Otsi Supplementary Submission to the NDIS Joint Standing Committee 15 September 2026

Executive Summary

The Occupational Therapy Society for Invisible Disabilities (OTSi) welcomes the opportunity to provide this supplementary submission to the Joint Standing Committee on the NDIS. It addresses four key elements of the current NDIS reform agenda: the proposed Support Needs Assessment and use of the ICAN; changes to NDIS access and functional capacity assessment; reform of access to allied health-delivered capacity-building interventions and the therapy market, including Early Childhood Intervention; and the urgent need to establish alternative pathways to occupational therapy and allied health-delivered functional interventions outside the NDIS.

These reforms are occurring at exceptional speed and at a scale that will affect hundreds of thousands of Australians. They are reshaping the gateway to the NDIS, the way disability and functional capacity are understood and assessed, the availability of capacity-building interventions, and the respective responsibilities of the NDIS, foundational supports, mainstream systems and Medicare.

In this context, rigorous parliamentary oversight is critically important, now more than ever. The Joint Standing Committee has an essential role in ensuring that the pace of implementation does not outstrip the evidence required to establish that these reforms are safe, equitable, clinically defensible and fit for purpose. Standardisation must not come at the expense of validity; perceived efficiency must not displace due process; and changes in funding responsibility must not be mistaken for changes in disability-related need.

OTSi thanks the Committee for its ongoing work and respectfully asks that it exercise the fullest possible due diligence as this vast program of reform accelerates. In particular, we ask the Committee to maintain close scrutiny of the evidence underpinning new assessment methodologies, the impacts of changing access thresholds, the capacity of alternative systems to meet emerging need, and the consequences for people who may lose access to disability-specific supports.

The future architecture of the NDIS and the broader disability support system will be determined not only by the legislation that has now passed, but by the assessment methodologies, implementation decisions, market settings and alternative pathways that follow. The Committee’s oversight is an essential safeguard of its integrity.

TABLE OF CONTENTS

Recommendations………………………………………………………………………………………………….4

PART 1: UNPACKING THE ICAN AS A SUPPORT NEEDS ASSESSMENT FOR THE NDIS

• 1.1 Can the ICAN enable equitable assessment of disability support needs across disability cohorts?
• 1.2 The ICAN does not have proven ability to assess for capacity-building disability support needs
• 1.3 Committee oversight of the NDIS Support Needs Assessment pilot and trial

PART 2: NDIS ACCESS CHANGES AND FUNCTIONAL CAPACITY ASSESSMENT

• 2.1 What is required for a fair, consistent, transparent, disability-informed and evidence-based process?
• 2.2 Can the ICAN be used as an assessment of functional capacity?
• 2.3 How can the process reduce administrative burden while remaining proportionate?
• 2.4 How can the process work across all disability cohorts?
• 2.5 When and how will impairment categories apply?
• 2.6 Functional assessment, the phrase “activity as a whole” and the risk of reductionism
• 2.7 Permanence, treatment and evidence
• 2.8 The evidence problem: what is being validated, and against what?
• 2.9 Safeguarding, transition and the consequences of being found ineligible
• 2.10 Trauma-informed assessment
• 2.11 Parliamentary and independent oversight

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PART 3: ACCESS TO ALLIED HEALTH DELIVERED CAPACITY BUILDING, AND THERAPY MARKET REFORM (INCLUDING NDIS EARLY CHILDHOOD INTERVENTION)………………………………………19

• 3.1 Reform risks creating a loss of therapy access across the disability population
• 3.2 Skilled occupational therapy and allied health expertise is not interchangeable with generic support
• 3.3 For those who lose NDIS access, the equity risk is substantial
• 3.4 ECI provides a clear example of the broader risk
• 3.5 Australia’s specialist workforce is infrastructure, not an expendable market input
• 3.6 Continuity must survive changes in funding
• 3.7 Priorities for consideration by the NDIS Joint Standing Committee

PART 4: PROPOSING NEW ACCESS PATHWAYS TO OCCUPATIONAL THERAPY AND ALLIED HEALTH DELIVERED INTERVENTIONS OUTSIDE THE NDIS…………………………………………..….24

• 4.1 Current reform will mean less access to occupational therapy function-focused interventions
• 4.2 The potential impact on the lives of people with disability
• 4.3 Proposing solutions and pathways to access occupational therapy and allied health delivered focused functional interventions
• 4.4 What are the focused functional interventions?
• 4.5 The occupational therapy workforce
• 4.6 Summary: Building the Policy Case for Access to Focused Functional Interventions Outside the NDIS

APPENDIX 1………………………………………………………………………………………………………..28

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SUMMARY OF RECOMMENDATIONS

Part OTSi recommends that the Australian Government:

1. Do not implement the ICAN/SNA nationally until its equity and validity across disability cohorts, including hidden, cognitive, psychosocial, fluctuating and multiple disability, are demonstrated.
2. Require the SNA to identify both current support needs and disability-related capacity-building needs, including allied health intervention.
3. Ensure ongoing parliamentary and independent oversight of the SNA pilot and trial, with transparent publication of validation, reliability, cohort, assessor, budget translation, participant verification, consent, data-use and automated decision-making findings.

Part 1: ICAN and Support Needs Assessment

1. Retain a functional, participation-focused approach to access, explicitly anchored in the ICF rather than diagnosis or impairment severity.
2. Defer implementation until the new access framework is independently validated as reliable, equitable and feasible across disability cohorts.
3. Ensure both functional capacity and real-world performance can inform eligibility decisions.
4. Clarify fundamental constructs, including “activity as a whole”, through consultation and co-design.
5. Provide transparency about impairment categories, attribution, timing and how multiple impairments will be considered.
6. Recognise cumulative and interacting disability rather than attributing limitations artificially to a single impairment.

Part 2: NDIS Access and Functional Capacity Assessment

7. Formally recognise OT expertise and ensure meaningful OT and lived-experience representation in assessment design, validation and governance.
8. Preserve meaningful consideration of participant-provided allied health evidence, particularly for complex, fluctuating, episodic or difficult-to-observe disability.
9. Embed trauma-informed assessment, including assessor choice, reasonable adjustments, participant control and minimisation of repeated disclosure.
10. Ensure permanence and treatment requirements respect bodily autonomy, informed consent and the right to decline treatment without losing disability supports.
11. Require a Participant Impact Assessment and Statement of Alternative Supports before NDIS access is withdrawn.
12. Establish safe, graded transitions that prevent abrupt withdrawal of essential supports.
13. Prohibit fully automated eligibility decisions and require meaningful, expert human review, transparency and independent audit of automated systems.
14. Provide access to independent functional assessment within merits review.
15. Maintain ongoing parliamentary and independent oversight, with transparent publication of validation, equity and implementation findings

Part 3: Allied Health Capacity Building and Therapy Market Reform

1. Undertake population-wide modelling of therapeutic need, service capacity, workforce requirements, geographic distribution and unmet need before restructuring therapy markets or transferring responsibilities.

