Recognition of osteopathic expertise in NDIS planning (Provider advocacy)

Submission 649

Osteopathy Australia

Suite 4, 11 Railway St, Chatswood NSW 2067

PO Box 5044, Chatswood NSW 1515

Ph (61) 02 9410 0099 www.osteopathy.org.au

Osteopathy Australia’s submission to National Disability

Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 senate inquiry

Introduction

Osteopathy Australia thanks the Parliament of Australia for the opportunity to provide feedback to the Senate inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

Whilst we understand the request for consultation responses to be four -five

pages, this is a complex issue and Bill, requiring fuller             discussion   and  consultation     .

Summary of recommendations Osteopathy Australia recommends that the Committee:

1.  Ensure the functional capacity framework reflects real           -world function,

participation, context, assistive technology, environmental barriers and support needs.

2.  Require structured input from relevant          Australian Health Practitioner

Regulation Agency (    Ahpra  )-registered allied health practitioners, including

osteopaths, in access, planning and reassessment decisions where a participant has physical, musculoskeletal, neurological, mobility, pain related or complex functional needs.

3. Ensure new framework planning retains structured consideration of osteopathic evidence where a participant has disability -related musculoskeletal, mobility, pain -related, neurological or complex functional needs, and require exposure drafts of new framewor k planning Rules, support needs assessment tools and budget methods to be released for consultation with Osteopathy Australia and relevant stakeholders before implementation.

   4. Resolve the current participant access and equity inco nsistency in NDIS

recognition of osteopathy by establishing a clear NDIS pricing and claiming pathway for osteopathic services, including a dedicated support item or line item in the relevant NDIS Pricing Arrangements and Price

Limits and Support Catalogue             , where services are disability      -related,

functional, goal    -linked, evidence    -informed, and delivered by an Ahpra           -

registered osteopath.

5. Ensure “all appropriate treatment” requirements do not delay or deny access where treatment is unavailable, unaffordable, unsuitable,

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geographically inaccessible, culturally inappropriate, or unlikely to remove the person’s substantial functional impairment.

6.  Recognise that musculoskeletal disability, pain           -related functional

limitation and secondary musculoskeletal complications can be genuine disability -related support needs.

7. Ensure the Bill does not artificially separate eligible impairments from secondary or interacting functional consequences where those consequences affect mobility, self -care, participation, safety or independence.

   8. Build safeguards into reassessment and plan -renewal processes so

participants can respond to changing needs, ineffective current supports, deterioration, changes in informal support, or emerging functional barriers.

9.  Treat provider recognition as a workforce and market           -stewardship issue,

not simply a billing matter. This should include reviewing whether current pricing, claiming and support catalogue arrangements unnecessarily restrict participant access to clinically appropriate osteopathic services and other Ahpra -registered allied health supports, particularly in regional, rural and thin -market contexts.

10. Recognise existing Ahpra regulation as a major safeguard for regulated allied health professions, including osteopathy, and avoid duplicative NDIS registration requirements unless clearly justified by risk. Any additional

    NDIS -specific registration or comp liance requirements should be

    proportionate, risk -based, non -duplicative, clearly justified, and introduced

with adequate transition time and consultation with all relevant allied health peak bodies.

11. Release exposure drafts of relevant Rules, pricing, claiming and support catalogue changes, assessment tools, provider registration requirements and implementation guidance for meaningful consultation with participants, disability advocates, Osteopathy Aus tralia and allied health peak bodies before commencement.

12. Ensure children transitioning to Thriving Kids retain access to clinically appropriate osteopathic supports where those supports address disability related movement, mobility, postural development, musculoskeletal

    function, pain -related participation or da ily activity needs. Osteopathy

should be explicitly considered in the design of Thriving Kids service

eligibility   , employment,   commissioning arrangements and continuity           -of-

care provisions.

13. Ensure any support determinations or budget controls affecting capacity - building, therapy -related or functional support budgets include safeguards so participants retain access to osteopathic supports where those supports

    are disability -related, goal -linke d, evidence -informed and directed toward

maintaining or improving function, mobility, independence or participation.

Submission 649

About Osteopathy and Osteopathy Australia

Osteopaths in Australia are university -qualified allied health practitioners registered with the Australian Health Practitioner Regulation Agency (Ahpra).

Osteopaths complete either a dual bachelor’s degree, or a bachelor’s and master’s qualification with education and training in anatomy, biomechanics, human movement, the musculoskeletal and neurological systems, clinical intervention approaches and biomedi cal science including pharmacology. Osteopathic practice is underpinned by a biopsychosocial management approach.

