Submission 834
Submission to the Senate Inquiry
National Disability Insurance Scheme Amendment
(Securing the NDIS for Future Generations) Bill 2026
Submitted by
Adelaide Wellbeing Society
Address: 9A/1700 Main North Road, Salisbury Plains, 5109
Contact Number: 0493 278 487
Email Address: admin@wellbeingsociety.com.au
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Submission 834
Introduction
Adelaide Wellbeing Society welcomes the opportunity to provide feedback regarding the
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations)
Bill 2026.
As a multidisciplinary allied health provider servicing NDIS participants across diverse socioeconomic, cultural, and clinical backgrounds, we strongly support the long-term sustainability, integrity, and accountability of the NDIS. We acknowledge the importance of addressing fraud, improving governance, and ensuring the Scheme remains viable for future generations of Australians living with disability.
However, we hold significant concerns regarding several proposed amendments which, in our view, risk undermining the participant-centred principles upon which the NDIS was established. We are concerned that aspects of the Bill may unintentionally reduce access to essential supports, increase inequity, create unsustainable pressures on allied health providers, and negatively impact vulnerable participants and their families.
Our concerns are informed by direct clinical experience supporting individuals living with neurological conditions, intellectual disabilities, acquired injuries, developmental delays, and intergenerational disadvantage. Many of the individuals and families we support already experience substantial barriers relating to transport, housing, healthcare access, employment, and community participation.
We believe reforms to the NDIS must remain evidence-based, clinically informed, transparent, and genuinely participant-focused. While sustainability is critical, it should not come at the expense of procedural fairness, appropriate care, or the long-term wellbeing of Australians living with disability.
About Adelaide Wellbeing Society
Adelaide Wellbeing Society is a small multidisciplinary allied health service based in Adelaide. Our organisation includes an all-abilities rehabilitation gym, play therapy centre, consulting rooms, and community outreach services. We provide clinic-based, home-based, and school based services to individuals across Adelaide, particularly within the northern suburbs.
Many of the families we support experience socioeconomic disadvantage, limited access to transport, unstable housing, and reduced informal supports. In numerous households, multiple family members live with disability, making access to community-based allied health services essential.
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Like many allied health providers, we operate within narrow financial margins despite the perception that allied health services are highly profitable. According to Australian Taxation Office data, established allied health businesses average approximately 15% take home profit margins. Relatively new businesses this figure is substantially lower, and those businesses who provide unbilled services to those who need it, it is lower again. Our organisation opened a purpose-built facility in 2024 and continues to absorb significant establishment and operational costs.
Ongoing expenses include:
Commercial leasing and utilities Professional insurances Accreditation and compliance costs Rehabilitation equipment purchase and maintenance Assessment tools and therapeutic resources Workforce and staffing costs Software and administration systems Vehicle and travel expenses for outreach services
Despite rising operational costs, NDIS pricing and travel arrangements have not kept pace with inflation or business expenditure increases, placing substantial pressure on providers attempting to maintain accessible and sustainable services
Ministerial Powers and Democratic
Oversight
We are deeply concerned by provisions within the Bill that would grant broad powers to the Minister to determine support categories, restrict funding, cap supports by participant cohorts, and amend operational aspects of the NDIS through delegated legislation without full parliamentary scrutiny.
In our view, these provisions reduce transparency, accountability, and democratic oversight. Decisions that directly affect the health, independence, safety, and wellbeing of
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Australians living with disability should be subject to full parliamentary debate, public consultation, and meaningful engagement with participants, providers, families, and the disability community.
The concentration of substantial decision-making authority within ministerial powers risks undermining participant confidence in the Scheme and weakening safeguards designed to ensure the NDIS remains participant-centred and publicly accountable.
Capacity Building Funding Reductions
The proposed 10% reduction to capacity building funding is of significant concern to allied health providers and participants alike.
Reducing funding does not reduce participant need. Instead, it limits access to therapy, rehabilitation and other essential allied health interventions that are critical for maintaining function, independence, and quality of life.
Our organisation already supports participants whose plans have been substantially reduced. In some cases, clinicians continue providing services without billing because withdrawing supports would place vulnerable individuals at risk. While providers attempt to maintain continuity of care, this is financially unsustainable over the long term.
Allied health services carry substantial operational expenses, including specialised rehabilitation equipment, assessment tools, software subscriptions, professional development, staffing costs, insurance, and outreach travel. Further reductions to funding, combined with existing travel cuts and stagnant pricing, risk forcing providers to reduce services, cease outreach programs, or leave the sector entirely.
