National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 735
Senate Submission
Paediatric Occupational Therapist
Introduction
I am writing as a paediatric Occupational Therapist with 15+ years’ experience supporting young children and their families. Every day I see how essential the NDIS is for children’s safety, developmental trajectories, occupational participation and family wellbeing. I am concerned that several proposed legislative changes will reduce access to necessary supports and increase longterm risk for children and families. Below, I outline my concerns in relation to the nine proposed legislative changes.
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Redefining Functional Capacity Assessing children without their usual supports, routines, coregulation, assistive technology or environmental adaptations creates an artificial and clinically inaccurate picture of functional capacity. In practice, children often demonstrate higher performance in structured assessments than in naturalistic environments due to masking, predictability, and adult scaffolding. Recommendation: Functional capacity must be assessed in realworld contexts, considering environmental fit, sensory demands, fatigue, safety, and the sustainability of occupational performance over time.
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Tightening the Definition of “Permanent” Disability Many lifelong developmental disabilities require ongoing therapeutic input to maintain function, prevent regression and support participation. Families frequently face financial, geographic or waitlist barriers to accessing treatment, which should not be interpreted as a lack of “appropriate treatment.” Recommendation: Ongoing therapy should not delay recognition of permanent disability. Definitions of “appropriate treatment” must be clear, realistic and accessible.
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Supports Must Arise “Directly” From Impairment Children’s support needs arise from the interaction between impairment and environment, including sensory processing demands, behavioural regulation needs, safety risks, housing suitability and participation barriers. A narrow interpretation risks excluding legitimate disabilityrelated supports that enable safe and meaningful engagement in daily occupations. Recommendation: Recognise the social model of disability and the role of environmental and contextual factors in shaping support needs.
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Changes to “Value for Money” Lowercost supports are not always clinically appropriate, safe or sustainable. Cheaper alternatives often fail to meet functional goals, increase caregiver burden, reduce participation or lead to crisis intervention. Recommendation: Value for money must consider longterm outcomes, safety, prevention, sustainability, and the cost of failed interventions, not just upfront expenditure.
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“Effective and Beneficial” Evidence Hierarchy Many children do not fit neatly into research populations. Paediatric OT practice relies heavily on clinical reasoning, functional assessment, environmental analysis and
individualised intervention planning. A rigid evidence hierarchy risks disadvantaging children with rare, complex or fluctuating presentations. Recommendation: Maintain strong weighting for participantspecific evidence, lived
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 735
experience, functional assessment and clinical reasoning.
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Increased Reliance on Informal Supports and Parents Families of children with disability often provide care that far exceeds “ordinary parenting,” including constant supervision, behavioural coregulation, sensory support, safety monitoring and highintensity personal care. This level of care is not sustainable without formal supports and contributes to caregiver burnout, reduced workforce participation and family stress. Recommendation: Recognise the intensity, frequency and complexity of disabilityrelated care and avoid shifting further burden onto families.
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WholeofPerson Assessment Children’s needs cannot be separated into isolated components. Occupational performance is influenced by the interplay of sensory processing, communication, behaviour, motor skills, emotional regulation and environmental demands. A narrow assessment approach risks missing the cumulative functional impact of multiple impairments. Recommendation: Maintain a holistic, wholeofperson assessment framework that reflects realworld functioning.
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Controlling Scheme and Plan Inflation Costcontrol measures must not restrict access to early intervention, which is timecritical for developmental outcomes. Delays or reductions in support often lead to increased longterm cost, regression in skills and greater reliance on crisis services. Recommendation: Ensure inflation controls do not limit timely, needsbased supports or early intervention principles.
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Funding Cuts, Caps & Ministerial Powers Broad ministerial powers or funding caps risk reducing transparency, predictability and equity. Children with disability require stable, consistent access to supports to maintain progress and safety. Recommendation: Safeguard participantcentred, evidencebased decisionmaking and ensure funding decisions remain transparent and clinically justified.
Closing Statement
As a clinician, I urge the Senate to ensure that the NDIS remains grounded in realworld disability experience, not administrative simplification. Children and families need a scheme that recognises context, complexity, sustainability and dignity. Thank you for considering this submission.