OTSi Supplementary Submission NDIS JSC - 15 September 2026

OTSi recommends that the Australian Government:

• 2. Protect access to appropriately qualified OT and allied health professionals where specialist intervention is required; generic or educator supports cannot substitute for clinical expertise and professional reasoning.
• 3. Protect workforce diversity, continuity and equitable access, including small and medium providers, senior expertise, and continuity of therapeutic relationships.
• 4. Monitor provider exits, waiting times, regional access, workforce turnover, specialist access, continuity, family experience and functional outcomes, particularly for people leaving the NDIS.

1. Establish new, alternative pathways to OT and allied health-delivered Focused Functional Interventions for people unable to access them through the NDIS.
2. Develop safe transition and foundational pathways, including functional intervention packages and consideration of a Medicare item.
3. Base pathway design on population need and evidence of effective intervention, rather than funding transfer or expenditure reduction.
4. Use Australia’s existing regulated OT workforce to maintain access to interventions addressing executive and cognitive functioning, routines and life skills, sensory regulation, social functioning, occupational balance and participation.

PART 1: UNPACKING THE ICAN AS A DISABILITY SUPPORT NEEDS ASSESSMENT FOR THE NDIS

OTSi has previously made a substantive submission to this inquiry on New Framework Planning (NFP) and Support Needs Assessment (SNA), including 46 recommendations. Those recommendations remain current. Within this supplementary submission, we ask the committee to consider:

• Can the ICAN enable equitable assessment of disability support needs across disability cohorts?
• The ICAN does not have proven ability to assess for capacity-building disability support needs
• Committee oversight of the NDIS Support Needs Assessment pilot and trial.

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1.1 Can the ICAN enable equitable assessment of disability support needs across disability cohorts?

The NDIA has described I-CAN v6 as a holistic, strengths-based and person-centred tool intended for use “for all disability types aged 16 years plus”.¹ It is explicitly based on the International Classification of Functioning, Disability and Health (ICF), encapsulated with a 12-domain structure. OTSi acknowledges the established strengths of the ICAN as a clinical practice tool, and the current efforts by the NDIA to pilot and trial an adapted version of the ICAN v6 for a brand new purpose - as a tool to assist NDIS plan development and budget-setting tool.

However, there are significant concerns about the extent to which the I-CAN subdomains, as presently structured, adequately capture the full scope of support needs, particularly when we map the 12-domain structure across the six NDIS functional domains of mobility, communication, social interaction, learning, self-care and self-management.

The principal concern is not that I-CAN fails to mention cognitive or executive tasks. It does mention several of them, including initiating and completing tasks, decision-making, daily routines, punctuality, medication management and safety. The concern is that these functions are distributed across multiple practical activities rather than being systematically assessed as underlying cognitive functions.

The following cognitive and executive functioning elements are essential to consider:

• executive functioning;
• planning, organisation and sequencing;
• initiation and task activation;
• sustained attention and working memory;
• cognitive flexibility and task switching;
• problem-solving;
• self-monitoring and error detection;
• processing speed;
• cognitive fatigue;
• the impact of stress, sensory load or psychological demands on cognition;
• fluctuating or episodic functional capacity;
• supported decision-making;
• communication supports required to enable decision-making;
• the person’s need for assistance to understand information, consider options, weigh consequences;
• the role of environmental and interpersonal barriers in producing functional limitation.

These gaps are particularly significant for people with psychosocial disability, autism, ADHD, intellectual disability, acquired brain injury, cognitive disability and some other conditions, where disability-related functional limitations may be predominantly cognitive, executive, behavioural, sensory, communicative or fluctuating rather than observable through conventional task performance.

There is therefore a risk that the I-CAN will systematically produce a more complete picture of support needs for people with observable physical or personal-care limitations than for people whose disability primarily affects cognition, executive functioning, communication, emotional regulation, initiation, decision- making or the ability to navigate complex environments.

¹ Assessments and Budgeting co-design working group meeting December 2025 | NDIS

OTSi Supplementary Submission NDIS JSC - 15 September 2026

This is not merely a clinical issue. If the I-CAN is used to determine access to, quantity of, or intensity of NDIS supports, these structural features have potential consequences for equity between disability groups. It also has implications for identifying support needs related to supporting executive functioning and decision making, both essential to ensuring autonomy, self-direction and safety.

[See Appendix 1 for a summary of gaps noted when ICAN domains are mapped to the NDIS functional/domains/activities and the ICF]

1.2 The ICAN does not have proven ability to assess for capacity-building

disability support needs

OTSi is concerned that the proposed Support Needs Assessment framework, including I-CAN, has not established a proven capacity to identify and assess disability-related capacity-building needs. This is a critical gap. If the assessment determines the quantum of a participant’s budget, but does not validly capture the supports required to build skills, independence and participation, capacity-building interventions risk being systematically under-recognised or displaced by a stagnant picture of immediate needs.

This has significant implications for access to allied health, including occupational therapy and other interventions directed towards functional outcomes. Within the newly proposed flexible budget2, where budgets are constrained, participants may be required to prioritise essential daily supports, leaving capacity-building and skill development with limited resources. Allied health access therefore risks becoming an optional or secondary intervention rather than an integral component of disability support.

This would also represent a significant departure from the insurance principles underpinning the NDIS. Investment in appropriate capacity-building supports is intended not simply to address present need, but to support improved functional outcomes, independence and participation and, where possible, reduce future reliance on funded supports. An assessment methodology that cannot identify these needs risks embedding a model of passive maintenance rather than enabling participants to realise their potential.

There is a further unintended incentive problem. If building capacity can contribute to a future reassessment of support needs, participants may reasonably fear that demonstrating improved skills could place essential supports at risk. The system must not create a perverse incentive for participants to remain dependent in order to preserve access to the supports that enable them to become more independent.

The proposed separation of budget-setting from participant goals compounds this concern. If goals are considered only after the budget has been determined, it remains unclear how the resources required to pursue those goals, including capacity-building and allied health interventions, will be secured.

OTSi therefore considers it essential that the SNA methodology demonstrate, before implementation, that it can identify not only what support a person requires to maintain their current functioning, but what disability- related supports may be required to build capacity, achieve greater independence and participate more fully in community life. Without this evidence, the reform risks moving the NDIS away from its social and insurance foundations and, for some participants, creating a system in which they are supported to cope with disability but not supported to reach their full potential.

