Protecting early intervention and developmental supports for children (Participant experience) (Provider experience)

Submission 668

Kristy Williams 20 Williams St

PO Box 1279Occupational Therapist

Bowen QLD 4805Ba Occ Thy

Registration No: OCC0001746692 PH: 0400 853 409 ABN: 81043554655 E: admin@ot4you.com.au Medicare Provider no. 5580882F

Allied Health Services for the Whitsundays Community

29/052026

Submission to the Senate Community Affairs Legislation Committee

Inquiry: National Disability Insurance Scheme Amendment (Securing the NDIS for Future

Generations) Bill 2026

Submitted by: Kristy Williams - OT4You Pty Ltd

Location: Bowen, Whitsundays region, Queensland

Role: Paediatric allied health provider supporting children and families accessing occupational therapy and speech pathology services across rural and regional communities.

Introduction

OT4You welcomes the opportunity to provide a submission to the Senate Community Affairs

Legislation Committee regarding the National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026.

OT4You is a paediatric allied health practice based in Bowen, North Queensland. We provide occupational therapy and speech pathology services to children and families across home, clinic, community, schools, kindies, daycare centres and at times telehealth settings Our service also delivers outreach services to a neighbouring town within our region.

This month, OT4You is celebrating 10 years of service. Over this time, we have had the privilege of working with many children and families, and we are extremely proud of the outcomes we have been able to support. OT4You began as a part-time service, operated by myself while raising my young family in the community I grew up in. It has since grown into a team that now includes three additional occupational therapists and a speech pathologist, allowing us to support the community I truly love and remain deeply committed to serving.

OT4You is embedded in our community in every way we can be. We attend Under 8s Days, visit daycare centres, kindergartens and schools, engage with community organisations, and participate in network meetings, interagency meetings and stakeholder discussions. Our service values:

• Connection,
• Empower,
• Learning,
• Individual,

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• Collaboration and
• Supported continue to guide the way we work with children, families, educators, referrers and the broader community.

As a result of the NDIS, we have been able to support many children and families who may previously have been missed, delayed in receiving support, or unable to access appropriate allied health intervention. The NDIS has not only allowed us to build the capacity of individual children and families, but also to contribute to the capacity, confidence and inclusion of our wider community.

Our submission is informed by our day-to-day experience supporting families who have children with developmental delay, autism, ADHD, intellectual disability, psychosocial and behavioural support needs, functional communication needs, sensory processing differences, motor coordination difficulties, self-care challenges, continence needs, assistive technology needs, complex family circumstances and trauma histories.

We support the goal of a sustainable NDIS. However, sustainability must not be achieved by reducing access to early, functional, developmentally appropriate, individually tailored and family centred supports for children with disability and developmental delay. The long-term sustainability of the Scheme depends on timely, evidence-informed intervention that reduces future crisis, improves participation, strengthens family capacity and supports children to be included in their homes, schools and communities.

Key concerns

We respectfully ask the Committee to consider the following concerns in relation to the Bill:

1. The Bill must protect access to early intervention and developmental supports for children.

2. Any changes to eligibility, planning, assessment or funding must be transparent, evidence- informed and developmentally appropriate.

3. Families in rural and regional areas must not be disadvantaged by reduced flexibility, narrow definitions of support or increased administrative burden.

4. Allied health evidence must remain central to planning decisions.

5. The Scheme must recognise the real costs and service delivery challenges experienced by rural and regional allied health providers.

6. Changes to the NDIS must not shift risk and cost onto families, schools, health services or small providers.

7. Protecting early intervention and developmental supports Children are not simply “small adults”. Childhood is a period of rapid development, during which functional capacity changes across time, environments, relationships and developmental stages. The early years are a particularly important period for brain development, with early experiences,

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relationships and environments helping to shape the foundations for learning, communication, emotional regulation, behaviour, social participation and future wellbeing.

Evidence regarding early childhood development shows that the early years are a period of heightened neuroplasticity. During this time, children’s brains are rapidly forming and strengthening neural connections in response to their experiences, relationships and environments. Positive, responsive and well-supported interactions with caregivers help build the foundations for regulation, communication, attachment, learning and participation. Conversely, when children and families experience ongoing stress, unmet developmental needs, exclusion or repeated failure without appropriate support, these patterns can become more established over time and harder to shift.

For many children, particularly young children with disability, developmental delay or emerging neurodevelopmental needs, early intervention can significantly improve long-term participation, strengthen family capacity and reduce the need for more intensive supports later in life. Early intervention is most effective when it is timely, functional, family-centred and embedded into the child’s everyday routines and environments. This includes supporting parents and caregivers to understand their individual child’s strengths and needs, respond to communication and regulation differences, adapt daily routines, and build skills across home, early childhood, school and community settings.

This level of support cannot be achieved through generic or standardised parenting programs alone, particularly where those programs have been designed primarily around neurotypical developmental expectations. Families raising children with disability, developmental delay or neurodevelopmental differences often require individualised, evidence-informed coaching and practical strategies that are responsive to the child’s functional profile, communication style, sensory processing, regulation needs, developmental stage, family context and everyday environments.

We are concerned that any narrowing of access, tightening of eligibility, or reduction in flexible developmental supports may result in children missing critical windows for intervention.

Children with developmental delay, autism, ADHD, intellectual disability, communication differences and sensory processing differences often require support before functional impacts become severe, entrenched or unsafe. Waiting until a child demonstrates significant failure across home, school or community settings is not consistent with early intervention principles. By this point, patterns of distress, avoidance, behavioural responses, exclusion and family stress may already be well established. These experiences can begin to shape the child’s sense of self, their relationships with others, and their capacity to feel safe and successful in everyday environments.