Osteopathy Australia is the peak body         representing   the interests of osteopaths,

osteopathy as a profession, and consumers’ rights to access osteopathic services. Our core work includes liaison with state and federal government, statutory

agencies, professi    onal bodies, and    private industry    regarding   professional,

educational, legislative, and regulatory issues. Most registered osteopaths are members of Osteopathy Australia.

In the NDIS context, osteopathic supports are most appropriately understood as functional capacity and participant -focused supports. Osteopaths work with people with disability across a range of presentations including acquired brain injury, cerebral palsy , neurological and developmental conditions, and complex and/or comorbid presentations.

The supports osteopaths provide are focused on improving or maintaining movement, mobility, physical function, pain -related participation, activities of

daily living, and safe engagement in home, community,           work  or education

settings. These outcomes are di rectly relevant to the purpose of NDIS therapeutic supports and should be assessed by participant need, evidence of functional benefit, measurable outcomes and value for money.

Ex ecutive Su mmary Osteopathy Australia supports reform that improves the sustainability, integrity and quality of the NDIS. A sustainable Scheme is essential for current and future participants. However, sustainability should not be achieved by narrowing participant access to clinically appropriate supports, reducing choice and control, or excluding relevant regulated allied health expertise from access, planning and reassessment processes.

Osteopathy Australia’s concern is not simply that osteopathy is absent from the NDIS support catalogue. The broader concern is the Bill tightens access, planning, funding and provider arrangements while leaving unresolved inconsistencies in

how osteopathy      is recognised as a clinically relevant Ahpra          -registered allied

health profession within the NDIS. This inconsistency has implications beyond the

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profession itself because it affects whether participants can access osteopathic supports where those supports are clinically appropriate, functional, goal -linked,

evidence  -informed and directed toward measurable functional benefit.               This

negative impact will be felt more strongl y in rural and regional communities.

These are not peripheral issues. They are central to functional capacity, participation, independence, choice and control, and the goals of the NDIS. The Bill should therefore be assessed not only by whether it improves Scheme sustainability, but by whethe r it preserves fair participant access to clinically

appropriate, evidence    -informed and outcome     -focused osteopathic supports

where these are relevant to disability        -related function, mobility, pain       -related

participation and daily activity.

1. Functional capacity must reflect real -world function and participation

What the Bill does The Bill introduces a definition of functional capacity and creates a rule -making power for NDIS Rules to prescribe methods, criteria, classifications, thresholds and matters to be taken into account when assessing functional capacity. The Explanatory Memo randum states this is intended to support a more structured and consistent approach to access decisions, including future functional capacity assessments. The Explanatory Memorandum further states that functional capacity will relate to a person’s ability to undertake an activity without assistance from other people, assistive technology or modifications, and in a setting that excludes, as far as possible, t he impact of environmental and personal circumstances.

Why this matters for participants Osteopathy Australia is concerned this approach risks assessing functional capacity in an artificial context rather than the real -world context in which participants live, move, communicate, work, study, self -care and participate.

Disability -related function is not only a matter of intrinsic physical or cognitive capacity. It is shaped by environmental barriers, assistive technology, informal supports, pain, fatigue, mobility demands, housing, transport, geography, community access and participation expectations. A functional capacity assessment that deliberately strips away these factors may produce a cleaner administrative test, but it may not produce an accurate picture of the participant’s lived functional needs.

This is particularly concerning for people with complex, fluctuating, musculoskeletal, neurological or pain -related impairments. Their limitations may

Submission 649

not be obvious in a short, standardised assessment but may significantly affect transfers, mobility, self -care, community access, employment, education, parenting, domestic tasks or participation over time.

Why this matters for osteopathy Osteopaths routinely assess movement, mobility, pain -related function, posture, load tolerance, gait, compensatory movement patterns, activities of daily living and participation barriers. These assessments are directly relevant where a participant’s disab ility -related needs involve musculoskeletal, mobility, neurological, pain -related or complex functional limitations.

In the NDIS context, osteopathic supports should be understood as functional capacity and participant -focused supports. They are directed toward improving or maintaining movement, mobility, physical function, pain -related participation and safe engagement in home, community, work and education settings.

Evidence from relevant osteopaths should therefore be built into access, assessment and planning processes where a participant’s disability -related needs involve movement, mobility, pain -related function, musculoskeletal impairment, neurological impairment , activities of daily living or participation restrictions. More broadly, evidence from relevant Ahpra -registered allied health practitioners should be considered where clinically applicable.