2 New Framework Planning and NDIS Supports Consultation - Australian Government Department of Health, Disability and Ageing - Citizen Space

1.3 Committee oversight of the NDIS Support Needs Assessment pilot and trial.

OTSi acknowledges that the NDIA has commenced piloting the SNA and respectfully asks the Committee to seek detailed information from the NDIA and participating universities about the design, conduct and preliminary findings of this work. In particular, OTSi considers the following matters essential to determining whether the SNA is safe, valid and fit for purpose:

Area	Matters OTSi asks the Committee to examine
Assessor training and expertise	Whether all assessments included in the trial were undertaken by appropriately trained/accredited I-CAN assessors. OTSi has received reports that some participants were assessed before assessors had completed required accreditation. The Committee should establish whether these assessments remain within the trial dataset and how assessor training status is being accounted for in evaluating results.
Assessor professional background	The proportion of assessments undertaken by qualified allied health professionals working within scope of practice, compared with other health professionals and non-allied health assessors. This should be transparently reported so that the influence of professional expertise on assessment quality within the pilot can be evaluated.
Validity and reliability	Publication of preliminary and final findings, including relevant psychometric indicators such as test-retest and inter-rater reliability, validity and error rates. Results should be reported across disability types, including complex, fluctuating, hidden, cognitive and psychosocial disability.
Participant verification	Why participants undertaking the pilot do not appear to receive a written SNA outcome. Participants should be able to see and verify whether their assessment accurately reflects their support needs. This feedback loop is also an important mechanism for identifying assessment errors and should form part of pilot evaluation.
Budget translation	How SNA outcomes are being translated into participant budgets, including the methodology, assumptions and validation of that process. This is a critical component of the reform and should be transparent and independently scrutinised.
Consent and data use	Whether pilot consent processes are genuinely informed, particularly where participants consent to access to NDIS records by two universities and unspecified third parties. The Committee should establish who can access participant information, for what purposes, and whether the identity and role of third parties are adequately specified.
Disability representation	Whether the pilot provides sufficiently robust representation across disability types and captures diverse support needs, including fluctuating, episodic, hidden, cognitive, psychosocial and multiple disabilities.
Automated decision-making	Whether automation or algorithmic decision-making is being tested as part of the SNA or budget translation process. If so, its reliability, error rates, explainability, safeguards and human review mechanisms should be tested before national implementation. Automation should not be deployed for the first time when SNA commences nationally on 1 April 2027.

PART 2: NDIS ACCESS CHANGES AND FUNCTIONAL CAPACITY ASSESSMENT

The consultation on NDIS access changes is one of the most consequential policy consultations currently underway for the disability community and for the future architecture of the NDIS. It follows a significant change to the threshold for NDIS access introduced by changing the definition of substantially reduced functional capacity by now considering it as it applies to functional activities “as a whole”, by operational guideline, on August 26“ 2026, enabled by the NDIS legislation change’. The altered definition could substantially limit access to the NDIS, in the absence of the new assessment, as it has already been applied.

The Government proposes that, from 1 January 2028, access will no longer rely primarily on diagnosis or the existing diagnostic lists. Instead, people will be required to demonstrate eligibility through a standardised, evidence-based assessment of functional capacity and its impact on day-to-day living. All existing NDIS participants are proposed to be reassessed over a three-year transition period. The scale is therefore unprecedented: more than 700,000 people currently receiving NDIS support will ultimately be subject to a new access test, with estimates associated with the reforms indicating that around 240,000 people may leave the Scheme.

This is not simply a change to an administrative process. It is a fundamental redefinition of the gateway to Australia’s principal disability support system. The new assessment will It help determine what constitutes sufficient evidence of disability, what functional capacity means in law and practice, how impairment is understood, whose professional evidence is relied upon, how people with complex or fluctuating disabilities are assessed, and ultimately who is recognised as requiring the level of disability-specific support that the NDIS is intended to provide.

OTSi supports the policy objective of improving consistency, transparency and fairness in access. We also support moving away from diagnosis-based access. The NDIS Review identified genuine problems with the existing system, including inconsistent access decisions and excessive reliance on diagnosis and the participant’s ability to produce supporting evidence.

However, a functional approach is only as fair as the construct of function being measured and the methodology used to measure it. This distinction is critical.

The proposed reforms create a significant risk that functional capacity will become reduced to something easier to measure than the complex phenomenon it represents.

The current legislative definition focuses on what a person can do in a standardised environment designed to minimise environmental and personal circumstances. OTSi considers that this definition requires careful consideration. A person’s ability to perform a task under controlled conditions is not equivalent to their ability to function safely, reliably and sustainably in everyday life. For many people with invisible, psychosocial, cognitive, sensory, fluctuating or multiple disabilities, the difference between capacity and performance is itself the most important evidence of disability.

Our guidelines | NDIS

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OTSi Supplementary Submission NDIS JSC - 15 September 2026

This is not an academic distinction. It is the difference between assessing a person as they function in the world and assessing an artificially isolated version of their ability.

The World Health Organization’s International Classification of Functioning, Disability and Health (ICF) recognises functioning as an interaction between health conditions, body functions and structures, activities, participation and environmental factors. Capacity and performance are related but distinct constructs. The proposed assessment framework must therefore be developed in a way that remains faithful to this conceptual foundation rather than using impairment severity or isolated task completion as a proxy for functional capacity assessment.

There is a second fundamental issue: the assessment methodology does not yet appear to have been established, validated or demonstrated at national scale. The Technical Advisory Group will consider different approaches, tools and thresholds, and its advice will inform future NDIS rules. The parliamentary inquiry into the recent NDIS Bill similarly acknowledged that further work is required to identify the appropriate assessment of functional capacity.

This creates a significant sequencing question. Parliament has now legislated the broad architecture before the methodology that will give that architecture practical meaning has been fully developed and tested. There is currently no single validated instrument capable of comprehensively assessing functional capacity across the breadth of NDIS domains and disability presentations. Developing such a system would require psychometric validation, cross-population testing, calibration, assessor training, reliability testing and independent evaluation.

OTSi’s position is therefore not that functional assessment should not occur. It is that the Government must not implement a national eligibility threshold until it can demonstrate that the assessment system used to determine that threshold is valid, reliable, equitable and clinically fit for purpose.

This is particularly important because the future NDIS has not yet been clearly articulated in a way that enables the community– including people with current, real and pressing needs – to understand the relationship between the new access gateway, Foundational Supports, mainstream services and the Scheme itself. The consultation acknowledges that access reform is occurring alongside significant changes outside the NDIS, while also acknowledging that further work is required on final thresholds, transition arrangements and implementation. The community is therefore being asked to consider a new gateway before the complete architecture through which people will receive support is known.

