Protecting essential social participation supports (Provider advocacy)

Submission 804

Submission NDIS REFORM

2026

Author: Emily Ward-Pahl & Narelle Chapman

Qualification: Occupational Therapist & Dietitian

Company: emOTe Occupational Therapy

THIS DOCUMENT HAS BEEN WRITTEN AS A COFIDENTIAL REPORT

If this report is not related to you, please delete immediately and let send know immediately. Hard copy documents are uncontrolled. This report is the property of emOTe Occupational Therapy and the client in which the report has been completed for as requested.

Submission 804

Table of Contents

WHO are we? …………………………………………………………………………………………………………………………. 3

The company ……………………………………………………………………………………………………………………………………. 3

Occupational Therapist ……………………………………………………………………………………………………………………… 4 Ms. Emily Gladys Ward-Pahl …………………………………………………………………………………………………………………………………… 4 Accredited Practising Dietitian ……………………………………………………………………………………………………………. 5 Ms Narelle Alayne Chapman …………………………………………………………………………………………………………………………………… 5 Perspective on the bill ……………………………………………………………………………………………………………… 5 What the bill gets wrong ………………………………………………………………………………………………………….. 7 What needs to be protected ……………………………………………………………………………………………………… 8 Final Statement ………………………………………………………………………………………………………………………. 9 Summary of Recommendations ……………………………………………………………………………………………….. 10 Concerns with current bill ……………………………………………………………………………………………………….. 12

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WHO are we? The company emOTe Occupational Therapy was first listed as a private provider in April 2023. Emily Ward-Pahl the sole

director of the family trust developed the company after a number of years in larger cooperations where KPI’s drove plans to be over utilised and clients missing out. emOTe employs 3 full-time females. One

principle Occupational Therapist, One Dietitian/Allied Health Assistant and one administrator. Narelle Chapman operates in a dual role as an Accredited Practising Dietitian (APD) and an Allied Health Assistant

(AHA). This unique framework allows her to provide highly cost-effective care, maximising therapy budgets while directly reducing the high demand on out OT services. In her dietetic role, Narelle supports families

navigating complex paediatric feeding challenges, severe fussy eating, and the profound sensory

sensitivities associated with Autism Spectrum Disorder (ASD) and Intellectual Disability (ID). She bridges a critical gap in mainstream healthcare, where standard dietetic frameworks and Medicare-funded services

often lack the specialised training required to manage the intersecting complexities of disability and nutritional risk. The key values in which emOTe practices under are the following;

e m O T e

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emOTe pride itself on the fair and equable service that it is able to provide to the wider community of

north metropolitan Melbourne and west metropolitan Melbourne. Currently we have 63 case activity with a mixed demographic of adults and paediatric clients. The clients have a variety of diagnoses including but

not limited to Cerebral Palsy, Autism Spectrum Disorder, Schizophrenia, Acquired Brain Injury,

Huntington’s Disease, Intellectual disorder, rare genetic mutations and many more. emOTe Occupational

Therapy has always endeavoured to work with the NDIS guidelines and legislation. Due to the size of the organisation, registration has always seemed outside the possibility due to the documentation level of

requirement for such a small business. We have tried to grow within this industry, however never found it sustainable due to the overhead cost associated with running the business. We aim to, as an organisation,

register within the next 6 months, to demonstrate our dedication to compliancy and oversight to the

organisation.

Occupa.onal Therapist

Ms. Emily Gladys Ward-Pahl

Assessor Qualifications Bachelor of Science (Psychology)

Bachelor of Psychological Science Honours – Achievement 2A

Masters of Occupational Therapy

CPPACC4020 – Provide access advice on building and renovations

CPPACC5016 – Provide expert access advice on renovations to private dwellings

Title                     Occupational Therapist (APHRA:                     )

Medicare

Ms Emily Ward-Pahl is a General Registered Occupational Therapist with AHPRA, with over seven years of

experience across Aged Care, TAC, Workcover Victoria, and the NDIS systems. She is the practice owner and has worked predominantly within the disability sector for the past six years, supporting participants

with highly complex needs.

Ms Ward-Pahl demonstrates strong NDIS-aligned assessment, clinical reasoning, and decision-making skills. She is competent in Functional Capacity and Housing Assessments, with particular expertise in complex

Assistive Technology and Home Modification, with additional qualifications within this domain. Her practice is grounded in client-centred care, safety, fairness, and ethical use of NDIS funding, ensuring

recommendations uphold participant dignity while meeting reasonable and necessary criteria.