These impacts are particularly severe for participants living in low socioeconomic areas, rural communities, or households experiencing intergenerational disability and poverty.
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Rehabilitation Services
We are highly concerned by proposed limitations surrounding rehabilitation services within the NDIS.
Our service supports many individuals living with brain injuries, stroke, amputations, neurological conditions, mobility impairments, and progressive disabilities. These participants require ongoing rehabilitation to maintain mobility, safety, independence, and community participation.
Rehabilitation is not simply short-term recovery treatment. For many participants, ongoing allied health intervention prevents deterioration, reduces hospital admissions, delays long term care dependency, and improves functional outcomes.
For example, individuals fitted with prosthetic limbs require continued physiotherapy, exercise physiology, and occupational therapy to safely regain mobility. Stroke survivors often require extensive community rehabilitation long after hospital discharge.
Removing or restricting rehabilitation services does not eliminate the need for rehabilitation — it shifts the burden onto hospitals, emergency departments, and aged care systems while increasing long-term healthcare costs
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NDIS Price Freezes and Financial
Sustainability
The ongoing price freezes and limited indexation applied to allied health services within the NDIS have failed to keep pace with rapidly increasing business and healthcare costs.
Providers have experienced substantial increases in wages, superannuation, insurance, rent, utilities, fuel, vehicle maintenance, software subscriptions, equipment, compliance requirements, and administrative staffing costs. At the same time, providers are absorbing increasing amounts of unpaid administrative work associated with reporting and compliance obligations.
The growing gap between capped NDIS pricing and actual operational costs is becoming unsustainable. Without meaningful pricing reform, many providers may be forced to reduce services, limit outreach work, stop accepting NDIS participants, or exit the sector altogether.
Travel Funding Reductions
The reductions to NDIS travel charging arrangements have disproportionately impacted participants with the highest support needs, particularly families without access to transport, families living in low socioeconomic areas, and households where multiple family members live with disability.
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For many participants, home-based and school-based allied health services are essential rather than optional. Despite the reduced reimbursement model, our organisation has continued to provide outreach services because discontinuing supports would leave vulnerable participants without access to care.
However, many providers have been unable to sustain outreach work under the current arrangements. Clinicians travelling to homes and schools are effectively billing at half rate during travel time while being unable to provide fully-billed concurrent services elsewhere. Combined with rising fuel, vehicle, and staffing costs, this creates significant financial losses for providers delivering community-based services.
These changes risk creating inequitable access to care where the participants facing the greatest barriers to attendance are the very individuals most likely to lose services.
Mandatory Registration
We support stronger regulation and mandatory registration measures aimed at addressing fraud, exploitation, and misconduct within the disability sector, particularly within areas such as support work services, Supported Independent Living (SIL), and Support Coordination.
However, allied health providers are already highly regulated, clinically governed, university qualified professionals operating under established professional standards and accreditation frameworks.
Imposing additional NDIS-specific registration requirements without recognising existing professional regulation risks duplicating compliance systems while imposing substantial financial and administrative burdens on providers already operating within narrow margins.
Current registration and auditing processes can cost tens of thousands of dollars and require extensive administrative resources. For small allied health providers, particularly
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those delivering rural and outreach services, these requirements may become financially unsustainable.
We strongly recommend the implementation of a streamlined, lower-cost registration pathway for allied health providers that recognises existing professional registration, reduces duplicated paperwork, and applies proportionate compliance requirements while still maintaining participant safety and accountability.
Functional Capacity Assessments
We hold serious concerns regarding proposals for functional capacity assessments to be administered by non-clinically qualified NDIS employees without adequate weighting given to allied health and medical evidence.
Many NDIS participants live with cognitive, neurological, psychosocial, intellectual, or communication-related disabilities that affect their ability to independently participate in assessments or accurately communicate their needs and limitations.
Without meaningful input from treating allied health professionals and medical practitioners who understand the participant’s clinical history and functional capacity, there is a substantial risk of inaccurate assessments, inappropriate funding reductions, and unsafe support outcomes.
Participant assessments must remain evidence-based, clinically informed, and supported by qualified healthcare professionals.
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Submission 834
Suspension of Funding Following
“Reasonable Attempts”
We are concerned by provisions allowing participant funding to be suspended or revoked where participants are deemed “uncontactable after reasonable attempts.”
This terminology is ambiguous and fails to account for the realities many participants face, including hospitalisation, mental health crises, unstable housing, communication barriers, holidays, or reliance on carers and advocates to manage correspondence.
