Creative arts therapies inadequate functional assessment (Provider experience)

Submission 756

SUBMISSION TO THE SENATE STANDING COMMITTEE

on Community Affairs

National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026

Submitted by:

Bluebottles Co team

Eriko Kinoshita, Registered Art Therapist (ANZACATA)

Sil Jin, Registered Music Therapist (AMTA)

Date: 30 May 2026 Contact: hello@bluebottles.co

This  submission  is made  jointly by  Eriko  Kinoshita,  Registered  Art  Therapist

(ANZACATA) and Sil Jin, Registered Music Therapist (AMTA) both operating in private practice under Bluebottles Co which is a creative arts therapy studio in Earlwood, NSW. Together we bring front-line clinical experience across creative arts therapies (music and art) serving primarily primary-aged children with Level 2+ Autism Spectrum Disorder (ASD), ADHD and PDA profiles, alongside adults living with severe psychosocial disabilities and complex mental health presentations.

We support and uphold the goal of strengthening systemic integrity within the scheme. However, we are deeply concerned that the Securing the NDIS for Future Generations Bill 2026

relies  on  a  rigid,  standardised  ‘functional  assessment’ framework  that  fundamentally

misrepresents the nature of disability, comorbid trauma, mental health and specialist allied health intervention. This misrepresentation, combined with recent unsustainable pricing reduction, the misclassification of creative arts therapies as social leisure rather than clinical intervention (inconsistent with research) and inequitable tax treatment, risks triggering a significant departure of highly qualified sole-trader clinicians from the scheme who are the very practitioners on whom participants most depend to exercise genuine agency and choice.

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Submission 756

This submission addresses five interconnected concerns:

●​ Over-regulation of already-credentialed allied health professionals ●​ Systemic exclusion of evidence-based Creative Arts Therapies ●​ The misclassification of creative arts therapies (music and art) as social participation rather than clinical intervention ●​ The inadequacy of redirecting complex psychosocial needs to mainstream health ●​ The inadequacy of standardised functional assessment for long-term disability support

Detailed Responses to Key Provisions

1.​ Registration requirements vs. existing professional standards

Issue: The Bill potentially expands mandatory registration across broader provider categories to combat fraud. Context: As Master’s-level qualified therapists registered with ANZACATA and AMTA which are peak professional bodies with rigorous ongoing standards, we already have maintained continuous professional development, clinical supervision and professional indemnity insurance for over 10 years. These obligations are not trivial. They represent thousands of dollars and hundreds of hours of investment annually. The Bill fails to distinguish between this cohort and the uncredentialed operators responsible for the fraud it seeks to address.

Recommendation: The Committee should establish a  clear,  legislated distinction

between uncredentialed providers and highly qualified, self-regulated allied health professionals. Imposing additional NDIS registration layers on credentialed sole traders is both administratively inefficient and counterproductive. It will accelerate the exit of experienced clinicians from the scheme without meaningfully reducing fraud risk.

2.​ Clinical scope and recognition of Creative Arts Therapies

Issue: The Bill establishes clearer definitions of ‘NDIS Supports’ and formalises the role of Support Coordinators. Context: Despite independent economic and health reviews including the Duckett Review acknowledging Creative Arts Therapy as well-integrated and often preferred support modality by our participants, our sector faces consistent systemic exclusion. Participants are routinely required to self-identify and self-navigate to our services because Support Coordinators are

either  under-informed  about  creative  arts  therapies or  are  actively discouraged from

recommending them, believing they are not NDIS Supports. This is not a clinical gap. It is a structural and administrative one. Non-verbal, sensory regulation-based therapeutic pathways are clinically essential for neurodivergent children and those with trauma histories who cannot meaningfully engage with traditional talking therapies.

Recommendation: The legislated ‘Support Lists’ enabled by this Bill must explicitly name and protect evidence-based Creative Arts Therapies as eligible NDIS supports as supported by the Duckett Review (2025), which found music and art therapy effective and beneficial for NDIS participants in appropriate circumstances. The NDIA should also mandate awareness training for Support Coordinators regarding the scope and evidence base of creative arts therapy modalities.