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Accredited Prac.sing Die..an

Ms Narelle Alayne Chapman

Assessor Qualifications Bachelor of Nutrition Science

Master of Dietetics

Title Accredited Practising Dietitian:

Medicare Provider Number:

Ms. Narelle Chapman is a compassionate Accredited Practising Dietitian with extensive experience

delivering evidence-based, person-centred care within the NDIS sector for the past 4 years. Specializing in complex community caseloads, she prioritises deep empathy and collaboration over rigid clinical rules to

support meaningful independence. Having successfully operated as a sole clinician in both rural and metropolitan Melbourne settings, she excels at producing high-quality NDIS documentation and tailored

clinical strategies. Ms Chapman works seamlessly alongside families and multidisciplinary allied health teams to translate complex nutritional needs into accessible, actionable lifestyle changes that improve

overall quality of life.

Perspec.ve on the bill

At emOTe Occupational Therapy, we hold serious concerns regarding the implementation of the proposed NDIS reform bill in its current form. While we acknowledge that the existing system is not meeting its intended performance targets, the bill places disproportionate emphasis on reducing supports for

participants without first establishing the foundational state-level services and adequate funding required to safely absorb those changes.

In its current state, the bill risks returning Australia to a disability support environment similar to the

pre-NDIS era—fragmented, inconsistent, and unable to meet the needs of people with disability. Participants should not bear the consequences of systemic issues, administrative inefficiencies, and

governance failures that have contributed to the NDIS exceeding its projected size. It has always been the

responsibility of government to implement safeguards, planning mechanisms, and oversight structures to ensure the Scheme remained sustainable and true to its purpose.

According to the Survey of Disability, Ageing and Carers (SDAC) 2022, 5.5 million Australians—21.4% of the

population—identified as having a disability. This represents a significant increase from 2018 (17.7%). In contrast, the 2021 Census identified 1,464,415 people (5.8% of the population) who require assistance

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with core activities such as self-care, mobility, and communication. However, Census data likely

underestimates disability prevalence, as it does not directly ask about disability and relies on literacy and self-reporting.

Of the 5.5 million Australians identified by SDAC, only around 660,000 people are NDIS participants (2024–

25 data). This means the NDIS currently supports approximately 12% of Australians with disability, demonstrating that the Scheme is already targeted toward those with significant and permanent functional

impairments, as originally intended.

The proposed reforms could result in up to 240,000 participants losing access to the Scheme, despite the absence of a fully funded, functional, and accessible foundational supports system to transition them into.

This presents a substantial risk of neglect, service gaps, and harm—particularly for individuals with complex needs who rely on consistent, multidisciplinary support.

The NDIS has demonstrated its social and economic value over the past decade. Independent evaluations

show a $2.25 return to the Australian economy for every $1 invested in participants. This reflects increased workforce participation, reduced informal carer burden, and improved long-term outcomes through early

and ongoing intervention.

As allied health professionals, we strongly support early intervention, evidence-based practice, and sustainable service delivery. However, we cannot support reforms that would severely and recklessly

disadvantage a vulnerable population in the name of budget containment—particularly when the necessary foundational supports are not yet in place.

We urge the government to prioritise:

• the development and funding of foundational supports before any large-scale participant transitions

• transparent modelling of the impacts on individuals and service systems

• collaboration with clinicians, participants, and sector experts

• safeguards ensuring no participant is left without essential supports The NDIS must evolve, but it must do so responsibly, ethically, and with the wellbeing of people with

disability at the centre of every decision.

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What the bill gets wrong

The bill assumes that participant behaviour is the primary driver of NDIS growth. Evidence indicates that

much of the system’s expansion is linked to administrative, structural, and governance issues within the Agency and government, rather than participant misuse or over-utilisation.

The proposed changes risk a return to pre-NDIS standards of care. Without fully developed and funded

foundational supports at state and territory levels, people with disability may experience reduced access to essential services, inconsistent support pathways, and increased reliance on informal or crisis systems.

The proposed functional capacity assessment tool does not adequately capture functional need. The tool

relies heavily on the judgement of the administrator, making it vulnerable to subjective interpretation. It does not account for environmental, social, or contextual factors that underpin functional performance. It

also does not adequately identify needs related to home modifications, assistive technology, or specialist disability accommodation—supports that are essential for many people with permanent and lifelong

disability.