For children and families experiencing trauma, family stress, instability, complex psychosocial circumstances or reduced informal support, timely early intervention is particularly important. Developmental delay, disability and neurodevelopmental differences can place additional pressure on families who may already be experiencing significant stress. Without early, practical and relationship-based support, families may move into patterns of crisis management, overwhelm and disconnection, increasing risks for the child’s development, wellbeing, participation and safety.

Early intervention can play an important protective role by strengthening caregiver understanding, confidence and capacity; supporting co-regulation and attachment; improving daily routines;

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reducing family stress; and helping families access consistent strategies across home, early childhood, school and community settings. When families are supported early, children are more likely to experience safe, predictable and responsive environments, and families are better equipped to meet their child’s needs before concerns escalate.

For many families, these challenges are further compounded by the reality that parents and caregivers may have their own neurodevelopmental differences, learning needs, sensory processing differences, regulation challenges, trauma histories or unmet support needs, many of which may never have been formally identified or supported during their own childhood. These parents are often doing their best with the tools and experiences available to them, while also trying to understand and respond to the complex needs of their child.

When children and families are not supported early, cycles of unmet need can continue across generations. Without timely intervention, families may remain in patterns of overwhelm, misunderstanding, distress and crisis, not because of a lack of love or commitment, but because they have not been given access to the knowledge, strategies and relational support required to understand and respond to disability and developmental difference effectively.

Early intervention can help interrupt these cycles by supporting both the child and the family system. By building caregiver capacity, strengthening relationships, improving understanding of neurodevelopmental differences, supporting regulation and embedding practical strategies into everyday routines, early intervention can reduce long-term risks for children, families, schools, communities, child safety systems and the NDIS itself.

As a service, OT4You has a strong focus on building parent capacity, connection, shared joy and understanding of each child’s unique strengths, needs and barriers. We develop functional, individualised strategies that are suited to each family and embedded into everyday routines, so that capacity is built across the whole family, not just the child. This model takes time, consistency and flexibility, but in our experience it leads to meaningful and long-lasting outcomes.

Through early intervention, our service has seen meaningful and long-term outcomes for children, families and the wider community. We have supported children who were frequently suspended in Prep due to unsafe behaviours to later receive academic awards, build friendships and develop aspirations for further study, including university pathways. We have seen families shift from surviving and relying heavily on formal and welfare supports, to gaining the confidence and capacity to support their child effectively, complete tertiary study, enter the workforce for the first time and contribute more fully to their community.

We have seen families shift from stress, confusion and disconnection to experiencing shared joy, stronger relationships and greater community participation. We have seen children progress from being unable to complete basic self-care tasks to becoming independent, confident and thriving. We have seen parents shift from doubting themselves to becoming confident advocates for their children.

These outcomes are not achieved through diagnosis alone, generic advice or short-term crisis responses. They are achieved when supports are provided early, functionally, individually and in genuine partnership with families. Reducing access to early intervention risks creating greater long

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term costs for children, families, schools, communities and the Scheme itself, as needs that could have been supported early may become more complex, entrenched and crisis-driven over time.

The children and families we support in the early intervention space often present with complex and intersecting developmental, functional, relational and psychosocial needs. These situations require more than brief advice, standardised programs or isolated therapy sessions. They require intensive, relationship-based, family-centred and functionally embedded intervention that builds skills, strengthens caregiver capacity, supports safe and responsive relationships, and helps interrupt cycles of unmet need before they become more entrenched and crisis-driven.

Recommendation: The Bill should explicitly protect timely access to early intervention and developmental supports for children, including children with emerging functional needs, developmental delay and complex neurodevelopmental presentations. Children should not be required to demonstrate severe, entrenched or crisis-level functional impacts before receiving support. Access should be based on functional need, developmental risk and evidence-informed professional judgement, with supports that are individualised, family-centred and embedded across home, early childhood, school and community environments.

2. Planning decisions must remain functional, individualised and evidence-informed NDIS planning must continue to be based on functional impact, not diagnosis alone. A diagnosis may identify a condition or developmental difference, but it does not, on its own, explain how a child functions across everyday environments, relationships, routines and expectations. Children with the same diagnosis can have vastly different support needs depending on their communication, sensory processing, regulation, motor skills, learning profile, family context, trauma history, health needs, environmental demands and access to informal and formal supports.

This is consistent with occupational therapy models of practice, which require therapists to consider the dynamic interaction between the person, their occupations and their environment. Models such as the Person-Environment-Occupation model, the Person-Environment-Occupation-Performance model and the Canadian Model of Occupational Performance and Engagement recognise that function is not determined by diagnosis alone. Functional capacity is shaped by the interaction between the child’s individual strengths and needs, the activities they are required or expected to participate in, and the physical, sensory, social, cultural and relational environments in which those activities occur.

As occupational therapists, we cannot determine a child’s treatment plan, support needs or functional capacity by diagnosis alone. We must consider how the child actually participates in meaningful daily occupations, including self-care, play, learning, communication, regulation, mobility, social participation and community access. This requires clinical reasoning, contextual assessment and observation across real-life environments. It also requires consideration of environmental barriers and supports, family capacity, routines, expectations, safety, fatigue, sensory demands, relationships and the child’s developmental stage.

Allied health professionals play a critical role in identifying a child’s functional capacity across real life environments. Functional Capacity Assessments, occupational therapy reports, speech

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pathology reports and multidisciplinary evidence provide important information about how a child’s disability impacts their participation and what supports are reasonable and necessary for the child to participate safely and meaningfully.

