Allied health workforce sustainability linked to NDIS scheme (Provider advocacy)

Submission 583

Submission to the National Disability Insurance Scheme (NDIS) Amendment

(Securing the NDIS for Future Generations) Bill 2026

Introduction

Professionals Australia represents allied health professionals and related practitioners

across Australia, including Occupational Therapists, Speech Pathologists,

Physiotherapists, Psychologists, Social Workers, Exercise Physiologists, Dietitians,

Behaviour Support Practitioners, Music and Creative Therapists, Equine Therapists,

Disability Support Coordinators, and Interpreters, including AUSLAN Interpreters.

These professionals deliver therapeutic, behavioural, developmental, psychosocial, and capacity building supports funded through the NDIS, often to participants with complex needs, communication barriers, trauma histories, or limited access to mainstream services (National Disability Insurance Agency [NDIA], 2023; Australian Institute of Health and Welfare[AIHW], 2022; Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, 2023). Our members work predominantly as sole traders, small and medium practice owners, not-for-profit providers, and clinicians embedded within community-based services. They interact daily with NDIA planners, payment systems, compliance mechanisms, and safeguarding frameworks, and experience firsthand the practical consequences of administrative and regulatory decisions made under the Scheme.

The allied health and community disability workforce constitutes a critical component of Australia’s social infrastructure. Therapeutic, psychosocial, behavioural, and capacity building supports delivered under the NDIS are not ancillary services; they are central mechanisms through which participants maintain safety, functional capacity, communication, emotional regulation, social participation, education engagement, employment readiness, and independent living capacity. The sustainability of the Scheme is therefore intrinsically linked to the sustainability of the workforce responsible for delivering these supports.

There is increasing concern across the sector that current reform approaches risk conceptualising allied health and community participation supports primarily as expenditure liabilities rather than medium and long-term social and economic investments. Such an approach may unintentionally undermine the preventative architecture of the NDIS by shifting costs into more acute and crisis-driven service

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systems, including public hospitals, mental health services, child protection systems, homelessness responses, aged care, and the justice system.

This submission responds to the proposed National Disability Insurance Scheme (NDIS) Amendment (Securing the NDIS for Future Generations) Bill 2026 and the broader reform agenda currently being implemented across the NDIS. While there is broad recognition that the NDIS must remain financially sustainable and protected from fraud, waste, and market instability, these reforms must also preserve the original intent and foundational principles of the Scheme: supporting the rights, inclusion, independence, and participation of people with disability (NDIA, 2026; Department of Social Services, 2023).

Disability support should not be viewed solely through a fiscal lens. International evidence consistently demonstrates that early intervention, therapeutic supports, community participation, and culturally safe services reduce long-term expenditure across health, housing, justice, and crisis systems (Productivity Commission, 2011; United Nations, 2006; World Health Organization, 2022). Australia also has obligations under the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD), which recognises the rights of people with disability to full participation, inclusion, autonomy, and access to supports that enable equal participation in society. These principles are further reinforced through Australia’s Disability Strategy 2021–2031 and Closing the Gap commitments, both of which emphasise equity, inclusion, cultural safety, and self-determination for Aboriginal and Torres Strait Islander peoples (Commonwealth of Australia, 2021, 2023).

Professional Australia’s previous Submission to the National Disability Insurance

Scheme Amendment (Integrity and Safeguarding) Bill, 2025

Professionals Australia notes that many of the concerns raised in this submission are consistent with issues identified in our previous submission to the Inquiry into the

National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Bill

2025. In our Submission, Professionals Australia emphasised that safeguarding, integrity, and long-term sustainability cannot be achieved solely through compliance expansion, restrictive administrative controls, or cost containment measures. Rather, the sustainability of the Scheme depends upon:

• a stable and skilled allied health workforce;
• continuity of therapeutic relationships;
• culturally safe and accessible service systems;

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• participant autonomy and procedural fairness;
• effective market stewardship; and
• early intervention and preventative supports. Professionals Australia remains concerned that reforms implemented without adequate consideration of these factors risk increasing long-term social and economic costs while reducing participant safety, independence, and inclusion. This Submission should therefore be read alongside our previous recommendations regarding procedural fairness and review rights; risks associated with overly compliance-heavy regulation; workforce instability and provider withdrawal; safeguarding impacts in thin markets; the importance of allied health continuity and support coordination; the risks associated with automated and standardised decision-making; and the need for culturally safe and participant-centred reform implementation. Allied health businesses currently co-ordinate across disciplines to provide quality, holistic and integrated care for people with disabilities.

Overview of the Proposed Legislative Changes

1. Tightening eligibility, access and “permanence” The proposed NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 introduces very substantial changes to participant eligibility, assessment processes, and administrative powers. These reforms represent a significant shift in how disability, functional impairment, and support needs may be interpreted within the Scheme.

The Explanatory Memorandum states that the reforms are intended to improve consistency, ensure the Scheme remains financially sustainable, and clarify access requirements for participants with permanent impairment. Professionals Australia supports the objective of consistency and sustainability. However, the practical operation of the proposed reforms may unintentionally disadvantage participants who experience barriers accessing healthcare, diagnostic pathways, and specialist intervention. Key proposed Legislative changes include:

• Requiring individuals to demonstrate that they have exhausted “all appropriate treatment options” prior to being able to make an access request to the NDIS;

o Including removing provisions for families and participants who are unable to afford services, assessments, and treatment; lack of available and accessible services due to geographical isolation.

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• A narrower interpretation of “permanent impairment”;

• Expanded reassessment powers for existing participants;

• Increased use of standardised assessments and administrative decision-making tools; and

• Broader ministerial authority in determining pricing, operational rules, and support classifications (Department of Health and Aged Care, 2026; Department of Social Services, 2023).

Professional Australia’s Concerns:

While these reforms are framed as mechanisms to improve consistency and sustainability, there is substantial concern that they may create unintended barriers for many participants, particularly those whose disabilities do not fit neatly within rigid medical or functional frameworks.

The requirement to exhaust “all appropriate treatment options” prior to eligibility is particularly concerning. This approach assumes that treatment pathways are universally available, affordable, culturally safe, and clinically appropriate. In practice, many people with disability, particularly those who reside in rural and remote communities, experience significant barriers in accessing specialist healthcare, allied health services, diagnostic assessments, and long-term treatment supports (AIHW, 2024; Australian Medical Association, 2024).

Clinical Practice Example A

A child living in remote Queensland is referred for autism and developmental assessment following significant communication and behavioural concerns identified at school. The family is placed on a 24-month public waitlist for paediatric assessment and cannot afford private assessment costs exceeding several thousand dollars.

Under a stricter interpretation requiring exhaustion of treatment options prior to NDIS eligibility, the child may be considered ineligible despite clear evidence of functional impairment because the healthcare system itself has failed to provide timely access to diagnostic and therapeutic pathways.

During this period the child and their family experience:

• An escalation in communication difficulties;

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• School disengagement increases;
• Behavioural incidents intensify;
• Parental workforce participation reduces; and
• Family stress significantly increases. The eventual costs to education, mental health, and family support systems may substantially exceed the cost of earlier therapeutic intervention (Productivity Commission, 2011; OECD, 2022).