The bill treats impairment categories and diagnoses as interchangeable concepts. Impairment categories do not reflect the complexity of individual support needs or the variability in how disability presents.

Diagnostic frameworks allow for person-to-person variation and clinical judgement; impairment categories do not. As a result, categorisation may oversimplify or misrepresent the level and type of support required.

Automated plan review cycles of 12 months, 3 years, or 5 years are not clinically appropriate for many

participants. People with progressive, fluctuating, or complex conditions require regular review to ensure supports remain aligned with their needs. Extended review periods risk delays in essential adjustments,

reduced responsiveness, and poorer outcomes.

Expanded ministerial powers may reduce NDIS expenditure but create cost-shifting to other systems. Reductions in funded supports may lead to increased hospital admissions, greater pressure on already

strained health and education systems, and higher welfare dependency if participants lose the supports that enable them to work. While NDIS expenditure may decrease, overall government spending may

increase due to higher demand in other sectors.

Broad ministerial powers do not account for individual circumstances. Wide-ranging authority to set rules and limits risks undermining participant choice and control, and may lead to uniform decisions that do not

reflect the diversity of disability experiences or support needs.

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What needs to be protected

• The NDIS was established as a naeonal insurance scheme designed to provide dignity, stability, and long-term support to people with significant and permanent disability. Any reforms should remain aligned with these foundaeonal principles and ensure that the Scheme conenues to meet its

original purpose.

• Choice and control are central to the Scheme’s design. Just as people without disability can choose their healthcare providers, childcare, schools, and support services, people with disability should retain the right to choose who delivers their supports and how those supports are structured.

• Parecipants should not be transieoned out of the NDIS unel state-based foundaeonal supports are fully developed, trialled, evaluated, and demonstrated to be effeceve. Removal of supports before

alternaeve systems are operaeonal risks service gaps, poorer outcomes, and increased reliance on crisis systems.

• Decision-making authority should not rest solely with the NDIA. An independent oversight body is required to ensure that the Agency operates within legislaeon, adheres to procedural fairness, and

is accountable for its decisions. The NDIS Quality and Safeguards Commission should operate with greater independence and act as a regulatory counterbalance to the Agency.

• Decisions regarding funding levels, support categories, and eligibility should be made by an independent statutory body rather than by ministerial direceve. Concentraeng decision-making power within government increases the risk of poliecal influence, reduces transparency, and limits

the voice of people with disability.

• The requirement for forced plan renewals to transieon parecipants onto a new system reflects administraeve shortcomings, including the widespread use of plan rollovers. Parecipants should be provided with clear, transparent informaeon about the purpose of a plan review, and informed

consent should be obtained before inieaeng any review process.

• Social, economic, and community parecipaeon supports should be protected from ministerial powers. These supports should be reviewed annually by an independent panel, but reduceons should not be based solely on whether a goal has been met. A reduceon of up to 50% in these

supports may increase hospitalisaeon, social isolaeon, and deterioraeon in funceonal capacity. No reduceons should occur without foundaeonal supports in place to miegate these risks.

• Safeguards must be implemented to protect parecipants from poteneal harms associated with automated decision-making systems. Lessons from the Robodebt Royal Commission highlight the

need for human oversight, transparency, and accountability to prevent administraeve errors and ensure parecipant safety.

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• Parecipants must retain the right to seek external review of NDIA decisions. Access to merits review is a fundamental democraec safeguard and should not be restricted or diminished.

• Indexaeon must be protected to ensure that funding keeps pace with the cost of living. Without appropriate indexaeon, both parecipants and providers face financial strain, reducing the Scheme’s

capacity to deliver effeceve supports.

• Parecipant data, including case notes, should be protected. Allied health professionals should be permiled to provide summaries of service rather than full clinical notes to maintain confideneality

and ensure that sensieve informaeon is shared appropriately.

• Funding for allied health services should not be reduced through ministerial powers. Capacity-building supports are esseneal for increasing independence and reducing long-term reliance on funded services. Reducing these supports may increase overall Scheme costs by shiming

demand to other, more intensive support categories.

• Ministerial powers should not override individualised decision-making. Broad powers risk prioriesing budgetary consideraeons over parecipant needs and may lead to decisions that do not

reflect the lived experience of disability.