Environmental factors must be central to NDIS planning decisions. A child may function well in a quiet, predictable and highly supported environment, but experience substantial functional difficulty in a busy, noisy, socially complex or less structured environment. The same child may present very differently across home, school, early childhood settings, playgrounds, shopping centres, sporting environments, community events and self-care routines. Environmental demands, sensory load, communication expectations, social complexity, transitions, fatigue, routine changes and the level of adult support available can all significantly influence a child’s functional capacity.

We are concerned that if the Bill results in more standardised, automated or less individualised decision-making, children with complex but less visible needs may be disadvantaged. If planning decisions rely too heavily on diagnosis, checklists, brief observations or standardised categories, they risk missing the real-world functional impact of disability. This may result in children being under-supported because they appear capable in one context, despite experiencing substantial barriers in another.

For example, a child may manage well in a quiet clinic room with one familiar adult, clear structure and reduced sensory demands, but be unable to participate safely or independently in a busy classroom, playground, shopping centre, sporting environment or self-care routine at home. Similarly, a child may appear verbally capable in a calm assessment setting, but be unable to communicate effectively when overwhelmed, fatigued, anxious, dysregulated or required to navigate complex social situations. Planning decisions that do not consider these contextual differences risk underestimating support needs and increasing the likelihood of exclusion, distress, unsafe behaviour, family stress and crisis escalation.

Recommendation: Planning decisions should be based on functional capacity, developmental need, environmental context and the child’s real-world participation across home, school, early childhood and community settings, not diagnosis alone.

Planning decisions should be made by appropriately qualified and experienced personnel who have a strong and demonstrated understanding of disability, child development, functional capacity, reasonable and necessary supports, and the practical realities of service delivery across home, school and community environments. This is particularly important for children with complex, emerging or less visible support needs, where functional impact may not be immediately obvious without appropriate clinical knowledge, developmental understanding and contextual reasoning.

The Bill should also ensure that allied health reports, Functional Capacity Assessments and multidisciplinary evidence are meaningfully considered in planning and review decisions, particularly where they identify environmental barriers, fluctuating capacity, safety risks, caregiver capacity needs, or support requirements that may not be evident from diagnosis or brief observation alone.

3. Rural and regional families require flexibility

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Families in rural and regional Queensland face additional barriers to accessing supports, including limited local provider availability, long travel distances, higher costs of outreach service delivery, workforce shortages, limited access to specialist paediatric services, reduced public transport options, limited access to diagnostic services, school and health system waitlists, digital access barriers for some families, and greater difficulty accessing coordinated multidisciplinary support.

In rural communities, rigid funding rules or reduced flexibility can quickly result in children going without support altogether. Unlike metropolitan areas, families may not have multiple alternative providers available if one service cannot meet their needs. A lack of flexibility does not simply create inconvenience; it can mean children miss out on therapy, families are left unsupported, and developmental, functional or behavioural concerns escalate while families wait for services that may not realistically be available locally.

Rural service delivery often requires a flexible and responsive model of care. For example, travel, collaboration, non-face-to-face work, assistive technology trials, caregiver coaching, school-based consultation, environmental observations and communication with other professionals may be essential for intervention to be effective. If these activities are not adequately recognised, funded or protected, families may technically have a plan but still be unable to access meaningful or functional support.

Therapy is not limited to the time a clinician spends face-to-face with a child. Effective paediatric allied health support often includes clinical reasoning, planning, communication with caregivers and educators, report writing, resource development, assistive technology recommendations, environmental modification advice, risk management, transition planning and collaboration with other professionals. These activities are particularly important in rural and regional areas, where families may have fewer informal supports, fewer specialist services and less opportunity to access coordinated multidisciplinary care.

For children, support must also occur in the environments where functional difficulties actually arise. A child’s support needs may not be fully understood in a clinic room alone. School, early childhood, home and community-based supports allow clinicians to understand the child’s real-world participation, environmental barriers, sensory demands, safety risks, communication needs, and caregiver or educator capacity needs. Removing or restricting flexibility for these supports risks creating plans that are administratively neat but functionally ineffective.

Rural and regional service delivery is also deeply relational. In our experience, families and communities value providers who take the time to understand their local context, share their commitment to the community, and build genuine relationships over time. Strong outcomes in rural and remote communities are rarely achieved through a simple “fly-in, fly-out” model of service delivery. While outreach can be necessary, it must be supported by continuity, trust, collaboration and visible investment in the community.

As a service, we have learnt that to achieve meaningful and lasting outcomes in rural communities, providers need to be embedded in the community as much as possible. This includes building relationships with families, schools, early childhood services, community organisations, local health providers and other stakeholders. When services are community-focused and relationship-based,

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change does not only occur for individual children and families; it also strengthens the capacity, confidence and inclusion of the broader community.

In rural and regional areas, flexibility is also essential for provider sustainability. Outreach services require travel time, fuel costs, vehicle costs, scheduling flexibility, staff capacity and administrative coordination. When these costs and pressures are not recognised, small regional providers may be unable to continue delivering outreach or community-based supports. This directly reduces access for families who already face significant barriers and widens the gap between metropolitan and rural participants.

OT4You has experienced these challenges directly. Our mission is to provide high-quality allied health services to rural communities, and our service previously provided outreach support to the Moranbah and Clermont communities. However, despite our commitment to rural access, staff retention in these areas was extremely challenging, and the costs, travel demands and practical realities of maintaining outreach services were not sustainable for our team over time. As a result, we have had to cease services in these areas and now focus our service delivery on Bowen and Collinsville.

This experience demonstrates that rural access cannot be solved by assuming providers will simply absorb the additional costs, travel demands, workforce pressures and sustainability risks associated with outreach. When rural and regional service delivery is not adequately recognised or supported, even services with a strong rural mission may be forced to reduce their service areas, leaving families in smaller communities with fewer or no practical options for accessing paediatric allied health care.