A. The Structural Inequity of “Treatment Exhaustion” The requirement to exhaust “all appropriate treatment” assumes that healthcare pathways are universally available, affordable, timely, and culturally safe. In clinical reality, waitlists for public paediatric developmental clinics and child health networks across Australia routinely exceed 12 to 18 months, with rural and remote waitlists often stretching beyond two years (AMA, 2024; Harding et al., 2022). This is likely to increase should demand be increased due to these NDIS changes.

Forcing families to wait out public health backlogs before granting NDIS access will catastrophically delay crucial early intervention. Decades of peer-reviewed research confirms that delayed therapeutic intervention during critical neurodevelopmental windows leads to permanent functional deficits, escalating long-term support costs (Productivity Commission, 2011; WHO, 2022).

B. Pressuring Families into Inaccessible, Burdensome Interventions For neurodevelopmental conditions and mental health-related impairments, this clause is exceptionally punitive. These impairments are lifelong. While clinical treatments and therapies are essential to improve daily functioning, teach compensatory strategies, and support self-regulation, they do not “cure” or remove the underlying disability.

Under the proposed Bill, families will be pressured to pursue costly, physically exhausting, or geographically inaccessible interventions simply to generate the administrative paperwork required to prove their child’s impairment is permanent. This places a disproportionate burden on low-income families and those living in regional and remote areas where specialists do not exist. It is purported to reduce the burden of seeking diagnosis to gain access to NDIS services, which has been falsely stated as

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necessary, but places an equally heavy, if not heavier, burden on the person and their family or carers.

C. Disproportion Impacts on First Nations Participants and Families For First Nations peoples, barriers may be even more pronounced due to limited access to culturally safe healthcare services; shortages of specialists in regional and remote communities; systemic distrust arising from historical and ongoing discrimination; and the mismatch between Western medical frameworks and culturally informed understandings of disability and wellbeing (Lowitja Institute, 2023). Consequently, requiring evidence that all treatment avenues have been exhausted risks creating structural inequity within the Scheme. Individuals may effectively be excluded from the NDIS not because their disability is absent, but because the healthcare system itself has failed to provide accessible treatment pathways.

In addition, the proposed reforms may disproportionately affect:

• Neurodivergent participants;

• People with psychosocial disability;

• Individuals with fluctuating conditions such as multiple sclerosis or chronic mental illness;

• People with degenerative neurological conditions;

• Rural, remote and discrete participants; and

• First Nations and CALD communities with limited access to specialist supports.

2. Standardised Assessments and Administrative Decision Making The Explanatory Memorandum identifies standardised assessments as a mechanism to improve consistency and equity in planning decisions. While consistency is important, disability presentation is highly contextual and cannot always be accurately captured through standardised functional tools alone. Functional capacity, participation, environmental barriers, and social inclusion must therefore remain central considerations in determining support needs. Decision making needs to involve Suitably Qualified and Experienced Personnel (SQEP). Generally decisions must be

Submission 583

made by SQEP, and making out of scope decisions opens personnel up to legal liability which is not covered by professional indemnity insurance should it be challenged.

Clinical Practice Example A

An Aboriginal participant with acquired brain injury attends a functional assessment conducted through a highly structured interview process. The participant demonstrates minimal verbal engagement due to:

• cultural communication differences;
• historical distrust of government systems;
• trauma-related responses; and
• anxiety within formal assessment environments. A standardised assessment tool may inaccurately conclude that the participant has lower support needs than are observed by local clinicians and family members in everyday environments. This creates substantial risk of underfunding and inappropriate planning outcomes.

There is also concern regarding increasing reliance on standardised assessments and administrative decision-making. While standardisation may improve administrative consistency, it risks oversimplifying the complexity of disability, particularly where support needs fluctuate or are influenced by social, cultural, environmental, and relational factors. Disability cannot be understood solely through a narrow medical model focused on diagnosis and permanence. Contemporary disability policy, including the social model of disability and the UNCRPD, recognises that disability arises through the interaction between impairment and societal barriers (United Nations, 2006). These assessor changes do not follow best practice and evidence based practice.

A. The Risk of Utilising Non-Clinical Assessors Furthermore, replacing qualified allied health and medical professionals with non clinical staff to conduct disability assessments threatens participant safety and misaligns funding from actual functional need.

The Disability Royal Commission explicitly highlighted the catastrophic outcomes that occur when individuals with cognitive and developmental disabilities are assessed or managed without adequate allied health intervention.

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Evidence presented to the Royal Commission showed that a lack of specialised allied health assessment puts individuals with cognitive disabilities at extreme risk of preventable physical harms, including recurrent falls, rapid health deterioration, and premature death due to unmanaged communication and swallowing difficulties (dysphagia) (Hogan & Watt, 2024).

Non-clinical staff are entirely unequipped to screen for, diagnose, or understand the severe health implications of secondary conditions like dysphagia, communication barriers, assistive technology, or complex sensory profiles. Allowing non-clinicians to dictate support budgets effectively silences the multi-disciplinary allied health expertise required to prevent systemic harm and premature death among vulnerable participants.

Government frameworks that position non-clinical assessors as independent decision makers violate established healthcare safety models. Non-clinical staff do not possess the university-level qualifications or regular professional development mandates enforced by national regulatory bodies like the Australian Health Practitioner Regulation Agency (AHPRA) or self-regulating professions. Elevating them to autonomous assessment roles compromises service quality and participant safety.

Research demonstrates that validly capturing functional impairment requires rigorous, credentialed professionals utilising psychometrically sound, standardised tools (Guthrie et al., 2024).

Non-clinical staff lack the specialized tertiary training and professional credentialing required to accurately administer and interpret complex functional tools. Without this clinical expertise, assessments degrade into subjective or heavily constrained administrative tasks.

Integrative reviews on the utilisation of support workforces emphasise that non qualified staff can improve service capacity, but only under the direct guidance and delegation of fully qualified Allied Health Professionals (Llewellyn et al., 2025). Standardised algorithms or administrative needs-assessments administered by non clinicians inherently lean into financial containment rather than functional reablement.

Allied Health Professionals also have ingrained ethical systems and values around diagnosis, intervention and management of participant needs. These are taught from early on in university studies and reinforced throughout the Allied Health Professionals’ studies and career, through ongoing professional development, and supervision. They are integral to Clinical Governance models used within Allied Health companies and

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businesses. These are essential in appropriately managing diagnostic and management processes for people with disability.

3. Permanence and Functional Stability The proposed narrowing of “permanence” may create significant uncertainty for participants with conditions that are lifelong yet variable in presentation. Many psychosocial, neurological, and developmental disabilities do not follow linear or predictable trajectories. Participants may experience periods of improvement alongside ongoing vulnerability, functional limitation, and support dependence.

A. The New Definition of Functional Capacity: Ignoring Context and Masking The proposed Section 9B introduces a highly restrictive definition of “functional capacity,” defining it as an individual’s ability to undertake activities:

1. Without assistance from other people;
2. Without assistive technology or home modifications;
3. In a context that excludes, as far as possible, environmental and personal circumstances.