• Individualised plans should remain tailored to the funceonal needs of each parecipant. Standardised maximum funding levels or preset support eers do not accurately reflect the diversity of disability or the complexity of individual circumstances.

Final Statement

Thank you for reviewing emOTe Occupational Therapy’s submission on the NDIS Review 2026 and the

proposed legislative changes; we urge the Committee not to progress this Bill in its current form because it advances significant, irreversible changes with inadequate consultation, insufficient clinical safeguards, and

no funded alternatives for supports that will be displaced. As allied health professionals who work daily to build participant capacity and keep families intact, we see firsthand that rushed reforms—reassessment

and suspension powers, broad mandatory registration, ministerial wage-setting without matched funding, and deep cuts to capacity-building and social participation—will reduce choice and control, destabilise

small and specialist providers, increase hospitalisations and child-protection involvement, and shift costs onto families and other public systems. We therefore recommend the Committee:

(1) pause the Bill and commission independent, cross-portfolio cost-modelling that includes health, mental

health, child protection and welfare impacts;

(2) remove or narrow ministerial powers over wage-setting and ensure any pay changes are determined by independent industrial mechanisms with matched, indexed funding;

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(3) adopt proportionate, risk-based registration that recognises existing allied-health regulation and

protects peer, culturally specific and micro-providers;

(4) protect early-intervention, behavioural and social participation budgets from percentage cuts and fund

multidisciplinary care-team meetings and rapid review pathways for high-risk cases; and

(5) establish an independent, genuinely arms-length commission to administer registration, oversight and transparent reporting rather than outsourcing to private auditors. Without these safeguards—transparent

public reporting, independent wage and registration processes, funded transitional supports, and rapid

clinical escalation pathways—the Bill will not protect participants, will reduce their choice and control, and should not proceed.

I ask the Committee to please consider my personal experiences when evaluating this bill

Summary of Recommendaeons

• Pause the Bill and delay progression unel independent analysis and consultaeon are complete.

• Commission independent cross-pornolio cost-modelling that includes health, mental health, child proteceon and welfare impacts.

• Remove or narrow ministerial wage-seong powers and restore independent industrial mechanisms for pay decisions.

• Adopt proporeonate, risk-based provider registraeon that recognises exiseng allied-health professional registraeon and avoids duplicaeve requirements.

• Administer registraeon and audits through an independent, arms-length commission with in-house assessment capability and consistent pricing, not outsourced private auditors.

• Protect early-interveneon, behavioural and social parecipaeon budgets from percentage cuts and prioriese these supports in any reform.

• Establish rapid clinical escalaeon pathways with clear targets (for example decisions within 14 days for high-risk cases).

• Require transparent quarterly monitoring and public reporeng on the reforms’ impacts, including provider exits, wait emes, hospitalisaeons and equity outcomes.

• Set up foundational supports and ensure correct implementation before removing supports currently accessed by participants; no participant should lose an existing service until alternatives are funded,

operational and proven.

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• Limit new assessments to qualified allied-health professionals; assessments that determine clinical need or funding must never be delegated to unqualified staff to maintain integrity and participant

safety.

• Introduce human-based safeguards into any AI-assisted planning or decision system so that clinical judgement, participant consent and independent review remain central and algorithmic outputs are

not actioned without human oversight.

• Maintain the democratic right to external review by preserving independent appeal and tribunal pathways for participants and providers.

Thank you for your time and consideration regarding a very important subject.

Emily Ward-Pahl Narelle Chapman

Director and Occupational Therapist Accredited Practicing Dietitian

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Concerns with current bill

Bill proposal        Concerns with recommendation                                 Experience from the community practice

The Definition of        •  The current definition of “permanent” disability under  Permanent disability definitions are necessary because allied

permanent the NDIS considers whether a person is likely to need health practice is grounded in functional assessment, long-term disability lifelong support and whether effective treatments capacity building, and evidence-based intervention planning. exist. The proposed definition would allow access to Impairment categories alone do not reflect the complexity of a be denied based on theoretical or potential person’s functional presentation or the interaction between treatments, regardless of whether those treatments multiple conditions, environments, and daily activities. Allied are financially, geographically, or practically accessible health professionals assess how a disability affects mobility, to the participant. communication, self-care, cognition, sensory processing, and