Recommendation

The Committee should recommend that the functional capacity framework be revised or clarified to ensure assessment reflects real -world function, participation and support needs. Functional capacity assessment should include structured

input from osteopaths     and other relevant Ahpra      -registered allied health

practitioners where a participant’s needs involve physical function, mobility, pain, musculoskeletal impairment, neurological impairment, activities of daily living or participation restrictions.

2. Standardised assessment should improve consistency, not downgrade clinical evidence

What the Bill does The Bill creates a rule -making power for NDIS Rules to prescribe methods, criteria, classifications, thresholds and matters to be taken into account when assessing functional capacity. The Explanatory Memorandum states that the definition of functional cap acity is intended to support future work to develop a framework for determining thresholds for substantially reduced functional capacity and to guide the use of functional capacity assessments by the Agency.

Submission 649

The Impact Analysis also identifies that the NDIS Review recommended a more consistent and robust approach to determining eligibility based on transparent methods for assessing functional capacity. It also notes the current approach relies heavily on exter nal reports from treating professionals, creating inequities between participants who can afford assessments and those who cannot.

Osteopathy Australia supports the objective of improving consistency and equity in access and planning decisions. However, greater consistency should not be achieved by downgrading relevant clinical evidence from Ahpra -registered practitioners, particularl y where a participant’s support needs involve physical, musculoskeletal, neurological, mobility, pain -related or complex functional limitations.

Why this matters for participants Osteopathy Australia supports more consistent, transparent and equitable access and planning decisions. Standardised assessment may help reduce variation in decision -making and reduce reliance on costly private reports. However, consistency should not be a chieved by replacing clinically informed evidence with a narrow administrative process.

A standardised tool may be useful as one input into access and planning decisions. It should not become the only input, particularly for participants with complex, fluctuating or poorly visible functional needs. These participants may require clinical inte rpretation from practitioners who understand the interaction between impairment, pain, movement, mobility, fatigue, function, environment and participation.

If relevant clinical evidence is downgraded or treated as optional, participants may have their support needs underestimated, especially where their disability related limitations are not readily captured in a single assessment encounter.

Why this matters for osteopathy There is a policy inconsistency if the Scheme places greater reliance on standardised functional assessments for high -stakes access and planning decisions, while continuing to inconsistently recognise osteopathy as an Ahpra

registered allied health profess       ion able to provide disability      -related supports.

The issue is not whether trained assessors can play a role. Standardised assessment may support consistency, provided its purpose and limits are clear. The issue is whether assessment processes informing access, planning and funding decisions adequately in corporate clinical evidence from regulated allied health practitioners where clinical interpretation is required.

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Where functional need involves movement, mobility, pain, musculoskeletal impairment, neurological impairment, fatigue, activity tolerance, self -care or participation, osteopathic evidence should not be treated as optional or secondary where osteopathy is c linically relevant to the participant’s goals or support needs. The same principle should apply to other applicable Ahpra registered allied health evidence. This is particularly important where the participant’s functional limitations are complex, fluctuat ing, poorly visible, or not readily captured in a single standardised assessment encounter.

Recommendation

The Committee should recommend that standardised assessment tools be used as part of a broader evidence framework, rather than as a substitute for clinically informed evidence. The assessment process should require structured

consideration of evidence from       osteopaths and other relevant Ahpra        -registered

allied health practitioners, where a participant has musculoskeletal, mobility, pain -related, neurological, fatigue -related or complex functional needs.

3. New framework planning must retain clinically informed osteopathic input

What the Bill does

The Bill supports the continued rollout of new framework planning, including

support needs assessments and budget -setting methods to be developed

through Rules and operational arrangements.

Why this matters for participants

New framework planning will shape how participant needs are assessed, how budgets are calculated, and how supports are described and funded. If the new planning process relies heavily on standardised assessment and budget methods, there is risk clinically relevant evidence may be reduced, especially for participants whose functional needs are complex, fluctuating, pain -related, musculoskeletal, neurological or not easily visible in a single assessment encounter.

Why this matter for osteopathy

For osteopathy, the key issue is osteopathic evidence must remain visible and usable in new framework planning where it is relevant to a participant’s disability related function. This includes evidence about movement, mobility, pain -related participation, activities of daily living, secondary musculoskeletal complications, functional deterioration, maintenance of capacity and participation goals. Under

the Government’s own     ‘Unleashing the Potential of our Health Workforce          – Scope

of Practice Review ’ a core recommendation to increase access and equity to

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health workforce      , was to focus on    professional   competency over professional title,

but it appear   s the NDIS   is continuing to follow     the la tter.