B. Direct Repudiation of the Social Model of Disability This definition is fundamentally inconsistent with the contemporary social model of disability enshrined in the UN Convention on the Rights of Persons with Disabilities (UNCRPD), which Australia ratified in 2008. The UNCRPD explicitly recognises that:

1. Disability is contextual and relational, arising from the dynamic interaction between persons with impairments and the attitudinal and environmental barriers that hinder their full, effective, and equal participation in society on an equal basis with others (UN, 2006, Preamble [e]).

2. Human functioning cannot be divorced from assistive technology or personal support, meaning that assessing functional capacity in their complete absence is a direct violation of Article 19, which guarantees the right to live independently and be fully included in the community with appropriate personal support (UN, 2006).

3. Support needs do not equal organic impairment levels; rather, they reflect the severity of systemic barriers, mismatch in communication partners, and sensory

Submission 583

environments, making contextualized evaluations a human rights mandate (UN Committee on the Rights of Persons with Disabilities, 2019).

By assessing capacity in a sterile, environment-free, and tool-free vacuum, the NDIA will systematically under-assess support needs. A participant’s functional capacity is not a fixed internal trait; it is highly contextual and changes based on environmental supports, reasonable adjustments, and assistive technology (UN, 2006).

Clinical Practice Example A

A participant with psychosocial disability experiences periods of relative stability when supported through psychology, occupational therapy, structured community participation, and support coordination.

During periods of apparent improvement, the participant may no longer outwardly present as requiring intensive support. However, this stability is directly dependent upon ongoing therapeutic intervention and structured supports. If funding is reduced because the participant appears “improved,” the participant may experience psychiatric relapse, hospital admission, housing instability and/or increased suicide risk.

The apparent functional improvement may therefore reflect successful support intervention rather than reduced disability-related need. There is substantial risk that these reforms may unintentionally prioritise short-term cost containment over long term investment in participation and independence. Restricting access to supports during earlier stages of disability may ultimately increase reliance on acute health services, crisis responses, homelessness systems, justice systems, and informal carers.

C. Severe Risks for Neurodivergent People and “Masking” This approach is particularly problematic for neurodivergent individuals, whose functional presentation is heavily shaped by context, sensory environments, executive functioning, communication supports, and co-occurring mental health conditions.

Neurodivergent individuals (such as Autistic children and adults, or those with Language Disorders as is commonly associated with intellectual disability, and autism) frequently engage in “masking”—exhausting their cognitive and emotional reserves to mimic neurotypical behaviours in structured, artificial settings. Assessing a participant in a vacuum ignores:

Submission 583

• Fluctuating Capacity: A participant may perform a task successfully in a quiet room but experience a complete cognitive or sensory meltdown in a standard school or community setting;

• The Role of Environmental Adjustments: The presence of visual schedules, sensory accommodations, and trained communication partners is what allows the individual to function. Stripping these context factors from the assessment yields a fundamentally inaccurate and dangerously inflated measure of independent capacity.

Clinical Practice Example A

A 7-year-old neurodivergent child (with autism spectrum disorder and a language disorder) undergoes a cognitive and functional evaluation. In a quiet, one-on-one, highly structured clinical assessment room, the child can follow single-step directions and express basic needs.

However, in their real-world classroom—a high-sensory environment with 28 children, ambient noise, and fluctuating social demands—the child experiences complete sensory and cognitive overload. Without communication partner training, visual schedules, and an Augmentative and Alternative Communication (AAC) device, the child is entirely non-functional, unable to self-regulate or access the curriculum.

If functional capacity is evaluated strictly under the proposed Section 9B, the assessor would document the child’s “vacuum” clinical performance, concluding they have low support needs. This results in an underfunded plan that fails to provide the communication adjustments required for real-world survival.

4. The Repeal of Section 31: Removal of Participant-Directed Planning One of the most regressive and philosophically damaging changes proposed in this Bill is the repeal of Division 1 of Part 2 of Chapter 3 of the NDIS Act, which encompasses the current Section 31.

A. Dismantling the Legislative Expression of “Choice and Control” Section 31 currently provides the statutory guarantee that participant plans must be:

• Individualised to the person’s unique circumstances;

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• Directed by the participant themselves;
• Focused on the goals, objectives, and aspirations of the individual;
• Designed to maximise independence and social and economic participation. The repeal of Section 31 removes the central legislative expression of “choice and control”—the very cornerstone upon which the NDIS was campaigned for and established. Removing this section weakens the statutory basis for arguing that supports must be tailored to each participant’s unique developmental and environmental needs.

The mechanism of utilising standardised, non-clinical assessment tools or rigid budget setting algorithms to generate “one-size-fits-all” support plans directly replicates the exact conditions of systemic neglect exposed by the Disability Royal Commission. The DRC’s final report consistently demonstrated that when disability services and funding systems prioritise administrative standardisation and fiscal caps over individualized functional realities, participant safety is fundamentally compromised (Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability [Royal Commission], 2023).

B. Shift to Bureaucratic Standardisation For allied health practitioners, carers, and neurodivergent participants, this represents a profound and dangerous philosophical shift. It signals a transition away from an individualised, rights-based, person-centred model of disability support toward a highly standardised, transactional system increasingly driven by rigid budget formulas, automated algorithms, and blunt fiscal sustainability targets. Stripping this statutory protection leaves participants entirely vulnerable to administrative overreach where individual clinical necessity is subordinated to mathematical averages.

5. Limits on Reassessments and the Danger of Automatic Plan Renewals The Bill introduces Section 48A, which restricts participant-requested plan reassessments, while also allowing the Agency to automatically renew plans without a planning conversation.

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A. The Risk of Automatic 12-Month Plan Renewals The proposed administrative mechanism allows plans to be renewed automatically for 12 months without a planning conversation and without a reviewable decision. While framed as a measure to reduce red tape, in reality, this:

• Silences Changing Needs: It severely reduces opportunities for participants to explain changing development, functional decline, or escalating crises;

• Blocks Administrative Review: Because an automatic renewal is structured so as not to constitute a reviewable decision, it strips participants of their legal right to appeal an inadequate funding package.

B. Non-Linear Paediatric Development, Progressive Neurological Disabilities,

Fluctuating Needs, and Restrictions on Reassessments

Section 48A restricts participant-requested plan reassessments to situations demonstrating a “significant and ongoing” alteration in functional capacity or living circumstances. Paediatric neurodevelopment, for example, does not occur in a predictable, linear fashion. Children experience rapid developmental shifts, critical transition phases, or sudden regressions (such as escalating distress, sudden school refusal, or family breakdown) that require immediate clinical pivot. Participants who have progressive neurological conditions, fluctuating needs, or have a breakdown in their informal supports require immediate support and under this Bill, that will become increasingly difficult and inaccessible.

Denying timely reassessments until a crisis is legally deemed “ongoing” prevents allied health professionals from providing agile, responsive care.

C. Clinical Practice Example: Urgent Mobility Aid Device Modification Under Section 48A, the family cannot request an urgent plan reassessment to fund the physical adjustments and equipment because the functional alteration must first be proven “ongoing” over a prolonged observation period. The child is left functionally mute for months, causing severe psychological trauma and developmental stagnation.

