Submission 657
Protecting Early Intervention, Choice and Community-Based Supports for Future
Generations
Submission to the Senate Community Affairs Legislation Committee
National Disability Insurance Scheme Amendment (Securing the NDIS for Future
Generations) Bill 2026
About Artform Therapies
Artform Therapies is a regional allied health practice providing Music Therapy and Art Therapy services to neurodivergent and disabled children, adolescents, adults and older
adults across Newcastle, Lake Macquarie, Maitland, Cessnock, Dungog, Muswellbrook and
the Upper Hunter region of New South Wales.
Our services are delivered primarily through a mobile model, supporting participants within their natural environments including homes, schools, early childhood settings and community locations. This approach allows therapeutic strategies to be embedded into everyday routines and environments, while also building the capacity of families, educators, support workers and carers.
The practice supports individuals with a broad range of disabilities and developmental differences including autism, developmental delay, intellectual disability, psychosocial disability, communication difficulties and complex support needs.
A significant proportion of participants supported by Artform Therapies are children and young people who experience challenges with communication, emotional regulation, social participation, sensory processing and engagement in education. Many of these participants live in regional communities where access to specialist allied health services is already limited.
The observations outlined in this submission are drawn from direct clinical practice, ongoing collaboration with families and educators, and the realities of delivering disability supports within regional and community-based settings.
Submission 657
My name is Karla Rignall. I am the owner of Artform Therapies and an AMTA Registered Music Therapist.
I am making this submission as both a frontline music therapy clinician and regional allied health business owner of music and art therapy. The views expressed are informed by my experience supporting neurodivergent and disabled children, adolescents, adults and older adults across regional New South Wales, and through ongoing collaboration with families, educators and community support networks.
Early Intervention Must Remain Accessible
Many children referred to my service do not initially present with severe disability. Instead, families seek support because their child is experiencing challenges with communication, emotional regulation, sensory processing, social participation, play skills or developmental milestones.
Early intervention is most effective when support is provided before difficulties become entrenched.
If access pathways become more restrictive, there is a risk that children who would benefit from support early will instead wait until difficulties become more significant, more complex and more costly to address.
In practice, delayed intervention often leads to increased stress for families, increased pressure on schools and educators, reduced participation opportunities and the need for more intensive supports later.
While Foundational Supports and Thriving Kids may provide valuable support for some families, these systems are still being established. There remains uncertainty regarding workforce capacity, service availability and accessibility in regional communities.
Functional Capacity Assessments May Not Reflect Real Life
I am concerned that greater reliance on functional capacity assessments may not adequately capture the lived experience of many neurodivergent children and people with disability.
Children often perform differently across settings. A child may appear capable during a short assessment but struggle significantly with communication, emotional regulation, learning, peer relationships and participation within everyday environments.
Many neurodivergent children work extremely hard to mask their challenges in structured settings. Families and educators often see a very different presentation at home, in the classroom and in community environments.
Submission 657
If decision-making relies too heavily on narrow assessments or thresholds, some children with genuine support needs may miss out on intervention that could significantly improve long-term outcomes.
Restrictions on Reassessments and Plan Flexibility
I am concerned about the proposed restrictions on reassessments and broader reductions in plan flexibility.
Children’s developmental needs change. Family circumstances change. Support needs change.
Families may experience changes in schooling, family structure, housing, informal supports, mental health or health circumstances that significantly affect a child’s functioning and support requirements.
If families face additional barriers when requesting reassessments, there is a risk that supports will no longer align with actual needs.
I have already seen how reduced flexibility can impact participants.
One child on my caseload experienced a reduction in access to Music Therapy following changes to quarterly funding arrangements. Prior to these changes, the child was able to access weekly therapy. Following the funding adjustment, access reduced to approximately monthly sessions.
For children working on communication, emotional regulation and developmental goals, consistency matters. Reduced frequency can slow progress and place additional pressure on families attempting to maintain gains between sessions.
Concerns Regarding Transition to Thriving Kids
I currently support three children living in regional New South Wales who are expected to transition from NDIS-funded supports to the Thriving Kids program.
All three children experience significant challenges with communication, social/play skills and emotional regulation.
Based on their individual needs, supported playgroups or group-based interventions would not currently provide an appropriate alternative to the supports they receive through Music Therapy and Art Therapy.
These children experience sensory overwhelm, communication challenges and regulation difficulties that make participation in busy group environments difficult and, at times, counterproductive.
Submission 657
Their current Music Therapy supports are delivered in their natural environments, including home and school settings. This allows therapeutic strategies to be embedded directly with families and educators where challenges occur every day.
