Restrictions on reassessment create safety risks for people with neurological conditions (Provider experience)

Submission 566

Submission to the Senate Community

Affairs Legislation Committee

National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026

28 May 2026

I am an occupational therapist with 36 years working within the disability sector on the NSW Central Coast. I am also Director of Coast Rehab, an allied health service provider supporting people living with complex neurological and degenerative disabilities including spinal cord injury (SCI), motor neurone disease (MND), acquired brain injury (ABI), multiple sclerosis (MS), cerebral palsy (CP), and other progressive conditions.

I strongly support the concerns and recommendations raised by Occupational Therapy Australia and the “No OT, No NDIS” campaign.

My concerns relate specifically to proposed reductions to capacity building and community

participation  supports, the  increased use  of automated or  standardised assessment

processes, restrictions on reassessment flexibility, and the broader powers within the Bill that may enable future reductions to therapy and allied health supports.

In practice, these proposed changes place some of the most vulnerable people in our community at significant risk.

Community participation funding is not optional for many neurological participants. These supports enable people to safely access their community, maintain social connection, preserve routine, reduce isolation, and participate in meaningful life roles. Without these supports, many participants will become increasingly isolated, vulnerable, and dependent on acute health services. For people living with progressive neurological conditions, community participation is often directly linked to mental health, physical wellbeing, carer sustainability, and prevention of functional decline.

The proposed restrictions on reassessment are particularly concerning for participants with

degenerative or  fluctuating  conditions. Neurological conditions do not remain  static.

Functional deterioration can occur rapidly and unexpectedly. Delays in reassessment can create serious safety risks.

Submission 566

For example, participants with Motor Neurone Disease can change from independent or sit to-stand transfers to requiring full hoist transfers within a very short period of time (weeks to months). These changes require reassessment, equipment prescription, environmental modification, carer training, and increased support coordination. Restricting reassessment access to only “exceptional circumstances” fails to reflect the clinical reality of progressive disability.

I have also seen situations where delayed reassessment and inadequate funding directly contributed to hospitalisation. One participant developed a mild pressure injury while awaiting plan reassessment after funding exhaustion. Without timely OT intervention and home support implementation, the injury significantly deteriorated, resulting in hospital admission with a higher-grade pressure injury. The participant remains in hospital due to insufficient funding and supports available to safely manage the condition at home. Earlier intervention would likely have prevented both the hospital admission and the increased long term healthcare costs.

Similarly, we have supported participants with spinal cord injuries who were not allocated adequate funding to manage essential self-catheterisation needs. This is not a luxury support. It is a fundamental daily requirement for dignity, health, infection prevention, and basic human functioning. Situations like this demonstrate the danger of systems that rely too heavily on standardised frameworks or “tick-box” approaches that fail to account for real world clinical needs.

We have also seen participants with spinal cord injury need replacement wheelchair parts and repairs which are not factored into their plans (and considered ‘major repairs’ requiring a request to be submitted for funding). These people then have no mobility, or at risk of pressure injury or postural and functional loss while waiting for funding approval. The new system seems to ensure further delays.

I am deeply concerned about the Bill enabling increased reliance on automation, algorithms, and standardised assessment tools in funding and eligibility decisions. Human judgement and appropriately qualified allied health assessment are essential when working with complex

neurological  disability.  Functional  capacity cannot be  accurately understood through

standardised scoring systems alone. Clinical reasoning, environmental context, progression of disease, psychosocial impacts, carer capacity, and safety risks must all be considered together.

There are also significant workforce and sustainability concerns associated with the proposed reforms.

The disability sector is already experiencing considerable strain following the 2024–25 NDIS pricing and travel changes. Allied health providers delivering community-based neurological services are now performing the same travel and service demands while only receiving half the travel funding previously available. This has placed substantial financial pressure on

Peta Hardy Occupational Therapist | Submission – NDIS Future Generations Bill 2026

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Submission 566

providers, particularly small and medium multidisciplinary practices servicing regional and community-based participants. While we have a clinic at Coast Rehab, our clients with complex needs more often need in home services for assistive technology, carer training, home modifications services etc.