A 12 year old young woman from a Muslim background with significant physical disabilities moves with her family to new rental accommodation when their lease is not renewed. The new accommodation, which was the only option available to the family, does not have appropriate bathroom facilities. The family cannot afford

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to purchase appropriate bathroom equipment, and the young woman’s plan does not have funding to pay for the equipment required.

The physiotherapist recommends a portable hoist and shower chair, but these cannot be purchased or rented until a new plan, with appropriate funding, is provided.

The young woman’s only option for showering ends up being using a hose in the garage area. This results in psychological distress to the young woman and her family, due to cultural implications of doing personal care in a semi-public place, risk of injury to the young woman and her carers, and risk to physical health as she is unable to access hot water during the colder months.

5. Foundational Supports and Service System Readiness The proposed transition toward foundational supports raises significant concerns regarding implementation readiness, funding adequacy, jurisdictional consistency, and service continuity. While Professionals Australia supports improved mainstream inclusion and early support pathways outside the NDIS, there is currently insufficient evidence that foundational support systems possess the workforce capacity, funding certainty, governance arrangements, or service availability required to absorb participants who may no longer qualify for individualised NDIS supports.

There is substantial risk that participants may experience a “service cliff” whereby they lose access to individualised NDIS supports before equivalent foundational services are operational, accessible, culturally safe, or clinically appropriate.

Clinical Practice Example

A child exits the NDIS under revised eligibility arrangements on the basis that foundational supports will provide ongoing developmental assistance. However:

• no local services exist;
• public waitlists exceed 18 months;
• school supports are inconsistent; and
• family income limits access to private therapy. The child effectively receives no meaningful intervention during a critical developmental period.

This risk is particularly acute for children requiring early intervention; participants with psychosocial disability; individuals with complex communication needs; rural and

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remote communities; First Nations communities; and participants requiring multidisciplinary support and coordination. Historically, state based disability, mental health, and community support systems were characterised by fragmentation, waitlists, geographic inequity, and inconsistent eligibility thresholds (Productivity Commission, 2011; Department of Social Services, 2023). There is concern that without substantial long-term investment and clear intergovernmental accountability arrangements, foundational supports may unintentionally recreate many of the service gaps the NDIS was originally established to address. The cost-shifting to other Government services is a real risk for people with disabilities.

Clinical Practice Example A

An adult with a psychosocial disability no longer meets eligibility under the revised NDIS access criteria despite previously receiving funded supports through their NDIS plan, including psychology, occupational therapy, and support workers to assist with activities of daily living, emotional regulation and social and community access. These funded supports played a critical role in maintaining the person’s stability within the community and reducing reliance on acute and crisis based interventions. Following the loss of NDIS eligibility, the individual is redirected to Foundational Supports. However, Foundational Supports are not yet fully operational, and there remains very limited or no clarity regarding the proposed service delivery framework.

There are also concerns that implementation of Foundational Supports may mirror other proposed and/or commissioned systems which utilise capped, time-limited, and eligibility-restricted approaches to service delivery. For individuals with complex and enduring psychosocial disability, the level, intensity, and continuity of support available under such a framework is highly unlikely to adequately meet their ongoing functional support needs. Without access to consistent therapeutic and disability-related supports, the person experiences a significant deterioration in their functional capacity and overall wellbeing, ultimately requiring admission to an acute inpatient mental health facility. National Mental Health expenditure data indicates that the average cost of a public acute mental health admitted patient was approximately $1,730 per day in 2023–24 with now slightly higher daily comparison rates in 2026.

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Clinical Practice Example B

Prior to the establishment of the National Disability Insurance Scheme (NDIS), allied health services for First Nations children in remote regions relied heavily on fly-in fly-out (FIFO) consultative models—an administrative structure that directly mirrors proposed “Thriving Kids” block-funded disability support alternatives. The clinical and systemic dangers of this model are demonstrated in the case of a nine-year-old First Nations child residing in a very remote community who speaks Standard Australian English as a second variety. The participant was subjected to an inappropriate cognitive assessment administered by a non-Indigenous metropolitan psychologist operating under a FIFO consultative framework. This decontextualised testing failed to account for cultural and linguistic variations, resulting in a severe clinical misdiagnosis of Intellectual Disability Disorder (IDD). Based on this invalid diagnosis, the child was placed into a segregated classroom setting; by age eight, they remained completely illiterate and presented with severe secondary psychosocial distress, including profound internalised shame (“I am stupid”) and defensive behavioural masking (“class clowning”) to evade learning and conceal deficits.

Following the allocation of an individualised, participant-directed NDIS plan, the child was able to bypass generic state-managed waitlists to access regular, intensive, one on-one speech pathology intervention delivered locally on Country. While standard classroom teaching alone was insufficient to remediate the child’s underlying communication deficits, twelve months of targeted, culturally responsive speech language pathology enabled the participant to achieve fluent literacy, mastering complex orthographic patterns, advanced vocabulary, and age-appropriate narrative themes. Targeted intervention meant that their communication disorder completely resolved the participant’s secondary mental health distress, restored academic self efficacy (“I can read”), and directly fulfilled multiple statutory targets under the National Agreement on Closing the Gap relating to early childhood development, emotional wellbeing, and educational attainment.

Under a block-funded model like “Thriving Kids,” or a culturally inappropriate standardised assessment completed by a non-clinical assessor, this child would have remained trapped in an undifferentiated, clinically unsafe system. Deprived of specialized, one-on-one allied health intervention, the participant faced an escalating trajectory of developmental stagnation, severe mental health deterioration, and educational exclusion, placing them at extreme risk of entering the “school-to-prison pipeline” where long-term suicide risk becomes a frightening reality.

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Clinical Practice Example C

A six-year-old First Nations child living in a very remote area of Australia had their ECEI NDIS funding stopped when they turned six years of age as they did not have a disability diagnosis to qualify for receiving the full NDIS. This family have not been able to access the assessments required to support their application for the full NDIS. They have been waiting for five months now to have an appointment with a paediatrician and psychologist working in the capital city many hours away to confirm this child’s disability diagnosis. Since their ECEI NDIS funding was ceased and while they are waiting in limbo for an assessment to be provided, this child’s vital speech pathology supports have had to be ceased as well. This child has been receiving regular, targeted, one on one speech pathology and occupational therapy supports via the ECEI NDIS funding provided in place, on Country since they were three years old. This child benefited considerably from receiving these regular therapies and they have made significant progress during the four years the ECEI NDIS funding was available, but they need access now to ongoing therapies to enable them to continue to achieve their developmental, learning and social participation goals. These therapies have not been able to continue. No alternative funding options for regular therapies exist where this child lives.

6. Impact on Therapeutic Supports and Allied Health A. Proposed changes Affecting Therapy The broader NDIS reform agenda and associated budget measures indicate increasing scrutiny of therapy supports, particularly those categorised within capacity building budgets. The Explanatory Memorandum emphasises sustainability and improved value within participant plans. Professionals Australia supports evidence-informed funding decisions. However, therapeutic supports must be understood as preventative and capacity-building investments rather than discretionary expenditure.

