Submission 660

Submission regarding practical impacts of the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 on a regional allied health practice

Senate Inquiry Submission

Submitted by: Active Health Riverina Services: Physiotherapy, Paediatric Physiotherapy, Exercise Physiology, Podiatry, Therapy Assistants, Group Classes Locations: Lewisham Avenue Wagga Wagga, Dobney Avenue Wagga Wagga, Coolamon NSW Client group: Mixed paediatric and adult NDIS status: Unregistered provider In operation: Over 25 years serving the Riverina community Date: May 2026 Website: www.activehealthriverina.com.au

About Active Health Riverina Active Health Riverina is a locally owned Allied Health Practice that has been serving the Riverina community for over 25 years. We operate across three clinic locations: Lewisham Avenue and Dobney Avenue in Wagga Wagga, and a third clinic in Coolamon, a rural community approximately 45 kilometres from Wagga Wagga. Our multidisciplinary team delivers physiotherapy, paediatric physiotherapy, exercise physiology, podiatry, group classes and therapy assistant services to children and adults across the region. Approximately 20 per cent of our current caseload is NDIS-funded. We are an unregistered provider. We work closely with participants, families, support coordinators and plan managers to ensure therapy is goal-focused and aligned with each individual’s plan. Our NDIS participants include children with developmental delay, autism and neurodevelopmental conditions, as well as adults with acquired brain injuries, progressive neurological conditions, chronic conditions and complex disability. Wagga Wagga is the major regional hub for the Riverina and Murray regions. Many of our clients travel significant distances to access services that are not available closer to home. Our Coolamon clinic was established specifically to reduce the travel burden on families in surrounding rural communities. For many of these families, we are not one of several options. We are the option.

We are making this submission because the reforms in this Bill, together with decisions already being made about how Thriving Kids will be delivered in NSW, will have serious and compounding consequences for regional families, children and practices like ours. We are not arguing against reform. We are asking the Committee to look carefully at how these changes will land in communities where the margin for disruption is much smaller than it is in metropolitan areas.

Submission 660

Schedule 1: CBDA Budget Reductions (10% from 1 October 2026)

Concern

Capacity Building Daily Activities (CBDA) is the primary funding line through which our NDIS participants access physiotherapy, exercise physiology and podiatry. A mandated 10 per cent reduction to these budgets, phasing from October 2026 as plans are reviewed, will directly reduce the number of therapy sessions our clients can access. The Impact Analysis supporting the Bill argues that the published evidence for high-volume long-term therapy is thin. We acknowledge that evidence standards matter. But this framing, applied broadly, obscures the clinical reality of what we deliver. Paediatric physiotherapy for a child with cerebral palsy or developmental delay is not optional. Exercise physiology for an adult with an acquired brain injury builds the physical capacity that underpins every other goal in their plan. Podiatry for a participant with neuropathy, diabetes or significant gait impairment is preventive care that reduces far more costly health events down the track. These are not high volumes of discretionary therapy. They are the baseline of what these participants need to maintain function, participate in their communities and avoid more intensive support later. A 10 per cent reduction in that context does not mean slightly less of something optional. For families already carefully rationing their plan budgets, it means choosing which appointment to cancel.

Likely real-world impact

• Participants will have fewer funded sessions available and will face real choices about which services to reduce or stop
• For children receiving paediatric physiotherapy through NDIS, reduced hours narrow the developmental window during which early intervention produces its greatest gains
• Adults with complex or progressive conditions may experience functional decline without adequate maintenance therapy, increasing dependence on higher-cost supports later
• This cut falls on top of the travel claiming reduction already in effect since 1 July 2025, which halved our billable travel rate and has already compressed the viability of outreach services to clients in Coolamon and surrounding communities
• The cumulative financial pressure on both the funding available to clients and the revenue available to providers makes NDIS work progressively less viable for small regional practices like ours

Submission 660

Sydney, where registered alternatives exist within a short distance of almost every participant, is not what it looks like in Wagga Wagga or Coolamon.