Recommendation: The Bill should include safeguards to ensure rural and regional participants are not disadvantaged by reduced flexibility, narrow definitions of support or planning approaches that do not reflect the realities of rural service delivery. Planning decisions should recognise the additional costs, travel requirements, workforce limitations and practical barriers involved in rural and regional allied health support.

Travel funding must be reinstated, protected and adequately recognised as an essential component of rural and regional service delivery. Without adequate travel funding, outreach and community based supports become financially and practically unsustainable for providers, leaving rural families with funding on paper but limited or no realistic access to services.

The Bill should also protect access to flexible, functional and context-based supports, including travel, non-face-to-face clinical work, caregiver coaching, school and early childhood consultation, assistive technology trials, environmental observations, multidisciplinary collaboration and capacity building supports across home, school and community settings.

Policy and pricing settings should also recognise that sustainable rural service delivery requires continuity, relationship-building and community connection, not simply episodic or transactional access to providers. Rural families should not be disadvantaged because meaningful service delivery in their communities requires additional time, travel, collaboration and investment.

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4. Allied health collaboration is essential, not optional For many children with with disability, developmental delay or neurodevelopmental differences, meaningful outcomes depend on collaboration between families, occupational therapists, speech pathologists, psychologists, physiotherapists, behaviour support practitioners, educators, medical professionals, support workers and other key people involved in the child’s everyday life.

Collaboration is particularly important where children have complex communication, regulation, sensory, behavioural, developmental or safety needs. These needs do not occur in isolation, and they are very rarely addressed effectively through separate, disconnected supports. Without funded collaboration, intervention can become fragmented, duplicated or inconsistent. This increases risk for children, families, schools and providers, and can result in families receiving conflicting advice or being left to coordinate complex supports on their own.

Effective paediatric allied health intervention often requires shared planning, communication, joint problem-solving and consistent implementation across environments. Families, educators and support workers need to understand not only what strategies to use, but why those strategies are important and how to embed them into daily routines. This is particularly important for children who require support with communication, regulation, transitions, sensory processing, self-care, behaviour, learning, safety or social participation.

For example, a child using augmentative and alternative communication may require input from speech pathology, occupational therapy, family members, educators and support workers to ensure the system is physically accessible, developmentally appropriate, consistently modelled and embedded into everyday routines. If this collaboration does not occur, the child may technically have access to an AAC system but may not be supported to use it meaningfully across home, school and community settings.

Similarly, children with sensory and regulation needs often require coordinated strategies across home, school and community environments. If one setting understands and supports the child’s regulation needs while another setting uses inconsistent or inappropriate responses, the child may experience increased distress, unsafe behaviours, exclusion, school refusal or family stress. Consistent, collaborative approaches reduce risk and support the child to participate more safely and successfully.

This week alone, our service has engaged in multiple liaison and collaborative meetings by email, phone and in-person consultation to support client outcomes. These discussions have included current functional concerns, therapy goals, strategy alignment across home and school, assistive technology requirements and applications, strategies to build parent capacity, risk management, behaviour and regulation supports, educator capacity-building, communication needs, environmental adjustments and planning for consistency across settings.

This work is not separate from therapy. It is the work that allows therapy to be implemented safely, consistently and meaningfully in a child’s everyday life. Without funded collaboration, families and educators may be left to interpret recommendations in isolation, strategies may not be implemented consistently, and children may not experience the functional gains that their plans are intended to support.

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Collaboration also plays an important role in safeguarding quality and reducing long-term costs. When professionals and key supports work together, they are better able to identify emerging risks early, reduce duplication, prevent conflicting recommendations, support generalisation of skills and ensure that therapy goals are functionally relevant. Without collaboration, supports may appear funded on paper but fail to translate into meaningful outcomes in the child’s everyday life.

Collaboration also carries a real cost for allied health providers and must be appropriately funded. Private practices cannot sustainably carry the cost of essential liaison, multidisciplinary meetings, phone calls, emails, planning, documentation, information sharing and coordination simply because this work occurs outside direct face-to-face therapy. These activities require clinician time, clinical reasoning, administration, professional responsibility, record keeping and follow-up.

For small regional providers, these costs are particularly significant. Staff wages, supervision, training, compliance obligations, professional development, administration, insurance, software systems and quality assurance requirements all sit behind the delivery of safe and effective allied health services. When collaboration is unfunded or inadequately recognised, providers are placed in the position of either absorbing the cost, reducing collaboration, or limiting services. Each of these options creates risk for children and families.

If collaboration is not funded, the quality, safety and effectiveness of therapy is compromised. Best practice early childhood intervention is family-centred, collaborative, capacity-building and embedded in children’s natural environments. When collaboration is removed or treated as an unfunded extra, therapy becomes disconnected from the people, routines and settings where children actually need to use their skills.

This creates several risks. Families may receive fragmented or conflicting advice. Educators and support workers may not be supported to implement strategies consistently. Assistive technology may be recommended but not embedded into daily routines. Behaviour, sensory and regulation supports may be applied inconsistently across environments. Safety risks may not be communicated or managed effectively. Skills developed in therapy sessions may not generalise to home, school, early childhood or community settings. As a result, children may not achieve the functional outcomes their plans are intended to support.

The risk is particularly high for children with complex communication, regulation, behavioural, sensory, developmental or safety needs. For these children, inconsistent implementation can increase distress, unsafe behaviour, exclusion from learning and community settings, family stress, school refusal, carer burnout and escalation to crisis. In this context, collaboration is not an administrative preference; it is a safeguard that supports quality, consistency, generalisation of skills and risk reduction across the child’s everyday life.