Proposed changes suggest reductions in capacity building funding; tighter oversight regarding therapy utilisation; greater standardisation of what constitutes “reasonable and necessary” supports; and increased pressure to limit long-term therapy provision (Department of Health and Aged Care, 2026; Department of Social Services, 2023).

While accountability and evidence-based practice are important, there is concern that the reforms risk reframing therapy as a short-term or episodic intervention rather than an ongoing investment in functional capacity, independence, participation, and

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preventative care and support. Disability-related therapy differs significantly from acute healthcare treatment models. For many participants, therapies such as occupational therapy, speech pathology, psychology, physiotherapy, social work, and behavioural supports are not designed to “cure” disability. Instead, they aim to:

• maintain functioning;
• prevent deterioration;
• support emotional regulation;
• build independence;
• reduce behavioural escalation;
• strengthen communication skills; and
• improve social and community participation.

Clinical Practice Example A

A teenager with an autism diagnosis receives occupational therapy, speech pathology, psychology, and community participation supports. Over several years, these supports assist the participant to develop emotional regulation, increase school attendance, improved communication, reduce reported “aggressive” incidents, and commence part-time employment preparation.

Where therapy funding is reduced due to assumptions that supports should become time-limited, the participant may lose functional gains during a critical developmental stage. The resulting impacts may include school refusal, family crisis, emergency mental health presentations, and lifelong increased support dependency.

A narrow interpretation of therapeutic effectiveness may fail to recognise the cumulative and preventative value of ongoing intervention (Productivity Commission, 2017; World Health Organization, 2022).

Clinical Practice Example B

A young child with Global Developmental Delay, Intellectual Disability, and a rare neurogenetic syndrome receives regular Speech Pathology intervention to support early communication, interaction, play, and participation in daily routines.

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The child has made slow but meaningful gains through consistent intervention, including increased engagement with others, increased use of gesture and vocalisation, emerging verbal communication, and improved participation in family interactions.

During periods where therapy has been interrupted or reduced, regression has been observed. The child becomes less engaged, uses fewer communication attempts, and relies more heavily on caregivers to interpret needs and manage distress.

If early intervention funding is reduced, delayed, or subject to standardised caps, the likely impacts include:

• loss of emerging communication skills;
• increased frustration and behavioural distress;
• reduced participation in family and early learning environments;
• increased pressure on parents and carers;
• greater need for more intensive supports later in childhood; and
• poorer long-term developmental and educational outcomes. This example demonstrates that reduced early intervention is not a neutral delay. For some children, interruption to therapy can result in loss of skills during critical developmental periods.

Clinical Practice Example C

A woman with a diagnosis of Huntington’s Disease, a progressive nuerodegenerative condition, receives support from occupational therapy, speech therapy, physiotherapy, podiatry, behaviour support clinician, complex supports coordination, and in home and community access support workers

With these supports she is able to maximise her quality of life, managing physical and cognitive changes in a proactive manner, maintaining contact with family and friends, having stable accommodation, and staying as well as possible.

If therapy and other funding is reduced or subject to standardised caps, likely impacts include:

• Increased hospitalisations due to falls and swallowing concerns

• More rapid and earlier loss of self care and daily living skills resulting in increased dependence of support workers

• Earlier loss of mobility and communication skills

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• Increased social isolation resulting in psychological distress and increased risk of dementia like symptoms. This is likely to result in increased need for behaviour support strategies requiring restrictive practices

• Poorer health outcomes and accelarated risk of death. B. Impacts on Allied Health Providers The proposed reforms may have substantial consequences for the allied health workforce and broader disability support market. The Explanatory Memorandum identifies workforce and market stewardship as important implementation considerations. Professionals Australia submits that workforce sustainability must be treated as a primary policy issue rather than a secondary implementation matter.

Concerns include workforce instability; increased provider burnout; withdrawal of providers from rural and remote communities; reduced viability of small and independent practices; increased administrative burden; increased compliance and reporting requirements; and difficulty attracting and retaining skilled clinicians. Many allied health providers are already reporting unsustainable administrative demands associated with NDIS compliance processes. Further restrictions, pricing pressures, and increased scrutiny may make disability practice financially and professionally unviable, particularly for smaller providers and sole practitioners.

The majority of experienced and skilled clinicians in the disability workforce are found in smaller businesses or sole practitioner roles. The potential loss of this workforce impacts on the efficiency and effectiveness of services provided to people with disability, meaning that overall services are less likely to deliver desired outcomes in expected timeframes. This area of allied health is not an area where the workforce emerges from university with the training and knowledge required to successfully navigate the complexities of disability, it is instead an area where early career allied health need significant support to build skills and knowledge required to be an effective practitioner. It is essential the experienced workforce, and the specialised skills and knowledge they have built up over time, are protected and preserved.

Clinical Practice Example

Submission 583

A regional occupational therapy practice servicing multiple rural communities experiences increasing unpaid administrative workload, pricing constraints, delayed payments, workforce shortages, and growing reassessment reporting requirements to maintain participant eligibility.

The practice ultimately withdraws from NDIS servicing due to financial unsustainability. As a result:

• participants lose continuity of care;
• waitlists increase;
• hospital discharge delays occur; and
• children experience interruption to early intervention services. In thin markets, the withdrawal of even a single provider may destabilise entire regional support systems. Workforce shortages already limit participant access to occupational therapists, speech pathologists, psychologists, physiotherapists, behaviour support and social workers outside metropolitan areas (AIHW, 2024). Additional market instability may further reduce service availability in these communities.

Many clinicians report spending substantial amounts of unpaid time navigating administrative requirements, responding to reassessment processes, preparing evidence for reviews, and supporting participants through funding disputes. There is growing concern that ongoing reform uncertainty may accelerate workforce attrition across the disability sector. There is also concern that reforms may increasingly favour low-cost, standardised, and transactional service models over relational, person centred, and interdisciplinary practice. Effective disability supports frequently depend upon continuity of care, therapeutic relationships, collaboration between providers, family engagement, and flexible, individualised approaches. Excessive standardisation risks undermining clinical autonomy and reducing the ability of allied health professionals to tailor interventions to participant-specific needs and contexts.

6. Likely Impacts on Participants A. Reduced Early Intervention The proposed reforms may significantly reduce access to early intervention and ongoing therapeutic supports for many participants. Reduced access to allied health services may particularly affect children, young people, and individuals with complex or

Submission 583

intersecting support needs. Participants may experience reduced access to occupational therapy, speech pathology, psychology, physiotherapy, social work, behavioural supports, and multidisciplinary intervention.

Early intervention has consistently been shown to improve long-term outcomes, particularly for children with developmental delay, autism, intellectual disability, and psychosocial disability (Productivity Commission, 2011; World Health Organization, 2022; OECD, 2022). Restricting therapeutic supports during critical developmental periods risks worsening long-term functional outcomes and increasing future service dependency. Any reduction in therapy supports may also increase crisis presentations, emergency department attendance, hospital admissions, mental health deterioration, family and carer burnout, school disengagement, behavioural escalation, and the potential for child protection involvement.