Recommendation

The Committee should recommend that new framework planning retain structured consideration of osteopathic evidence where a participant has

disability  -related musculoskeletal, mobility, pain         -related, neurological or complex

functional needs. Exposure drafts of new framework planning Rules, support needs assessment tools and budget methods should be released for consultation with Osteopathy Australia, participants, disability advocates and relevant allied health stakeholders before implementation.

4. Treatment requirements must not over -medicalise NDIS access

What the Bill does The Bill introduces requirements relating to “all appropriate treatment” before a person can meet access requirements.

The Explanatory Memorandum states that “appropriate treatment” means treatment that is evidence -based, can reliably be expected to materially improve, reverse or alleviate the impact of the impairment, and is regularly undertaken or performed in Australia. The Bill also provides for NDIS Rules to prescribe circumstances in which a person is, or is not, required to undergo particular treatment.

The Explanatory Memorandum includes an example of a child in regional Australia who is found not eligible because further investigations and treatment options have not yet been completed; the Explanatory Memorandum states that the fact she lives in a regio nal area with longer specialist waitlists cannot be taken into account.

Why this matters for participants Osteopathy Australia is concerned that the “all appropriate treatment” requirement could delay or deny NDIS access for people who continue to experience substantial functional impairment, even where some form of treatment may theoretically exist.

Treatment availability should not be confused with functional independence. A person may have undertaken treatment and still require disability -related support. A person may also face long waits, cost barriers, geographic barriers, cultural barriers, limit ed local provider availability, or treatment options that may improve symptoms without removing substantial functional impairment.

Submission 649

This is particularly relevant for people with progressive conditions, chronic pain, neurological impairment, complex musculoskeletal disability, developmental conditions or disability -related secondary complications.

The requirement may also reduce participant autonomy if access decisions place excessive weight on whether a person has pursued particular treatment options, rather than whether they continue to experience permanent or likely permanent impairment and subst antial functional limitation.

Why this matters for osteopathy

If the NDIS adopts a more      treatment  -focused access threshold, it is important this

does not narrow the range of clinical evidence, osteopathic input or functional information considered in access decisions, particularly where a participant has a

disability  -related musculoskeletal,      mobility, pain   -related or complex functional

needs. Participants with such needs may require evidence from practitioners who understand how impairment affects daily function, not only whether a treatment pathway has been completed .

NDIS access should not depend on whether a participant has exhausted every possible treatment pathway. It should focus on whether the person has a permanent or likely permanent impairment resulting in substantial functional impairment and disability -relate d support needs.

For osteopathy, the key issue is that disability -related functional needs should not be treated as unresolved “treatment” issues simply because some clinical management options remain available. Osteopathic supports may be directed

toward maintaining funct       ion, supporting mobility, reducing pain         -related

participation barriers, preventing deterioration and supporting daily activity, rather than ‘curing’ or removing the underlying impairment.

Recommendation

The Committee should recommend that the “all appropriate treatment” provisions be amended or clarified so they do not delay or deny access where treatment is unavailable, unaffordable, geographically inaccessible, culturally inappropriate, clinically unsui table, unlikely to remove substantial functional impairment, or only likely to produce partial or delayed improvement.

The Committee should also recommend that access decisions retain a clear focus on functional impairment and disability -related support needs, rather than whether a participant has exhausted all possible treatment or clinical management options.

Submission 649

5. Choice and control require equitable access to appropriate Ahpra -registered allied health , like

osteopaths

What the Bill does The Bill forms part of a broader reform package involving tighter access, standardised planning, support determinations, budget controls, provider registration changes and changes to plan management. Under current NDIS arrangements, osteopathy may be funde d under “Other” practitioner/professional pathways, but plan managers have historically rejected osteopathy under participant plans, creating inconsistent application.

This inconsistency can lead to delayed care, disrupted therapy continuity, greater stress on carers, more time appealing or re -explaining supports, reduced choice and control, and worse outcomes for participants in regional areas or those with complex disa bilities.

Why this matters for participants Participant choice and control are not meaningful if clinically appropriate supports are technically possible but practically difficult to access.

Where a participant has disability        -related musculoskeletal, mobility, pain         -related

or functional needs, they should be able to access an appropriate Ahpra registered allied health practitioner whose skills match those needs. The Scheme should not make acce ss easy for some regulated professions while leaving others administratively uncertain.

This is a participant equity issue, not simply a professional recognition issue.

Why this matters for osteopathy

Osteopathy is currently treated differently from other             similar  allied health

professions    , such as physiotherapy,      in the NDIS pricing, claiming and support

catalogue arrangements. This creates structural inequity for participants who

could benefit   and would prefer to control their choice for          osteopathic care but

face barriers that do not apply to other allied health disciplines.

