Concerns regarding NDIS reforms impacting families with disabled children (Family or carer experience)

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Submission 61

National Disability Insurance Scheme Amendment (Securing the NDIS for Future

Generations) Bill 2026: Submission

18/05/2026

To whom it may concern,

Re: National Disability Insurance Scheme Amendment (Securing the NDIS for

Future Generations) Bill 2026

I am writing to express my serious concerns regarding the above-named bill. I am a parent, a member of the Bayside City Council in Melbourne, a therapist (Speech Pathologist) of 26 years, and practice owner of 18 years. My therapy practice, Sensational Kids, has been in operation since long before the NDIS was established. We service disabled children and young adults with mild to complex disabilities and provide education, training and support to parents, carers, teachers and support workers to aid expansion and transition of skill development into the community and schooling environments.

Prior to the NDIS roll out, children accessing our services utilised the FaCHSIA/ DSS Helping Children with Autism funding and Medicare programs or paid privately if able. Children who did not have a diagnosis (for example, those with significant developmental delays, dyspraxia, developmental language delay, Developmental Coordination Disorder [DCD] and many more presentations) were not able to access any funding options other than a ECP/Chronic Diseases Management Plan - 5 rebateable Medicare sessions totalling a maximum of $275 in rebates a year. Those who were fortunate enough to be able to afford private funding could receive some level of rebates if their coverage included allied health services specific to what we were offering.

As you can imagine, for families with children without funding, and limited financial means, there were few options available. Those options included not for profit, block funded sessions

  • therapy provided often by key workers (not always therapists specialised to work on the child’s area of need/ focus), in blocks (6 weeks was common) - and involved long waitlists. Of note, this was common for metropolitan areas - rural and regional areas often experienced much longer waits (up to 18 months) for assessment and treatment to start.

Evidence shows that intensive early intervention with a focus on family inclusion and training results in the best functional outcomes for the child. This approach is supported by the PRECI National Best Practice Framework for Early Intervention.

Sensational Kids – Every Child, Every Possibility

Add: Level 2, 11 Chesterville Rd., VIC 3192 Ph: 03 9578 7560 Add: 70 Robertson St, Kensington VIC 3031 Ph: 03 8560 4050 Email: info@sensationalkids.com.au Web: sensationalkids.com.au 1

Submission 61

Sensational Kids services over 750 families each year - many of the children we provide therapy to go on to make significant progress in their development. Some examples of how NDIS funds have made this progress possible include: -​ Families of low socioeconomic backgrounds have been able to access high quality, timely early intervention. -​ Teenagers have been able to transition from dependent to independent, including developing the skills necessary to write CVs and apply for jobs, getting their Learners Permits, accessing public transport to get to school, therapy appointments or their jobs. -​ Children have been able to communicate effectively both verbally, and using Alternative and Augmentative Communication devices (AAC) at home, at school and in the community. AAC assessment and implementation takes a significant amount of time, coordination, commitment and education to be successful. AAC devices promote meaningful participation in all classrooms, including mainstream classrooms. -​ Children with previously unfunded presentations (as previously listed) have been able to access therapy and improve their functional outcomes. -​ Children have been able to attend mainstream schooling with support when in the past they have been enrolled in non-mainstream schools.

These are just some examples of how NDIS funds have been able to help children and teens (and more broadly, families) realise their potential, participate meaningfully in their communities and establish strong functional outcomes that set them up for success in their school years and beyond. This investment in their future means a potential reduced dependence on healthcare and government services longer-term. Reduced dependence on others (including family members) also provides opportunity for family members to participate in the workforce or other areas of their community, where they would have otherwise been unable to due to caring responsibilities. This extends also to siblings of disabled children who often share caring responsibilities and who are often the unseen carers.

Targeted evidence-based therapy is indeed an undeniable pathway towards independence, participation in community and general health and wellbeing - all of which reduce the demand on healthcare services longer term.

The NDIS Act establishes that the Scheme is intended to:

  • support people with disability to pursue their goals and aspirations;
  • facilitate participant choice and control; and
  • provide reasonable and necessary supports based on individual needs. I have serious and unreserved concerns that the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 departs significantly from

Sensational Kids – Every Child, Every Possibility

Add: Level 2, 11 Chesterville Rd., VIC 3192 Ph: 03 9578 7560 Add: 70 Robertson St, Kensington VIC 3031 Ph: 03 8560 4050 Email: info@sensationalkids.com.au Web: sensationalkids.com.au 2

Submission 61

these intentions. I have expressed my concerns repeatedly through many prior submissions and wish to expand on them now in relation to this bill.

The proposed amendments create substantial risks for disabled Australians, particularly:

  • tightening eligibility criteria;
  • redefining permanence and functional capacity;
  • expanding Ministerial powers with limited oversight;
  • enabling broad funding reductions across participant groups;
  • increasing reliance on unpaid informal supports;
  • reducing access to therapy and community participation supports;
  • introducing automated decision-making powers;
  • weakening reassessment safeguards; and
  • creating pathways for participants to lose access to the Scheme without meaningful procedural protections.