•  The concept of “appropriate treatment” may restrict    participation—not just the presence of an impairment. A

access to the Scheme even when the treatment is permanent disability framework allows clinicians to provide unrealistic, experimental, or prohibitively costly. This accurate, holistic recommendations that reflect real-world needs could force participants into the medical system to and long-term functional trajectories. In contrast, impairment pursue treatments simply to prove their disability is categories oversimplify disability, risk overlooking key functional “incurable” or “lifelong,” delaying early intervention limitations, and do not align with contemporary allied health and increasing long-term risks and costs. models of practice, which prioritise person-centred,

•   Early intervention has consistently demonstrated       goal-directed, and context-specific assessment.

strong outcomes and cost-effectiveness within the NDIS. The proposed changes may delay access,

increase administrative burden, and ultimately lead to

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poorer functional outcomes and higher long-term

expenditure.

• The use of impairment categories to classify participants is concerning. Many disability profiles do

not fit neatly into a single category, and

categorisation may fail to capture the full scope of functional limitations. This risks underestimating

support needs and overlooking key areas of functional impairment.

Functional Capacity     •  Functional complexity Functional capacity is             In current allied health practice, clinicians already provide

– the development multidimensional and cannot be accurately captured objective, evidence-based assessments of a person’s functionalof a standarised

assessment tool           by a single standardised assessment. Allied health       capacity using validated tools, clinical reasoning, and longitudinal

practice considers physical, cognitive, sensory, observation. Introducing an additional standardised functional behavioural, and environmental factors that vary assessment administered by individuals without disability-specific widely between individuals. training duplicates existing work, adds administrative burden, and

•  Subjective administration Standardised tools rely on     risks inaccurate or incomplete representation of a participant’s

the judgement of the assessor, meaning results can needs. In practice, planners frequently attend meetings stating vary depending on training, experience, and they have limited understanding of the participant’s disability and interpretation. This reduces reliability and fairness no background in disability or allied health, yet they are still across assessments. responsible for removing or altering funding without being able

•  Context is ignored Functional performance changes     to justify these decisions against legislation or clinical evidence.

across environments such as home, school, and This disconnect between professional assessment and administrative decision-making undermines the integrity of the

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community. A single tool cannot account for planning process and places participants at risk of losing essential

environmental barriers, supports, or cultural factors supports based on assessments that do not reflect their lived that influence real-world functioning. experience or functional reality.

• Misalignment with allied health practice Allied health professionals use clinical reasoning, observation, and

longitudinal information. A rigid tool does not reflect person-centred, goal-directed practice and may

misrepresent a participant’s actual needs.

• Missed support areas Standardised assessments often fail to identify needs related to home modifications,

assistive technology, communication supports, or specialist housing, which are essential for long-term

independence.

• Risk of underestimating needs Many disabilities do not fit neatly into impairment categories or standardised scoring systems. This can lead to

under-reporting of functional limitations and reduced access to necessary supports.

• Unsuitable for fluctuating or progressive conditions A single assessment point cannot capture conditions

that change daily or deteriorate over time, leading to inaccurate planning and delayed intervention.

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• Increased administrative burden Requiring extensive evidence to prove functional impairment shifts time

and resources away from therapy and toward paperwork, reducing access to meaningful

intervention.

• Delays early intervention If participants must undergo lengthy assessments or trial treatments before qualifying, early intervention is delayed, increasing

long-term risks and costs.

• Not aligned with lived experience Standardised tools cannot capture fatigue, sensory overload, behavioural escalation, or the cumulative impact of multiple

impairments on daily life.

Ministerial powers      •  Concentration of authority Expanded ministerial         In practice, my experience as an occupational therapist has

to cut support powers centralise decision-making and increase the shown that increasing ministerial power risks further reducingfunding risk that funding and policy changes are driven by participant choice and control at a time when funding cuts are political or budget priorities rather than participant already occurring without adequate justification or evidence. I needs. have seen planners attend meetings stating they have no

•  Reduced transparency Broad powers weaken          understanding of the participant’s disability and no background in

independent oversight and reduce transparency, disability practice, yet they still remove essential supports making it harder to ensure decisions align with without being able to reference legislation or clinical reasoning. legislation and the original intent of the NDIS. Centralising authority at the ministerial level would amplify this problem, shifting decisions even further away from those with

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•  Override of clinical evidence Ministerial direction may   lived experience and the allied health professionals who assess

override allied health recommendations, participant functional needs. This approach reflects a move back toward goals, and functional evidence, leading to decisions institutional thinking, where decisions are made about people that do not reflect real-world disability needs. rather than with them, and it does nothing to address fraud or

•   Risk to choice and control Centralised authority        budget misuse. Focusing on participants as the source of

undermines participant choice and control, replacing overspend overlooks the systemic and administrative issues individualised planning with uniform decisions that driving costs and risks undermining the core purpose of the NDIS. fail to account for diverse disability experiences.

