Submission 547
26th May 2026
Practical Concerns Regarding the National Disability Insurance Scheme Amendment (Securing the
NDIS for Future Generations) Bill 2026
I am the owner of a small private paediatric allied health practice supporting children and families accessing the NDIS, primarily neurodivergent children and children with developmental disabilities, sensory processing differences, emotional regulation difficulties and complex support needs.
Much of our work involves supporting children to participate safely in daily life, education, self-care, communication, emotional regulation and family routines. Many of the families we support are already under significant stress and are managing long waitlists, workforce shortages, school challenges and limited informal supports. Being able to manage a small business alongside my own neurodivergent children’s lives allows me the unique ability to connect, relate and understand the on the ground practical and functional challenges of parenting, school and accessing services within my region and via telehealth. I have worked on both sides of the fence as an educator in schools, teacher and therapist trainer in many countries, in an advocacy and public health capacity and as an on the ground Occupational therapist visiting communities, homes, schools and local spaces together with my participants and their support teams.
I appreciate the need for long-term sustainability of the NDIS and agree that fraud and inappropriate claiming should be addressed. However, I am concerned that several measures in the proposed Bill may create unintended consequences for participants, families, therapists and small community based providers.
In practice, many of these changes are likely to reduce flexibility, delay access to quality supports and increase administrative burden at a time when the sector is already under strain.
One significant concern is the proposed definition of functional capacity, particularly the requirement to assess a person’s ability without supports, assistive technology or environmental modifications.
For many neurodivergent children, functional capacity is highly dependent on environment, sensory supports, routines, trusted relationships and co-regulation. A child may appear capable in a highly supported environment but become unable to participate safely or consistently without those supports in place. We know that our Autistic girls mask and camouflage at school to appear to be coping to unravel when they complete school which sets them up for long term mental health challenges and reduced capacity. This is not picked up on face to face assessments and only those in which they feel safe with can truly understand their days spent in the cycle of fight, flight and fawn… repeat.
Submission 547
Removing environmental and relational context risks underestimating real-world disability impact. It may disadvantage children with autism, PDA profiles, developmental delay, sensory processing difficulties and fluctuating regulation needs whose challenges are not always visible in brief assessments and who will change as quickly as their routine’s changes. A new school year, teacher, inconsistent teacher, challenging family dynamics, breakdown in a trusted support. Every change and transition causes significant distress for our neurospicy population.
There is also concern that this approach may unintentionally discourage early intervention and preventative supports. In paediatric practice, low-cost early supports often prevent later escalation into school refusal, family breakdown, mental health presentations, restrictive practices or crisis responses. These supports are often flexible, practical and relational in nature rather than highly medicalised.
The proposed tightening of reassessment processes is another major concern.
While it is reasonable to discourage unnecessary reassessments, children’s developmental needs can change rapidly. Functional impacts often emerge when school demands increase, family circumstances change or developmental expectations shift. Many changes are gradual but still clinically significant.
The proposed requirement for a “significant and ongoing” change before reassessment may create barriers for families seeking timely adjustments to supports.
In practice this may mean:
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children waiting extended periods without appropriate supports
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increased stress on families and carers
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schools managing escalating behaviours without adequate assistance
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increased emergency presentations and crisis responses
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children losing access to education and community participation while waiting for reassessment decisions
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families in crisis often resulting in separations, loss of employment and further poverty and reliance on governmental supports
The extension of reassessment decision timeframes from 21 days to 90 days is also likely to create practical difficulties for families already struggling to maintain supports.
For children, three months is a significant period developmentally. Delays in accessing therapy, equipment, sensory supports or school-related assistance can have lasting impacts on participation and regulation.
There are also likely impacts on workforce sustainability and provider viability, particularly for small private practices and regional services.
Small allied health businesses are already managing:
- increasing administrative requirements
- workforce shortages
- high report-writing demands
Submission 547
- rising operating costs
- workforce burnout
- long waitlists. Additional compliance complexity, tighter reassessment thresholds and uncertainty around support approvals may further reduce sustainability for small providers who deliver community-based early intervention and family-centred supports.
This is particularly concerning in regional and rural areas where service options are already limited. If smaller providers reduce services or close, families may have no realistic alternative support available locally.
I am also concerned about the proposed strengthening of the requirement that supports arise “directly” from impairments.
In paediatric disability practice, functional difficulties are often interconnected. Emotional regulation, sensory processing, school participation, communication, fatigue, behaviour and family functioning frequently overlap. It is rarely clinically simple to separate supports into narrow categories.
There is a risk that practical and preventative supports may become harder to justify despite being highly effective in maintaining participation and reducing long-term costs to the Scheme and broader community.
Many families already struggle to navigate complex systems. Increasing thresholds and administrative barriers may unintentionally advantage families with greater advocacy capacity while disadvantaging those experiencing poverty, burnout, language barriers or social isolation.
Over time, reduced access to timely supports is likely to increase pressure on:
- schools
- emergency departments
- mental health systems
- child protection services
- informal carers and extended family networks. It may also reduce long-term educational participation, independence and employment outcomes for children currently benefiting from early intervention and community-based supports.
Practical Recommendations
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Retain stronger recognition of environmental, sensory and relational factors in assessments of functional capacity for children and neurodivergent participants.
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Ensure assessments are undertaken by neuroaffirming specialists to so that they do not add to the trauma this population is already experiencing due to the systems they are required to participate in that do not support their sensory, learning and functioning needs.
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Ensure reassessment criteria allow flexibility for developmental change, emerging functional impacts and preventative early intervention.
Submission 547