I have many concerns regarding these changes including:

  • That these changes appear rushed and unplanned. There are no meaningful Foundational Supports available in the community yet children have been removed from the scheme in their thousands since last year. We have personally experienced many children removed from the current system without any appropriate services to engage with. The risk to these children and those supporting them are significant including regression, an increase in behaviours of concern and mental health decline for both participants and their support network. •We have had to field many conversations with parents whose children are no longer able to access our services who have expressed helplessness and hopelessness, distress and anxiety. The fear and anxiety is palpable in the community and has been for some time.

  • A clear expectation that disabled people and/ or their families will be required to expend all other therapy options and increase reliance on private payment despite many families not having the means to fund said services.

  • That many children whose conditions are impacted by these changes will no longer be able to access timely and effective treatment.

  • Lack of clear modelling of impacts on First Nations communities, women carers, rural and remote participants, culturally and linguistically diverse communities, and people with complex disability.

  • Lack of clear modelling around workforce shortages/ limitations and broader impact on a therapy workforce that is largely a female-dominated industry.

  • Lack of ability for participants to request review of inadequate or inappropriately supplied funding in plans.

  • A lack of adequate, meaningful consultation with disabled people and the Disability sector and

Sensational Kids – Every Child, Every Possibility

Add: Level 2, 11 Chesterville Rd., VIC 3192 Ph: 03 9578 7560 Add: 70 Robertson St, Kensington VIC 3031 Ph: 03 8560 4050 Email: info@sensationalkids.com.au Web: sensationalkids.com.au 3

Submission 61

  • A lack of evidence or modeling published regarding the likely downstream costs to hospitals, mental health systems, homelessness services, education systems and aged care systems.

Schedule 1: Access and Planning

1.1 Functional Capacity Definition

The Bill proposes a new definition of functional capacity which assesses what a person can do:

  • without assistance from other people;
  • without assistive technology or modifications; and
  • excluding, as far as possible, environmental and personal circumstances. Assessing function, functional ability, and functional capacity sits at the heart of occupational therapy and other health professions. This expertise focuses on understanding how people operate within their environments and how the right supports can minimise risk and foster participation.

Evidence shows that strong health professional input is critical to identifying disability support needs accurately, preventing harm, avoiding adverse events, and supporting safe, effective planning. Disregarding well-founded professional opinion puts participants at risk and sidelines the expertise health professionals bring in favour of a one-size-fits-all assessment approach.

Excluding environmental and personal circumstances from functional assessment is an approach that cannot be justified. Functional capacity does not exist in isolation, it is fundamentally contingent on the environments in which a person lives and operates, as well as their individual circumstances. Disregarding these factors risks generating an artificial and misleading representation of disability and support needs, undermining the integrity of the assessment process and the outcomes it is intended to inform.

There is a significant gap and lack of transparency exhibited in this bill including:

  • how impairment categories will be determined through functional capacity assessment;
  • who will be conducting these assessments;
  • what will inform categorisation;
  • how consistency will be ensured. 1.5 Tightening of Permanence and Appropriate Treatment

Sensational Kids – Every Child, Every Possibility

Add: Level 2, 11 Chesterville Rd., VIC 3192 Ph: 03 9578 7560 Add: 70 Robertson St, Kensington VIC 3031 Ph: 03 8560 4050 Email: info@sensationalkids.com.au Web: sensationalkids.com.au 4

Submission 61

I am deeply concerned that there appears to be a clear expectation that disabled people and/ or their families will be required to expend all other therapy options and increase reliance on private payment despite many families not having the means to fund said services.

People’s ability to access services (both public and private) can be contingent upon:

  • workforce shortages/ availability and availability of specialists;
  • socio-economic status;
  • transport barriers;
  • accessible healthcare systems;
  • communication barriers;
  • lack of culturally safe services;
  • ability to tolerate treatment environments;
  • trauma;
  • knowledge of available services and access pathways;
  • carer capacity (mental health/ wellness) to assist with accessing said services. The demands on participants in regards to record keeping are significant. There are many reasons why a person may have challenges with accessing or storing records proving service these barriers include challenges with executive function [organisation, planning), carer capacity, communication challenges, cessation of services and closure of services and challenges navigating the bureaucratic pathways to accessing information. The cognitive load is real and cannot be underestimated.

In addition to this, I have deep concerns that capacity building support under this bill may be interpreted to mean that the very therapy supports that are core to how a participant maintains function and participation over time may be further limited. It is vital to note that many disabilities are lifelong and degeneration can occur, so adequate funding to help maintain function and reduce risk of degeneration requiring further medical intervention is essential.