Our service has supported participants who have spent extended periods in intensive care or hospital settings without access to phones, email, or mail. Under the proposed provisions, there is concern that individuals could lose funding during periods of medical crisis despite urgently requiring supports upon discharge.
Greater safeguards, clearer definitions, and compassionate review processes are required to ensure vulnerable participants are not unfairly penalised.
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Automated Planning and Computer-
Generated Budgets
We are highly concerned by proposed automated planning systems and computer generated participant budgets.
NDIS participants often have highly complex and individualised circumstances that cannot be accurately captured through standardised algorithms or automated assessments. Effective planning requires nuanced consideration of allied health evidence, psychosocial factors, communication barriers, cultural needs, and fluctuating functional capacity.
The proposed approach raises concerns similar to those identified during the former Centrelink Robodebt scheme, where automated decision-making processes contributed to widespread errors, distress, and unfair financial consequences.
We are particularly concerned by proposals allowing funding reductions without updated plans being formally issued to participants. This creates confusion regarding available supports, financial liability, and provider payment certainty.
There is a significant risk that providers may deliver services in good faith under existing plans only to later discover funding has been retrospectively reduced or withdrawn, potentially leaving participants personally liable for unpaid invoices.
These proposals appear inconsistent with Section 31 of the NDIS Act, which requires participant plans to be highly individualised, participant-directed, and tailored to unique goals and circumstances.
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Thriving Kids Program
The introduction of the Thriving Kids initiative has created significant uncertainty for allied health providers due to the limited information currently available regarding implementation, funding pathways, workforce planning, and the role of private providers.
This lack of transparency makes it difficult for small providers to plan staffing, infrastructure, and long-term service delivery models.
Without adequate transition planning, there is concern that reducing reliance on private allied health providers may place unsustainable pressure on already overstretched public systems, resulting in increased waitlists and reduced access to early intervention services for children and families.
Allied health providers who support a range of ages and cohorts may not be able to practice with the immediate loss of revenue associated with the thriving kids cohort of participants. This runs the risk of businesses closing their doors as operating costs remain, despite the reduced customer base – leading to non-thriving kids NDIS participants no longer having providers to support their needs.
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Client Case Studies for Reference
Client 1 – 24 years of age – Autism, diagnosed with additional physical disabilities last year
This case concerns a 24-year-old woman with severe, permanent, and treatment-resistant autonomic failure and multiple associated conditions, including POTS, hypermobile Ehlers Danlos syndrome (hEDS), chronic fatigue, chronic pain, cardiovascular instability, gastrointestinal and bladder dysfunction, mobility impairment, and significant deconditioning following prolonged illness and hospitalisation.
Although she receives NDIS funding for Autism Spectrum Disorder, her current plan does not adequately recognise or fund the substantial disability arising from her autonomic and multisystem conditions. Her treating cardiologist has confirmed that her condition is permanent, significantly disabling, and resistant to all available evidence-based treatments, including medication, intravenous fluids, enteral feeding, lifestyle interventions, and specialist allied health care.
As a result of her conditions, the participant experiences severe fatigue, dizziness, syncope (fainting), falls risk, joint instability, reduced endurance, left-sided weakness, impaired motor control, tremors, and cognitive overload. She requires a four-wheel walker, uses a wheelchair for longer distances, relies on support workers, and needs structured assistance to manage daily activities. She is also preparing for major high-risk urological surgery.
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Concerns About the NDIS Decision
The NDIS rejected or reduced requested supports under the criteria of value for money, effectiveness and benefit, and the expectation that informal supports could meet her needs.
The review argues that this decision does not adequately consider the severity of the participant’s disability, the permanence of her condition, or the predictable consequences of inadequate support.
Value for Money
The report contends that supports such as Exercise Physiology, Occupational Therapy, psychology, and increased support worker assistance are preventative and capacity-building interventions. These services are intended to maintain function, reduce falls and hospitalisations, prevent further deconditioning, and preserve independence.
Without these supports, the participant is at greater risk of injury, medical crises, hospital admissions, increased care needs, and higher long-term support costs. The review argues that funding preventative supports is more cost-effective than managing avoidable deterioration later.
Effective and Beneficial
The report states that the requested supports are consistent with evidence-based management of severe autonomic dysfunction and chronic illness. While they cannot cure the participant’s condition, they are clinically necessary to:
Maintain function and independence Reduce falls risk Improve activity tolerance and safe mobility Prevent further physical decline Support community participation Reduce the likelihood of hospitalisation
The participant’s cardiologist has confirmed that ongoing multidisciplinary intervention remains medically necessary despite the absence of curative treatment options.
