Submission 755
Submission to the Senate Community Affairs Legislation Committee
Submitted by: Jump Start Therapy Services
1st June 2026
Introduction
Jump Start Therapy Services is a small mobile occupational therapy private practice based on the Far South Coast of New South Wales. We provide community-based occupational therapy services to children, young people, adults and families across regional and rural communities.
We support people with a range of disabilities and support needs including Autism Spectrum Disorder and other neurodevelopmental conditions, intellectual disability, genetic conditions, acquired brain injuries, physical disabilities, neurological conditions such as Multiple Sclerosis and Motor Neurone Disease, and complex social support needs.
Our services include occupational therapy assessment, intervention, coaching, consultation, assistive technology and home modification assessments and recommendations, functional capacity assessments and participation-focused supports across home, early childhood, school, workplace and community settings.
We are a small team of two occupational therapists, each with more than 20 years of experience across government, non-government and private disability and health services. Having worked both before and after the introduction of the NDIS, we have seen the significant positive impact that access to disability supports, early intervention, assistive technology, home modifications and participant choice has had on people with disability and their families.
We acknowledge the importance of ensuring the long-term sustainability of the NDIS. However, we are concerned that several aspects of the proposed National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 may unintentionally reduce access to appropriate supports, increase pressure on families and mainstream systems, create additional barriers for regional communities and move decision-making further away from the lived reality of disability.
We are particularly concerned that the proposed changes place greater emphasis on standardisation, eligibility restriction and cost containment, while reducing recognition of individual circumstances, environmental context and functional participation. This risks shifting responsibility to families, health, education and community systems, while reducing access to the supports that enable people with disability to participate safely and meaningfully in everyday life.
Area of Concern 1: Redefining Functional Capacity
The proposed definition of functional capacity requires assessment of what a person can do without assistance, assistive technology, modifications and environmental supports.
Submission 755
Occupational therapy is built on the understanding that function occurs within context. Many of the people we support function safely and successfully because supports, routines, environmental modifications, assistive technology and co-regulation strategies are already in place.
We regularly support:
-
children who participate in school because sensory, behavioural and environmental supports have been implemented
-
adults with neurological conditions who remain independent because of assistive technology and home modifications
-
people with autism who mask difficulties during assessments but experience significant fatigue or distress afterwards
-
ageing parents providing substantial levels of supervision and support that are often invisible during formal assessments.
Removing these factors from consideration risks creating an artificial picture of disability that does not reflect participation, safety or sustainability.
We are also concerned about the potential loss of whole-of-person assessment.
Many of the people we support live with multiple disabilities, health conditions and intersecting support needs. It is often not clinically realistic to separate functional impacts into isolated categories or determine that a support need arises from only one impairment. Examples include:
- autism and intellectual disability
- ADHD and psychosocial disability
- physical disability and chronic health conditions
- neurological conditions alongside cognitive, behavioural or sensory challenges
- degenerative conditions where physical, cognitive and emotional impacts interact over time. Functional capacity is often influenced by the cumulative interaction of impairments, environmental barriers, fatigue, health-related needs and support availability. Attempting to isolate disability-related needs into single impairments risks creating distinctions that do not reflect how disability presents in everyday life.
The proposed legislation is unclear about who determines which impairments are associated with a participant’s disability, how overlapping impairments will be considered and how support needs will be assessed when multiple conditions interact.
A reductionist approach risks people with complex or intersecting disabilities being found ineligible for supports, receiving reduced supports, or being required to repeatedly prove which impairment is responsible for functional limitations.
Suggested alternatives:
- Ensure assessments consider environmental factors, assistive technology, informal supports, fatigue, behavioural regulation and sustainability of performance over time.
Submission 755
-
Retain a whole-of-person approach to functional assessment and support planning.
-
Recognise fluctuating conditions, invisible disability, masking and support dependency.
-
Ensure assessment frameworks recognise the cumulative and interacting impact of multiple impairments and health conditions.
-
Avoid requiring support needs to be artificially separated into diagnoses where this is not clinically realistic.
-
Involve appropriately qualified allied health professionals in determining functional capacity and support needs.
Area of Concern 2: Tightening the Definition of Permanent Disability The proposed provisions suggest impairments may not be considered permanent unless all appropriate treatment has been undertaken.
Many disabilities are lifelong, even when people continue to engage in therapy, rehabilitation, medical treatment or other supports. We support children who require ongoing therapy to maintain participation and independence, adults with neurological conditions such as Multiple Sclerosis and Motor Neurone Disease who engage in therapy to manage decline and maintain quality of life, and people with physical disabilities who require ongoing intervention to remain safe and independent.
