Submission 714
Submission on the National Disability Insurance Scheme
Amendment (Securing the NDIS for Future Generations) Bill 2026: Practical concerns from frontline paediatric practice
To the Senate Community Affairs Legislation Committee,
Thank you for the opportunity to provide feedback on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.
I am a paediatric occupational therapist working in private practice in New South Wales. I work with children and families who are navigating developmental, sensory, emotional regulation, motor, social, behavioural and participation challenges. I am part of MoveAbout Therapy Services, a paediatric therapy organisation with clinics in Warners Bay, Berkeley Vale and Bella Vista.
In my day-to-day work, I support children and families who are doing their best to participate in ordinary life: getting dressed, going to school, managing transitions, eating meals, playing with peers, joining community activities, sleeping, communicating, regulating emotions and building independence over time.
I understand that the NDIS must be sustainable. I also understand the need to address fraud, poor practice and inconsistency. These are valid concerns. However, I am worried that parts of this Bill may create significant unintended consequences if they are implemented without enough attention to the practical realities faced by children, families, schools, therapists and communities.
The Bill proposes changes across access and planning, fraud measures, governance, automation, new framework planning and transitional rules. It also introduces changes relevant to functional capacity, reassessments, support determinations, reasonable and necessary supports, plan suspension, permanence and eligibility where other services may be considered available. The inquiry was referred on 14 May 2026, with submissions closing on 29 May 2026 and a reporting date of 16 June 2026. The Department describes the Bill as focusing on clarifying eligibility and supports, addressing fraud, and updating governance and administrative arrangements.
My concern is not with the goal of sustainability. My concern is that children and families may be caught in the gap between a policy intention and the real-world systems that are supposed to support them.
- Children’s functional needs are often complex, contextual and changing In paediatric practice, a child’s functional capacity cannot be fully understood outside their everyday environments. A child may appear capable in a quiet assessment room but be unable
Submission 714
to manage the same task in a busy classroom, a loud shopping centre, a rushed morning routine or a playground with unpredictable social demands.
For many neurodivergent children, the difficulty is not simply whether they can perform a skill once. It is whether they can use that skill consistently, safely and meaningfully across real-life settings, especially when tired, overwhelmed, anxious, dysregulated or unsupported.
I am concerned about any approach that risks separating a child’s functional capacity from the personal and environmental contexts that shape their actual participation. In practice, the environment is not an optional extra. It is often the difference between a child participating or not participating.
For example, many children I work with can complete tasks when an adult breaks the task down, provides visual supports, co-regulates with them and adjusts the sensory environment. Without those supports, they may not be able to start, sequence, persist or recover when something goes wrong. That is not a lack of effort. It is a functional support need.
- Functional assessments must be completed by appropriately trained professionals
I am also concerned about how functional capacity assessments may be carried out in practice.
The Bill defines functional capacity as a person’s ability to undertake an activity without assistance from other people, assistive technology or modifications, and in a context that excludes, as far as possible, the impact of environmental and personal circumstances. It also allows NDIS rules to prescribe methods, criteria, classifications and thresholds for assessing that functional capacity.
This makes the quality of assessment extremely important. In paediatric practice, assessing a child’s functional capacity is not a simple checklist exercise. It requires an understanding of child development, disability, neurodivergence, sensory processing, regulation, communication, motor skills, learning, behaviour, family systems and school environments.
If these assessments are conducted by people who are not appropriately trained allied health professionals, there is a real risk that children’s needs will be misunderstood or underestimated.
For example, a child may appear to “manage” a task during a short assessment because they are masking, highly supported, motivated by novelty, or in a calm one-to-one setting. That same child may not be able to complete the task in a busy classroom, during a rushed morning routine, when emotionally overwhelmed, or without adult co-regulation. A trained clinician knows to look beyond whether a child can perform a skill once, and consider whether they can use that skill consistently, safely and meaningfully across everyday environments.
I am particularly worried that assessments completed without paediatric clinical training may miss:
Submission 714
● Children who mask their difficulties until they are exhausted or distressed ● Children whose needs fluctuate depending on sensory, emotional or environmental demands ● Children with complex communication needs ● Children whose regulation and behaviour are misunderstood as “choice” or “non-compliance” ● Children who appear capable because parents, teachers and therapists are providing constant invisible scaffolding ● Children whose support needs increase during transitions, such as starting school, moving into upper primary or entering adolescence
A poor assessment does not just create an administrative problem. It can lead to a child losing access to therapy, families being left without support, schools carrying needs they are not resourced to meet, and problems escalating until the child is in crisis.
If functional capacity assessments are going to play a central role in access, reassessment and planning decisions, they must be completed or meaningfully overseen by professionals with appropriate qualifications and experience. For children, this should include paediatric allied health expertise and input from people who know the child across real environments, including families, educators and existing treating clinicians.
- Reassessment and review processes need to be accessible and responsive
Families often seek reassessment when their child’s needs have changed, when school demands increase, when a transition is approaching, when informal supports are burning out, or when previous funding no longer matches the child’s current needs.
Children’s needs do not always change neatly or dramatically. Sometimes the child’s disability-related support needs become more visible because the environment changes. Starting school, moving into upper primary, beginning high school, puberty, family stress, educator changes, or increased academic and social demands can all expose support needs that were previously hidden or heavily scaffolded.