A dedicated line item or clear claiming pathway would not create automatic entitlement to osteopathy. It would create a transparent mechanism for

participants     , assessors  and program managers       to access osteopathic services

where those services meet NDIS requirements and are linked to disability -related functional need. Supports would still need to be disability -related, reasonable and

necessary, goal    -linked, evidence   -informed and outcome     -monit ored. It would

simply remove avoidable administrative barriers.

Submission 649

Recommendation

The Committee should recommend that the Government establish a clear NDIS pricing and claiming pathway for osteopathic services, including a dedicated support item or line item in the relevant NDIS Pricing Arrangements and Price Limits and Support Catalogue, where services are disability -related, functional,

goal -linked, evidenc   e-informed and delivered by an Ahpra        -registered osteopath.

This pathway should include clear claiming rules to reduce inconsistent interpretation by NDIS delegates, plan managers and providers, and to ensure participants are not prevented from accessing clinically appropriate osteopathic supports solely because of administrative uncertainty.

6. Provider recognition is workforce policy, not just a billing issue

What the Bill does The Bill is framed as a reform to improve sustainability, quality, integrity and market stewardship. The Explanatory Memorandum states that the Bill seeks to improve quality of supports, place the Scheme on a more sustainable footing, address fraud and str engthen regulation.

Why this matters for participants The NDIS does not operate in a separate workforce universe. It draws on the same allied health workforce that supports primary care, rehabilitation, aged care, compensable injury schemes, private practice, community health and disability services.

If the NDIS selectively recognises some Ahpra -registered allied health professions’ while leaving others uncertain or administratively sidelined, it creates artificial workforce constraints. Participants experience this as reduced provider choice, longer w ait times, disrupted continuity, greater travel burden and reduced access to locally available care.

This is especially important in regional, rural and thin -market areas, where the available allied health workforce may not neatly match the NDIS pricing, claiming and support catalogue arrangements.

Why this matters for osteopathy and the wider allied health workforce Osteopathy is the immediate issue for this submission, and it is also an example of a broader system -design problem. Where osteopaths are clinically appropriate, Ahpra -regulated, locally available and able to support disability -related

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musculoskeletal, mobility, pain -related or functional needs, excluding or inconsistently recognising them reduces participant access and system capacity.

A reform package aimed at sustainability should not narrow the effective allied health workforce available to participants. Underusing regulated allied health capacity while increasing pressure on already recognised provider groups is poor workforce design .

This is firstly an issue for osteopathy, because osteopathy remains inconsistently recognised within NDIS pricing, claiming and support catalogue arrangements. It is also a broader allied health workforce issue. The NDIS relies on allied health practitione rs to assess, maintain and build functional capacity across disability, health, rehabilitation, aged care and community settings. Treating some regulated allied health professions as peripheral to the Scheme risks fragmenting a workforce already shared acr oss multiple service systems.

Recommendation

The Committee should recommend that provider recognition be considered as part of NDIS workforce and market stewardship. The Government should review whether current pricing, claiming and support catalogue arrangements unnecessarily restrict participant ac cess to clinically appropriate osteopathic services and, where appropriate, other Ahpra -registered allied health practitioners, particularly in regional, rural and thin -market contexts.

This review should consider the cumulative effect of provider recognition decisions on participant access, allied health workforce capacity, thin -market service availability and pressure on already recognised provider groups.

7. Musculoskeletal disability and secondary complications must be recognised as functional support needs

What the Bill does The Bill strengthens the link between supports and impairments that meet the disability or early intervention requirements. The Explanatory Memorandum states that supports must arise directly from impairments for which the participant meets access requirem ents and that needs relating to impairments that do not meet those requirements should not be funded.

Osteopathy Australia understands the policy intent of ensuring NDIS supports are linked to eligible disability -related needs. However, the practical application of this requirement will need to be carefully managed where participants have

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interacting impairments, comorbidities, secondary complications or functional consequences arising from their primary disability.

Why this matters for participants Participants do not experience their impairments in neat legislative boxes. A person with cerebral palsy, spinal cord injury, acquired brain injury, limb difference, multiple sclerosis, developmental disability, wheelchair dependence or lower -limb impairment may develop secondary musculoskeletal complications

affecting mobility, t     ransfers, self  -care, pain, participation, work, education or

community access.

If the Scheme treats these secondary functional consequences as separate or unrelated, participants may lose access to supports necessary to maintain function and prevent deterioration.

This is particularly important where the secondary complication affects the participant’s ability to use other disability -related supports. For example, pain, reduced mobility, compensatory movement patterns or upper -limb overuse may affect wheelchair use, transfers, personal care, domestic activities, employment, education or community participation.