Recommendation: The Bill should ensure that collaboration, capacity building, caregiver coaching and multidisciplinary coordination remain recognised and funded as reasonable and necessary supports where they are directly linked to functional outcomes, safety, participation, consistency across environments, generalisation of skills, and risk reduction across the child’s everyday life.

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Planning and pricing arrangements should explicitly recognise the time and cost required for allied health professionals to communicate with families, educators, support workers, medical professionals and other treating providers. Collaboration should not be treated as an optional administrative task or an unfunded provider responsibility, but as an essential component of safe, effective and evidence-informed paediatric allied health intervention.

5. Assistive technology and consumables must remain accessible Many children require assistive technology and consumables to support communication, continence, mobility, sensory regulation, self-care, learning, independence and participation. These supports are often practical, low-cost and highly functional, yet they can make a significant difference to a child’s ability to participate safely and meaningfully in everyday life.

Assistive technology is not simply “equipment”. For many children, it is the tool that allows them to communicate, access learning, participate in routines, regulate their body, complete self-care tasks, move safely through their environment, or reduce reliance on adult assistance. Appropriate assistive technology can improve dignity, safety, inclusion, independence and quality of life.

Examples include communication devices, visual supports, toileting aids, adaptive seating, sensory regulation tools, mealtime equipment, handwriting supports, personal care aids, environmental modifications, mobility supports, continence products and other practical resources that support daily functioning.

We are concerned that overly narrow or inflexible rules around what can be funded may delay or prevent access to practical supports that significantly improve daily functioning. In many cases, early access to appropriate assistive technology or consumables can reduce the need for more intensive supports, improve participation, reduce carer burden, support safety and prevent escalation of functional difficulties.

Delays in access can have significant consequences. A child who does not have access to appropriate communication supports may experience increased frustration, behavioural escalation, reduced participation and limited ability to express needs, choices or distress. A child without appropriate continence supports may experience reduced dignity, exclusion from school or community activities, increased caregiver stress and greater risk of health or hygiene concerns. A child without suitable seating, sensory or self-care supports may require higher levels of adult assistance and may be less able to participate independently across home, school and community settings.

Assistive technology and consumables should be considered in relation to the child’s functional needs, developmental stage, environments and participation goals. Decisions should not be based only on whether an item appears “everyday”, “low cost” or “ordinary”. The key question should be whether the support is required because of the child’s disability or developmental needs, and whether it improves functional participation, safety, dignity, independence or capacity.

Assistive technology applications should also be reviewed by appropriately qualified and experienced personnel who have relevant clinical, functional and equipment-specific knowledge. This is particularly important where occupational therapists, speech pathologists or other allied

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health professionals have completed detailed assessments, equipment trials, clinical reasoning and written reports to justify essential supports.

It is deeply concerning when assistive technology recommendations are declined or delayed by decision-makers who may not have the clinical background required to understand the functional impact, risk considerations, implementation requirements or evidence presented in allied health reports. When this occurs, children may be denied access to supports that are essential for communication, self-care, mobility, safety, regulation, independence or participation.

In rural and regional communities, access to assistive technology and consumables is already challenging. Families may face limited local suppliers, fewer opportunities to trial equipment, longer delivery times, higher freight costs, limited access to specialist prescribers, and reduced availability of clinicians who can support setup, training and implementation. These barriers mean that rural families often wait longer, travel further and carry additional costs to access the same practical supports that may be more readily available in metropolitan areas.

If funding rules become more restrictive or approval processes become more difficult, these existing barriers will be amplified. Rural children may experience further delays in accessing communication supports, continence products, adaptive equipment, sensory regulation tools or other practical resources that support daily functioning. This risks widening the gap between rural and metropolitan participants and leaving children without supports that could improve independence, dignity, safety and participation.

Recommendation: The Bill should protect timely access to assistive technology and consumables where they are evidence-informed, linked to functional need, represent value for money and support participation, safety, dignity, independence or capacity-building.

Assistive technology applications should be reviewed by appropriately qualified and experienced personnel with relevant clinical, functional and equipment-specific knowledge. Decision-makers should be required to meaningfully consider allied health reports, functional evidence, clinical reasoning, equipment trials, risk considerations and implementation requirements before declining or delaying recommended supports.

Planning decisions should allow flexibility for practical, low-cost and early assistive technology solutions, including trials where clinically indicated, so that children are not required to wait until needs escalate before appropriate supports are provided.

The Bill should also include safeguards to ensure rural and regional children are not further disadvantaged by delays, limited supplier access, higher freight costs, limited trial opportunities or reduced access to specialist prescription and implementation support.

6. Families with English as an additional language require accessible processes Many families accessing the NDIS experience additional barriers due to language, literacy, cultural safety, disability literacy, trauma, limited understanding of complex systems, or reduced confidence navigating government processes. These barriers can significantly affect a family’s ability to

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understand correspondence, gather evidence, communicate their child’s needs, participate in planning meetings, request reviews and advocate for appropriate supports.

In our experience, families with English as an additional language often require additional support to understand NDIS processes and correspondence, prepare evidence, participate meaningfully in planning or review meetings, and advocate for their child’s functional needs. Even when interpreters are available, families may still require support to understand disability-specific language, funding categories, planning terminology, reasonable and necessary criteria, assistive technology processes, and the difference between diagnosis, functional impact and support needs.

We are currently supporting a family for whom English is an additional language, whose child has significant disability-related support needs, including a diagnosis of Autism Spectrum Disorder Level

3. This family recently received a phone call from the NDIS; however, due to language and system- navigation barriers, they were unable to clearly explain what the outcome of the call was, what decisions had been made, or what the next steps in the process were.

