Early intervention occupational therapy supports children's skills development (Provider experience)

Submission 773

31 May 2026

To whom it may concern,

Re: Submission to the Senate Inquiry

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill

2026

I am writing as an occupational therapist and the director of an allied health business in Melbourne’s outer west. We provide occupational therapy services to children, adolescents and their families across our clinic, in homes, in the community, in schools and early learning settings. Alongside direct therapeutic intervention, we provide education, training and support to parents, carers, teachers and support workers, so that a child’s skills are built and carried into their everyday home, community and schooling environments.

While  I acknowledge the importance of ensuring the long-term sustainability of the NDIS,  I am deeply

concerned that this Bill places the goal of reducing spending ahead of the wellbeing, safety and rights of children with disability and their families. The proposed measures in this Bill will reduce children’s access to support, transfer cost and care onto families and other service systems already under strain, and weaken the early intervention that prevents far more costly outcomes later in life.

My concerns relate in particular to the narrowing of who can access the Scheme and how a child or adult’s disability is assessed, the reduction of capacity building and other essential supports and the broad new powers to reduce and cap funding at a system level. Reducing the cost of the Scheme should not mean moving children or adults into other systems that are not equipped to support them, leaving their needs unmet as a result. The concerns in this submission come from working directly with children, young people, families, carers, educators and schools across Victoria.

The role of occupational therapy in children’s outcomes Early intervention through occupational therapy supports children to build the skills they need to participate in everyday life, aiming to reduce their reliance on more intensive support as they grow. Our work as therapists goes well beyond one-to-one therapy. We build a child’s independence, social participation and self-regulation in the places they actually live and learn (home, school, in the community) and we educate parents, carers and teachers around them so those skills are sustained.

The evidence for early intervention is overwhelming. Children supported early need less intensive and less costly support later, do better at school, regulate and connect more easily and have better long-term mental health, with the strongest outcomes coming from early, intensive support that

Submission 773

includes and educates the family. This is the approach set out by the PRECI National Best Practice Framework for Early Childhood Intervention. The benefits extend to the whole family, reducing the full time care that parents and siblings would otherwise carry. Despite this evidence, the direction of this Bill runs the other way.

Occupational therapy is delivered with strong clinical governance: goals set with families and reviewed often, regular supervision, keeping up to date with research and best practice, with the level of intervention matched to a child’s need. Support is targeted and accountable, not open-ended. Those outcomes are only made possible within a flexible, individualised funding model which is exactly what these reforms put at risk.

Capacity building is not an optional extra. It is what lets a child learn, communicate, form relationships and become more independent. Its purpose is to develop a child’s skills and family’s capacity and the return on that investment is reduced long-term reliance on costlier services, support workers, health care, hospitals and income support. This is the very nature of an insurance scheme. Reducing capacity building does not remove the underlying need. It removes the mechanism that lowers future cost to the government. The need does not disappear when the funding does; it shifts to families, schools and other systems not equipped to meet it.

Schedule 1: Access and Planning 1.1 Functional capacity assessed without real-world context Section 9B assesses what a person can do without help, without assistive technology or modifications and with their environment and personal circumstances stripped out. This is not how disability presents, for children or adults, and it cannot be applied reliably.

A person’s functioning is inseparable from their environment and support. A person may appear capable in a quiet, structured appointment or setting and be unsafe, unable to sustain activity, unable to manage at home, at work, at school or in the community. Autistic people and those with intellectual

disability,  invisible  disability or fluctuating conditions often mask or hold together  for a short

assessment and struggle afterwards. What looks like independence frequently depends on a routine, a prompt, a support person or a modified environment already being in place.

Strip that context away and the assessment will record children and adults as more capable than they are and miss genuine disability-related needs. Functional capacity must be assessed in real-world conditions, accounting for the environment, the supports already in place, masking, fatigue and how function fluctuates and conducted by appropriately qualified allied health professionals.

1.8 Permanence and the requirement to undertake all appropriate treatment Treating an impairment as permanent only once all appropriate treatment has been undertaken creates a direct problem across the disability community. “Appropriate treatment” is not defined and there is no clear limit to what a person may be expected to try.

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Therapy often works on the premise that the right support improves function. Under this provision, that improvement can be used to argue the impairment is treatable, and therefore not permanent, excluding people whose disability is in fact lifelong and trapping others in a cycle of repeatedly proving an enduring condition. Autism, intellectual disability, psychosocial disability and many neurological and degenerative conditions are lifelong and often require ongoing therapy precisely to maintain function, reduce decline or stay safe. Ongoing treatment is not evidence that a disability is temporary.

The provision also counts a treatment as appropriate whether or not a person can actually access it, regardless of cost or distance. For those who cannot afford private therapy, or who live where waitlists are long and specialists scarce, this builds disadvantage into the eligibility test and is potentially discriminatory. People may be refused access over treatment they were never able to obtain. The term must be clearly defined, ongoing therapy must not count against permanence and treatment expectations must be realistic and genuinely accessible.

1.3 The requirement that support needs arise directly from impairment Requiring a support need to arise directly from a recognised impairment does not match how disability is experienced and risks legitimate disability-related needs being reframed as lifestyle, social or environmental issues and excluded.