Reliance on Informal Supports
The review argues that the participant’s needs exceed what can reasonably be expected of family members, carers, or community supports. Her condition requires management of
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autonomic instability, syncope, falls risk, fatigue, and post-surgical recovery, which informal supports are not trained to provide.
The participant already relies heavily on her partner and support workers, and further reliance on informal care would be unsafe, unsustainable, and likely to increase caregiver burden.
Risks of Inadequate Funding
The review raises concerns that failing to adequately recognise and fund the participant’s autonomic disability may contribute to foreseeable deterioration. Without appropriate supports, she faces increased risks of:
Falls and injury Further deconditioning Reduced mobility Greater wheelchair dependence Increased hospitalisation Loss of independence Social isolation Psychological distress Higher future support needs
These risks are particularly significant given her upcoming high-risk surgery and ongoing medical complexity.
Conclusion
The review concludes that the participant has severe, permanent, and medically complex disabilities that are well documented by her treating specialists. The requested supports— Exercise Physiology, Occupational Therapy, psychology, increased support worker assistance, and multidisciplinary coordination—are evidence-based, clinically necessary, disability-related, and aimed at preventing further decline.
The report argues that the current NDIS funding decision does not adequately reflect the severity of the participant’s condition or her documented functional impairment. It concludes that failure to provide appropriate supports is likely to result in avoidable deterioration, increased medical complications, reduced quality of life, and higher long-term support costs.
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Client 2 – Woman in her 50s with Friedrichs Ataxia – a neurodegenerative disease
This case concerns a self-managed client seen in clinic and at her home for various needs. This client mobilises with a motorised wheelchair and is fiercely independent and still works full time for the government, pays tax and is strongly trying to support herself to continue living her life before she deteriorates to the point of complete reliance on the support of others.
This client requested a change of circumstance to SIL due to complicated social issues within the home, lack of support for in home care, and deteriorating symptoms. Poor Support Coordinator management and case-management support led to dangerous delays and ultimately NDIS total withdrawal of her funding support when transferring to SIL. Client 2 relied on regular Speech Pathology (for swallowing assessments due to dysphagia and deteriorating speech due to the disease, and will eventually be reliant on Alternative Communication Devices), Intensive Exercise Physiology, to keep her remaining useful limbs strong enough to continue to care for herself, participate in society and work, and Physiotherapy for assisting her with transfers in and out of her wheelchair, bed, toilet etc, Chest Physio for her breathing etc. She had all of this funding cut and remains without services, deteriorating at home.
Client 2s case has “remained with tribunal” for ~12 months. This client is the epitome of an example of why the NDIS was established, to provide a disabled person with independence and dignity and the ability to remain in and engage in their community, yet these cuts are being conducted blindly and without evidence-based decisions.
Rather than an economic approach. Fixing the fraud would save far more funds rather than cutting essential services such as allied health support.
The actions being taken by blindly cutting funding are putting real people with real needs at risk and will ultimately burden the system in the future when these clients who lose the support they need to maintain independence become further disabled and requiring more care and support as they decline.
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Client 3 - 48 years of age – Multiple Sclerosis
This case concerns a participant diagnosed with Relapsing Remitting Multiple Sclerosis (RRMS), a progressive neurological condition that causes fatigue, motor weakness, balance impairment, neuropathic pain, sensory disturbances, reduced mobility, and fluctuating functional capacity. Following a recent significant relapse, the participant experienced further deterioration in mobility, endurance, neuromuscular control, and independence.
Since March 2023, the participant has participated in regular supervised Exercise Physiology (EP) sessions focused on neurological rehabilitation, strength development, balance retraining, gait improvement, cardiovascular conditioning, fatigue management, falls prevention, and maintaining independence. Due to the complex and fluctuating nature of MS, these interventions require ongoing clinical supervision and frequent modification based on fatigue levels, pain, balance deficits, tremors, coordination changes, and relapse-related symptoms.
The participant’s Exercise Physiology program has been essential in maintaining function, preventing deconditioning, reducing falls risk, supporting community participation, and preserving independence.
NDIS Decision and Concerns
Following review, NDIS funding for Exercise Physiology was reduced from weekly sessions to one 60-minute session per month. The decision was based on concerns relating to:
Value for Money (Section 34(1)(c)) Effective and Beneficial Supports (Section 34(1)(d)) Duplication of Supports (Rule 5.1(c))
The Agency stated that independent exercise and existing supports were sufficient and that additional Exercise Physiology was not considered cost-effective or necessary.
