Submission 769
Submission to the Senate Community Affairs Legislation Committee
Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for
Future Generations) Bill 2026
Submitted by: An occupational therapy Service in Illawarra, NSW
Executive Summary
Our service is a community-based provider delivering in-home occupational therapy services to adults with complex physical, neurological, psychosocial and less visible disabilities.
Our work focuses on assessing how people function in real-world environments and implementing supports that maintain safety, independence, and stability over time. Much of this work is preventative, aimed at reducing the likelihood of deterioration and avoiding escalation into higher-cost systems.
The proposed reforms introduce a shift toward more standardised and administratively driven decision-making, with reduced emphasis on clinical context and individual circumstances.
From a provider perspective, this is likely to result in:
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Overestimation of functional capacity where assessments do not reflect real-world conditions
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Reduction or misalignment of supports required to maintain safety and function
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Increased reliance on families and informal supports beyond sustainable levels
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Reduced community participation and increased social isolation
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Decline in participant health, functioning, and independence
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Increased demand on crisis and acute systems These outcomes do not reduce need. They delay it and redistribute it, often at significantly higher long-term cost.
Introduction
Our service provides in-home services across the Illawarra to adults with complex and often interacting conditions.
We regularly support participants whose functional capacity is influenced by multiple interacting factors, including physical impairment, fatigue, cognitive challenges, environmental barriers, and psychosocial needs. Many participants present with ongoing risk
Submission 769
factors, meaning small changes to supports can have disproportionate impacts on safety, health, and overall functioning.
Our role is to assess how people function in real-world environments and implement supports that reduce risk and prevent escalation.
In practice, many participants maintain stability only because the right supports are in place. When those supports change, even slightly, the impact is often immediate and cumulative.
Functional capacity and real-world application
The proposed approach to functional capacity (section 9B) separates the individual from their environment, supports, and daily demands.
From a service delivery perspective, this does not reflect how function presents in practice.
We regularly observe that:
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Participants may demonstrate tasks in a controlled setting but cannot sustain them safely over time
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Functional performance varies significantly due to fatigue, pain, or cognitive load
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Tasks may be completed, but outcomes are unsafe or inadequate For example:
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Meal preparation may occur, but result in nutritionally inadequate intake or unsafe practices
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Personal care may be performed inconsistently, with hygiene, safety, and risk not adequately managed
Where assessments do not capture these factors, capacity is overestimated. This leads directly to:
- Reduction in supports
- Increased risk within the home
- Gradual decline in health and functioning There is also concern that increasing reliance on standardised tools and automated processes may reduce the role of clinical judgement in decision-making, particularly for people with complex or non-linear presentations.
Submission 769
Administrative complexity, uncertainty and fairness
From a provider perspective, there is increasing reliance on administrative systems, discretionary frameworks, and processes that lack transparency.
Many of the practical implications of the proposed reforms are yet to be defined through future rules and administrative mechanisms. This creates uncertainty for both participants and providers.
There is also concern that decisions affecting support availability may increasingly be made at a system level, rather than based on individual need.
Participants already experience significant barriers navigating the Scheme, particularly those with cognitive impairment, psychosocial disability, or limited support networks.
Increasing system complexity while reducing clarity raises concerns about fairness, consistency, and accessibility.
Impact when supports are reduced
When supports are reduced or misaligned, a consistent pattern is observed in practice:
- Participants initially compensate
- Functional capacity declines over time
- Risks increase within the home
- More intensive supports are required later This commonly results in:
- Deterioration in health
- Reduced safety
- Increased reliance on others
- Escalation into crisis services These outcomes are not unexpected. They are a well-established and predictable pattern in service delivery.
Impact on families and informal supports
Where formal supports are reduced, responsibility shifts to families and informal supports.
This often results in:
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Increased caring responsibilities
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Reduced workforce participation
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Significant physical and emotional strain Over time:
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Carer fatigue and burnout increase
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Carer health deteriorates
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Informal supports break down When this occurs, participants often experience a sudden loss of support, leading to:
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Immediate safety risks
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Crisis presentations
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Need for emergency or acute intervention Community participation and functional decline
Supports that enable community engagement and capacity building play a critical role in maintaining function.
Supports that build capacity and enable participation are not optional in practice. They are essential to maintaining function, preventing isolation, and reducing long-term support needs.
When these supports are reduced:
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Participants disengage from the community
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Isolation increases
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Mental health declines
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Daily functioning deteriorates Participants who become socially isolated often require:
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Increased supports
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Mental health or crisis interventions Impact on service delivery and workforce
The proposed reforms increase pressure on service providers through:
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Increased administrative burden
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Funding constraints
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Greater standardisation This results in:
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Reduced time available for direct clinical work
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Delays in service delivery
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Reduced responsiveness to participant needs Over time, service delivery is likely to shift toward:
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Higher-volume, standardised models
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Reduced continuity of care
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Less opportunity for in-depth clinical assessment and intervention Where clinical input is reduced:
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Interventions become task-focused
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Underlying functional issues are not addressed
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Preventative opportunities are missed System-level impact
Reducing supports within the NDIS does not reduce underlying need.
Instead, need is displaced into other systems.
We observe the following escalation pathway:
- Supports are reduced
- Functional capacity declines
- Risk increases
- An incident occurs (e.g. fall, medical issue, mental health crisis)
- Acute services are engaged This includes:
- Hospital admissions
- Emergency department presentations
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Crisis mental health services Once participants enter these systems:
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Functional decline often accelerates
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Complexity increases
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Higher levels of ongoing support are required From a provider perspective, this is a predictable outcome when supports are not aligned with need.
It is more accurate to understand these changes as redistributing cost across systems, rather than reducing it.
Conclusion
From a provider perspective, the proposed reforms risk reducing the effectiveness of the NDIS as a preventative system.
Where supports are appropriately aligned with need, participants maintain function, safety, and stability.
Where supports are reduced or misaligned, we consistently observe:
- Decline in safety and functioning
- Increased reliance on families
- Escalation into crisis systems
- Higher long-term support needs These changes do not reduce need. They delay and redistribute it, often at greater long-term cost.
In its current form, the Bill presents a high risk of poorer outcomes for participants and increased pressure across the broader system.
For these reasons, our service does not consider it appropriate for the Bill to proceed without substantial revision.
A sustainable system requires accurate, context-based assessment, clinically informed decision-making, flexible supports, and early intervention. Without these elements, cost is not reduced. It is delayed and increased.