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Submission 756

3.​ Misclassification of Creative Arts Therapies as social and community participation

Issue: The Bill introduces a Ministerial power to reduce funding for specified groups of supports, with social and community participation supports identified as a primary target for reduction. The

proposed  Inclusive Communities Fund ($200  million over three years)  is positioned as an

alternative for participants whose social participation funding is reduced. Context: Creative arts therapies (music therapy and art therapy) are routinely funded under social and community participation line items in NDIS plans. This classification misrepresents what these sessions are. A music therapy session is not equivalent to funding a participant’s choir membership. An art therapy session is not equivalent to funding attendance at a painting class. The therapeutic work occurs within the participatory structure; the participation is the medium, not the outcome. Reducing or capping funding in this category does not redirect participants toward community leisure. It removes access to clinical intervention.

The Inclusive Communities Fund is not a therapeutic alternative for participants who rely on individual music or art therapy as a primary clinical support. For participants with complex

psychosocial  presentations, severe trauma  histories or neurodevelopmental  profiles that

preclude group-based participation, this substitution is not clinically viable. The Parliamentary Library’s Bills Digest notes that the Office of Impact Analysis has found that participants with psychosocial disability will be most significantly affected by reductions in social and community participation funding. For this cohort in particular, creative arts therapies are often the most accessible and sometimes the only accessible therapeutic modality available. Removing it will be a clinical harm not a cost efficiency.

Recommendation: The proposed reduction to social and community participation funding must explicitly exempt registered creative arts therapy supports (music therapy, art therapy and allied creative arts disciplines) delivered by credentialed practitioners. The NDIA should create a distinct funding classification for therapeutic creative arts interventions that reflects their clinical nature, separating them from non-clinical social

and community  activities,  to be  consistent  with  the  Duckett Review's (2025)

recommendations. The Inclusive Communities Fund must not be positioned as a replacement for individual therapeutic support.

4.​ The inadequacy  of  redirecting psychosocial  disability to mainstream

systems

Issue: The  Bill  seeks  to  clarify  the boundary between NDIS-funded supports and those

appropriately provided by mainstream health systems. Context: The NDIA routinely attempts to classify anxiety, depression, personality disorders and complex mood disorders as the responsibility of the Medicare-funded system. However, Medicare currently subsidises a maximum of ten psychology sessions per calendar year, a threshold inadequate for individuals managing profound childhood trauma, systemic trauma

arising from  institutions  such  as  the Family Court or education system or complex,

treatment-resistant presentations due to their disabilities. Ten sessions cannot stabilise, let alone rehabilitate these conditions. Despite decades of advocacy by ANZACATA, AMTA and PACFA, Medicare still does not include access to creative arts therapy.

Recommendation: The NDIS cannot  ethically  divest  itself  of  responsibility  for

psychosocial disabilities under the rationale of ‘mainstream system overlap’ until those

mainstream systems are  realistically and  sufficiently funded to manage complex,

long-term  care  of  disabled  people. Any  boundary-drawing  legislation must be

accompanied by a concurrent commitment to adequately resource the Medicare mental health framework.

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Submission 756

5.​ Standardised support needs assessment and the quality-of-life imperative

Issue: The Bill proposes the introduction of standardised support needs assessments to be delivered via the I-CAN (Instrument for Classification and Assessment of Support Needs) tool.

Context: The persistent NDIS narrative of ‘function, function, function’ fails to account for a foundational clinical reality that individuals with permanent disabilities live with permanent impairments and meaningful progress where it is achievable is neither linear nor rapid. In our clinical experience, the third year of consistent therapeutic engagement is the inflection point at which sustainable, measurable improvement in psychosocial functioning and independent living skills begins to solidify. Subjecting participants to a standardised, time-limited assessment before that threshold is reached does not measure failure of the intervention. It manufactures it. Quality-of-life-centred care is not an alternative to functional outcomes, it is the mechanism through which sustainable functional outcomes are achieved. A particularly serious concern is the impact of any standardised assessment framework on children with Pathological Demand Avoidance (PDA) profiles and other participation-based presentations. Standardised assessments, however well-designed, assume a baseline level of voluntary engagement that many of the children most in need of NDIS support cannot access, not as a behavioural choice, but as a direct manifestation of their disability. A child whose neurotype manifests as an inability to engage with structured tasks, answer questions from an unfamiliar assessor or perform on demand will not fail a support needs assessment. They will be invisible to it.