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Concerns About the Decision
Value for Money
The review argues that reducing Exercise Physiology may create higher long-term costs by increasing the risk of:
Falls and injury Hospital admissions Functional decline Increased support worker reliance Reduced community participation Accelerated physical deconditioning
Exercise Physiology is described as a preventative, rehabilitative, and capacity-building intervention that helps maintain independence and reduce future support needs. Independent exercise is not considered an equivalent alternative because the participant has significant fatigue, balance deficits, neuropathic pain, sensory impairment, and a need for real-time clinical adjustments.
Effective and Beneficial
The review argues that improvements achieved through Exercise Physiology demonstrate that the intervention is effective, not that it is no longer required.
Neurological rehabilitation for MS depends on consistent supervision, progressive exercise prescription, repetition, and ongoing adaptation to maintain gains and support neuroplasticity. A monthly session is considered insufficient to provide the level of monitoring, progression, and symptom-responsive management required for a fluctuating neurological condition.
Duplication of Supports
The report disputes the claim that Exercise Physiology duplicates support worker or community access funding.
Exercise Physiologists provide specialised clinical services including:
Neuromuscular rehabilitation Exercise prescription Strength and balance training Fatigue management
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Falls prevention Clinical assessment and monitoring
Support workers do not provide rehabilitation or clinical therapy. The supports are therefore complementary rather than duplicative.
Clinical Concerns
The reduction from weekly sessions to monthly reviews is considered inconsistent with accepted neurological rehabilitation principles.
The participant continues to experience:
Significant fatigue Neuropathic pain Motor weakness Balance impairment Reduced endurance Increased falls risk Ongoing instability following relapse
Monthly intervention is unlikely to adequately support motor relearning, prevent deconditioning, monitor symptom progression, or safely progress exercise programs. The review argues that unsupervised exercise is not clinically equivalent or safe for someone with the participant’s level of neurological complexity.
Likely Impact of Reduced Supports
The review warns that reduced Exercise Physiology funding may result in:
Accelerated deconditioning Reduced mobility and gait efficiency Increased fatigue Loss of strength and endurance Greater falls risk Increased dependence on support workers Reduced community participation Social isolation Increased psychological distress Greater long-term disability and support needs
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Because MS is progressive and sensitive to inactivity, loss of function can occur rapidly and may be difficult and costly to regain once lost.
Conclusion
The review concludes that regular supervised Exercise Physiology is evidence-based, clinically justified, rehabilitation-focused, and directly aligned with NDIS capacity-building goals. Given the participant’s recent MS relapse, ongoing neurological impairments, and need for specialised supervision, reducing support from weekly sessions to one session per month is considered inconsistent with best-practice neurological rehabilitation.
The report argues that the decision does not adequately reflect the participant’s clinical needs and may contribute to preventable deterioration, increased future support dependence, and poorer long-term health outcomes.
The participant has Relapsing Remitting Multiple Sclerosis (RRMS), a progressive neurological condition causing fatigue, weakness, impaired balance, pain, mobility decline, and fluctuating functional capacity. Following a recent relapse, the participant experienced further deterioration in mobility, endurance, motor control, and independence.
Since March 2023, the participant has engaged in regular supervised Exercise Physiology intervention focused on strength, balance, gait retraining, fatigue management, falls prevention, and maintaining functional independence. Due to the complexity of their neurological condition, sessions require continual clinical monitoring and modification in response to fatigue, pain, balance impairment, tremors, and changing neurological symptoms.
Following an NDIS review, Exercise Physiology funding was reduced from weekly sessions to one 60-minute session per month under “value for money,” “eƯective and beneficial,” and “duplication of supports” provisions.
This reduction raises significant clinical concerns. Supervised Exercise Physiology is a preventative and capacity-building support designed to maintain independence, reduce falls risk, prevent deconditioning, and reduce long-term reliance on supports. Independent exercise is not clinically equivalent for a participant with neurological instability, falls risk, fatigue variability, and recent relapse-related decline.
The decision also incorrectly categorised Exercise Physiology as duplicative of support workers or community access supports. Exercise Physiology provides clinical rehabilitation,
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neuromuscular retraining, fatigue management, and evidence-based therapeutic exercise that support workers are not qualified to deliver.