Finally, OTSi considers that access reform cannot be separated from safeguarding. If a new threshold results in people leaving the NDIS, disability-related support needs do not necessarily disappear. The recent parliamentary inquiry on the NDIS legislation has already heard evidence that alternative supports outside the NDIS do not yet reliably exist in all communities and that states and territories have not agreed to provide like-for-like services to people who leave the Scheme.

The central question is: How can Australia construct a disability access system that is valid, legally sound, equitable across disability, genuinely informed by lived experience, and safe for the people whose lives will depend upon its decisions?

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2.1 What is required for a fair, consistent, transparent, disability-informed and evidence-based process?

The Government proposes to replace diagnosis-based access with standardised functional assessment. This is potentially a significant improvement. However, the reform will only achieve its stated purpose if “functional capacity” is understood as a multidimensional construct rather than as a measure of whether someone can complete a task during a short assessment.

The proposed legislative definition describes capacity as what a person can do in a standardised environment that minimises environmental and personal circumstances. This creates tension with both the ICF and with contemporary occupational therapy practice.

Occupational therapists know that function emerges through the relationship between the person, occupation and environment. We therefore do not ordinarily determine functional capacity by asking only whether a person can perform a task in isolation. We consider whether the task can be initiated, sequenced, completed safely, repeatedly and sustainably; whether prompting or supervision is required; whether sensory, cognitive, psychosocial or physical demands alter performance; and what environmental or assistive supports are necessary to make participation possible.

A person may be able to physically hold a spoon but be unable to prepare and consume an adequate meal independently. They may be able to remove their clothing but be unable to shower safely without assistance. They may be able to walk 100 metres in a clinic but be unable to reliably leave their home and avigate the community. They may communicate fluently in a structured interview but be unable to manage the communication, planning and cognitive demands of multiple services in everyday life.

This is why the distinction between capacity and performance matters. The ICF conceptualises capacity as what a person can do under standardised conditions and performance as what they actually do in their usual environment. The gap between the two can reveal key aspects of functional capacity.

A capacity-only model therefore risks systematically under or over-estimating people whose disability is context-dependent, fluctuating or hidden.

The issue is particularly acute for people living with acquired brain injury, psychosocial disability, autism, intellectual and cognitive disability, neurological disability, ME/CFS, dysautonomia, sensory disability and multiple co-occurring conditions. Exhaustion, post-exertional deterioration, pain, autonomic dysfunction, sensory overload, executive dysfunction and cognitive fatigue may not be observable during a brief assessment.

The assessment system must also recognise executive functioning as a substantive component of self- management. Planning, organisation, initiation, sequencing, emotional regulation, system navigation and maintaining routines are functional activities. They cannot be reduced to whether a person can perform isolated personal-care tasks.

The assessment method cannot disadvantage the person because of the nature of their disability and instead must accommodate the person’s needs - including cognitive, communication, psychosocial, neurological and executive functioning difficulties.

Otsi Supplementary Submission NDIS JSC - 15 September 2026

Assessments also need to carefully consider gender. There has been insufficient analysis of the extent to which the assessment processes and standardised assessment tools used in the NDIS may contribute to gender inequities in access. This is particularly important given evidence of substantial differences in eligibility rates. An analysis of NDIS administrative data by Disney, Yang et (2025)⁴, found that, among applicants with physical disability, women and girls had 145 fewer approvals per 1000 applicants than men and boys, while women and girls with psychosocial disability had 83 fewer approvals per 1000 applicants than men and boys. The authors concluded that women and girls with certain disability types were less likely to be deemed eligible for NDIS support and that changes to eligibility processes could reduce these inequalities.

The selection and validation of assessment tools should therefore explicitly consider whether they adequately identify disability and support needs across genders and whether the constructs being measured privilege particular presentations of disability over others. For example, an assessment may place greater weight on observable behaviours that present as challenging, disruptive or risky to others, while failing to adequately capture disability-related vulnerability, including vulnerability to coercion, exploitation, abuse or being the recipient of aggression. A person whose disability substantially increases their vulnerability to harm may therefore have significant support needs that are not adequately reflected if the assessment primarily captures behaviours that are more visible or disruptive to others. We support the consideration of gender equity as a principle but recommend that there is explicit analysis in the selection, validation and ongoing evaluation of standardised assessments used to inform NDIS access decisions, including examination of whether particular assessment constructs or scoring systems produce systematic false negatives for girls and women.

2.2 Can the ICAN be used as an assessment of functional capacity?

There appears to be potential consideration of using the I CAN as an assessment of functional capacity for the purposes of determining access to the NDIS. This would represent a significant departure from the purpose for which the tool was developed and would require a major, currently unproven assumption: that a person’s level of disability support need can be used as a reliable proxy for substantially reduced functional capacity.

High support needs and substantially reduced functional capacity are related concepts, but they are not synonymous. Support needs are shaped not only by the person’s underlying functional capacity, but also by the nature and severity of impairment, environmental demands, available informal and formal supports, assistive technology, communication requirements, safety considerations and the extent to which capacity translates into actual performance over time. Using the I CAN as an access assessment would therefore risk assessing NDIS eligibility through an unvalidated instrument for that purpose, and potentially through an adapted version of the instrument that has not itself been demonstrated to validly establish the statutory threshold of substantially reduced functional capacity. This is particularly concerning if the adapted assessment does not provide an explicit mechanism for considering and weighing medical, disability and allied health evidence.

⁴ Disney, G., Yang, Y., Summers, P., Devine, A., Dickinson, H., & Kavanagh, A. M. (2025). Social inequalities in eligibility rates and use of the Australian National Disability Insurance Scheme, 2016–22: An administrative data analysis. Medical Journal of Australia, 222(3), 135–143. https://doi.org/10.5694/mja2.52594

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The I CAN is an unstructured interview and self-report tool designed to explore disability support needs in real-world environments; it is not, in its original form, a functional-capacity measurement instrument. Its value lies in eliciting information about what a person can and cannot do, what support is required, and how functioning is affected in context. That information should be considered alongside, rather than substituted for, appropriately qualified clinical and functional evidence. Establishing substantially reduced functional capacity, particularly where permanence and change over time are relevant, requires triangulation across multiple sources of information, including the person’s own account, observation where appropriate, longitudinal history, medical and allied health evidence, information from family or other people who know the person well, and evidence of actual performance across relevant environments. A support-needs interview and self-report tool may make an important contribution to that assessment, but it should not be assumed to establish functional capacity or NDIS eligibility in isolation.

2.3 How can the process reduce administrative burden while

remaining proportionate?

OTSi strongly supports the objective of reducing the extraordinary administrative burden currently experienced by participants and families.

However, the answer cannot be to reduce the evidentiary quality required for a high-consequence decision. It should instead be to place greater responsibility upon government to obtain, integrate and interpret evidence.

