, increasing the risk that children are directed into inappropriate service pathways that do not meet their needs.
- Clinical reality: intensity and duration are not optional for severe CAS A central policy risk is that reforms intended to standardise, cap, or constrain supports may treat speech therapy as a uniform, time limited input. That assumption does not hold for severe CAS.
Children with CAS often require 2–4 sessions per week, particularly in early and severe stages, and may require this intensity for extended periods to achieve functional speech.
This has direct relevance to the Bill’s intent to clarify eligibility and funded supports. If implementation settings narrow what is considered fundable, or apply cohort-based constraints that do not reflect clinical reality, the children most at risk of lifelong communication disability are the ones most likely to lose out.
- Lived experience case example illustrating the impact of delayed access
In my clinical work, I have seen the impact when appropriate therapy is not available early.
For example, I worked with a client whose experience was publicly shared through national media. This individual missed access to appropriate, intensive therapy for many years. As a result:
- communication development was significantly delayed
- opportunities for participation and learning were significantly reduced
- intervention became more complex and prolonged in adolescence Their story reflects a broader pattern:
When children miss early access to intensive, evidence based intervention for CAS, the result is years of frustration, exclusion, and missed opportunities that could have been prevented.
While progress is still possible later, outcomes are markedly diPerent compared to children who begin therapy early (for example, at ages 2–3), many of whom go on to develop clear, natural speech and participate fully in education and social settings.
Olga Komadina | Speech Pathologist | Olga Komadina Apraxia Therapy Albury–Wodonga, VIC | 2Submission 533
Without access to NDIS funded therapy, most families cannot aPord the level of intervention required.
- Additional evidence of therapy outcomes (video demonstration) In addition to written clinical evidence, I have also documented therapy progress across multiple children with Childhood Apraxia of Speech (shared with appropriate consent) through publicly available educational video material. These examples demonstrate how children can progress from limited or absent speech to functional communication over time. These outcomes are not spontaneous, they are the result of sustained, intensive, specialist intervention, and would not occur without access to appropriate NDIS funded supports.
A publicly available example demonstrating these outcomes can be viewed here
- The false economy of replacing specialist therapy with generic or group programs
One of the most common “ePiciency” approaches within service systems is shifting children into group delivery or generic programs.
Group settings can be highly valuable for social connection, participation, and skill generalisation in appropriate populations. However, when complex motor speech disorders such as CAS are involved, individual therapy is not optional.
Generic or group-based approaches for children with severe CAS are unlikely to produce meaningful progress. This results in:
- wasted funding on inePective interventions
- delayed or missed communication development
- increased behavioural distress and educational barriers
- greater long term support needs This is not a cost saving. It is a cost shift to future systems.
-
ARordability and equity Even if Medicare rebates for speech therapy were increased, most families would still be unable to aPord the level of therapy required for severe CAS.
Olga Komadina | Speech Pathologist | Olga Komadina Apraxia Therapy Albury–Wodonga, VIC | 3
Submission 533
Without NDIS funded access to intensive intervention, children with severe communication needs will continue to fall through the cracks.
This is a fundamental equity issue: access to communication should not depend on a family’s capacity to privately fund high frequency therapy.
- Recommendations To ensure children with severe communication disability are not unintentionally excluded or under supported under the Bill’s reforms, I recommend:
A. Protect access for severe communication disability within eligibility and support decisions Ensure that children with conditions such as CAS are recognised as having significant functional impairment even where disability is not visually obvious.
B. Protect therapy intensity where clinically required Ensure the scheme continues to fund high frequency, individualised therapy when clinically justified.
C. Do not default severe cases into group models Avoid implementing system settings that substitute specialist individual therapy with generic group programs for high needs cohorts.
D. Safeguard continuity of supports Ensure that support is based on functional need over time, not arbitrary review cycles or assumptions about developmental timelines.
E. Preserve access to specialist providers Ensure reforms do not inadvertently reduce access to experienced clinicians, particularly in regional areas.
- Conclusion The NDIS has the capacity to change the entire life trajectory of a child with severe communication disability.
Childhood Apraxia of Speech is a clear example of a condition where the right therapy, delivered at the right intensity, can be remarkably ePective, but where delayed or inadequate intervention can result in years of avoidable disadvantage.
If this Bill is to secure the NDIS for future generations, it must explicitly protect the children who depend on intensive, specialist support to gain a voice.
Olga Komadina | Speech Pathologist | Olga Komadina Apraxia Therapy Albury–Wodonga, VIC | 4Submission 533
Signed
Olga Komadina
Speech Pathologist | DirectorOlga Komadina Apraxia Therapy
Olga Komadina | Speech Pathologist | Olga Komadina Apraxia Therapy Albury–Wodonga, VIC | 5