Reducing therapy to one session per month does not align with best-practice neurological rehabilitation principles and is unlikely to adequately maintain functional gains, monitor deterioration, or safely progress rehabilitation. The reduction places the participant at increased risk of falls, physical decline, loss of independence, reduced community participation, and greater future support needs.
This case highlights broader concerns regarding NDIS funding reductions across the board, where short-term cost savings may contribute to preventable deterioration and increased long-term expenditure across health and disability systems.
Client 4 - 48 years of age – Erdheim-Chester Disease - Neurological
This case concerns a 48-year-old woman diagnosed with Erdheim-Chester Disease (ECD), a rare, chronic, progressive, and multi-system blood cancer that causes ongoing neurological impairment, systemic inflammation, and gradual functional decline. Her condition includes ataxia, dysarthria, impaired coordination, balance deficits, reduced mobility, fatigue, and progressive deconditioning. Her health is further complicated by a myocardial infarction in 2023 and kidney failure in 2024, making her medically fragile and requiring careful clinical monitoring during exercise.
The participant currently receives clinically supervised Exercise Physiology (EP) intervention, consisting of two 30-minute sessions per fortnight. The program focuses on maintaining strength, endurance, balance, coordination, mobility, independence, fatigue management, falls prevention, and slowing disease-related decline. Due to the progressive and fluctuating nature of ECD, Exercise Physiology is considered a key component of her multidisciplinary care.
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NDIS Decision and Concerns
The NDIS declined a request for increased Exercise Physiology funding under the Improved Daily Living budget. The decision was based on:
Section 34(1)(c) – Value for Money Section 34(1)(d) – Effective and Beneficial Section 34(1)(f) – Supports are NDIS Supports
The Agency concluded that Exercise Physiology was comparable to general fitness or personal training services, that Physiotherapy and Occupational Therapy could address exercise-related needs, and that Exercise Physiology duplicated existing supports.
Concerns About the Decision
Value for Money
The review argues that Exercise Physiology is a relatively low-cost, preventative intervention that helps reduce:
Functional decline Falls and injuries Hospital admissions Future care needs Reliance on support workers and intensive services
Given the participant’s neurological impairments, cardiovascular history, kidney disease, and falls risk, ongoing Exercise Physiology is viewed as a cost-effective strategy for maintaining function and avoiding more expensive interventions later. The report argues that the decision focuses on short-term costs while overlooking the long-term financial consequences of deterioration.
Effective and Beneficial
The review states that Exercise Physiology has demonstrated clear effectiveness. During a previous period when funding ceased, the participant experienced:
Reduced strength Declining balance Reduced mobility Loss of independence
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Increased difficulty completing daily activities
Following the return of Exercise Physiology services, treatment helped rebuild physical capacity, improve safety, stabilise function, and reduce further decline.
Because ECD is progressive and incurable, maintaining function and slowing deterioration are considered meaningful clinical outcomes. The participant’s documented decline without intervention and improvement after recommencing therapy are presented as evidence that Exercise Physiology is both effective and beneficial.
Exercise Physiology as an NDIS Support
The report argues that Exercise Physiology is being incorrectly characterised as general fitness or a daily living expense.
The intervention is a disability-specific therapeutic service designed to address impairments directly related to ECD, including:
Neurological dysfunction Ataxia Balance impairment Fatigue Deconditioning Mobility limitations Cardiovascular and systemic complications
The service requires clinical assessment, physiological monitoring, risk management, exercise prescription, and ongoing adaptation, which differs significantly from recreational exercise or personal training.
Claims of Duplication
The review disputes the claim that Exercise Physiology duplicates Physiotherapy or Occupational Therapy.
While these services work together, they have different roles:
Physiotherapy focuses on rehabilitation, mobility, and pain management. Occupational Therapy focuses on daily activities, equipment, and independence strategies.
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Exercise Physiology focuses on long-term conditioning, strength development, neuromuscular retraining, fatigue management, cardiovascular fitness, and maintaining physical capacity in chronic disease.
The report argues that these services are complementary rather than interchangeable.
Clinical Concerns
The review states that limiting Exercise Physiology funding does not reflect the participant’s medical complexity or accepted principles of chronic disease management.
Without ongoing clinically supervised intervention, the participant faces increased risks of:
Accelerated physical decline Falls and injury Reduced mobility Increased fatigue Loss of independence Greater reliance on support services Hospitalisation Reduced community participation
The report also highlights concerns that the participant’s previous deterioration without Exercise Physiology demonstrates the foreseeable consequences of reducing support.