Ongoing treatment should not be interpreted as evidence that a disability is temporary.
Accessing treatment is also influenced by communication difficulties, cognitive disability, psychosocial disability, trauma histories, sensory sensitivities, inability to tolerate clinical environments, lack of culturally safe services and previous negative healthcare experiences.
For some people, treatment environments may be distressing, unsafe or retraumatising. Others may be unable to meaningfully engage with treatment approaches due to their disability, communication needs or personal circumstances.
Within our regional area there are significant shortages of paediatricians, psychiatrists, neurologists and other specialist healthcare providers. Many people face extensive waiting lists, delayed diagnosis pathways, significant travel requirements and substantial out-of-pocket costs. Some families simply cannot afford repeated travel or private specialist services.
Participants may be disadvantaged because treatment is considered theoretically available despite being practically inaccessible due to workforce shortages, geography, cost or service availability. We are also concerned about who determines what constitutes appropriate treatment, what evidence is required to demonstrate treatment has been explored and how disagreements between participants, families, clinicians and decision-makers will be managed.
People with disability should not be placed in a position where access to disability support becomes dependent on undertaking treatment that they do not believe is appropriate, cannot safely tolerate, or choose not to pursue based on their values, cultural considerations, risks or previous experiences. The proposed shift to eligibility based on substantially reduced functional capacity also requires clarification.
Submission 755
People with life-limiting, degenerative or progressive conditions may be disadvantaged if access to the NDIS is delayed until disability has significantly progressed. For people with Motor Neurone Disease, Multiple Sclerosis and other progressive neurological conditions, early access to supports, assistive technology, home modifications and intervention is often critical to maintaining function, independence and quality of life.
In regional areas, where workforce shortages and waiting lists already create delays, extending eligibility decision timeframes to 90 days may further reduce opportunities for timely intervention. By the time a person receives an eligibility decision, engages services and has recommendations implemented, their functional capacity may have significantly deteriorated.
This risks creating a system where people are required to become more disabled before they can access support, reducing opportunities for early intervention, prevention and maintenance of function. It may also increase costs across the NDIS, health system and informal support networks while reducing quality of life and social and economic participation.
Suggested alternatives:
-
Clarify the definition of appropriate treatment and who determines it.
-
Ensure ongoing therapy, rehabilitation and maintenance-based intervention do not prevent recognition of permanent disability.
-
Recognise that treatment availability does not necessarily equate to realistic treatment access.
-
Ensure participants are not disadvantaged due to workforce shortages, geography, financial barriers, communication needs, cultural safety concerns, trauma histories or treatment tolerability.
-
Protect the right of people with disability to make informed decisions regarding treatment without jeopardising access to disability supports.
-
Recognise that many lifelong disabilities require ongoing support to maintain function, reduce decline and maximise participation.
-
Maintain eligibility pathways for early intervention for people with progressive and life-limiting conditions.
Area of Concern 3: Supports Must Arise Directly from Impairment
Disability support needs rarely arise from impairment alone. They are influenced by the interaction between impairment, environment, housing, transport, behavioural regulation, sensory demands, community accessibility and available supports. Examples include:
-
home modifications required because housing environments are unsafe (e.g. level access vs stairs for someone with a mobility impairment)
-
assistive technology required to maintain independence and reduce carer burden
-
support workers required because environmental demands contribute to behavioural escalation
-
community participation barriers related to sensory processing, anxiety or accessibility issues. An overly narrow interpretation risks reducing recognition of genuine disability-related needs.
Submission 755
Suggested alternatives:
- Maintain recognition of the interaction between impairment, environment and participation.
- Ensure supports aimed at preventing crisis, safeguarding risks and social isolation remain recognised.
- Retain alignment with contemporary disability and occupational participation frameworks. Area of Concern 4: Changes to Value for Money We understand the importance of responsible use of public funding. However, stronger emphasis on lower-cost comparable supports may fail to consider long-term outcomes.
Occupational therapists regularly assess supports based on:
- safety
- independence
- participation
- prevention of decline and crisis. Cheaper options are not always comparable and may not achieve the same outcomes.
We have observed inadequate equipment, delayed intervention and insufficient supports contribute to falls, hospital admissions, increased family burden, reduced participation and higher long-term costs.
Suggested alternatives:
-
Require consideration of long-term outcomes and preventative benefits.
-
Ensure comparable supports provide equivalent safety, participation and functional outcomes, with consideration to access to timely servicing and repairs in regional areas.
-
Include carer burden, sustainability and safeguarding considerations within value for money assessments.