The NDIS Review’s Action 3.1 envisaged a transparent and robust functional capacity approach in which existing instruments would be tested against the populations for which they are intended, new instruments would be developed where necessary, assessment would span relevant domains, fluctuating disability and environmental circumstances would be recognised, and treating professionals would remain an important source of evidence. Action 3.1 was intended to establish a more consistent and robust approach to NDIS eligibility and an agreed definition of substantially reduced functional capacity.

A proportionate process should mean that people with clearly profound and permanent disability are not repeatedly required to prove what is already established. It should not mean that people with complex, fluctuating or less visible disabilities are given a superficial assessment because a superficial assessment is administratively easier.

2.4 How can the process work across all disability cohorts?

The consultation explicitly identifies communication, cultural, cognitive, degenerative, fluctuating, episodic and complex support needs. OTSi considers these characteristics must be embedded into the architecture of the assessment rather than treated as special cases.

The most significant risk is that standardisation becomes synonymous with uniformity. Fairness does not require every person to be assessed in precisely the same way. It requires that the same legal threshold be applied through methods that are valid for the people being assessed.

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OTSi Supplementary Submission NDIS JSC - 15 September 2026

A person with ME/CFS may demonstrate capacity during an appointment and experience post-exertional deterioration afterwards. An autistic person may mask significant functional limitations in an unfamiliar environment. A person with psychosocial disability may function very differently depending on stress, trauma, executive load and environmental predictability. A person with cognitive disability may demonstrate a learned skill but remain unable to independently initiate and generalise that skill. A Deaf participant may require communication through Auslan; a non-speaking participant may require AAC. A person in a rural or remote community may have no practical access to the specialist whose evidence the system expects. These differences do not make functional capacity assessment impossible. They demonstrate why the assessment methodology must be robust and sensitive enough to deeply understand ‘substantially reduced functional capacity in a non-discriminatory way.

The same principle applies to multiple impairments. A participant’s functional limitation may arise from the interaction of several conditions rather than from one discrete impairment. A person may require mobility equipment because of the combined effects of visual and musculoskeletal impairment, even though neither condition independently explains the support need. OTSi’s previous analysis has identified the risk that a whole-of-person functional assessment could subsequently be undermined if eligibility decisions are limited to functional impact of a single impairment category.

This leads to one of the most important unresolved questions in the entire reform.

2.5 When and how will impairment categories apply?

The consultation is focused on access, but the broader legislative framework gives impairment categories potential significance. At present it is unclear how impairment categories will be determined, what methodology will be used, whether categorisation will depend upon clinical judgement, administrative rules or algorithmic processes, and how overlapping impairments will be handled. Impairment categories defined at the point of access, may determine what supports that person can access.

Most importantly, will impairment categories be determined at the point of access?

If so, how will an assessor isolate the functional contribution of individual impairments where the person’s actual disability arises through interaction?

If categories are determined after a whole-of-person functional assessment, will the process subsequently disaggregate the person’s impairments in a way that undermines the assessment that established them?

And if a person’s reduced functional capacity is attributed to an impairment that is not recognised as qualifying, could the person effectively fail the access test despite having substantial disability?

These questions cannot be left to future administrative guidance.

Without transparency, there is a real risk that diagnosis lists will simply be replaced by an alternative form of categorical reduction. The current impairment categories are effectively diagnostic lists and not aligned with an ICF-based understanding of impairment.

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2.6 Functional assessment, the phrase “activity as a whole” and the risk of reductionism

OTSi is particularly concerned about the implementation of the phrase “considering each activity as a whole”, enshrined within the amended legislation to paragraph 24 (1) (c).

Under a narrow interpretation of “ considering each activity as a whole“ “, it could be argued that because the individual can perform one component of the task, they do not meet the threshold for being unable to complete the activity “as a whole”. NDIS Operational guidelines, implemented on August 26²⁰²⁶, as enabled by the NDIS legislation change^?, effectively use this altered definition to change the access threshold for accessing the NDIS, effective immediately. This has implications for the ongoing eligibility for the NDIS, for hundreds of thousands of people. The altered definition could substantially limit access to the NDIS, prior to the introduction of news assessment due to commence in early 2028.

The phrase requires clarity because everyday occupations are not singular acts. They are complex sequences of interdependent activities.

Eating involves recognising hunger, planning, accessing food, preparing it, tolerating sensory demands, physically consuming it and monitoring nutritional needs. Showering involves initiation, preparation, sequencing, sensory tolerance, balance, physical access, safety and completion. Community participation involves leaving the home, navigating transport, communicating, regulating sensory and emotional demands and sustaining participation.

A person can perform one component while remaining substantially unable to perform the occupation independently. If “activity as a whole” is interpreted to mean that capacity to perform one component negates significant limitations elsewhere within the activity, the threshold could become substantially more restrictive.

2.7 Permanence, treatment and evidence

OTSi recognises that permanence is an important component of NDIS eligibility. However, permanence should be determined clinically and functionally, not through a requirement that a person exhaust every theoretically available intervention.

The proposed approach to “appropriate treatment” is particularly concerning because it can render treatment availability as a theoretical proposition rather than a lived reality.

The parliamentary inquiry heard directly from the Commonwealth Ombudsman that the proposed provisions could produce discriminatory outcomes for people unable to afford treatment or living where treatment is not reasonably accessible. Rural and remote health stakeholders similarly highlighted the absence of services, affordability barriers and the limited research base for some conditions.

• Our guidelines | NDIS

OTSi Supplementary Submission NDIS JSC - 15 September 2026

OTSi’s concern extends further. People may be unable to reconstruct their treatment history because clinics have closed, records have been lost, treating practitioners have retired, family members who held information have died, or the person’s own disability, homelessness, trauma, domestic and family violence or cognitive or psychosocial impairment disrupted continuity of care. These are not failures of treatment. They are disability-related barriers to producing historical evidence.

Treatment also cannot be conflated with cure. Many lifelong, fluctuating and degenerative disabilities are managed through interventions that maintain function, prevent deterioration, preserve participation, reduce hospitalisation or reduce carer strain. A treatment that improves one aspect of functioning does not establish that the person’s disability is no longer permanent or significant.

The concept of treatment must also respect bodily autonomy. A Deaf person may choose not to undergo cochlear implantation for reasons including personal preference, cultural identity, communication preferences, perceived risks or expected outcomes. A person with psychosocial disability who experienced significant cognitive impacts following electroconvulsive therapy should not be required to repeat an intervention that previously caused functional harm merely to demonstrate that treatment options have been exhausted. OTSi has previously raised both examples in its analysis of the NDIS Bill.

People must retain the right to refuse treatment without losing access to disability support.

