Submission 814 - Supplementary Submission
Submission to the Senate Inquiry into Proposed Amendments to the National Disability Insurance
Scheme Act 2013
Thank you for the opportunity to provide feedback regarding proposed amendments to the National Disability Insurance Scheme Act 2013.
This submission is provided from the perspective of an established multidisciplinary allied health provider supporting children, young people, adults, and families, including many participants accessing the National Disability Insurance Scheme (NDIS).
We support the need for a sustainable, effective, and accountable NDIS. We recognise the importance of ensuring funding is directed toward evidence-informed supports that achieve meaningful outcomes and that measures are in place to prevent fraud, misuse, and poor-quality services.
However, reform must ensure that efforts to control costs do not unintentionally reduce access to early intervention, appropriate therapeutic supports, or the experienced workforce required to deliver them.
Functional Capacity and Individualised Assessment
The introduction of a definition of “functional capacity” has the potential to support a more consistent and equitable NDIS if implemented carefully.
In clinical practice, diagnosis alone does not determine a person’s support needs. Children with the same diagnosis can present with vastly different abilities, challenges, environments, family circumstances, and developmental trajectories.
A functional approach can be positive when assessment considers:
- communication
- emotional regulation
- social participation
- independence in daily routines
- learning and developmental needs
- family and environmental factors However, functional assessment must remain holistic and undertaken by appropriately qualified professionals. There is a risk that overly narrow interpretations of functional capacity may overlook children whose needs are significant but less visible, particularly children with communication differences, psychosocial needs, sensory processing differences, or developmental vulnerabilities.
Early Intervention and Prevention of Escalating Needs
The NDIS has played an important role in allowing children to access early supports that improve participation and development.
Any changes requiring clearer links between support needs and eligible impairments should recognise the complexity of child development.
Submission 814 - Supplementary Submission
Young children often present with developmental differences before diagnostic clarity is available. Early supports can reduce the likelihood of children requiring more intensive intervention later.
Restricting access too early risks moving the system from a preventative model toward one where families must wait until difficulties become more severe before receiving help.
Reasonable and Necessary Supports
We support clearer guidance around reasonable and necessary supports and agree that services funded through the NDIS should be evidence-informed and outcome-focused.
However, consideration must also be given to what quality disability support requires in practice.
Effective allied health intervention often includes:
- direct therapy
- parent and caregiver coaching
- collaboration with schools and early childhood settings
- multidisciplinary consultation
- assessment and outcome measurement
- supporting participation in everyday environments These activities may not always look like traditional therapy appointments but are essential components of contemporary disability practice.
Interaction Between the NDIS and Other Service Systems
The proposal to consider whether other service systems are more appropriate before granting NDIS access is understandable. A sustainable disability ecosystem requires strong mainstream and foundational supports.
However, changes must not occur before alternative systems have sufficient capacity.
Families should not find themselves in a gap where they are considered ineligible for the NDIS but unable to access timely support elsewhere.
Clear pathways, workforce capacity, and service availability must be established before responsibility is shifted between systems.
Provider Sustainability and Participant Access
A sustainable NDIS requires a sustainable provider workforce.
Community-based allied health providers are a critical part of the disability system. Many have developed specialised skills, multidisciplinary teams, governance systems, and relationships with families and communities.
Over recent years, providers have experienced significant increases in:
- wages
- rent
Submission 814 - Supplementary Submission
- insurance
- compliance obligations
- technology systems
- administration requirements
- professional supervision and training costs At the same time, pricing arrangements have not consistently reflected the increasing cost of delivering safe, high-quality services.
If experienced providers reduce services or leave the sector, participants will experience:
- reduced choice and control
- longer waiting times
- disruption of established therapeutic relationships
- reduced access to multidisciplinary supports Scheme sustainability should consider not only government expenditure but also the sustainability of the workforce delivering supports.
Scheme Integrity and Fraud Prevention
We support stronger measures to identify fraud, misuse, and non-compliance.
Providers acting ethically and delivering quality services also benefit when inappropriate practices are addressed.
However, increased compliance expectations must be balanced with realistic implementation requirements, particularly for small and medium community providers.
Regulatory changes should strengthen quality without creating administrative burdens that make ethical providers less viable.
Recommendations
We respectfully recommend that government:
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Ensure functional capacity assessments are holistic, developmentally informed, and consider environmental and family contexts.
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Protect access to early intervention so children receive support before needs escalate.
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Recognise parent coaching, multidisciplinary collaboration, and capacity building as legitimate evidence-informed supports.
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Ensure foundational and mainstream services have sufficient capacity before reducing NDIS access pathways.
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Consider provider sustainability as essential to participant choice, access, and quality.
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Engage directly with experienced community providers when designing pricing, implementation, and regulatory changes.
The goals of improving sustainability, consistency, and integrity within the NDIS are important. However, reform must protect the skilled workforce and community-based services that participants and families rely upon.
Submission 814 - Supplementary Submission
A sustainable NDIS requires not only responsible spending but a strong, capable, and sustainable service system.