This creates significant concern. Where families are unable to understand NDIS communication, clarify decisions, respond to requests, provide evidence or advocate for their child’s functional needs, there is a real risk that children with substantial support needs may lose funding or experience delays in access, not because their needs have reduced, but because their families face barriers navigating a complex system.

A more complex, rigid or less flexible system risks widening inequity. Families who are already confident, resourced, highly literate and familiar with service systems may be better able to navigate changes, gather evidence and challenge decisions. In contrast, vulnerable families may lose access to essential supports simply because they cannot effectively understand or engage with the process.

This creates a significant risk for children whose needs may already be less visible, emerging, complex or misunderstood. If families are unable to clearly explain their child’s functional impact, understand what evidence is required, or respond to NDIS requests within required timeframes, children may be under-supported or lose access to supports that are essential for their safety, development, independence and participation.

Cold calls should not be used as the primary method for communicating important NDIS decisions, review outcomes, requests for evidence or changes to participant plans. Many families accessing the NDIS are already under significant stress and may be operating in survival mode. Receiving unexpected calls about complex funding, planning or review matters can create confusion, anxiety and distress, particularly where families are caring for children with significant disability, managing crisis situations, experiencing trauma, or navigating language, literacy or system-access barriers.

This is not an isolated issue. Many of the families we support have experienced unexpected NDIS phone calls about planning, reviews, evidence requests or funding matters. Families often report feeling overwhelmed, confused or unable to recall exactly what was discussed, particularly when the call occurs without notice, when they are caring for their child, at work, managing other family responsibilities, or already under significant stress.

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For families with English as an additional language, low literacy, trauma histories, disability, or limited understanding of the NDIS, these calls can create additional barriers to informed participation. Without written follow-up, families may be left uncertain about what decisions have been made, what evidence is required, what deadlines apply, or what steps they need to take next. This creates a risk that children may lose access to essential supports, not because their needs have reduced, but because the communication process was not accessible or fair.

Accessible processes are particularly important in rural and regional communities, where families may already face limited access to interpreters, advocacy services, specialist clinicians, support coordinators, diagnostic services and culturally safe supports. Without clear communication and additional support to engage with the system, the children and families who most need assistance may be the least able to access it.

For families with English as an additional language and for families experiencing stress, trauma or complex circumstances, accessible communication is not an optional support. It is essential to procedural fairness, informed participation and equitable access. Children with significant disability should not be placed at risk of losing essential supports because their parents or caregivers are unable to understand phone calls, written correspondence, review processes or evidence requirements.

Recommendation:

Recommended accessible communication process: The NDIS should implement a clear, trauma-informed and accessible process for contacting participants and families about planning, reviews, evidence requests, funding decisions or changes to supports.

This process should include:

1. Advance notice of contact Families should be contacted by email, SMS or letter to schedule a suitable time for any significant NDIS phone call or meeting. Cold calls should not be used as the primary method for discussing important planning, review or funding matters.

2. Clear purpose of the call or meeting The notice should clearly state the purpose of the contact, such as plan review, evidence request, funding decision, reassessment, assistive technology request, or clarification of support needs.

3. Agenda provided before the meeting Families should receive a simple agenda before the call or meeting, outlining the key topics to be discussed and any decisions that may be made.

4. Required documents and evidence clearly listed Families should be told what documents, reports or evidence may be required, including who needs to provide them and what information the NDIS is seeking.

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5. Reasonable timeframes Families should be given reasonable time to gather evidence, contact providers, arrange support people, book interpreters, and prepare for the discussion. Timeframes should be clearly communicated in writing.

6. Opportunity to include support people Families should be offered the opportunity to have a support person, interpreter, advocate, support coordinator, allied health professional or trusted person present during the call or meeting.

7. Accessible communication Information should be provided in plain language and in an accessible format. Interpreter support should be offered where required, and written information should be available for families who have difficulty processing verbal information.

8. Written follow-up after contact After the call or meeting, families should receive written confirmation of what was discussed, any decisions made, evidence requested, deadlines, next steps and review rights.

9. No adverse decision without accessible follow-up Participants and families should not lose access to supports, have funding reduced, or be disadvantaged because they did not understand an unexpected phone call or were unable to provide information without reasonable notice and support.

10. Sustainability must include provider sustainability A sustainable NDIS requires a sustainable provider market. This is particularly important in rural and regional communities, where there may be only a small number of allied health providers available and families may have limited alternatives if services reduce, close or withdraw from NDIS work.

Provider sustainability is not separate from participant access. When small regional providers are no longer viable, children wait longer, families travel further, early intervention opportunities are lost, and pressure increases on schools, health services, child safety systems and families.

Small allied health providers are experiencing increasing administrative burden, compliance expectations, reporting demands, workforce shortages, pricing uncertainty and frequent changes to funding rules. These pressures sit alongside the ordinary and necessary costs of running a safe and ethical allied health service, including wages, superannuation, leave entitlements, professional supervision, clinical training, continuing professional development, administration, compliance, insurance, registration, software systems, resources, equipment, premises, recruitment, onboarding, quality assurance and leadership support.

These costs are not optional. They are the foundation required to provide safe, evidence-informed and high-quality services to children and families. Paediatric allied health work also requires significant non-face-to-face time, including planning, documentation, clinical reasoning, liaison with families and stakeholders, report writing, supervision, risk management and preparation of

Submission 668

resources. If pricing and funding arrangements do not recognise the full cost of delivering quality services, providers are forced to absorb unsustainable costs, reduce service quality, limit non-face to-face work, reduce outreach, or withdraw from NDIS service delivery.