• Inconsistent decision-making Increased ministerial influence may lead to rapid or sweeping changes that

create instability, inconsistent planning outcomes, and reduced trust in the Scheme.

• Budget-driven reductions Ministerial powers may prioritise cost-containment over participant wellbeing, resulting in reduced supports and

cost-shifting to health, education, and welfare

systems.

• Weakening of safeguards Without strong independent checks, ministerial powers risk eroding

the safeguards designed to protect people with disability from unfair or harmful decisions.

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Family support for      •  Increased burden on families Changes to reasonable    Careful consideration of family responsibility is essential because

children and necessary risk shifting responsibility for personal changes to “reasonable and necessary” supports risk shifting care, behavioural support, and daily living tasks onto substantial care onto families who are already at capacity. In my families, many of whom are already at capacity. practice I have observed increased demand for respite, more

•   Unrealistic expectations Families may be expected to   frequent activations of Orange Door and child protection services,

provide levels of care that exceed what is typical, safe, and three of the twelve children on my caseload currently placed or sustainable, particularly for high-needs or complex in residential care under DFFH; several participants with extreme participants. behaviours lack access to behavioural support practitioners.

•  Impact on employment Increased caring              These outcomes illustrate how reduced funded supports can

responsibilities can force parents or carers to reduce escalate crisis involvement, compromise safety, and increase work hours or leave employment entirely, increasing system costs across health, child protection, and residential care. financial stress and reliance on welfare systems. Any policy change must therefore include clear safeguards:

•  Not aligned with NDIS principles The NDIS was         guaranteed access to respite and specialist behavioural supports,

designed to reduce the burden on families, not targeted funding for families with high care needs, independent increase it. Shifting responsibilities back to families review mechanisms, and monitoring to prevent cost-shifting and contradicts the Scheme’s foundational intent. protect both participants and carers.

• Risk of carer burnout Additional expectations on families increase the risk of physical, emotional, and psychological burnout, which can lead to crisis

situations and higher long-term system costs.

• Safety concerns Families may be expected to manage behaviours of concern, complex medical needs, or

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mobility tasks without training or support, creating

safety risks for both the participant and the carer.

• Equity issues Families with fewer financial resources, limited English, or reduced social support will be

disproportionately affected, widening inequities

across the disability community.

• Not reflective of lived experience Many families already provide significant unpaid care. Further

reductions in funded supports fail to acknowledge the real-world demands of caring for a person with

disability.

• Potential for family breakdown Increased pressure on families can contribute to relationship strain, breakdown, and involvement of crisis or child

protection systems.

• Contradiction with early intervention Reducing supports and expecting families to fill the gap undermines early intervention principles, which rely

on consistent, skilled, and structured support.

Plan reassessment      •  Increased delays and interruptions Any additional       In the community I work in, long administrative delays are already

and suspensions reassessment steps or suspension powers will add causing serious harm: many participants wait more than 100 days administrative time and create more opportunities for for a change-of-circumstance decision, increasing the risk of

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supports to lapse, increasing clinical risk and crisis deterioration, injury, or prolonged hospitalisation. A recent case

presentations. highlights the consequences—one client who is legally blind and

•   Risk of inappropriate suspensions Suspension without  deaf was denied urgently needed assistive technology after a

timely human and clinical review can remove planner attempted to contact him despite clear paperwork essential 24/7 supports for high-need participants, showing he cannot participate in phone calls; the decision is now placing them at extreme risk. subject to a 90-day review. This person requires 24/7 supports,

•  Burden shifted to families and mainstream services    and any suspension or further delay would place them at extreme

Reduced NDIS supports do not remove need; they risk. These examples show that proposed reassessment and transfer it to families, health, education, and child suspension reforms would worsen the situation and not improve protection systems, increasing overall public cost and outcomes for participants, by creating more administrative inequity. hurdles, enabling abrupt funding pauses without timely clinical

•  Administrative duplication reduces clinical capacity     review, and shifting care into crisis, state and family systems

Requiring new standardised assessments duplicates rather than preventing deterioration through timely, allied health work, diverting clinicians from therapy to community-based supports.

paperwork and worsening waitlists.