Likely real-world impact

• If unregistered providers are set lower price limits, participants choosing us will face a choice between paying a gap fee out of pocket, finding a registered alternative, or going without
• The pool of NDIS-registered allied health providers in Wagga Wagga is small. In Coolamon and surrounding rural communities, it is effectively non-existent
• Practices like ours face a forced choice: absorb a lower rate that does not cover the cost of delivering the service, pursue costly and time-consuming registration, or reduce NDS intake
• If small regional unregistered providers reduce NDIS work or exit the market, participants do not move to a registered alternative. They lose access entirely
• The implementation timeline remains unclear. Consultation is not scheduled to conclude until late 2026, which means we cannot plan staffing, service mix or financial viability with any certainty

3. Thriving Kids: Private Practice Exclusion and the Risk of a Regional Service Gap

Concern

This is the area of greatest concern for Active Health Riverina, and the one we believe is most poorly understood in the context of regional service delivery. A significant portion of our paediatric caseload consists of children who, under proposed changes taking effect from January 2028, will be directed to the Thriving Kids program rather than the NDIS. Children aged 8 and under with developmental delay or autism with low to moderate support needs will no longer access individualised NDIS plans. They will instead be supported through a state-commissioned program. In NSW, the Thriving Kids delivery model has already been confirmed. Services will be delivered by non-government organisations commissioned by the Department of Communities and Justice (DCJ). Private providers will only be engaged in what DCJ describes as “limited circumstances” where NFP services are not available. This is not a minor procurement preference. It is DCJ’s structural policy, applied consistently across all human services it funds, including child protection, homelessness and out-of-home care. Thriving Kids in NSW is following the same framework. For Active Health Riverina, this means that a cohort of children we currently support through NDS-funded paediatric physiotherapy may no longer be able to access our services under any funded pathway. We will not automatically transition into the Thriving Kids delivery model. We will need to be specifically engaged, either as a commissioned provider or as a subcontractor to a commissioned NFP, and neither pathway is currently confirmed for private practices in regional NSW. Following advocacy from peak bodies including Occupational Therapy Australia, DCJ has since indicated it is exploring a panel arrangement for private allied health providers. Further detail is promised in the second half of 2026. This is welcome, but it does not resolve the core problem: private practices that currently hold the expertise, the client relationships and the workforce capacity to deliver paediatric allied health therapy in regional NSW are being structurally repositioned from primary providers to contingency options, without a clear transition plan for the families or the clinicians involved.

Submission 660

Why this is particularly acute in regional NSW

In metropolitan areas, the NFP organisations likely to be commissioned for Thriving Kids already have established service footprints, workforce pipelines and referral networks. The transition, while disruptive, has some structural foundation to build on.

In Wagga Wagga and the broader Riverina, the picture is different. The NFP organisations operating here are not currently delivering paediatric allied health therapy at scale. To do so under Thriving Kids, they will need to recruit qualified physiotherapists, exercise physiologists and podiatrists. Those clinicians currently work in practices like ours. This creates a direct and foreseeable workforce competition: the same people who are currently delivering the therapy component of early childhood intervention in our region will be targeted for employment by commissioned NFPs, potentially destabilising the regional allied health workforce at exactly the point when demand is expected to increase.

Families currently on our waitlist for NDIS-funded paediatric physiotherapy need to know now whether the service they are waiting for will still exist in a form they can access. We cannot answer that question. The government has not provided enough operational detail for us to do so.

Submission 660

Section 48A: Stricter Thresholds for Unscheduled Reassessment

Concern

The Bill tightens the circumstances under which an unscheduled plan reassessment can be triggered, requiring evidence of a significant and ongoing change in support needs. For children, this threshold does not reflect how development actually works. Children’s needs change because of growth, developmental progression, school transitions, changing family circumstances and the shifting participation demands of new environments. These changes are often gradual but clinically meaningful. For adults, the same problem applies differently. A participant recovering from acquired brain injury may reach a plateau and then make unexpected gains. A person with a progressive neurological condition may deteriorate in a way that is clinically significant but gradual. Requiring these participants to demonstrate a significant and ongoing change before accessing reassessment creates a system that is designed around administrative convenience rather than clinical reality.

Likely real-world impact

• Children in paediatric physiotherapy may remain on outdated plans that no longer reflect their current developmental needs or functional capacity
• Practitioners will be required to document deterioration rather than developmental progress or changing need to satisfy a reassessment threshold
• Families will be pushed to crisis points before the system is designed to respond
• In regional areas, where families have fewer informal support options to bridge gaps, the consequences of delayed reassessment are more severe
• Critical developmental windows may close while children wait for plans that accurately reflect their current needs

Submission 660

• Children and adults with complex or overlapping presentations are most vulnerable to funding gaps created by a narrow impairment-link requirement

Workforce and Regional Business Sustainability

Concern

Each of the changes described above has consequences in isolation. The concern we want to put to the Committee is what happens when they arrive simultaneously in a regional market that has significantly less capacity to absorb disruption than a metropolitan one. Active Health Riverina has operated in this community for over 25 years. We have built our team, our referral networks and our NDIS capability over a long period. Recruiting qualified physiotherapists, exercise physiologists and podiatrists to Wagga Wagga is a genuine ongoing challenge. Our Coolamon clinic was a deliberate investment in extending access to a rural community that would otherwise have very limited local options. These are not decisions that can be quickly replaced if conditions become unsustainable.