Area of Concern 5: Effective and Beneficial Evidence Hierarchy
Participant-specific evidence, lived experience and clinical reasoning should not be given less weight than published research evidence.
Many people we support have highly individualised needs that do not fit neatly within research populations, particularly people with rare conditions, complex disability, psychosocial disability, neurodevelopmental conditions and highly individualised assistive technology requirements.
Occupational therapy clinical reasoning considers context, occupational performance, environmental fit and individual circumstances.
Suggested alternatives:
- Maintain strong weighting for participant-specific evidence and clinical reasoning.
- Recognise maintenance of function, prevention of decline and quality of life as valuable outcomes.
- Ensure evidence frameworks remain flexible enough to account for individual complexity. Area of Concern 6: Increased Reliance on Informal Supports and Families Many families already provide extraordinary levels of unpaid care.
Submission 755
Examples include:
- overnight supervision and support
- ongoing behavioural co-regulation
- seizure monitoring
- physical assistance with transfers and personal care
- extensive advocacy and coordination
- transport across large regional areas to access services. While some of these tasks may appear similar to ordinary parenting or family support on paper, the intensity, complexity and long-term impact are often significantly different.
Reducing formal supports risks transferring burden and responsibility onto families rather than reducing support need.
Suggested alternatives:
-
Assess informal supports based on intensity, complexity and sustainability compared with same-aged peers.
-
Recognise caregiver burden and family functioning within decision-making processes.
-
Ensure funding decisions consider impacts on family wellbeing and workforce participation.
Area of Concern 7: Whole-of-Person Assessment and Standardised Assessment Models
Many disabilities cannot be adequately understood through standardised assessment tools alone.
Clinical judgement remains essential when assessing:
-
participation
-
environmental barriers
-
sensory processing
-
fatigue
-
behavioural regulation
-
executive functioning
-
sustainability of performance across environments. Suggested alternatives:
-
Ensure assessment tools include human oversight.
-
Prohibit fully automated eligibility or funding decisions.
-
Ensure appropriately qualified clinicians remain central to assessment processes.
Area of Concern 8: Controlling Scheme and Plan Inflation
We understand the need for financial sustainability within the NDIS.
However, broad reductions to capacity building and participation supports may create unintended consequences.
These supports often:
- build independence
Submission 755
- reduce future support needs
- increase participation
- reduce crisis presentations
- support school attendance
- maintain employment
- reduce family stress. Reducing preventative supports may increase costs elsewhere across health, education, disability and social service systems.
Suggested alternatives:
- Prioritise early intervention and prevention.
- Evaluate long-term system costs rather than short-term savings.
- Maintain investment in participation and capacity-building supports.
Area of Concern 9: Ministerial Powers, Funding Reductions and Governance
Funding decisions should remain transparent, evidence-informed and based on individual need.
Broad funding reductions, support caps or cohort-based cuts risk leaving people without adequate supports and shifting pressure onto health, education, child protection and family systems. Clear review and appeal pathways are essential to protect participant safety.
We are also concerned about the cumulative impact of:
- pricing pressures
- workforce shortages
- increased compliance obligations
- reduced participant budgets
- regional service sustainability challenges. As a small regional provider, workforce sustainability remains one of the most significant barriers to service access.
Suggested alternatives:
-
Ensure individual needs are considered before funding reductions are applied.
-
Maintain transparent and independent oversight of funding decisions.
-
Limit broad powers to reduce support categories without consultation and agreement with State and Territory Governments and collaboration with the disability community.
-
Ensure pricing arrangements support sustainable regional service delivery.
-
Include allied health representation in assessment, pricing and implementation advisory processes.
Conclusion
Jump Start Therapy Services supports the goal of ensuring the long-term sustainability of the NDIS.
However, several aspects of the proposed legislation risk shifting decision-making away from the lived reality of disability and toward increasingly standardised and administratively driven systems.
Submission 755
Disability does not occur in isolation. Functional capacity, participation, safety and wellbeing are shaped by the interaction between people, environments, supports and communities. Legislation, assessment frameworks and funding decisions must continue to recognise this complexity.
We encourage the Committee to ensure the legislation retains strong recognition of environmental context, professional clinical judgement, participant experience, family sustainability and occupational participation.
We also encourage continued investment in preventative, participation-focused and capacity-building supports that reduce long-term costs while improving outcomes for people with disability, families and communities.
For regional communities, maintaining access to appropriately qualified allied health professionals, sustainable service delivery models and timely supports will remain critical to achieving the long-term goals of the NDIS.
I welcome the opportunity to discuss this submission further.
Alison McDonald (Director) on behalf of Jump Start Therapy Services E: info@jsts.com.au