1.7 Funding Cuts and Ministerial Powers

Proposed section 34A would give decision-makers sweeping power to apply blanket percentage cuts to funding in existing NDIS plans on the grounds of “financial sustainability.” These cuts could be made without individually reassessing what supports a participant needs, considering their safety, evaluating the functional impact of reduced funding, or analysing the risks a funding cut would create.

This is a significant departure from the core principles of the NDIS, which are built on individualised assessment. Blanket cuts of this kind put essential supports at risk and increase risk of harm, loss of independence and impacts on progress and wellbeing. Of note,

Sensational Kids – Every Child, Every Possibility

Add: Level 2, 11 Chesterville Rd., VIC 3192 Ph: 03 9578 7560 Add: 70 Robertson St, Kensington VIC 3031 Ph: 03 8560 4050 Email: info@sensationalkids.com.au Web: sensationalkids.com.au 5

Submission 61

the explanatory materials highlight risks for women carers, first nations people, those in rural and remote areas and children requiring early intervention. It is therefore difficult to reconcile proceeding with this provision in light of those acknowledged harms and I strongly recommend that Section 34A be removed from the Bill.

Schedule 3: Governance

3.1 Pricing Powers

The Bill would give the Minister the power to set maximum NDIS prices.

Capping prices has a direct and serious impact on workforce viability. The allied health sector is already facing significant workforce shortages, with many services relying on overseas-trained workers. Freezing or capping prices over an extended period destabilises the workforce and risks services reducing their capacity or closing altogether. This is especially damaging in rural and remote areas, where access to services is already limited and alternatives are scarce.

Price caps on items like assistive technology could also place essential equipment out of reach for many families. Communication devices, for example, are not something most families can afford to fund privately. Without access to these devices, participants may lose the ability to communicate effectively, with far-reaching consequences for their social and community participation, mental health and wellbeing, and education.

NDIS pricing must reflect the real cost of delivering services, keep pace with inflation, and account for the level of expertise required to provide each service. Pricing that fails to meet these benchmarks is not sustainable for providers.

To ensure pricing remains fair, realistic, and grounded in participant need rather than budget reduction, it should be overseen by an independent body. Independent oversight would help ensure that pricing decisions are informed, transparent, and not driven by fiscal pressures.

I strongly oppose this Bill proceeding in its current form. Implementation should be delayed until meaningful consultation has taken place ( not a rushed two-week process), comprehensive impact assessments have been completed and shared publicly, and genuine alternative supports are in place rather than simply talked about in theory.

While the Australian Government has stated its commitment to returning the NDIS to its original purpose, the legislation as written is clearly aimed at reducing Scheme expenditure. These reforms may meet financial targets, but they do so at serious risk to the health, safety, dignity, and rights of disabled Australians to have genuine choice and control over their own lives. The impact will not be felt equally with those from lower socioeconomic backgrounds,

Sensational Kids – Every Child, Every Possibility

Add: Level 2, 11 Chesterville Rd., VIC 3192 Ph: 03 9578 7560 Add: 70 Robertson St, Kensington VIC 3031 Ph: 03 8560 4050 Email: info@sensationalkids.com.au Web: sensationalkids.com.au 6

Submission 61

people without strong family support networks, first nations people and those living in rural and regional communities facing a disproportionate burden.

The Government expects community trust and buy-in for these reforms. But trust is not built through a lack of transparency. The absence of measurable, publicly available analysis of the broader impact on disabled people, the healthcare and education sectors, women, and carers is deeply concerning, frustrating and difficult to justify.

It is clear the Government is intent on reducing NDIS expenditure to deliver a more fiscally conservative budget. That goal is not unreasonable but the way these changes are being implemented, in a rushed, fragmented, and opaque manner, has left the disability community anxious, unheard, and I strongly believe, with a weakened, not strengthened system. Any reform should result in an improved way of doing things, not just a tightened budget.

These proposed changes have real world implications for hundreds of thousands of Australians - a thoughtful, considered, responsible and safe change should not have to be argued for but rather should be the default position of the government who was responsible for the implementation of this life-changing scheme. The risks outlined in this submission are substantial and well-documented and they should be sufficient grounds to pause this Bill rather than rush it through to meet a budgetary deadline.

Speech Pathologist

Manager/ Director

Sensational Kids - established 2007 Level 2, 11 Chesterville Road, Cheltenham, VIC. 3193 70 Robertson Street, Kensington, VIC. 3031

Employer of 30 experienced health professionals 421 current clients aged 0-22 with mild-complex disabilities

Sensational Kids – Every Child, Every Possibility

Add: Level 2, 11 Chesterville Rd., VIC 3192 Ph: 03 9578 7560 Add: 70 Robertson St, Kensington VIC 3031 Ph: 03 8560 4050 Email: info@sensationalkids.com.au Web: sensationalkids.com.au 7