For participants with psychosocial disability, therapy often provides essential relational support, emotional regulation strategies, and preventative mental health intervention. Reducing access to these supports may increase the likelihood of acute psychiatric presentations and long-term disengagement from community participation.

For participants with complex or severe disability, therapy is essential to ensure they develop independence to the maximum degree possible, supporting their ability to autonomy wherever possible. This may be in being able to hold their own spoon when eating, in using a communication device, or standing while being supported to be dressed. Such supports help maintain skills and physical wellbeing and reduce need for hospitalisations or more intensive in home supports. For others, such as person who is non-speaking, speech therapy supports may reduce the need for more costly intensive behaviour supports.

B. Functional Decline and Reduced Capacity Building The proposed reforms risk reframing therapy as an optional or time-limited service rather than a core component of disability support and capacity building. This contradicts substantial National and International evidence demonstrating that ongoing therapy and early intervention:

• reduce long-term support costs;
• improve functional independence;
• strengthen daily living skills;
• reduce behavioural complexity;

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• improve educational and employment participation; and
• support community inclusion (AIHW, 2024). For many participants, therapeutic supports are essential in preventing deterioration rather than producing measurable “improvement” in a traditional medical sense. The concept of maintenance therapy is well recognised internationally within disability and rehabilitation frameworks. A funding environment that prioritises short-term measurable outcomes may disadvantage participants whose progress is gradual, non linear, or primarily preventative in nature.

7. Economic Risks, Cost Shifting, and Child Protection Impacts: The Burden on

Families, Carers, and Women

While the proposed reforms are intended to improve the financial sustainability of the NDIS, there is significant risk that short-term expenditure reductions may generate larger long-term fiscal liabilities across other Government systems. International evidence consistently demonstrates that investment in disability supports, allied health intervention, psychosocial supports, and community participation reduces downstream expenditure associated with:

• emergency healthcare utilisation;
• psychiatric admissions;
• homelessness;
• family violence;
• child protection involvement;
• justice system contact;
• long-term unemployment;
• carer burnout; and
• premature residential care admission. The Productivity Commission originally recognised the NDIS as a long-term social and economic investment designed to improve workforce participation, reduce informal care burden, and increase social inclusion. There is also concern that reforms may generate hidden economic costs through increased administrative complexity, higher review and appeal activity, provider exits from the market, increased workforce turnover,

Submission 583

service fragmentation, and greater reliance on crisis responses. The Committee should carefully consider whether apparent short-term Scheme savings may ultimately represent cost transfers rather than genuine reductions in overall public expenditure.

While the Bill is framed as a fiscal sustainability measure, short-term NDIS expenditure cuts will generate massive, compounding long-term liabilities across state-funded health, justice, education, and child protection portfolios (Kavanagh et al., 2015).

A. The Expansion of “Parental Responsibility” Proposed subsections 34(1G)–(1J) seek to dramatically expand the definition of “parental responsibility,” creating a strong statutory presumption that parents must provide extraordinary levels of care, including complex behavioural support, constant medical/physical supervision, specialised transport, and intensive emotional support. Under these subsections, the CEO must not fund supports where the primary purpose is deemed to:

• Reduce parental burden below what is “reasonably expected”;
• Improve household efficiency;
• Reflect parental preference rather than absolute, survival- level necessity.For NDIS families, this is a catastrophic development. Many parents are already providing extraordinary, round-the-clock levels of unpaid care that far exceed typical parental duties.

B. Gendered Impacts on Women and the Workforce The proposed expansions to statutory “parental responsibility” boundaries under subsections 34(1G)–(1J) create an irreconcilable policy contradiction with the Commonwealth’s own legislative objectives managed by the Workplace Gender Equality Agency (WGEA) under the Workplace Gender Equality Act 2012. While WGEA is legally mandated to eliminate structural barriers to women’s workforce participation and protect employees from discrimination relating to family and caring responsibilities, these NDIS amendments artificially restrict core funding, shifting clinical and operational burdens onto families. Empirical data from the Australian Bureau of Statistics (ABS) confirms that women already perform 62% more uncompensated, unpaid labour than men, and that 71.8% of primary informal carers in Australia are women. Coercing primary informal caregivers—the majority of whom are women—to absorb the clinical service deficit created by restricted NDIS budgets will

Submission 583

actively worsen the national gender pay gap, counteract WGEA’s enforceable workplace targets, and systematically entrench gendered economic inequity. By stripping funded support workers, respite care, and developmental therapies, this Bill will:

• Force Women out of the Workforce: Mothers will be forced to abandon employment or reduce hours to perform unpaid, high-intensity disability caregiving, directly undermining decades of gender equity and workforce participation progress. Working-age primary carers already have a catastrophically low workforce participation rate of 56.5% (compared to 81.1% for non-carers);

• Escalate Financial Strain: Forcing families onto a single income while managing the high out-of-pocket costs of disability causes severe financial stress and poverty;

• Heighten Family Violence and Mental Health Crises: The intersection of severe caregiver burnout, sleep deprivation, isolated home environments, and financial distress significantly elevates the risk of family breakdown, domestic violence, and parental mental health crises.

Clinical Practice Example:

A family who cares for multiple children who have complex support needs, are minimally verbal, and have challenging behaviours is not provided with adequate in home supports, has their social and community participation budget cut, and have their therapy budget cut. The father of this family works 12-14hrs to provide for their family. The mother is unable to go to work, leave the house to get groceries, or safely take her children out of the house independently. The lack of appropriate supports results in significant carer strain which contributes to significant concerns regarding the parent’s mental health which triggers a Child Protection notification. This mother is unable to shower, cook, or clean the house due to her caring responsibilities for her children. The mother is unable to earn her own money, is socially isolated, and her caring capacity breaks down until she must relinquish care of her children for their and her safety.

Submission 583

The ongoing risk to this family’s financial security, mental wellbeing, and physical wellbeing are significant. The changes introduced by this Bill will have drastic consequences for families like this.

C. The Catastrophic Cost of Out-of-Home Care (OOHC) When families are pushed beyond their physical and mental breaking points, the inevitable outcome is caregiver abandonment, family breakdown, and the relinquishment of children with complex disabilities into the state child protection system.

According to the Australian Productivity Commission’s 2024 Report on Government Services (RoGS):

• National OOHC Expenditure: Recurrent expenditure on child protection and OOHC services reached $10.2 billion nationally in 2023–24, a real increase of 6.6% from the previous year. Care services alone accounted for 64.9% ($6.6 billion) of this spend.

• Unit Cost of Out-of-Home Care: The annual recurrent cost per child in care is astronomical:

o Non-residential (foster/kinship) care costs between $55,223 and $71,436 per child annually.

• Residential care (congregate, group-home settings) ranges between $608,542 and over $1.2 million per child annually. These figures demonstrate the gross economic inefficiency of the proposed cuts. A proactive NDIS capacity-building plan providing $40,000 to $60,000 of coordinated therapy, home modifications, and professional respite preserves the family unit, allows mothers to remain in the workforce, and prevents the child from entering residential care, saving state and federal taxpayers over $1.1 million per year per child.