Workforce sustainability is particularly challenging in rural and regional communities. Recruiting and retaining allied health professionals requires investment in supervision, training, mentoring, reasonable workloads, professional development, administration support and a workplace culture that protects staff wellbeing. Without this investment, staff burnout and turnover increase. In rural areas, the loss of even one clinician can significantly reduce access for children and families across an entire community.

If reforms increase administrative complexity without recognising the actual cost of service delivery, small regional providers service may reduce NDIS services, limit intake, cease outreach work or withdraw from communities where services are already scarce. This would directly reduce access for children and families in rural areas and widen the gap between metropolitan and regional participants.

This has already occurred within our own service. OT4You previously provided outreach services to Moranbah and Clermont; however, due to the cost, travel demands, workforce pressures and difficulty retaining staff, this outreach model was not sustainable and we made the difficult decision to withdraw from those communities. We have also recently been informed that the only other service providing regular outreach to those communities has also withdrawn due to similar sustainability pressures and difficulties retaining staff.

This means that families in these communities may now have significantly reduced access, or potentially no regular access, to paediatric allied health outreach services. Families may now need to travel to Mackay to access services, which can involve a travel time of approximately two to three hours each way, depending on where they live. For families already managing disability, developmental needs, financial stress, work commitments, school attendance, siblings, transport limitations and fatigue, this is not a minor inconvenience. It can make access to therapy practically impossible.

This is not a theoretical risk. It is a current reality for rural families. When outreach is not financially and operationally sustainable, providers withdraw, children wait longer, families travel further, and early intervention opportunities are lost.

A sustainable Scheme cannot rely on providers absorbing unfunded labour, unpaid collaboration, reduced travel recognition, increasing reporting expectations or pricing arrangements that do not reflect real service delivery costs. If the provider market becomes unstable, participant choice and control becomes theoretical rather than practical, particularly in communities where there are few or no alternative providers.

This demonstrates why provider sustainability must be considered as part of NDIS sustainability. If the Scheme does not adequately recognise the costs of rural service delivery, travel, workforce retention, administration, collaboration and non-face-to-face clinical work, then rural participants may have plans that identify a need for support but no practical way to access that support.

Submission 668

Recommendation: The Bill and any related implementation measures should recognise that provider sustainability is essential to participant access, particularly in rural and regional communities.

This should include:

• reviewing NDIS therapy pricing to ensure it reflects the true cost of delivering safe, ethical and high-quality paediatric allied health services;

• ensuring therapy pricing recognises the higher non-face-to-face clinical workload often required in paediatric practice, including planning, documentation, parent communication, educator liaison, resource development, clinical reasoning, risk management and collaboration with other providers;

• reinstating, protecting and adequately funding travel costs for rural and regional service delivery, including travel time, fuel, vehicle costs, accommodation where required, scheduling impacts and the administrative burden of coordinating outreach;

• recognising that outreach services are often financially and operationally unsustainable when travel funding is reduced or capped, particularly in communities where there are few or no local providers;

• ensuring pricing and policy settings account for the full cost of running a sustainable allied health service, including wages, superannuation, leave entitlements, supervision, training, continuing professional development, compliance, insurance, administration, software systems, resources, equipment, premises, recruitment, onboarding, quality assurance and staff retention;

• reducing unnecessary administrative burden, reporting duplication and compliance requirements that take clinicians away from direct clinical service delivery without improving participant outcomes;

• recognising collaboration, caregiver coaching, multidisciplinary coordination and non-face-to- face clinical work as essential funded components of paediatric allied health intervention, not optional or unfunded provider responsibilities;

• actively monitoring rural and regional provider markets, particularly where communities rely on one or two small providers for access to paediatric allied health services;

• treating provider withdrawal from rural or regional communities as a participant access and equity issue, not merely a provider business issue;

• ensuring any NDIS reforms are assessed for their likely impact on small and regional providers before implementation; and

• avoiding reforms that reduce flexibility, increase administrative burden or shift unfunded costs onto providers in ways that reduce service availability for children and families.

Submission 668

8. Avoid shifting responsibility onto schools, families and health systems NDIS reform must be carefully coordinated with education, health, child development, child safety and foundational support systems. If NDIS access is reduced before clear, funded, accessible and accountable alternative supports are available, children and families may fall through service gaps.

Schools, families and public health services all play important roles in supporting children, but they are not substitutes for individualised disability supports. Schools are responsible for education, inclusion and reasonable adjustments within the school environment. They are not designed or resourced to replace individualised therapy, family capacity-building, assistive technology prescription, home-based support, community participation support or specialist intervention across all areas of a child’s life.

In our local community, schools are already managing significant complexity. Teachers and school staff are supporting increasing numbers of children with disability, developmental delay, trauma histories, behavioural needs, communication difficulties, regulation challenges, learning needs and complex family circumstances. This is occurring within the broader context of a national teacher shortage, high levels of teacher burnout, and increasing expectations placed on schools to respond to needs that extend well beyond education alone.

We have been informed through local stakeholder discussions that in some classrooms in our community, a significant number of children have been affected by domestic and family violence, and approximately one third of children may have additional developmental, learning, behavioural, emotional or support needs in some form. These classroom realities are already placing substantial pressure on educators.

In this context, reducing access to NDIS-funded supports risks shifting further responsibility onto schools that are already stretched. Schools play a critical role in inclusion and education, but they cannot be expected to replace individualised disability supports, allied health intervention, caregiver coaching, assistive technology support, behavioural and regulation planning, family capacity building, or coordinated therapy across home, school and community settings.