Likely Impact of Reduced Funding
The review predicts that reduced or denied Exercise Physiology support may lead to:
Progressive deconditioning Worsening balance and coordination Increased falls risk Greater mobility limitations Increased support worker dependence Reduced participation in daily activities Social isolation Psychological distress Increased hospital admissions and medical complications
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These outcomes would likely increase both the participant’s support needs and long-term NDIS costs.
Conclusion
The review concludes that Exercise Physiology is an evidence-based, disability-specific, capacity-building intervention that is clinically necessary for this participant. It plays a vital role in maintaining function, reducing future support needs, improving safety, and supporting community participation.
The report argues that the NDIS decision does not adequately account for the participant’s progressive neurological disease, complex medical history, or demonstrated need for ongoing intervention. It concludes that restricting Exercise Physiology funding is inconsistent with best-practice management of ECD and may contribute to preventable deterioration, increased dependence on supports, and higher long-term costs
Client 5 - 36 years of age – Below Knee Amputation
This case concerns a 36-year-old woman who underwent a right below-knee amputation in May 2025 following years of chronic ankle instability, injury, and multiple surgical interventions. Since the amputation, she has actively participated in multidisciplinary
rehabilitation, including Physiotherapy, Exercise Physiology, Occupational Therapy,
hydrotherapy, adaptive sports, gym-based exercise, para ice hockey, and archery.
The participant has made significant progress and is now independently ambulant using a prosthesis for daily mobility. However, she remains in an active rehabilitation phase and continues to experience substantial limitations due to a poorly fitting interim prosthesis, including pain, skin irritation, reduced prosthetic tolerance, fatigue, mobility restrictions, and intermittent reliance on a wheelchair for longer distances.
Importantly, she has not yet received her definitive long-term prosthetic limb, which has been identified by clinicians as the primary barrier to further rehabilitation progress.
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NDIS Decision and Concerns
Following review, the participant’s funding was reduced to:
No Physiotherapy funding One Exercise Physiology session per month
The Agency also suggested that rehabilitation support could be delivered by therapy assistants rather than qualified Physiotherapists or Exercise Physiologists.
At the same time, the participant has not been appropriately funded for her definitive prosthesis or the intensive rehabilitation required to support its use.
Concerns About the Decision
Reduction of Rehabilitation Supports
The review argues that reducing rehabilitation at this stage is inconsistent with accepted lower-limb amputation rehabilitation principles.
The participant:
Is less than one year post-amputation Has not yet received her definitive prosthesis Continues to experience socket-related pain and fit issues Has not completed advanced gait retraining Has not returned to work Has not achieved stable prosthetic tolerance
Successful prosthetic rehabilitation requires ongoing gait retraining, strength development, balance training, movement correction, endurance conditioning, and progressive loading. Monthly Exercise Physiology sessions are considered insufficient to support these goals or provide adequate monitoring and progression.
Lack of Funding for Definitive Prosthetic Rehabilitation
The review highlights a major contradiction in the current funding approach.
The participant is expected to improve gait efficiency, increase prosthetic tolerance, return to work, and achieve higher levels of independence, while simultaneously:
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Using an inadequate interim prosthesis Receiving minimal rehabilitation funding Having no Physiotherapy support Receiving only monthly Exercise Physiology sessions
The report argues that receiving a definitive prosthesis without sufficient rehabilitation support will significantly compromise outcomes, as new prosthetic devices require intensive retraining, balance work, strengthening, and supervised adaptation.
Use of Therapy Assistants Instead of Allied Health Professionals
The review disputes the suggestion that therapy assistants can replace Exercise Physiology and Physiotherapy services.
It argues that therapy assistants do not have the clinical training required to:
Assess gait biomechanics Identify compensatory movement patterns Monitor prosthetic loading tolerance Manage falls risk Progress neuromuscular rehabilitation Modify rehabilitation programs Prevent secondary musculoskeletal complications
The participant’s rehabilitation requires ongoing clinical assessment, reasoning, and exercise prescription that can only be provided by appropriately qualified allied health professionals.
Clinical Concerns
The review states that the participant remains in a critical stage of recovery and is still dependent on specialist rehabilitation services to maximise outcomes.
Without adequate support, she is at increased risk of:
Long-term gait abnormalities Chronic pain Reduced prosthetic tolerance Falls and injuries Overuse injuries to the intact limb
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Increased wheelchair dependence Delayed return to work Reduced independence
The report notes that the participant has demonstrated strong motivation, engagement, and rehabilitation potential, but that these gains may be undermined by insufficient access to therapy and prosthetic services.