D. Parents with Disabilities The Bill fails to recognize that parents who themselves live with cognitive, physical, or psychosocial disabilities require additional, specialised supports to execute their parenting roles. Failing to support these parents violates the UN Convention on the

Submission 583

Rights of the Child (UNCRC) and leads directly to discriminatory child removal practices.

8. Social and Community Participation Cuts Recent NDIS reform measures indicate substantial reductions to social, civic, and community participation funding categories, including:

• a reported 50% reduction in social, civic, and community participation budgets; and

• a 10% reduction in capacity building daily activity budgets (Department of Health and Aged Care, 2026).

These proposed reductions represent a significant shift away from the original principles of the NDIS, which recognised participation and inclusion as central to quality of life and social citizenship. The Explanatory Memorandum references sustainability and improved targeting of participant supports. Professionals Australia submits that social participation supports are directly linked to safeguarding, mental health, and long-term independence.

Social and community participation should not be viewed as optional, recreational, or non-essential expenditure. Participation is a core determinant of mental health and wellbeing, community inclusion, social connection, identity formation, confidence and skill development, safety, independence, and prevention of social isolation.

Clinical Practice Example

A young adult with intellectual disability attends weekly community participation activities supported through the NDIS. These activities and supports provide social connection, travel training, communication practice, routine development, and informal safeguarding oversight.

Following a significant reduction in social participation funding, the participant becomes increasingly isolated at home. Over time:

• anxiety increases;
• physical health deteriorates;
• family carer strain escalates; and

Submission 583

• vulnerability to exploitation increases. The removal of relatively low-cost preventative supports may therefore increase future reliance on crisis services and intensive support arrangements.

The UNCRPD explicitly recognises the right of people with disability to participate fully in cultural, recreational, community, and social life (United Nations, 2006; United Nations Committee on the Rights of Persons with Disabilities, 2019). Community participation is therefore not merely a discretionary support but a rights based component of inclusion and citizenship. For many participants, particularly those with complex support needs, community participation supports function as protective factors against mental health deterioration, homelessness, exploitation, and crisis system involvement.

The proposed cuts may disproportionately impact neurodivergent participants, individuals with psychosocial disability, young adults transitioning to independence, participants without strong informal support networks, participants living alone, rural and remote participants, and culturally and linguistically diverse communities. There is significant concern that reducing social participation funding risks unintentionally re-institutionalising people socially through isolation, exclusion, and reduced community presence. While institutionalisation may no longer occur within traditional congregate settings, social exclusion and disconnection can produce similar outcomes in terms of reduced autonomy, diminished wellbeing, and loss of community belonging. Ultimately, reducing participation supports may generate short term fiscal savings while increasing long-term social and economic costs across health, mental health, housing, justice, and informal care systems.

9. Human Rights and Procedural Fairness Considerations Professionals Australia submits that the proposed reforms engage significant human rights considerations, particularly regarding equality before the law, access to supports, procedural fairness, participation in decision-making, and freedom from discrimination. Participants with disability frequently experience structural disadvantage when navigating complex administrative systems, particularly where disability intersects with poverty, geographic isolation, trauma, discrimination, or cultural marginalisation (Kavanagh et al., 2015; People with Disability Australia, 2023).

Increased reliance on standardised assessment tools and administrative decision making may unintentionally reduce opportunities for participants to meaningfully explain the lived impact of their disability and the contextual factors influencing

Submission 583

functional capacity. Professionals Australia is concerned that overly rigid planning frameworks may inadequately account for trauma histories, cultural context, episodic disability, environmental barriers, communication differences, and cumulative disadvantage.

The Committee should consider whether sufficient safeguards exist to ensure participants retain meaningful access to transparent decision-making, independent review pathways, accessible communication, culturally safe processes, and natural justice protections.

10. Impact on First Nations Peoples and Closing the Gap Professionals Australia strongly urges the Committee to consider the likely impact of the proposed reforms on First Nations Peoples with disability, particularly given the Explanatory Memorandum itself acknowledges that aspects of the reforms may impact upon Closing the Gap outcomes and equity of access. Professionals Australia submits that this acknowledgement warrants significantly greater scrutiny regarding the interaction between the proposed legislative changes and Australia’s obligations under the National Agreement on Closing the Gap.

The Committee should carefully consider whether the cumulative effect of tighter eligibility thresholds, increased reassessment activity, standardised assessment models, and reliance upon foundational supports may disproportionately disadvantage First Nations participants due to:

• cultural differences in communication and wellbeing;
• historical distrust of government systems;
• geographic isolation and thin markets;
• cumulative disadvantage and intergenerational trauma;
• limited access to culturally safe assessment and support pathways;
• reduced availability of allied health professionals in remote communities;
• digital exclusion and administrative complexity; and
• overrepresentation of First Nations peoples in poverty, housing instability, justice systems, and child protection systems.

Aboriginal and Torres Strait Islander peoples with disability frequently experience overlapping structural disadvantage across multiple service systems. These

Submission 583

intersecting factors may substantially affect an individual’s capacity to navigate increasingly complex administrative and evidentiary requirements within the NDIS.

The proposed requirement to demonstrate exhaustion of treatment options prior to NDIS eligibility may create particular inequity for First Nations communities where healthcare access itself remains significantly constrained.

Clinical Practice Example A

A 4 ½ year old First Nations child due to start school in 2027 is refused access to the EDEI NDIS in November 2025 and instead provided a Community Connections Plan. The Plan suggested the family seek a GP referral to access community therapy which does not exist. The family instead was provided a CDMP by the GP to seek Medicare rebated sessions via a private allied health practice. The Medicare rebate does not cover the costs of allied health therapy, it merely provides a small rebate, and families are expected to pay the gap between the Medicare rebate and the real cost of providing allied health supports to young children. The family are unable to afford to pay a Gap Fee so the child receives nothing. No other funding stream is available for the family to receive the regular, targeted, one on one speech pathology and OT support provided in place, on Country the child needs. The child’s kindy are extremely concerned that this child will be so far behind when they then are expected to start school in 2027. An AQ TRAK assessment administered during late 2025, indicated that this child was significantly behind in all developmental areas.

Clinical Practice Example B

A First Nations child living in very remote Australia who was ‘discharged’ due to ‘limited attendance’. They attended a Children’s Centre, and they were placed within a ‘speech’ group provided by a school support officer, so, not being delivered by a suitably qualified speech pathologist. The consultative service and program development delivered by the Department for Education and which looks like the concerning Thriving Kids initiative failed this child. This was a state funded ‘speech group’, supported by intermittent consultative speech pathology visits from a major regional centre. It did not work. Now this child aged nine years, is not able to access the full NDIA as they do not have a recognised disability diagnosis. This child is now situationally mute and is being touted as having a cognitive disability. They require a multidisciplinary team around the family and if provided with adequate allied health therapies (i.e. speech pathology, occupational therapy etc.) their progress will improve, as per the research evidence. There are currently no alternative speech pathology supports available where they live.