Support needs rarely come from one impairment in isolation. They arise from how a person’s impairments interact with each other and with their environment, housing, transport, sensory demands, fatigue, emotional regulation and the supports available to them. A person may need support with transport because their environment is inaccessible, suitable housing because their current home is unsafe, or a support worker because dysregulation occurs in the community. These needs are still disability-related, even where the environment contributes. Narrowing them to a single impairment will produce fragmented plans that fail people and overlook supports that prevent crisis and keep people safe. Assessment and funding must continue to recognise needs arising from the interaction between a person’s impairments and their environment, consistent with the social model of disability the Scheme is built on.

1.6 Increased reliance on families and informal support The strengthened presumption that families, including parents, are responsible for substantial care, together with the restriction on funding support, fails to account for the intensity and complexity of disability-related care.

All parents supervise and support their children, but the difference is intensity, not task. Many provide constant line-of-sight supervision, manage absconding or self-harm risk, monitor seizures overnight, sleep in shifts to keep someone safe, or provide hours of behavioural and emotional co-regulation every day, for years. The provision looks at the type of task and ignores how much, how often, how complex and at what cost to the family, and for children it risks treating intensive disability-related care as ordinary parenting.

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Withdrawing support because a family member could provide it does not reduce the need; it shifts it onto carers and siblings already at capacity, reducing their own health, workforce participation and wellbeing. The cost reappears later as carer breakdown, family breakdown and, at worst, child protection involvement or out-of-home care, all far more expensive than the support removed. The legislation must distinguish ordinary family responsibility from disability-related care and seriously weigh caregiver burden, family sustainability and the real cost of withdrawing support.

1.4 & 1.6 Funding reductions, caps and Ministerial powers The proposed Bill allows the Minister to reduce funding for whole groups of supports by a fixed percentage, applied across plans by legislative instrument and even below the actual cost of a support and to cap the amount, intensity and worker-to-participant ratio of supports. These powers move the Scheme away from individualised funding and toward benchmarked and capped systems, in which funding decisions may increasingly be driven by budget control rather than individual functional need.

Participants with the same diagnosis often have very different functional needs, environmental barriers and support requirements. Benchmarked or capped approaches ignore that complexity and risk people receiving funding based on what is considered financially sustainable at a system level rather than what is actually required to keep them safe, participating and independent.

Reducing funding does not reduce disability-related need. It transfers risk onto families, increases crisis presentations and carer burnout, reduces preventative intervention and creates greater long-term costs elsewhere. These powers should not rest with the Minister. Funding decisions must continue to

prioritise  individualised  functional  assessment,  occupational  participation,  safeguarding and

long-term sustainability and must ensure that preventative, therapy and participation supports remain recognised as critical components of disability support.

Reform without the structures in place will repeat past failures These changes reduce access and tighten eligibility before the alternative supports families are told to rely on actually exist or are funded and operational. Australia has been here before. When large institutions were closed, spending was cut on the promise of community supports that never arrived and the cost reappeared in hospitals, homelessness services, the justice system and exhausted families.

Passing this  Bill before the replacement structures are built  will repeat that pattern, this time for

children. Poorly supported disability does not disappear. When a child does not get the support they need, the need does not resolve; it re-emerges later and in a more serious and more costly form,

through  school  disengagement,  deteriorating mental  health,  behaviours  of concern,  hospital

presentations, carer breakdown and family breakdown. Reducing what is spent within the NDIS does not reduce the cost. It moves it to the health, education, mental health, housing and justice systems and onto families, where the human impact on children is far greater.

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I have seen this first hand. I have watched what happens when a person grows up without the support they need: mental health admissions, no path through education, parents who left work to provide care, no sustained employment and an adult who remains dependent and reliant on income support decades later. The system failed that person and it failed the family around them. That is not a saving. It is a far larger lifetime cost. Reducing support that is needed, and before alternatives exist, does not protect the Scheme; it fails the people who depend on it and leaves the families to carry what is left behind.

Conclusion

I acknowledge the need for a sustainable NDIS. But sustainability achieved by narrowing access faster than alternatives are built, stripping context out of how disability is assessed, and shifting care onto families already at capacity, will not strengthen the Scheme. It will displace cost and harm to less visible parts of the system and onto those least able to carry it.

These changes carry real consequences for hundreds of thousands of people. People with disability are not a budget problem to be managed. Reforms of this kind may meet a financial target, but they do so at the expense of the health, safety, dignity and choice of the people the Scheme exists to support. Careful, safe, properly staged reform should not be something families have to argue for. It should be the starting point for the government that built this scheme.

Reform  must  ground  funding  decisions  in  individualised  functional assessment  rather  than

budget-driven caps, recognise lifelong disability without repeated demands to prove it, assess people in the real-world conditions they actually live in and keep preventative, therapy and participation supports recognised as essential. Decisions of this kind should not rest with the Minister alone and access should not be reduced until genuine, funded alternatives are in place.

No family chooses to need the NDIS, and no child seeks therapy for its own sake. These supports are what allow children to take part in everyday life and to grow into adults who can participate in and contribute to their communities. I ask that future legislative decisions keep those children, and every person who relies on this Scheme, at the centre of its decision.

Thank you for the opportunity to provide this submission.

Jess Nyman

Occupational Therapist

Only About Kids Occupational Therapy

Caroline Springs, Victoria

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