Likely real-world impact

• Therapists facing deteriorating NDIS funding conditions have a rational incentive to redirect their capacity to private and Medicare-funded caseloads where conditions are more stable
• Commissioned Thriving Kids NFPs will compete for the same small regional allied health workforce, creating additional pressure on practices already finding recruitment difficult
• Increased compliance and reporting requirements fall disproportionately on small practices without dedicated administrative or compliance support
• The travel claiming reduction already in place has reduced the financial viability of outreach services to Coolamon and surrounding rural communities. Further funding pressure accelerates the case for withdrawing those services
• If a small regional practice reduces NDIS intake, reduces rural outreach or closes, the community impact is not absorbed by nearby competitors. In many cases there are none
• Schools and early learning settings across the Riverina are already managing significant unmet developmental and disability support needs among students. Reduced community access to allied health therapy increases pressure on teachers and school support staff who are not funded, trained or resourced to fill clinical roles
• The downstream costs of reduced early intervention do not disappear from the budget. They shift to education, mental health, family support and later disability systems, often at greater total cost

Conclusion

Active Health Riverina has been part of the Riverina community for over 25 years. We have watched the NDIS transform access to therapy for people in our region who previously had few options. We have invested in building the capacity to serve that community well, including establishing a rural clinic in Coolamon to reduce the travel burden on families who cannot easily get to Wagga Wagga. We support reform of the NDIS. We understand that the scheme needs to be sustainable. We are not making this submission to protect our revenue at the expense of good policy. We are making it because we work with real families in a real regional community, and we can see clearly how these changes will land for the people we treat every day.

Submission 660

The10percentCBDCut,differentiatedpricingforunregisteredproviders,theThrivingKidsNFP-firstprocurementmodel,tighterreassessmentthresholdsandthenarrowingoftheimpairment-supportlinkareindividuallysignificant.Together,in aregionalmarketwithlimitedsupply,thinworkforcecapacityandonometropolitan safetynetofotherservices,theircombinedeffectisamaterialrisktothecontinuity ofalliedhealthisotherapyaccessforsomeofthemostvulnerablechildrenandadultsinourcommunity. Childrenonlyhaveoneearlychildhood.WeasketheCommitteetosurethatthesequencing,designandregionalsafeguardsattractedtoseverereformsaresufficienttoprotectaccesstothefamiliesinWagga Wagga,CoolamonandthewiderRivernawhodependonservicesslikeours.

Practical Recommendations

• Establish a clear and accessible pathway for private allied health providers to participate in Thriving Kids as primary providers, not only as a last resort, particularly in regional and rural areas where NFP workforce and service capacity is limited
• Publish confirmed provider eligibility arrangements, panel processes and pricing for Thriving Kids in NSW before October 2026 so that families and providers can plan for the transition with certainty
• Delay the restriction of NDIS access formild-to-moderate paediatric presentations in any region untilThrivingKids servicesaredemonstrablyavailableat scale in that region, withconfirmed workforc e and deliveryarrangements inplace
• Applyregional exemptions or loadings todifferentiatedpricingforunregisteredprovidersinareswhere registeredprovider supplyisinsufficientsometo meet participant demand,to avoid creatingaccessgapsinalreadyunderserved communities
• Modify Section48A reassessment thresholds toreconize developmental change childhood transitions and gradual but clinically meaningfulchangeinanticipantsaslegitimategroundsforplanreviewwithoutrequiringevidenceofdeteriorationorcrisis -Assessth ecumulativeimpactofCBDAreductions,travellingclaimingchangesanddifferentiatedpricingtogetheron smallregionalserviceviability,ratherthantreatingeachmeasureasindependent Requiremonitoringofregionalaccesworkforceretentionandservicaviabilitiasimplementationproceeds,w ith a clear and responsive mechanism for adjusting settings where unintended consequences emerge particularlyinareaswithlimitedservicecapacity

ActiveHealthRiverina www.activehealthriverina.com.au May2026