Submission 583

Professionals Australia is also concerned that increased reliance on standardised assessments may inadequately capture culturally informed understandings of disability, functioning, communication, kinship, caregiving, and community participation. Many standardised assessment tools were not developed within culturally diverse or First Nations contexts and may inadvertently privilege Western communication styles, behavioural norms, and clinical presentation patterns. There is substantial risk that First Nations participants may therefore be under-assessed, underfunded, incorrectly deemed ineligible, or subject to inappropriate planning outcomes.

The Committee should also consider whether the reforms are fully consistent with the National Agreement on Closing the Gap, particularly commitments relating to Priority Reform One (Formal partnerships and shared decision-making), Priority Reform Three (Transforming government organisations), Priority Reform Four (Shared access to data and information), strengthening community-controlled services, culturally safe systems, and reducing systemic inequity.

There is concern that reforms implemented without meaningful co-design with First Nations organisations may unintentionally reproduce historical patterns of administrative exclusion, institutional mistrust, and service inequity. Additional compliance burdens, reassessment requirements, reporting obligations, and funding uncertainty may disproportionately impact smaller community-controlled providers with limited administrative infrastructure.

Professionals Australia submits that reforms should not proceed without explicit safeguards for culturally safe implementation, co-design with First Nations organisations, and protections against unintended exclusion from supports. Professionals Australia further recommends that the Committee consider:

• mandatory cultural safety impact assessments prior to implementation of major reforms;

• independent monitoring of First Nations access and reassessment outcomes;

• dedicated investment in culturally safe allied health and disability workforces;

• strengthened support for Aboriginal Community Controlled Organisations (ACCOs);

• flexible evidentiary pathways where specialist access is limited;

• culturally responsive assessment frameworks;

Submission 583

• improved outreach servicing models for remote communities; and
• formal partnership mechanisms with First Nations disability organisations throughout implementation and evaluation processes.

Professionals Australia submits that Closing the Gap cannot be advanced through reforms that unintentionally increase barriers to disability support access, reduce culturally safe service availability, or deepen inequities experienced by First Nations peoples with disability.

11. Consultation Integrity and Workforce Representation Professionals Australia is concerned that current consultation and engagement processes across the NDIS reform agenda may not be adequately capturing the full extent of workforce sustainability concerns emerging across the disability and allied health sectors. While many Peak Bodies, professional associations, and representative organisations continue to engage constructively with Government and the NDIA regarding proposed reforms, there is growing concern across the sector that workforce risks associated with the reforms are not being discussed as openly or robustly as required given the scale of the proposed legislative and system changes.

Professionals Australia submits that effective policy development depends upon the ability of stakeholders to raise legitimate implementation concerns—including workforce instability, market failure risks, service withdrawal, and unintended participant harm—without concern that critical feedback may reduce opportunities for ongoing engagement, co-design participation, advisory involvement, or funding relationships.

The Committee should consider whether current consultation structures sufficiently support independent and transparent policy scrutiny, particularly in circumstances where organisations may perceive pressure to align with predetermined reform directions. This concern is particularly significant in the context of workforce sustainability. The proposed reforms have major implications for allied health workforce retention, provider viability, thin markets, sole traders and small providers, regional and remote service delivery, interpreting workforces, support coordination, early childhood intervention capacity, and culturally safe service provision.

However, workforce impacts are often framed primarily as implementation matters rather than central policy risks capable of undermining the reforms themselves. Professionals Australia submits that workforce sustainability is not ancillary to NDIS reform; it is foundational to the Scheme’s long-term viability, safeguarding capacity, and

Submission 583

participant outcomes. Reform processes that insufficiently account for workforce realities risk creating legislation that is administratively implementable in theory but unsustainable in practice.

The Committee should therefore consider whether additional independent workforce consultation, modelling, and public reporting mechanisms are required before major reforms are implemented. This should include:

• transparent workforce impact assessments;
• independent allied health and disability workforce modelling;
• consultation processes that support frank and evidence-based feedback;
• public reporting on provider exits and workforce attrition; and
• formal mechanisms for frontline clinicians, support coordinators, interpreters, and small providers to contribute to policy development.

A sustainable and effective NDIS reform agenda depends upon transparent consultation processes that encourage robust scrutiny, diverse perspectives, and evidence-informed debate, including where stakeholder feedback challenges the assumptions underpinning proposed reforms.

12. Recommendations Professionals Australia respectfully recommends that the Committee:

13. Delay implementation of major planning reforms until foundational supports are operational, accessible, and independently evaluated.

14. Ensure no participant loses access to existing supports until equivalent foundational services are demonstrably available.

15. Introduce nationally consistent minimum standards for foundational supports.

16. Clarify within the legislation or associated Rules that inability to access treatment due to geographic, financial, cultural, or workforce barriers must not operate as a basis for denying eligibility. Ensure “reasonable access to treatment” is assessed in the context of actual service availability, affordability, and cultural safety.

17. Ensure standardised assessment tools inform, but do not determine, funding decisions.

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6. Preserve professional clinical judgement, multidisciplinary evidence, and procedural fairness protections within planning and reassessment processes.

7. Strengthen review and appeal rights for participants.

8. Undertake an independent Closing the Gap impact assessment prior to implementation of the proposed reforms, including ongoing public reporting regarding First Nations access, reassessment outcomes, workforce impacts, and culturally safe service availability.

9. Implement culturally safe safeguards for First Nations peoples and CALD participants.

10. Recognise that functional stability achieved through ongoing support should not be interpreted as evidence that disability-related support needs have resolved.

11. Recognise maintenance and preventative therapy as consistent with the principles of reasonable and necessary supports. Avoid arbitrary assumptions regarding therapy duration or participant “graduation” from supports.

12. Undertake independent workforce sustainability modelling prior to implementation. Publicly monitor provider withdrawal risks, workforce attrition, and thin market impacts.

13. Protect the viability of small, community-based, rural, and culturally specific providers.

14. Recognise outreach servicing, travel, home visiting, and relational practice within pricing and commissioning models.

15. Preserve support coordination and continuity of therapeutic relationships.

16. Extend consultation periods and introduce exposure draft processes for major reforms.

17. Ensure independent evaluation of the social and economic impacts of reductions to participation and capacity building supports.

18. Embed human rights principles, including participation, inclusion, autonomy, and procedural fairness, throughout reform implementation.

19. Establish staged implementation linked to demonstrated system readiness and independent evaluation.

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20. Embed relational safeguarding principles within reform implementation.

Conclusion

Professionals Australia acknowledges the importance of ensuring the long-term sustainability and integrity of the NDIS. However, sustainability cannot be achieved solely through expenditure restraint, tighter eligibility thresholds, or administrative standardisation. A sustainable Scheme requires investment in preventative supports, a stable and skilled workforce, participant trust, culturally safe systems, procedural fairness, strong safeguarding mechanisms, and genuine partnership with people with disability, families, and frontline providers.

The NDIS was established as a transformational social reform grounded in rights, inclusion, and participation. Reforms that unintentionally reduce access to early intervention, therapeutic supports, social participation, and relational practice risk undermining the very outcomes the Scheme was designed to achieve. Professionals Australia therefore urges the Committee to adopt a staged, evidence-informed, and human rights-based approach to reform implementation that prioritises both fiscal sustainability and the long-term wellbeing, safety, and inclusion of people with disability.

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