Protecting children with complex needs: A provider experience (Provider experience)

Submission 758

Submission to the Senate Community Affairs Legislation Committee

1. Executive summary All Together Therapy welcomes the opportunity to provide this submission on the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

We support a sustainable NDIS. We support action on fraud, poor practice and waste. We also believe the Scheme must be protected for future generations. However, sustainability cannot be achieved by reducing access to essential supports, narrowing eligibility, weakening safeguards, or shifting responsibility onto families, schools, health services and communities that are already stretched.

This submission focuses on the impact of the proposed changes on children and families, particularly children with developmental delay, autism, intellectual disability, cerebral palsy, complex physical disability, communication disability, sensory and regulation needs, and children who rely on early, consistent and relationship-based support to participate in family, learning and community life.

Children are not small adults. Early childhood support does not work when it is reduced to a short assessment, a generic budget, or a narrow view of disability separated from the environments, relationships and supports that make participation possible. In paediatric allied health, function is never understood in isolation. A child’s capacity depends on their communication system, sensory environment, family support, school or early learning setting, assistive technology, health needs, fatigue, regulation, relationships, routines and trust.

We are concerned that the Bill, taken as a whole, risks moving the NDIS away from individualised, participant-directed planning and toward a more standardised, financially driven model. For children and families, this could mean delayed access to support, reduced therapy access, loss of trusted providers, increased parent stress, worsening developmental outcomes, greater pressure on schools and health services, and increased risk of family breakdown.

2. About All Together Therapy All Together Therapy is a multidisciplinary paediatric allied health provider based in Port Macquarie, New South Wales. We have supported children and families in the Hastings region and surrounding communities for more than 12 years, providing occupational therapy, speech pathology, physiotherapy, dietetics and allied health assistant supports across clinic, home, preschool, school, community and telehealth settings.

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Submission 758

We are a regional provider with deep local knowledge of the access barriers families face. We currently support hundreds of children each year and have supported approximately 1,500 local families over the life of our service. Our work includes children with mild to moderate developmental concerns, neurodevelopmental disability, complex physical disability, communication disability, feeding needs, sensory and regulation differences, and children requiring assistive technology or coordinated care.

Our practice is family-centred, child-led, strengths-based, neuro-affirming and grounded in best practice early childhood intervention. We work closely with families, educators, GPs, community services and other professionals because outcomes for children are strongest when support is coordinated around the child’s everyday life.

3. Key recommendations

4. Do not proceed with the Bill in its current form. At minimum, delay implementation until there has been meaningful consultation with disabled people, children, families, providers, advocates and state service systems, and until impact assessments are publicly available.

5. Retain strong legislative protection for individualised, participant-directed planning. The repeal of section 31 should not proceed unless equivalent or stronger protections are clearly embedded elsewhere in the Act.

6. Amend the proposed functional capacity definition so children are assessed in real-world contexts, including assistive technology, environmental barriers, family support, communication supports, fluctuating capacity, sensory needs, executive functioning and cumulative impacts of multiple impairments.

7. Do not exclude children from NDIS supports based on hypothetical mainstream or foundational supports. Alternative supports should only affect access or funding where they are actually available, timely, accessible, culturally safe, geographically reachable and substantially equivalent.

8. Remove or significantly constrain proposed broad Ministerial powers to reduce funding for participant groups or support categories without individual reassessment and without transparent human rights, safeguarding and child impact assessment.

9. Ensure reassessment pathways remain responsive when a child or family’s circumstances change, including school transitions, developmental changes, puberty, burnout, assistive technology requirement changes, family illness, escalation in behaviours of distress, mental health deterioration or loss of informal support.

10. Protect continuity of care, therapy access, assistive technology, communication supports, community participation and capacity-building supports for children.

11. Prohibit fully automated eligibility, planning and funding decisions. Any use of automation must be transparent, reviewable, independently audited and supported by meaningful human decision-making.

12. Ensure integrity and fraud measures are proportionate and do not create fear, surveillance or administrative burden for families already navigating complex disability systems.