One child currently accesses both Music Therapy and Art Therapy. This combination has been the most effective intervention for supporting communication, social interaction and play development.
The family reports that previous interventions, including speech pathology and occupational therapy, did not achieve the same level of engagement or progress. They describe Music Therapy and Art Therapy as emotionally safe, validating and accessible approaches that allow their child to express emotions, build relationships and communicate in ways that traditional talking-based approaches could not.
Another child has Autism Spectrum Disorder Level 2 and experiences communication delays, emotional regulation difficulties and reduced social confidence.
These challenges affect her ability to participate in classroom discussions, advocate for herself and navigate peer relationships.
Music Therapy provides a safe environment for developing communication, confidence, emotional expression and social participation skills. Removing this support without a suitable alternative, risks slowing or reversing progress that has taken years to build.
Children should not lose access to therapies that are demonstrably working simply because they do not fit neatly within a standardised evidence framework or because a new service system is still being established.
Evidence Must Include More Than Research Alone
I support evidence-informed practice and accountability within the NDIS.
However, evidence-informed practice should not be reduced to a narrow interpretation of published research alone.
Many children with disability present with highly individual needs, complex developmental profiles and unique family circumstances.
As clinicians, we draw on multiple sources of information including research evidence, clinical expertise, family feedback, participant outcomes and lived experience.
Several children within my service have made meaningful gains through Music Therapy and Art Therapy after limited success with more traditional interventions.
Submission 657
These outcomes are visible to families, educators and clinicians and should continue to be recognised when determining what supports are appropriate and effective for individual participants.
The most effective intervention is not always the one with the largest research base. Sometimes it is the intervention that the child can meaningfully engage with and sustain over time.
Regional Workforce and Provider Sustainability
Regional communities already face significant challenges accessing creative allied health services such as Music Therapy and Art Therapy.
Families frequently experience:
- workforce shortages
- lengthy waitlists for Occupational Therapy and Speech Pathology supports
- long travel distances
- reduced provider choice
- limited access to specialist services Small, creative allied health music and art therapy providers play a critical role in addressing these gaps.
As a regional small business owner, I am concerned about the cumulative impact of ongoing reforms, increasing administrative requirements, workforce shortages, pricing pressures and uncertainty regarding future service pathways.
If reforms unintentionally reduce the viability of community-based music and art therapy providers, participants may experience reduced choice, longer waitlists and the loss of local services.
This risk is particularly significant in regional and rural communities where alternatives are often limited or unavailable.
Long-Term Consequences
While the intention of the Bill is to improve sustainability, it is important to consider where costs may shift if supports become less accessible.
Reduced access to early intervention and effective supports may contribute to:
- increased educational support needs
Submission 657
- greater school disengagement
- increased pressure on families and carers
- increased demand on health and mental health services
- reduced social participation
- poorer long-term employment outcomes The long-term social and economic costs of delayed support should be carefully considered alongside short-term financial savings.
Recommendations
-
Ensure functional capacity assessments consider participation across real-world environments, including home, school and community settings.
-
Maintain flexible pathways for reassessment when participants experience genuine changes in circumstances or support needs.
-
Ensure children transitioning from the NDIS to Foundational Supports or Thriving Kids can continue to access individualised allied health supports where clinically appropriate.
-
Avoid a one-size-fits-all approach that assumes group programs or supported playgroups will meet the needs of all children with developmental delay or autism.
-
Establish continuity-of-support arrangements so children do not lose effective therapies before alternative services are available.
-
Ensure evidence-informed decision-making incorporates research evidence, clinical expertise, participant outcomes and lived experience.
-
Monitor regional and rural impacts separately to ensure reforms do not disproportionately affect families outside metropolitan areas.
-
Consider the impact of reforms on provider sustainability and workforce availability, particularly in regional communities.
-
Ensure pricing and funding decisions are transparent and reflect the true cost of delivering services in regional and remote areas.
-
Continue meaningful consultation with participants, families, clinicians, providers and peak bodies throughout implementation.
Submission 657
Conclusion
As a frontline music therapy clinician and regional business owner of music and art therapy, I support efforts to strengthen the sustainability and integrity of the NDIS.
However, sustainability should not come at the expense of timely access to effective supports for children and families who are already navigating significant challenges.
The success of these reforms will depend not only on legislative change but on careful implementation. Particular attention should be given to unintended consequences for neurodivergent children, regional communities, families and the providers who support them every day.
Thank you for the opportunity to provide this submission.