Why this matters for osteopathy Osteopaths support participants with disability -related presentations including chronic pain arising from neurological or musculoskeletal disability, postural and movement difficulties, secondary musculoskeletal complications arising from primary disabilit y, non -pharmacological pain management needs, and functional goals related to daily living, community participation and capacity building. These are not necessarily “extra” health concerns sitting outside disability support. For many participants, they are part of how disability affects daily function.

Where these needs are connected to a participant’s eligible impairment and affect functional capacity, they should be considered as part of the participant’s disability -related support needs. The key issue is not diagnosis alone, but whether the support ad dresses functional consequences directly relevant to the participant’s disability, safety, independence and participation.

Recommendation

The Committee should recommend that the Bill and associated Rules clarify how secondary musculoskeletal complications, pain -related functional limitations and interacting impairments will be considered where they affect a participant’s

mobility, self   -care,  safety, participation or ability to use other disability           -related

supports.

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This clarification should ensure that legitimate disability -related functional needs are not excluded simply because they present as musculoskeletal pain, compensatory movement, overuse, fatigue, mobility limitation or secondary functional deterioration.

8. Reassessment and plan -renewal changes need stronger participant safeguards

What the Bill does The Bill limits participant -requested reassessments to circumstances involving significant and ongoing changes in support needs. The Explanatory Memorandum states that new section 48A sets conditions for reassessment, including significant and ongoing chan ges in functional capacity or personal/environmental circumstances. It also states that the NDIA decision period for reassessment requests will be extended from 21 days to 90 days.

The Bill also introduces plan -renewal arrangements for old framework plans. These arrangements may renew plans without a full reassessment, while preventing unused funding from carrying over into the next plan.

The Bill also creates mechanisms that may reduce funding for specified groups of supports through support determinations. Where these mechanisms affect

capacity  -building or therapy     -related supports, there is a risk that participants may

lose access to supp orts that maintain function, prevent deterioration, reduce future reliance on higher -cost supports, or support participation.

Why this matters for participants Osteopathy Australia recognises the need to prevent unnecessary or provider driven reassessment requests. However, reassessment is also one of the few mechanisms participants have to respond when their support needs change, their current supports are not working, their informal supports change, their function deteriorates, or their plan no longer reflects their goals. A plan can be technically current but functionally inadequate.

Participants should not be trapped in support arrangements no longer meeting

their needs  or negatively impacting/reducing their functionality            simply because

the reassessment threshold is too rigid. This is particularly important for participants with fluctuating, progressive or complex disability -related needs, where functional capacity, informal supports, pain, mobility, fatigue or participation barriers may change over time without fitting neatly i nto a narrow

reassessment threshold         . The Government would     never consider or    suggest

consumers should not      or cannot   return to their GP if    a proposed   treatment plan

w as not working, but considers this appropriate for people living with disabilities?

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Why this matters for osteopathy Participants need a responsive pathway to adjust supports where current funded supports are not achieving functional benefit, including access to osteopathic supports where clinically appropriate.

Where a participant’s current supports are not maintaining or improving function, mobility, independence or participation, the Scheme should allow reasonable adjustment of supports based on evidence of functional need and

expected benefit. This may include        access to an Ahpra     -registered osteopath

where that support is better matched to the participant’s preferences and disability -related goals, and where osteopathic care is appropriate to the participant’s functional needs.

Recommendation

The Committee should recommend that reassessment and plan -renewal provisions include safeguards allowing participants to seek review or adjustment where current supports are not achieving functional outcomes, where functional needs have changed, where info rmal supports have changed, or where access to osteopathic support, or another Ahpra -registered allied health support, may better meet disability -related goals.

The Committee should also recommend that any support determinations or

budget controls affecting capacity         -building or therapy     -related or functional

support budgets include safeguards to ensure participants retain access to

osteopathic supports where those        supports are disability     -related, goal   -linked,

evidence -informed and directed toward maintaining or improving function, mobility, independence or participation.

These safeguards should ensure participants are not left with plans that are administratively current but no longer adequate to maintain function, safety, independence or participation.

9. Evidence standards should focus on functional outcomes, not only profession -specific evidence hierarchies

What the Bill does The reform package emphasises quality, evidence, reasonable and necessary

supports, and Scheme sustainability. Osteopathy Australia             supports evidence      -

informed decision -making. However, evidence requirements must be applied in a way proportionate to the support being considered, the participant’s functional

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goals, and the realities of evidence generation across different allied health professions and disability cohorts.

Why this matters for participants Evidence matters. But evidence should not be applied in a way that excludes supports simply because the profession -specific evidence base is still developing, especially for smaller Ahpra -registered professions such as osteopathy or complex disability coho rts where large trials are difficult.