13. Establish, fund and evaluate foundational supports before restricting access to the NDIS. Children must not be moved into service gaps, allowing them to continue to access their trusted local providers.

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Submission 758

4. Children and families must be central to this reform The NDIS has become the place families turn because other systems have not consistently delivered early, timely or coordinated support. In our region, families often face long waitlists for public and community allied health and family support, pressure on schools and early learning centres, and difficulty accessing paediatricians, child mental health services, AAC expertise, feeding support, complex physical disability services and culturally safe supports.

For many children, the NDIS is not an optional extra. It is the mechanism that allows a child to communicate, move, play, eat, regulate, attend preschool, participate in school, build friendships, reduce distress, access equipment, and be included in family and community life. It also gives families practical strategies and confidence to support their child in everyday routines.

Early intervention is often described as “early”, but for families it is also urgent. Developmental windows matter. A child who receives timely support with communication, mobility, feeding, play, emotional regulation or participation may avoid years of escalating distress and exclusion. A family who receives the right support early may avoid crisis, burnout and disconnection from community. Delays and cuts do not make needs disappear; they often make them more complex and more expensive later. Early intervention was always a key part of the NDIS from its inception and must not be diminished. It must co-exist alongside foundational supports/thriving kids.

5. Functional capacity must be assessed in real life, not in isolation

We are deeply concerned by the proposed approach to functional capacity, particularly where capacity may be assessed without assistance from others, without assistive technology or modifications, and excluding environmental and personal circumstances as far as possible.

This approach is not consistent with how children function in real life. A child’s functional capacity is shaped by their environment and supports. A child who communicates through AAC may appear to have very different capacity depending on whether the device is available, programmed, modelled and supported by familiar communication partners. A child with cerebral palsy may participate safely at preschool because they have appropriate seating, mobility equipment, therapy strategies and trained educators. A neurodivergent child may regulate and learn when sensory, communication and relational supports are in place, but may experience distress or shutdown when those supports are removed.

Removing the supports from the assessment does not reveal the “true” child. It creates an artificial scenario that may misrepresent both need and outcome. It also risks penalising children and families for successful intervention. If a child is functioning because support is working, that is evidence of the support’s necessity, not evidence that the support can be removed.

This is particularly concerning for autistic children, children with ADHD, PDA profiles, psychosocial disability, intellectual disability and children with hidden or fluctuating disabilities. Many children mask in short assessments, collapse later at home, or present differently depending on sensory load, relationship safety, communication demands, sleep, pain, environmental factors, fatigue and

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Submission 758

predictability. A snapshot assessment cannot safely replace evidence from families, educators and treating clinicians who understand the child across time and settings.

6. Do not move children into service gaps The Bill appears to place greater emphasis on whether a participant is, or could be, supported by other service systems. In principle, children should be supported by inclusive universal systems. In practice, those systems are not currently resourced to provide the level of disability-specific support many children require.

Families are already being told to seek support from schools, Medicare, state health, community programs, foundational supports or services that either do not exist locally, have long waitlists, are not disability-specific, are not accessible, or are not equivalent to NDIS supports. In regional areas, this gap is even more pronounced.

We are particularly concerned about children with developmental delay and autism being redirected to future foundational or Thriving Kids-style supports before those services are designed, funded, staffed and proven to work. No child should lose or be denied NDIS support because a theoretical alternative is named in legislation or policy. Alternative supports must be real, timely, accessible, culturally safe and capable of meeting the child’s needs. Early intervention and targeted supports is critical in ensuring these children and families have long term positive outcomes.

A referral pathway is not a support. A website is not a support. A generic parenting program is not a replacement for specialist communication intervention, seating and mobility prescription, feeding support, AAC implementation, sensory and regulation support, or coordinated therapy for children with complex needs. Thriving Kids must be an addition, not a replacement or cost saving exercise at the expense of our children.