Likely Impact of Reduced Funding
The review predicts that inadequate rehabilitation funding may result in:
Persistent gait compensations Reduced balance and mobility Increased falls risk Chronic low back, hip, and contralateral limb pain Reduced exercise tolerance Delayed return to employment Reduced participation in community and recreational activities Greater reliance on mobility aids and support services
Over time, poor prosthetic rehabilitation may contribute to joint degeneration, chronic musculoskeletal dysfunction, increased healthcare utilisation, and reduced quality of life.
Conclusion
The review concludes that the participant remains in an active rehabilitation phase and has significant capacity for further improvement. Physiotherapy and Exercise Physiology are described as evidence-based, prosthetic-specific, capacity-building interventions that are essential to achieving long-term independence and successful prosthetic use.
The report argues that reducing support to one Exercise Physiology session per month, removing Physiotherapy funding, and suggesting replacement by therapy assistants significantly underestimates the complexity of lower-limb amputation rehabilitation. It concludes that without appropriate funding for both a definitive prosthesis and ongoing multidisciplinary rehabilitation, the participant faces a substantial risk of avoidable long term disability, chronic secondary complications, and reduced independence.
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Case Study Overview
Across these case studies, a concerning pattern emerges whereby participants with severe, permanent, and well-documented disabilities continue to experience significant difficulties obtaining appropriate NDIS funding despite extensive medical and allied health evidence supporting their needs. These participants present with complex conditions including severe autonomic failure, multiple sclerosis, rare progressive neurological disease, limb amputation and multi-system disability, all of which are supported by specialist reports, functional assessments, and clear clinical recommendations.
In each case, treating specialists and allied health professionals identified the need for ongoing capacity-building and preventative supports to maintain function, reduce deterioration, minimise hospitalisation risk, and preserve independence. However, funding decisions frequently appeared to discount or misunderstand the clinical evidence provided, often characterising essential therapeutic interventions as non-essential, duplicative, or insufficiently cost-effective.
A recurring concern is that highly complex clinical decisions are being made by non-clinical NDIS administrators who may not possess the specialist knowledge required to appropriately assess the functional impact of progressive, neurological, cardiovascular, or multi-system conditions. This can result in decisions that are inconsistent with established clinical practice, rehabilitation principles, and the recommendations of treating health professionals.
The consequences for participants are significant. Inadequate funding can lead to distress, reduced access to essential supports, preventable deterioration in physical and mental health, loss of independence, increased hospital admissions, and greater reliance on formal care services. Participants and their families are often forced to pursue lengthy review processes, external appeals, and Administrative Review Tribunal proceedings to obtain supports that were clinically recommended from the outset.
This process not only places substantial emotional and financial strain on participants but may also generate significantly greater costs for the Scheme through legal expenditure, review processes, crisis interventions, hospitalisations, and increased long-term support needs. In many cases, the cost of funding the clinically recommended supports in the first
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Submission 834
instance would likely be substantially lower than the cumulative costs associated with appeals, litigation, deterioration, and subsequent higher-intensity care requirements.
These case studies highlight the need for greater clinical expertise within NDIS decision making processes and stronger consideration of specialist medical evidence when determining reasonable and necessary supports for participants with severe and complex disabilities.
Summary
Adelaide Wellbeing Society supports the long-term sustainability and integrity of the NDIS and acknowledges the importance of reducing fraud, improving accountability, and strengthening governance across the disability sector.
However, we believe several proposed amendments within the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 risk undermining the participant-centred foundations of the Scheme and creating unintended harm for both participants and providers.
Our key concerns include:
Excessive ministerial powers with reduced parliamentary oversight Reductions to capacity building and rehabilitation supports Inadequate NDIS pricing and travel funding arrangements Unsustainable compliance burdens for allied health providers Functional capacity assessments conducted without sufficient clinical oversight Ambiguous provisions regarding suspension of participant funding Automated planning systems replacing genuinely individualised assessments Lack of transparency surrounding future program implementation
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Submission 834
We respectfully urge the Committee to carefully consider the practical consequences these reforms may have on Australians living with disability, particularly those experiencing socioeconomic disadvantage, complex support needs, and barriers to healthcare access.
We strongly encourage the adoption of reforms that remain clinically informed, evidence based, transparent, financially sustainable, and genuinely participant-focused to ensure the NDIS continues to uphold its original purpose of improving the independence, wellbeing, and quality of life of Australians living with disability
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