For NDIS purposes, the key question should be whether the support is disability related, safe, proportionate, goal -linked, clinically reasoned and capable of being monitored through functional outcomes.

Participant -level evidence should matter. Baseline function, goal attainment, pain -related participation, mobility, self -care, transfers, activity tolerance, community access and reassessment outcomes should all be relevant.

A narrow evidence hierarchy may disadvantage participants whose needs are complex, individualised, or poorly represented in large clinical trials. It may also discourage supports that are reasonable, low -risk and functionally beneficial simply because the available evidence is emerging, mixed, or not specific to one profession.

Why this matters for osteopathy Osteopathy should be assessed according to whether the proposed support is

disability  -related, clinically appropriate, evidence        -informed, safe, proportionate,

goal -linked and capable of demonstrating functional benefit. This is the same standard that shoul d apply across allied health.

A functional outcomes model would apply more fairly to osteopathy and allied health supports. It would require osteopaths, like other providers, to show what functional need is being addressed, what outcome is expected, how progress will

be measured, and w    hen the support should be reviewed              . The NDIA appears to

discount evidence that is acceptable in other funding schemes, especially those

focused on   biopsychosocial,    functional capacity        , such as  workers or traffic

accident schemes        . These decisions or changes           , act as if functional capacity for

people with disabilities     needs to be   ignored or   treated differently    to

biomechanical or physiological evidence associated with functional capacity for people without disabilities.

This approach would support Scheme sustainability by requiring clear links between supports, participant goals, functional outcomes and review points, rather than relying only on profession -specific evidence hierarchies or blanket assumptions about provide r type.

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Recommendation

The Committee should recommend that NDIS evidence requirements include functional outcome evidence, clinical reasoning, participant goals, baseline and progress measures, safety, proportionality and value for money. Evidence standards should be applied con sistently across allied health professions and should not operate as a de facto exclusion mechanism for osteopathy or other smaller Ahpra -registered professions.

Evidence requirements should recognise both published research and participant -specific functional evidence, including documented baseline function, goal attainment, progress measures, review points and demonstrated

impact on mobility, self      -care, participa   tion, independence, safety or capacity

building.

What the Bill does The Bill includes provider regulation and registration reforms. Osteopathy Australia supports proportionate measures that improve participant safety, service quality and Scheme integrity. However, registration reforms should recognise existing regulatory frameworks for Ahpra -registered allied health professions, including osteopathy, and a void duplicating obligations that are already addressed through professional registration.

Why this matters for participants Quality and safeguards are essential. But duplicative or disproportionate registration requirements may reduce provider participation, particularly among small and solo allied health practices.

If regulated providers leave the NDIS because compliance requirements are duplicative, unclear or disproportionate, participants may face fewer choices, longer wait times and reduced continuity of care.

This risk is greatest in regional, rural and thin -market areas, where participants may already have limited access to allied health providers. Additional regulatory requirements should strengthen safeguards without unintentionally reducing access to approp riately qualified practitioners.

Why this matters for osteopathy Osteopaths are already regulated through Ahpra. Any additional NDIS requirements should be clearly justified by risks not already addressed through professional registration, codes of conduct, professional standards, insurance, continuing professional deve lopment (CPD) and existing regulatory obligations.

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For regulated allied health professions, including osteopathy, Ahpra registration already provides an established framework for practitioner qualification, professional conduct, public safety, complaints and disciplinary processes, CPD

and professional acc     ountability. NDIS    -specific requirements should therefore

focus on disability -specific obligations that are genuinely additional to the Ahpra framework.

Recommendation

The Committee should recommend that existing Ahpra registration be recognised as a major baseline safeguard for regulated allied health professions, including osteopathy. Any additional NDIS registration requirements should be

proportionate, risk    -based, no  n -duplicative and accompanied by clear guidance,

transition time and consultation with relevant allied health peak bodies.

The Committee should also recommend that the Government clearly identify which NDIS -specific obligations are additional to existing Ahpra requirements, why they are necessary, and how they will be implemented without reducing participant access to regulate d allied health providers.

11. Implementation must include meaningful consultation and independent monitoring

What the Bill does The Explanatory Memorandum indicates that several key aspects of the reforms will be implemented through Rules, legislative instruments, assessment methods, thresholds and future operational detail.

Several of these matters will determine how the reforms operate in practice, including how functional capacity is assessed, how support needs assessments are conducted, how budget methods are applied, how thresholds are applied, how supports are priced and claimed, how provider registration requirements are implemented, and how participants move through access, planning, new framework planning reassessment and plan -renewal processes.