The framework must also guard against capacity-building supports being reclassified as “treatment” that a person must exhaust before becoming eligible. This risks turning the NDIS’s own mechanisms for maintaining and building functional capacity into prerequisites for entering the Scheme. For people with energy-limiting disabilities in particular, inappropriate or exertion-based interventions may worsen functioning rather than improve it.

The appropriate question should therefore be whether a person’s impairment is likely to be substantially remedied by evidence-based, clinically appropriate and realistically accessible intervention undertaken with free and informed consent. It should not be whether a person has exhausted every intervention that could theoretically exist.

2.8 The evidence problem: what is being validated, and against what?

Perhaps the most significant unanswered question arising from this consultation is how the Government intends to establish that the future assessment methodology is fit-for-purpose. The Consultation Paper states that the future process should be reliable, valid, equitable and consistently applicable across diverse disability cohorts. OTSi strongly supports this standard. But those properties must be demonstrated empirically.

There is currently no single validated national tool capable of comprehensively measuring functional capacity across all NDIS domains and disability presentations. OTSi’s analysis identified three broad conceptual pathways: domain-based assessment; impairment tables used as a proxy for function; and an integrated ICF-aligned model incorporating both capacity and real-world performance. OTSi considers an integrated ICF-aligned approach the strongest long-term direction, but recognises that developing it properly will require substantial work.

This is where the role of occupational therapy is particularly important. Occupational therapists already assess the relationship between impairment, activity, participation, environment and support. We routinely integrate self-report, observation, standardised measures, collateral information, longitudinal history, environmental assessment and clinical reasoning. We understand that the same diagnosis can produce profoundly different functional outcomes and that apparently similar functional presentations may arise from very different combinations of impairment and context.

2.9 Safeguarding, transition and the consequences of being found

ineligible

The Consultation Paper appropriately asks how the access process can determine whether the NDIS is the most appropriate system of support and connect people with other available services. OTSi supports this principle, but “available” must mean available in real terms, within the person’s actual circumstances.

Recent parliamentary inquiries have already heard that the disability support ecosystem outside the NDIS is not yet reliably established and that states and territories have not agreed to provide equivalent services to people who leave the Scheme. This creates an obvious safeguarding obligation.

Where a participant loses eligibility, the Agency should be required to undertake a Participant Impact Assessment identifying foreseeable consequences for health, safety, functional capacity, mental health, housing, parenting, family stability, carer sustainability and community participation.

Alongside this, the participant should also receive a Statement of Alternative Supports identifying the actual service available to replace the NDIS support, its eligibility requirements, expected waiting period, cost, accessibility, geographical availability and capacity to meet the person’s need.

No responsible health or disability service would routinely withdraw an essential intervention without considering the consequences of withdrawal and establishing an appropriate handover. The Commonwealth should apply the same principle when withdrawing disability supports.

For the approximately 240,000 people expected to leave the Scheme under the broader reform agenda, this should include graded transition arrangements, including consideration of step-down plans, rather than a support and funding cliff drop. The purpose of transition should be to establish safe continuity of support.

2.10 Trauma-informed assessment

For many disabled people, repeated assessment is itself part of a history of institutional, medical and administrative trauma. Participants may have repeatedly been required to demonstrate that their disability is real, severe enough, permanent enough or costly enough to warrant support. A new access system should not compound that experience.

Participant choice of assessor is therefore not merely a consumer preference. It can be a clinical safeguard. Trust, communication, familiarity and longitudinal knowledge can materially affect the quality of information obtained. This is particularly important for people who mask, have difficulty communicating under stress, experience psychosocial distress, use alternative communication, or have disability-related barriers to participating in formal administrative processes.

Trauma-informed assessment should therefore be embedded in the design of the system through choice of assessor, accessibility, reasonable adjustments, minimisation of repeated disclosure, participant control over evidence and explicit assessment of the potential harms created by the process itself.

2.11 Parliamentary and independent oversight

The scale and consequences of the proposed reform warrant oversight beyond the administrative machinery responsible for implementing it. The Technical Advisory Group is an important mechanism. The Consultation Paper states that it will consider approaches, tools and thresholds and provide expert advice to governments.

However, the development of the access framework should not become a closed technical exercise. OTSi recommends ongoing scrutiny by the Joint Standing Committee on the NDIS, with publication of the evidence underpinning the eventual assessment methodology, validation results, cohort-specific performance, error rates, equity impacts and implementation outcomes.

There should also be independent assessment available through merits review where functional capacity findings and eligibility decisions, are disputed. The Administrative Review Tribunal must be able to interrogate the methodology underlying a decision rather than simply reviewing an administrative conclusion generated by an opaque assessment system. This is especially important if automated or algorithmic processes are introduced. No participant or applicant should be subject to a high-consequence eligibility decision that cannot be meaningfully explained, challenged and independently reviewed.

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PART 3: ACCESS TO ALLIED HEALTH DELIVERED

CAPACITY BUILDING, AND THERAPY MARKET REFORM (INCLUDING NDIS EARLY CHILDHOOD INTERVENTION)

OTSi supports the objectives of strengthening early identification, community-based supports and collaboration across health, education, disability and community systems. However, we are concerned that market reform, both within and outside the NDIS, is progressing at considerable speed without sufficiently robust modelling of the population need it will be required to meet. Broad sweeping 10% cuts to NDIS therapy budgets by Ministerial Support Determination are due to commence in October^©, and the participant-level and market impacts have not been adequately demonstrated or publicly modelled. This will take place despite the NDIA recognising the value of capacity building intervention

“[When] we’ve been able to build the participant’s functional capacity and independence, and really that is what this scheme is about: not creating dependence, but trying to create independence where we can. And I think that’s a good outcome for the society more broadly’ Andrew Maitland NDIA General Manager, National Operations and Performance - JSC hearing Friday September 10th 2026

The proposed ICAN support needs assessment does not have demonstrated capacity to measure need for allied health delivered capacity building interventions, raising questions around how future capacity-building interventions will be calculated for existing NDIS participants. In addition, over 240,00 people will lose NDIS access over the next years, raising the risk of immediate loss of access to allied health delivered capacity building intervention.

The current reforms take place against a backdrop of disabled people and their families experiencing significant cost-of-living pressures. For children, schools, early childhood services, health and mental health systems are already under considerable strain. At the same time, substantial numbers of children with autism and developmental delay are expected to experience changes to their access to the NDIS as responsibility for some children transitions to the new Thriving Kids system of foundational supports^®. This will place unprecedented strain on carers, particularly female carers^®. For example, ABS data indicate that 84.3% of primary carers of children and young people with disability are female, while 61.6% provide an average of 20 or more hours of care each week. Families may simultaneously manage multiple children, disability-related needs, employment, appointments and substantial costs¹⁰. For families of children who have dropped out of formal education, or experiencing ‘school can’t’, current Thriving Kids plans offer no options- these families will be significantly impacted, including loss of carer work roles.