7. Expanding parental responsibility risks harm to families

We are concerned that the proposed amendments may narrow recognition of disability-related parenting and family supports, or increase expectations that parents absorb support needs that are beyond ordinary parental responsibility.

Parents already do extraordinary unpaid work. They attend appointments, implement strategies, advocate at school, manage equipment, coordinate services, monitor safety, support communication, respond to behaviours of distress, manage sleep and feeding concerns, and provide emotional regulation support often while working, caring for siblings and navigating financial pressure.

There is a critical difference between ordinary parenting and disability-related support. It is ordinary for a parent to help a young child get dressed. It is not ordinary for a parent to need specialised manual handling training, AAC modelling, daily routines that include therapeutic strategies, complex sensory regulation and coregulation plans, pressure care, tube feeding support, equipment maintenance, or constant advocacy so their child can participate safely.

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Submission 758

When disability-related supports are withdrawn, the work does not disappear. It shifts to parents, most often mothers. It increases carer burnout, reduces workforce participation, impacts siblings, increases family stress and may increase contact with child protection systems. It is neither ethical nor economically sensible to reduce preventative supports and then absorb the downstream costs through crisis systems.

8. Reassessment and flexibility are essential for children

Children’s needs change quickly. Development, school transitions, puberty, changes in communication, physical growth, mental health, family stress, medical events and environmental changes can all alter support needs. A child may need more intensive support during transition to school, following surgery, during family illness, when behaviours of distress escalate, when AAC is introduced, or when a new mobility or seating need emerges.

We are concerned about any reform that makes reassessment harder, slower or dependent on narrow definitions of “exceptional” or “unanticipated” circumstances. Many changes in childhood are foreseeable in a broad developmental sense but still require timely and responsive support. A school transition is predictable, but that does not mean the support need is optional. Puberty is predictable, but it can still significantly change regulation, safety, care and participation needs.

A 90-day decision timeframe can be a long time in the life of a child. For a family in crisis, it can be the difference between remaining engaged in therapy, school and community, or falling into breakdown. Families should not have to wait months for support when the need is clear, urgent and disability-related. We are already facing significant challenges to access AT when needs or postural deformities change with significant wait times and administrative burdens that impact children and families. Further restrictions to access these reviews risk the health and wellbeing of children.

9. Continuity of care protects outcomes Families deserve the right to have choice and control over the supports they receive, access to continuity of care, and flexibility to suit their needs. The proposed changes will be felt deeply by the families of disabled children. In paediatric practice, continuity is not a luxury. It is part of the intervention.

Many children take months, and sometimes years, to build trust with clinicians. Children with trauma histories, neurodivergent children, children with communication differences, children with medical complexity, and children who have experienced repeated assessment or service disruption may need substantial time before they can safely engage. AAC implementation can take years. Emotional regulation, motor planning, feeding, participation and family confidence develop slowly through consistent, responsive work across settings.

If funding reductions or provider restrictions disrupt therapy relationships, children do not simply “swap providers”. They start again. Families retell histories, children rebuild trust, educators learn new strategies, and progress can be lost. This is especially concerning in regional areas where there may not be an alternative specialist provider available.

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Submission 758

10. Therapy, assistive technology and participation supports are not extras

Capacity-building therapy supports are often described narrowly as “therapy”, but in children’s lives they are much more than therapy appointments. They are the strategies that help a child communicate pain, ask for help, join play, access learning, move safely, eat safely, tolerate care tasks, sleep, regulate emotions, reduce behaviours of distress, and participate in family and community routines.

Assistive technology is equally essential. AAC, mobility equipment, seating, orthoses, sensory supports, home modifications and environmental adaptations can be the difference between participation and exclusion. If functional capacity is assessed without these supports, or if funding is reduced because a child appears to function with them in place, the assessment misses the point.

Social and community participation supports also matter for children. Inclusion is not only about access to therapy. It is about playgrounds, sport, birthday parties, school excursions, community events, friendships and belonging. Reducing these supports risks increasing isolation for disabled children and families who are already excluded from many ordinary community opportunities.