When children do not receive appropriate disability and developmental supports, the impact is often felt in classrooms. This can increase distress for the child, disruption to learning, risk of exclusion, pressure on teachers, and stress for other students and families. Supporting children through timely, individualised and collaborative NDIS-funded intervention is therefore not only important for the child and family, but also helps support safer, more inclusive and more sustainable school communities.

Families should not be expected to provide specialist intervention without appropriate therapy support, coaching and capacity-building. Many families are already managing complex care needs, financial pressure, work commitments, siblings, trauma, stress, disability, system-navigation demands and reduced informal support. Shifting responsibility onto families without funded support risks increasing carer burnout, family stress, crisis escalation and reduced child participation.

Public health services are also not a direct replacement for NDIS-funded allied health supports. In many communities, public health and child development services have long waitlists, limited appointment availability, narrow eligibility criteria, and may provide assessment or short-term

Submission 668

intervention rather than ongoing functional capacity-building. Rural and regional families often face even greater barriers to accessing these systems.

If NDIS supports are reduced before alternative systems are fully established and funded, the result will not be reduced need. The need will simply shift elsewhere — to families, schools, hospitals, mental health services, child safety systems and already stretched community organisations. This risks increasing long-term costs and reducing outcomes for children, particularly those with complex developmental, communication, regulation, behavioural, self-care, assistive technology or family support needs.

Reform must avoid creating a gap between the NDIS and future foundational supports. Foundational supports must be clearly defined, funded, available locally, developmentally appropriate, culturally safe, accessible for rural and regional communities, and capable of meeting the needs they are intended to address. Until these systems are in place and functioning, children should not lose access to NDIS supports that are currently enabling safety, participation, development and family capacity.

Recommendation: The Bill should not proceed in a way that reduces access to NDIS supports before clear, funded, accessible and accountable alternative systems are in place.

Any transition to foundational supports, education supports, health supports or other service systems must include:

• clear definitions of what supports will be available, who will be eligible, and who will be responsible for delivering them;

• guaranteed funding, workforce planning and implementation timelines to ensure supports exist in practice, not only in policy;

• recognition that already established allied health services should be utilised to support the design and delivery of foundational supports. Existing providers often hold strong relationships with families, schools, early childhood services, community organisations and local health networks, and have the clinical knowledge, workforce, infrastructure and community understanding required to deliver practical and effective supports;

• safeguards to ensure children do not lose access to essential NDIS supports during transition periods;

• recognition that schools, families and public health services cannot absorb responsibility for individualised disability supports without additional resourcing, training, workforce capacity and accountability;

• recognition of the current pressures already being experienced by schools, including national teacher shortages, teacher burnout, increasing classroom complexity, trauma-related needs, and growing numbers of children requiring additional support;

Submission 668

• specific planning for rural and regional communities, where alternative services may be limited, delayed or unavailable;

• mechanisms to monitor whether children and families are actually able to access replacement supports in their local community;

• clear accountability measures if replacement supports are not available or are not meeting children’s functional needs;

• protection of access to individualised allied health, assistive technology, caregiver coaching, collaboration and capacity-building supports where these are required for safety, development, participation and family functioning; and

• a commitment that children with disability, developmental delay or complex functional needs will not be left without support while systems are being redesigned.

Summary of recommendations

OT4You respectfully recommends that the Committee ensure the Bill:

1. Protects access to early intervention and developmental supports for children.

2. Maintains individualised, functional and evidence-informed planning.

3. Recognises allied health evidence as central to decision-making.

4. Protects access to collaboration, caregiver coaching and multidisciplinary coordination.

5. Ensures rural and regional participants are not disadvantaged.

6. Maintains access to assistive technology, continence supports and practical capacity- building supports.

7. Includes safeguards for families with English as an additional language and other access barriers.

8. Considers the sustainability of small and regional allied health providers.

9. Avoids shifting responsibility onto families, schools or public health systems without funded alternatives.

10. Ensures any changes are implemented transparently, gradually and with meaningful consultation.

Conclusion

OT4You supports the aim of a sustainable NDIS. However, sustainability must be understood in long-term human, social and economic terms. A sustainable Scheme is not achieved by delaying access, narrowing supports, reducing flexibility, or shifting responsibility onto families, schools, health systems or providers that are already stretched.

Submission 668

Early, functional, evidence-informed and family-centred allied health supports help children develop independence, communication, regulation, participation, safety and confidence. These supports strengthen families, reduce crisis, improve inclusion and can reduce future reliance on more intensive services. For children with disability, developmental delay or complex neurodevelopmental needs, early support is not optional. It is the foundation for long-term participation and wellbeing.

We urge the Committee to ensure that the Bill protects the rights and needs of children with disability and developmental delay, particularly those living in rural and regional communities. Rural children and families should not be disadvantaged because services are harder to access, providers are harder to retain, travel is more costly, or local systems are already under pressure.

The NDIS must remain a scheme that is fair, functional, evidence-informed, accessible and genuinely individualised not only for those who can advocate strongly, but for all children and families who need support. This includes families experiencing language barriers, trauma, disability literacy challenges, complex social circumstances, rural isolation or limited access to alternative services.

If reform is to strengthen the NDIS for future generations, it must protect timely early intervention, recognise functional and contextual evidence, support collaboration, preserve access to assistive technology, ensure accessible communication, and maintain a viable provider market. Without these safeguards, the children and families most at risk of being missed may be the very people who experience the greatest harm.

OT4You respectfully asks the Committee to ensure that any changes to the NDIS are implemented in a way that protects access, equity, dignity and long-term outcomes for children, families and rural communities.

Submitted by:

Kristy Williams

Director / Principal Occupational Therapist

OT4You Pty Ltd

Bowen, Queensland