• Decisions made without disability expertise Planners who lack disability-specific background are making or endorsing funding changes that clinicians cannot

support, undermining evidence-based planning and participant choice.

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Mandatory            •   Smaller, specialist, culturally specific or peer-led       Mandatory provider registration, applied broadly, will reduce

registration of all providers may be unable to meet onerous registration client choice and control by shrinking the market to larger,providers costs and audit requirements, forcing them out of the well-resourced organisations and excluding small, specialist, market and narrowing participant options. peer-led and culturally specific providers; it is prohibitive in cost

•   Registration, audits, and ongoing compliance increase  and complexity and therefore prioritises organisational

provider overheads; these costs are likely to be compliance over what matters to the client. Current reporting reflected in prices or reduced service availability, and review processes already take months, so adding another limiting affordable choices. layer of registration will not safeguard participants or speed up

•  Mandatory registration can restrict the use of          responses—it will simply create more administration and

informal, family, or community-based supports and oversight for government rather than faster protection for peer programs that do not fit a formal registration people. Allied health professionals are already regulated through model, undermining self-direction. accrediting bodies with annual registration and ongoing CPD, so

•  National practice standards may not reflect local,       duplicative provider registration offers little additional clinical

cultural, or disability-specific ways of delivering assurance while increasing costs and reducing local supports, reducing culturally safe and person-centred responsiveness. If registration is to proceed, the process must be options. administered by a truly independent commission (separate from

•   Registration processes (which can take months) delay   the NDIA and direct government control), with in-house,

consistent assessment and pricing rather than outsourced audits, new providers entering the market and slow so that oversight is timely, transparent, and any fees or savings participants’ ability to change or trial supports.

•    If only large, registered organisations can deliver       are reinvested into the system rather than private contractors.

certain supports, participants may be steered toward

standardised, congregate models rather than flexible,

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home-based options—recreating institutional

dynamics.

• Allied health professionals are already subject to professional registration, annual renewal, and CPD

through accrediting bodies; imposing additional

provider registration requirements duplicates oversight without clear participant benefit.

• Start-ups, micro-providers, and innovative service models may be discouraged by regulatory complexity, reducing novel solutions that enhance choice.

• Providers in remote or low-resource areas may lack capacity to comply, worsening access inequities for

participants who already have limited options.

Ministerial powers      •   Ministerial direction can prioritise short-term fiscal or  As an allied health professional with six years in the sector

to set allied health political objectives over independent, evidence-based operating at break-even, I am deeply concerned that grantingpay increases wage setting, undermining industrial processes ministers power to set pay increases will politicise wage designed to balance fairness and sustainability. decisions, undermine independent industrial processes, and

•  Award and pay changes are normally determined        destabilise small and independent providers; wage-setting must

through the Fair Work Commission and bargaining be independent of ministerial direction, indexed to CPI and WPI processes; ministerial overrides risk legal and to protect real wages and workforce retention, and accompanied operational conflict. by publicly available independent reports so the community can

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•  Mandated pay increases set by ministers can raise       scrutinise impacts rather than having findings hidden when they

operating costs for small and medium NDIS providers, conflict with political goals as occurred in the 2025 price review; many of whom already operate on tight margins; without transparent, independent review and matched, indexed these costs are likely to be passed on to participants funding in NDIS pricing, mandated pay rises will force providers to or reduce service availability. cut services, raise prices, or exit the market—reducing participant

•  Higher wage floors without corresponding funding      choice and continuity of care—and expanding ministerial powers

adjustments can force smaller, specialist, or rural in this bill would fail to guarantee the oversight, transparency, providers to exit the market, narrowing participant and workforce security the sector needs.

choice and undermining self-directed options.

• Rapid or unilateral pay changes increase administrative burden for providers to reprice services, renegotiate contracts, and manage

cashflow—delays that directly affect participant continuity of care.

• If federal funding does not match mandated pay rises, the NDIS may reduce service scope or shift costs to

participants, families, or state systems (health, aged care, child protection).