This is not a theoretical risk. It is a pattern we observe consistently in our practice. Children arrive at Bluebottles Co after being unable to engage with other therapy modalities not because they are untreatable but because the tools used to assess and support them were incompatible with their neurotype. These children have often been described by previous systems as non-compliant, disengaged or unengageable. By the time they reach us, many carry the accumulated weight of that misrecognition. They have internalised the message that they are the problem. The work of the first year (sometimes two) can not be skill-building. It is the slow, relational work of establishing enough safety that the child can begin to be seen at all.

What changes after that point is not incidental. Children who could not tolerate structured engagement begin to initiate. Children who had stopped attempting creative expression begin to play. Children who arrive in silence begin to make music, to show up, to want things for themselves. These outcomes are not measurable at the point of referral. They are not legible to a standardised checklist at six or twelve months. But they are real, they are consistent across our caseload. These kinds of outcomes are what the NDIS was designed to make possible.

Music therapy addresses this through the IMCAP-ND (Individual Music-Centered Assessment Profile for Neurodevelopmental Conditions), a validated discipline-specific assessment tool designed to meet children where they are rather than where a standardised instrument expects them to be. The IMCAP-ND captures domains a support needs checklist cannot: pre-verbal

communication,  affect,  relational attunement, regulatory  states and  self-initiated musical

expression. These are observable, documentable and clinically meaningful indicators and crucially they can be assessed in children who cannot complete a structured interview or cooperate with an unfamiliar assessor.

Recommendation: The support needs assessment framework must formally recognise

validated  discipline-specific  tools as legitimate evidence  of need and therapeutic

progress,  particularly  for  children and  participants whose  presentations make

standardised assessment inaccessible. A model distinguishing between short-term functional goals and long-term stabilisation pathways for complex presentations would better serve both participants and the scheme’s long-term outlook. The undefined assessment gap for children under 16 must be addressed before the framework is

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Submission 756

implemented and provisions must be established for participation-based and non-verbal assessment pathways for children with PDA profiles and other presentations where demand-avoidance, trauma or neurotype make conventional assessment inaccessible. Children who cannot engage with standardised assessment must not be rendered ineligible by the assessment process itself.

Financial Sustainability of Frontline Micro-Providers

The viability of the allied health sole-trader workforce is at a critical breaking point and the mathematics are no longer sustainable.

Since late 2025, music therapy and art therapy providers have absorbed two simultaneous financial shocks:

●​ A 20% price reduction, with standard therapeutic support caps falling from $193.99 to $156.16 per session ●​ Ongoing liability for GST on all income above the $75,000 threshold, despite that threshold remaining static for decades against a backdrop of sustained cost-of-living and business cost inflation.

This dual impact is particularly acute for Creative Arts Therapists, who are not afforded the

same GST-exempt  status  as  psychologists or  occupational  therapists, despite delivering

equivalent therapeutic outcomes for comparable participant cohorts. At the revised rate, a sole trader operating above the threshold effectively receives approximately $141 per session after GST obligations before factoring in rent, professional insurance, supervision costs, professional development and practice administration.

This is not a sustainable business model. Without urgent intervention, the scheme will face significant provider attrition precisely among the specialist practitioners whose skills are most difficult to replace.

Recommendation: The federal government must urgently engage the Australian Taxation Office (ATO) to grant GST-exempt status to registered Creative Arts Therapists, aligning our tax treatment with comparable allied health professions. Concurrently, the $75,000 GST registration threshold should be reviewed and indexed to reflect current economic conditions. These measures are prerequisites not options for maintaining a viable frontline provider workforce.

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Submission 756

Conclusion

The financial and administrative conditions facing frontline creative arts therapy providers are no longer viable. If this Bill proceeds in its current form prioritising standardised assessments, impractical compliance and cost-cutting over genuine, long-term, quality-of-life-centred care, it will erode the very provider network upon which participants rely. It will also make the NDIS structurally incapable of seeing and supporting the children and adults who most need it: those whose disability does not present legibly to a generalised checklist and who can only be reached through the relational, non-verbal and participatory approaches that creative arts therapies offer.

We urge the Committee to treat this submission not as a complaint, but as a diagnostic. The concerns raised here are systemic, they are clinically evidenced and they are shared across the allied health community. Addressing them is not at odds with the goal of a sustainable NDIS. It is essential to it.

Respectfully submitted,

Eriko Kinoshita

Registered Art Therapist  | The Australian, New Zealand and Asian Creative Arts Therapies

Association (Registration No. 46962009)

Sil Jin

Registered Music Therapist | Australian Music Therapy Association (Registration No. 694)

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