I am concerned that tighter reassessment thresholds may make it harder for families to obtain timely support when the need is real but difficult to present in a simple administrative way. Many families already struggle to gather reports, understand NDIS language, attend appointments, manage work, care for other children and advocate for their child. If the process becomes more complex, the families with the least time, money and capacity may be the ones most likely to miss out.
This will not reduce need. It may simply delay support until the child, family or school is in crisis.
- Early intervention and capacity building must not be undermined
Submission 714
Early and consistent intervention is often what prevents long-term escalation. In paediatric occupational therapy, we are not just treating isolated skills. We are building capacity in children, families and support networks.
Good therapy helps caregivers understand their child. It supports educators to adjust expectations and environments. It helps children develop regulation, confidence, motor skills, communication, self-care, play, flexibility and participation. It reduces reliance on adults over time when implemented well.
If children lose access to support too early, or if families are moved between systems that are not ready, available or funded to support them, we risk creating higher long-term costs. Children may present later with increased school refusal, family burnout, mental health concerns, reduced independence, social isolation or more entrenched participation barriers.
In my experience, families do not seek NDIS support because they want unnecessary therapy. They seek support because daily life is hard, and the ordinary systems around them are often already stretched.
- There must be a realistic plan for children who are redirected to other systems
If children are found ineligible or are expected to access “alternative supports”, those supports need to actually exist, be accessible, be affordable, and be appropriate for the child’s needs.
At the moment, schools, public health services, community services and private therapy providers are already under pressure. Many families face long waitlists, limited local options and significant out-of-pocket costs. Teachers and educators are also carrying increasing responsibility for children with complex developmental and regulation needs, often without enough training, time or specialist support.
Redirecting children out of the NDIS without a properly resourced alternative system risks shifting the pressure onto schools, families, GPs, emergency services and already stretched public systems. It may also widen inequity. Families with money and knowledge will keep finding pathways. Families without those resources may simply go without.
This is particularly concerning for children over 9 years old, who still require developmental, emotional, social, executive functioning and participation supports. A child does not stop needing capacity-building support because they have reached a certain age. In many cases, functional needs become more complex as the child gets older and expectations increase.
- Continuity of care matters For children with developmental and neurodivergent profiles, trusted relationships are not a bonus. They are part of effective therapy.
Submission 714
Many children need time to feel safe with a therapist before they can participate meaningfully. Families also need time to build trust, share concerns honestly and learn strategies that fit their real routines. Frequent disruption to funding, reassessments, providers or support arrangements can interrupt progress and make therapy less effective.
If the Bill leads to more uncertainty, more funding gaps, or more abrupt changes to plans, children may lose access to clinicians who know them well. Families may need to retell their story repeatedly. Schools may lose the external support that helps them understand and respond to a child’s needs. Therapists may spend more time writing reports and justifying support, and less time providing therapy.
- Workforce and provider sustainability should be considered part of scheme sustainability
Frontline clinicians are already working in a high-pressure environment. Many therapists are managing high caseloads, complex family needs, long reports, funding uncertainty, emotionally intense work and increasing administrative demands.
If reforms reduce provider viability, increase unpaid administration, delay payment, or create greater uncertainty around therapy access, some providers may reduce services, close waitlists, shift away from NDIS work or leave the sector. This would make access harder for families, particularly in regional and outer suburban areas.
Private practice is often filling a gap that public systems cannot currently meet. If private paediatric services become less sustainable, the impact will be felt by children, families, schools and communities.
Practical recommendations
I respectfully ask the Committee to consider the following recommendations:
1. Ensure functional capacity is assessed in real-world context, including home, school, community, sensory, relational and environmental factors. 2. Require functional capacity assessments for children to be completed or overseen by appropriately qualified professionals, including paediatric allied health clinicians with relevant training in child development, disability, neurodivergence and functional participation across home, school and community settings. 3. Protect timely access to reassessments, particularly where children’s needs change due to development, school transitions, family circumstances, increased expectations or emerging risks. 4. Do not redirect children to alternative supports unless those supports are funded, available, appropriate and accessible in practice. 5. Maintain strong access to early intervention and capacity-building supports, including for children over 9 where functional needs remain significant.
Submission 714
6. Protect continuity of care, recognising that trusted therapeutic relationships are central to effective paediatric practice. 7. Consult directly with frontline clinicians, families, schools and providers before implementation, not only peak bodies and system-level stakeholders. 8. Monitor unintended consequences, including increased waitlists, provider closures, school pressure, family burnout, reduced access in regional areas and delayed support leading to crisis. 9. Provide clear, plain-English guidance for families and clinicians, so families are not left trying to interpret complex legislative or administrative changes while caring for children with significant needs.
Conclusion
I support a sustainable NDIS. I also support stronger safeguards against fraud and poor practice. However, sustainability should not be achieved by making it harder for children and families to access the right support at the right time.
The children and families I work with are not abstract policy cases. They are children trying to get through the school day, join play, manage big feelings, learn daily routines, communicate their needs and feel like valued members of their community. Their parents are often exhausted, committed and doing everything they can. Their teachers are often stretched and asking for practical help.
The success of this reform should not only be measured by reduced spending or reduced participant numbers. It should be measured by whether children are more able to participate in everyday life, whether families are less overwhelmed, whether schools are better supported, and whether communities are more inclusive.
I urge the Committee to slow down where needed, listen closely to frontline experience, and ensure that any changes are implemented in a way that is practical, fair and safe for children and families.