Without sustainable pricing and funding structures, the sector risks:

• increased clinician burnout;
• difficulty retaining experienced occupational therapists and neurological clinicians;
• reduced multidisciplinary collaboration;
• increased participant waitlists;
• reduced access to specialised neurological services;
• closure of smaller community-based providers; and
• consolidation of services into larger corporate models with reduced flexibility and continuity of care.

These reforms may ultimately reduce access to the very skilled workforce required to keep participants safe, independent, and living within the community.

Occupational therapy and allied health supports are not simply costs within the system. They are preventative, functional, and enabling supports that reduce hospital admissions, prevent injury, support carers, maintain independence, and improve long-term outcomes.

I urge Parliament to carefully consider the real-world consequences of these proposed reforms and adopt the recommendations put forward by Occupational Therapy Australia, including:

• ensuring functional assessments are conducted by appropriately qualified allied health professionals;

• prohibiting fully automated funding or eligibility decisions;

• retaining flexible reassessment pathways;

• reversing reductions to capacity building and community participation supports;

• protecting therapy supports from broad future funding reductions; and

• ensuring pricing reforms support a sustainable allied health workforce. The future sustainability of the NDIS cannot come at the cost of participant safety, dignity, independence, and access to essential therapy supports.

Thank you for the opportunity to provide this submission.

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Submission 566

Peta Hardy

Occupational Therapist

MAppScOT, BAppScOT

Reg. # OCC0001752712

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Submission 566

Peta Hardy – Occupational Therapist

BAppSc(OT),MAppSc(OT) Reg. # OCC000175712

Peta is the Founding Director of Coast Rehab. She is a registered Occupational Therapist and member of the Australian Occupational Therapy Association and ARATA (Australian Rehabilitation and Assistive Technology Association Inc). She has extensive experience working with adults and children with physical disability and neurological conditions and has a particular interest in assistive technology and Motor Neurone Disease. Peta has developed training workshops and presented at both state and national conference level and been published in the Australian Occupational Therapy Journal (May 2004).

Areas of clinical knowledge / experience include:

• Rehabilitation and disability (Progressive Neurological disorders, MND, MS, TBI, SCI, and CP)
• Functional Assessment including Care and Home Safety Reviews
• Upper limb function-fine motor skill development
• Daily Living Equipment prescription including Assistive Technology
• Wheelchair Seating & Mobility prescription
• SDA Assessment
• Powered wheelchair mobility training and program development
• Medico-legal assessment

Recent Presentations

Peta presented at the Australian Assistive Technology Conference (Gold Coast) Nov 2024. MND and AT - an overview of the scope of AT and issues associated with rural and regional service provision.

Verve OT Learning - Peta is a presenter offering the following self-paced learning Modules

Mobile Shower Commode Chairs

Sleep Tight: Selecting the Most Suitable Bed

EMPLOYMENT HISTORY

2005 -present Director Coast Rehab Coast Rehab provides allied health services to people with catastrophic injuries and disabilities. Services are provided in the home and include assistive technology assessment and prescription, minor home modifications, manual handling assessments and carer training. Peta leads multidisciplinary team including occupational therapists, physiotherapists, speech pathologists and dietitian.

2004 – 2010 SIA Rehab Medico-Legal Assessment and reporting

1/92-2004 Occupational Therapist. The Cerebral Palsy Alliance (Formally the Spastic Centre of NSW). Providing services to children and adults with cerebral palsy and allied neurological conditions. Skills include complex customised seating and mobility prescription, upper limb intervention (including splinting and casting), assessing handwriting and visual perception, and prescribing assistive technology. Preparation and presentation of training for external agencies.

7/97 - 11/97 Locum Tutor. The University of Sydney, Faculty of Health Sciences, School of OT.

Tutoring first year occupational therapy students as part of the occupational performance subject component (including upper limb muscle testing and orthotics).

1992 Locum Occupational Therapist. The Royal Institute for Deaf and Blind Children.

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