11. Regional communities need flexible local solutions Regional families experience additional barriers including provider shortages, travel distances, limited specialist services, reduced public options and fewer choices when a provider is not the right fit. Pricing, registration, commissioning and administrative changes that destabilise local providers will have real consequences for children.

A regional family may not have five providers to choose from. They may have one local multidisciplinary service, one visiting specialist, or no local provider with the expertise required. If pricing is reduced, travel is restricted, or administrative burden increases, providers may reduce outreach, close books, stop complex services or withdraw from the NDIS market. This will not reduce disability support need; it will reduce access.

12. Integrity measures must not punish families We support appropriate fraud and integrity measures. Public money should be protected, and children and families deserve safe, ethical providers. However, the narrative around fraud must not be allowed to justify reforms that make ordinary families feel surveilled, blamed or unsafe to use the supports their child needs.

Most families are not misusing the Scheme. They are exhausted, worried and doing their best within an administrative system that is already complex. Compliance processes must be accessible, proportionate, trauma-informed and supported by advocacy. They must recognise that disability itself may affect communication, organisation, executive functioning and capacity to respond quickly to notices or requests for evidence.

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Submission 758

13. Automation and standardisation create particular risks for children

We are concerned by broad powers for automated administrative action and decision-making. Some automation may be appropriate for low-risk administrative tasks. It should not be used to make, or effectively determine, eligibility, functional capacity, support needs or funding decisions for children.

Children’s needs are contextual, developmental and relational. They cannot be safely reduced to a score without careful interpretation. A standardised tool may miss masking, fatigue, communication differences, environmental barriers, cumulative impairments, family stress and the interaction between health, disability, learning and participation. Any use of assessment tools must preserve clinical judgement, family evidence, educator input and review rights.

14. Broader concerns While this submission focuses on children and families, we also share broader concerns raised by disability advocates and allied health organisations, including:

• the cumulative impact of the Bill on participant safeguards, access, planning, funding and review rights;

• the proposed narrowing of permanence and the risk that people may be expected to pursue “all appropriate treatment” even when treatment is inaccessible, unaffordable, unsafe, inappropriate or not freely chosen;

• the risk that broad funding reduction powers could override individualised reasonable and necessary decision-making;

• the lack of clear evidence that mainstream and foundational supports will be ready before NDIS access is restricted;

• the risk of increased pressure on unpaid carers, state health services, education systems, mental health services, child protection and crisis supports; and

• the need for independent human rights, gender, First Nations, rural and remote, child wellbeing and socioeconomic impact assessments before implementation.

15. What government needs to understand Families do not come to the NDIS because they want more systems in their life. They come because their child needs support to participate, communicate, move, regulate, learn, connect and be safe.

Progress takes time. Consistency matters. Trusted relationships matter. Flexibility matters. Disability support is not one-size-fits-all. The supports that appear small on paper are often the supports that hold a family together, keep a child included, and prevent needs from escalating.

A sustainable NDIS must not be built by narrowing the doorway, cutting supports, shifting costs to families and hoping that systems which are not yet ready will catch children before they fall. A sustainable NDIS is one that invests early, listens to lived experience, uses professional evidence wisely, supports families before crisis, and keeps children connected to their communities.

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Submission 758

16. Conclusion All Together Therapy urges the Committee to recommend that the Bill not proceed in its current form. At minimum, implementation should be delayed until there has been genuine consultation, transparent modelling, child and family impact assessment, human rights analysis, and establishment of accessible foundational supports across Australia, including regional communities.

We ask Parliament to ensure that any reform strengthens the NDIS rather than weakening its foundations. The NDIS exists because Australians recognised that disabled people deserve dignity, safety, participation and equality. Children and families deserve a Scheme that protects those principles, not one that makes them harder to access.

References

Available on Request

For more information or to discuss this submission please contact Pip Cullen – CEO – All Together Therapy on 02 6583 4063 or referrals@alltogethertherapy.com.au

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