^© [https://www.health.gov.au/our-work/ndis-legislation-changes/amendments/ndis-amendment-securing-the-ndis-for-future- generations-bill-2026/about-the-changes-to-the-ndis]

⁷ Thriving Kids | Australian Government Department of Health, Disability and Ageing

⁸ Thriving Kids | NDIS

⁹ Revised Explanatory Memorandum — National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 | Australian Government Department of Health, Disability and Ageing

¹⁰ Disability, Ageing and Carers, Australia: Summary of Findings, 2022 | Australian Bureau of Statistics

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In this context, it is critical that reform does not begin from the question of what services can be commissioned within a constrained funding envelope, but from the question of what children and families need, how access to therapy can be sustained, and what system reform is required to meet that need. The hreshold for NDIS access is central to the conversation around market reform and must be defined before markets can be accordingly stewarded. Currently, high-quality therapy does not reside solely in large organisations; in fact, the majority of occupational therapy services, offering effective and person-centred supports, are delivered by small and medium sized community based practices with the flexibility to deliver genuinely customised interventions.

OTSi’s position is that market reform for therapy, including ECI, must be underpinned by four guiding principles: population need must come before market design; equitable access to targeted therapist intervention must be protected; Australia’s existing therapy workforce and ECI ecosystem must be retained; and quality must remain the organising principle of reform.

A significant risk in the current reform direction is that Australia reduces the number of people formally receiving NDIS-funded therapy without first ensuring that the therapeutic capacity they require exists elsewhere. That would not represent successful system reform. It would represent a transfer of unmet need.

Disabled people, within and outside the NDIS, must continue to have timely, equitable and sustainable access to skilled and experienced professionals whose intervention improves participation, autonomy, safety, development and quality of life.

3. 1 Reform risks creating a loss of therapy access across the

disability population

OTSi is deeply concerned that the current direction and discourse of NDIS reform risks disabled people both within and outside the NDIS losing access to skilled and experienced occupational therapists and allied health professionals, and to the therapeutic intervention they require. The concern is shared by allied health peak bodies11 12

This risk extends beyond questions of NDIS expenditure or market efficiency. If people are moved between the NDIS, foundational supports, mainstream services and other systems without equivalent therapeutic availability being established, the result may be a reduction in access to disability-focused allied health expertise, rather than a more efficient allocation of it.

The central question is therefore not simply who funds therapy, but whether the system as a whole will retain sufficient access to therapeutic support for people with disability to access the right professional, with the right expertise, at the right time and in the context in which it is required.

11 AHPA Responds to NDIS Bill 2026 Passage Aug 2026 — Allied Health Professions Australia 12 NDIS changes put ‘thousands’ of small allied health businesses at risk - Inside Small Business

3.2 Skilled occupational therapy and allied health expertise is not interchangeable with generic support or educators.

Occupational therapy, speech pathology, physiotherapy, psychology and other allied health professions provide distinct clinical expertise. Assistants, support workers, educators, peer workers and family- mediated approaches can appropriately extend specialist intervention, but cannot substitute for qualified clinical intervention where it is required. Workforce substitution must not become a mechanism for addressing inadequate pricing, workforce shortages or pressure to reduce expenditure.

Individualisation is fundamental. People with similar disabilities can have substantially different functional needs, environments and goals. Effective intervention consequently requires professional assessment and clinical reasoning. A standardised program, either within or outside the NDIS, may be easier to commission and measure, but risks excluding people whose individual needs are complex, fluctuating, or invisible, leading to poorer outcomes.

High-quality therapy frequently occurs outside clinics - in homes, natural environments, workplaces and communities. Travel, preparation, collaboration, supervision and outreach are often integral to effective intervention, not optional extras. Current pressures around pricing, travel reimbursement, administration and non-billable work risk making outreach financially unsustainable and risk rendering therapy inaccessible due to funding restrictions, including for NDIS participants. This would disproportionately affect people living rurally and regionally, people with complex disability, and people whose functional needs cannot be adequately understood or addressed in a mainstream setting; or for children, in a school-based setting.

3.3 For those who lose NDIS access, the equity risk is substantial

If access to specialist allied health increasingly depends on private payment, people with greater financial resources will retain access while those experiencing financial hardship will not. This is an equity issue, not simply a market issue. This is particularly concerning during current cost-of-living pressures. Families and individuals are already making difficult decisions about housing, food, education and health care.

In an austerity driven reform, this risk applies to people both inside and outside the NDIS. A person who exits the NDIS or loses capacity-building funding, does not cease to have a disability or lose the need for specialist expertise. Similarly, a child who does not meet NDIS eligibility, or who transitions to another program, may still require targeted intervention.

Universal, mainstream and community-based services are essential, but they are complementary to, not interchangeable with, therapeutic intervention delivered by allied health professionals.

3.4 ECI provides a clear example of the broader risk

The proposed ECI reforms illustrate how these risks may emerge across the wider disability system.

Australia doesn’t yet have a sufficiently clear picture of the population requiring ECI, the proportion requiring targeted and specialised intervention, the workforce required to meet that demand, or the service infrastructure needed. There is also a risk for children who meet neither NDIS eligibility; nor engage with Thriving Kids pathways. Population planning must therefore consider the whole population requiring developmental support, rather than assuming need disappears when eligibility or funding responsibility changes.

For example, children requiring targeted ECI need access to intervention that is individualised, family- centred, trauma-informed, neurodiversity-affirming and developmentally appropriate. The National Best Practice Framework for Early Childhood Intervention¹³ describes high-quality intervention as family-centred, strengths-based, delivered in everyday settings, coordinated around the child and family, provided by appropriately qualified and experienced practitioners, and evidence-informed with outcome measurement.

The broader lesson is clear: changing the funding pathway without establishing equivalent occupational therapy and allied health access does not constitute reform of need; it constitutes withdrawal of access.

Before substantial restructuring, government should strive to model: the population requiring disability- related intervention; the proportion requiring targeted or occupational therapy/allied health expertise; geographic distribution and unmet need; existing service capacity; workforce requirements; and the capacity required across the NDIS, foundational supports and mainstream systems. This must be population planning, not simply NDIS budget constraint planning. OTSi proposes additional solutions in section 4 of this paper.

¹³ National Best Practice Framework for Early Childhood Intervention | Australian Government Department of Health, Disability and Ageing

3.5 Australia’s specialist workforce is infrastructure, not an expendable market input

Australia’s existing allied health workforce is a substantial national asset. The NDIS supported a major shift of allied health professionals into community and private practice, creating extensive local infrastructure and specialist disability expertise. This workforce cannot simply be assumed to remain available through reform.