• State wage deals and national ministerial directives can interact poorly, producing inconsistent outcomes across jurisdictions and exacerbating rural workforce

shortages

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10% reduction to       •   Capacity-building supports fund allied-health,            In my practice we are seeing a sustained and damaging

capacity building behaviour supports and skill development that contraction of provider capacity: multiple providers are exitingsupports prevent escalation; a 10% cut reduces the preventive the sector, waitlists are lengthening, and participants are work that avoids costly acute episodes. Early experiencing significantly longer delays for routine and urgent intervention importance supports; this is already driving increased hospitalisations and

•  Short-term savings in NDIS budgets are likely to be      greater reliance on hospital pathways to meet unmet

offset by higher costs in hospitals, child protection, capacity-building needs. Planners are routinely issuing blanket or welfare and residential care when needs are unmet. fixed funding amounts that fail to reflect documented complexity Cost-shifting risk or risk, care-team meetings for holistic review are unfunded, and

•   Rural, low-income and culturally diverse participants    therapy outcomes are being delayed because sessions are less

will be disproportionately affected, as local frequent and support workers are expected to implement allied-health capacity is fragile and waitlists will therapeutic programs without training, supervision, or lengthen. Equity impacts multidisciplinary backing. Moving payment cycles from fortnightly

•  Lower budgets force providers to cut hours, reduce     to monthly, reducing capacity-building budgets, or imposing

staff or exit the market, narrowing participant choice one-size-fits-all funding will further degrade gold-standard and undermining self-directed supports. Provider practice, reduce continuity of care, slow progress toward NDIS capacity effects goals, and place the most vulnerable participants at immediate

•  When supports are reduced, families must navigate      risk of deterioration, injury, or institutionalisation.

more reviews and appeals; this increases stress and Opera)onal impacts and clinical risk diverts clinician time from therapy to paperwork.

Administrative burden                                        •  Longer wait times for allied health and behaviour supports

as providers reduce caseloads or close.

Submission 804

• Increased acute demand on hospitals and emergency pathways as community supports lapse.

• Reduced market choice as small and specialist providers become financially unviable.

• Therapy dilution when untrained support workers are relied upon to deliver complex interventions without

clinical oversight.

• Slower goal attainment due to reduced session frequency and fragmented care coordination.

• Heightened safety risk for participants requiring 24/7 or high-intensity supports if plans are suspended, reduced, or delayed.

  50% reductions in • Increased isolation and poorer outcomes — social In practice I have repeatedly seen how social and community

social and participation funding enables community connection, participation funding underpins everyday safety, independencecommunity

supports                          skill development and informal supports; halving it     and family stability: respite keeps parents able to care for their

will worsen mental health, reduce employment and children and remain employed rather than relying on DFFH

education participation, and increase loneliness. placements; a participant with chronic psychosis who previously

•  Higher downstream costs — short-term savings in      could not collect his medication because of delusions is now

NDIS budgets are likely to be offset by increased supported to do so and to re-engage in the community instead of demand on hospitals, mental health services, child cycling through crisis care; a woman who had been rejected from

protection and welfare systems. over 100 paid roles because of her intellectual disability now

Submission 804

•  Unequal impact across disability groups — modelling   volunteers at an op shop, gaining confidence, social connection

shows some cohorts allocate a much larger share of and meaningful daily routine; and a young child who requires two their plans to social participation and will therefore be people to safely use a ventilator can attend swimming sessions so

disproportionately harmed. a parent can maintain meaningful employment. These are not

•   Loss of informal and community supports — cuts         trivial social activities—they are essential tasks: grocery shopping

reduce funding for activities that build independence at sensory-appropriate times, daily travel to work, library and community networks, increasing reliance on paid programs, medication management, and basic community

or institutional care. participation that most people take for granted. Cutting these

•  Market contraction and reduced choice — smaller,     supports will not remove the underlying need; it will shift demand

specialist and culturally specific providers are most to hospitals, welfare and child-protection systems, increase carer

vulnerable to budget reductions, narrowing burnout and unemployment, and reduce opportunities for people participant options. with disability to work, volunteer and live independently. The

lived, anecdotal evidence from my caseload shows the cost of these supports does not outweigh their benefits—reductions will

worsen outcomes, increase downstream public costs, and erode participant choice and community inclusion.