Why this matters for participants The practical impact of the Bill will depend heavily on implementation. Poor implementation could narrow access, reduce choice, create inconsistent decisions, increase administrative burden, and worsen inequity for participants whose needs are complex, flu ctuating or difficult to capture in standardised tools.

This is particularly important because many participants, families, carers and providers will experience the reforms through operational decisions, forms,

Submission 649

guidance, assessment tools, pricing arrangements and planner or assessor interpretation, rather than through the legislation itself.

Why this matters for osteopathy and implementation Osteopaths and other allied health providers will be central to making the reforms work in practice. If Rules, tools, support categories and pricing arrangements are developed without meaningful input from Osteopathy Australia and the full allied health se ctor, the Scheme risks designing processes that look coherent on paper but fail in real -world service markets.

This includes ensuring that implementation materials reflect osteopathy’s role in functional assessment, capacity building, therapeutic supports and participant outcomes as well as the full range of Ahpra -registered allied health professions that may contr ibute to functional assessment, capacity building, therapeutic supports, participant outcomes and service delivery in thin markets.

Recommendation

The Committee should recommend that exposure drafts of relevant NDIS Rules, support needs assessment tools, budget methods, pricing, claiming and support catalogue changes, and provider registration requirements be released for meaningful consultation befo re commencement.

Consultation should include participants, disability advocates, rural and regional stakeholders, Osteopathy Australia, Ahpra -registered allied health peak bodies, plan managers and providers. The rollout should include independent monitoring and evaluation of participant impact, access equity, workforce effects, regional availability and unintended consequences.

Independent monitoring should include specific attention to whether the reforms affect participant access to clinically appropriate osteopathic supports and other allied health supports, including in regional, rural and thin -market areas.

12. Thriving Kids must not exclude clinically appropriate osteopathic supports for children

What the Bill does The Explanatory Memorandum states that access reforms will support the rollout of Thriving Kids, which is intended to support children aged eight and under with developmental delay and/or autism with low to moderate support needs. The details of these arra ngements remain subject to further agreement between the Australian Government and state and territory governments.

Submission 649

Why this matters for participants Children who currently receive NDIS -funded supports may move into a different service model. If the new model does not recognise the full range of clinically appropriate providers, children may lose access to established therapeutic relationships and suppo rts that assist movement, postural development, mobility, musculoskeletal function, participation and daily activities. Continuity of care is particularly important for children with developmental delay, autism, dyspraxia, cerebral palsy, movement difficulties, postural concerns or musculoskeletal consequences associated with developmental or neurological conditions.

Why this matters for osteopathy Many osteopaths provide paediatric care that supports postural development, movement patterns, musculoskeletal function, pain -related participation and daily activity. If osteopathy is not clearly recognised within Thriving Kids eligibility, employment, commissioning and referral pathways, children who currently access osteopathic support through NDIS plans may lose access, even where, that support is clinically appropriate, and linked to functional goals.

Small and solo osteopathic practices may also be excluded if commissioning models favour larger organisations. This would reduce participant choice and may be particularly problematic in regional and thin -market areas where local provider options are alrea dy limited.

Recommendation

The Committee should recommend that osteopathy be explicitly considered in

the design of Thriving Kids service eligibility         and continuity   -of-care provisions.

Children transitioning from NDIS budgets to Thriving Kids should not lose access to clinically appropriate osteopathic supports where those supports address

disability  -related movement, mobility, postural development, mus             culoskeletal

function, pain -related participation or daily activity needs.

Conclusion

Osteopathy Australia supports reform that strengthens the NDIS for future generations. However, the Bill must not create a narrower, more administratively controlled Scheme that loses sight of real -world function, participant choice and

the clinical expert     ise needed to understand disability        -related support needs.

Osteopathy is not the only issue, but it is a clear example of a broader design problem. The Scheme is tightening access, planning and funding controls while unresolved provider -recognition gaps remain. Unless those gaps are fixed,

participants with muscul       oskeletal, mobility, pain     -related and complex functional

needs may face reduced access to appropriate supports, especially in regional and thin -market areas.

Submission 649

The Committee should recommend amendments and implementation safeguards that preserve participant choice, require clinically informed assessment, recognise relevant osteopathic expertise and, where appropriate,

broader Ahpra   -registered allied health expert        ise, and ensure NDIS pricing,

claiming and support catalogue arrangements reflect the availability and role of clinically appropriate Ahpra -registered osteopaths, alongside other regulated allied health providers available to participants. Provider recogni tion is not just a billing issue. It is participant access policy, workforce policy and system design.

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