Poorly designed market changes, including inadequate pricing, excessive administration, highly standardised service specifications, and restrictive commissioning, may cause providers to reduce disability services, move clinicians into other sectors or leave practice altogether. OTSi has previously responded to the NDIS ‘Quality Supports’ pilot. Market consolidation must not be confused with quality. Small and medium providers may hold highly specialised expertise, strong local relationships and continuity that larger organisations cannot replicate.

Senior clinicians are also workforce infrastructure and this perspective must be recognised within reform planning. They provide specialist intervention while supervising, mentoring and developing future practitioners. Once this expertise is lost, it is difficult and time-consuming to rebuild, and service quality and outcomes are at risk in the interim.

3.6 Continuity must survive changes in funding

People should not be required to change a trusted clinician simply because the funding mechanism changes. This is particularly important where therapeutic relationships, accumulated clinical knowledge and continuity are significant to effective intervention.

For example, children transitioning between the NDIS and Thriving Kids should, where appropriate, be able to retain their occupational therapist, speech pathologist or other clinician. The same principle should apply to adults and other NDIS cohorts transitioning between the NDIS, foundational supports and mainstream services. Access to a consistent occupational therapist or other allied health professional, can be a safeguard and ensure continuity during periods of transition and uncertainty (See Section 4).

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14 OTSi Statement on the NDIS Therapy Supports Pilot 23

3.7 Priorities for consideration by the NDIS Joint Standing Committee

OTSi proposes that the Committee consider the following priorities, in their advice to government:

Priority	Government action
Population need	Model disability-related therapeutic need across the whole population, not only current NDIS participants.
System capacity	Establish the service, workforce and infrastructure required before transferring responsibility between systems.
Specialist expertise	Protect access to appropriately qualified and experienced occupational therapists and other allied health professionals where specialist intervention is required.
Equity	Ensure access does not depend on ability to privately purchase therapy.
Workforce	Retain senior clinicians and support supervision, professional development and development of the future workforce.
Provider diversity	Avoid commissioning or administrative requirements that unnecessarily exclude small and medium specialist providers.
Continuity	Allow therapeutic relationships to continue across changing funding pathways where appropriate.
Flexibility	Maintain viable telehealth, outreach, home, school, workplace and community-based intervention.
Family capacity	Recognise the limits of informal care and fund implementation support where required.
Monitoring	Monitor provider exits, closures, waiting times, regional availability, workforce turnover, specialist access, continuity, family experience and functional outcomes throughout transition.

PART 4: PROPOSING NEW ACCESS PATHWAYS TO OCCUPATIONAL THERAPY AND ALLIED HEALTH DELIVERED INTERVENTIONS OUTSIDE THE NDIS

Occupational Therapist delivered Focused Functional Interventions

4.1 Current reform will mean less access to occupational therapy function-focused interventions:

As NDIS reform accelerates, significant proportions of people with disabilities cannot currently access evidence-based interventions to enhance functional capacity, delivered by occupational therapists. There is established identified need to enable these cohorts to live full lives and to participate in our communities, through building functional skills, and addressing disability-related participation barriers.

This issue is compounded by:

• A new, higher threshold to access NDIS, and increased rates of planned revocation of NDIS access
• Over 240,000 people losing access to the NDIS, who are currently eligible
• The absence of function-focused foundational supports in the community
• The limited nature of existing Medicare items to address functional capacity for these cohorts, and the cost-prohibitive nature of co-payment systems.

4.2 The impact on lives

• Reduced social and economic participation
• Barriers to community access, engagement and to living an independent life
• Increased risk of requiring more intensive disability supports, sooner

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4.3 Proposing solutions and pathways to access occupational

therapy and allied health delivered focused functional interventions

Provide access to evidence-based interventions focused on building and enhancing functional capacity, for the identified cohorts. This could be achieved by:

• Create a step-down, transitional package of supports for people with significant disability who will no longer be eligible for the NDIS under the new access threshold.
• Create a foundational support package focused on occupational therapy delivered Focused Functional Interventions; or an enhanced program through an Early Intervention pathways
• Create an escalate pathway to access a foundational support package focused on occupational therapy delivered Focused Functional Interventions through mainstream systems and services.
• The introduction of a new Medicare item centralising Focused Functional Interventions. Existing Medicare items such as Better Access to Mental Health, target mental -health specific interventions or ‘focused psychological strategies’, and do not focus on building functional capacity.

4.4 What are the focused functional interventions?

A significant and growing evidence base exists for the following interventions, which can be adapted in an age and disability appropriate manner.

1. Executive functioning and cognitive strategies/approaches
2. Lifestyle re-design/time-use/occupational balance
3. Social functioning and social prescribing
4. Routine development and life-skill development
5. Sensory based strategies

4.5 The occupational therapy workforce

Occupational therapy is a person-centred, outcomes-based and participation-focused, profession with current national reach, including to people with disability through NDIS.. Occupational Therapists are degree qualified (Bachelor and/or Masters and Doctorates) and regulated by the AHPRA.

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4.6 Summary: Building the Policy Case for Access to Focused Functional Interventions Outside the NDIS

The current direction of NDIS reform creates an urgent policy gap in access to occupational therapy and other allied health interventions that build functional capacity and enable participation. As eligibility thresholds increase and substantial numbers of people transition out of the NDIS, there is a significant risk that people with genuine and ongoing disability-related functional needs will lose access to interventions that can support independence, social and economic participation, and prevention of further escalation in support needs.

OTSi considers that this gap cannot be addressed through the NDIS alone. A sustainable disability support system requires complementary pathways through foundational supports, mainstream services, early intervention and Medicare, including access to evidence-based, occupational therapy-delivered Focused Functional Interventions. These interventions are distinct from clinical treatment and from the mental health-focused services currently supported through existing Medicare pathways. They address the practical impact of disability on cognition, executive functioning, routines, sensory regulation, social functioning, life skills and social participation.

OTSi therefore proposes consideration of a range of complementary access pathways, including transitional supports for people exiting the NDIS, dedicated foundational support packages, enhanced early intervention pathways, escalation pathways through mainstream services, and the introduction of a new Medicare item for Focused Functional Interventions. Such pathways could provide an important bridge between individualised NDIS supports and broader foundational and mainstream systems, while making better use of Australia’s existing, nationally regulated occupational therapy workforce.

OTSi is currently developing a more detailed policy paper examining the evidence, potential cohorts, intervention model, workforce implications, funding pathways and implementation options for Focused Functional Interventions outside the NDIS. OTSi would welcome the opportunity to provide this work to the Joint Standing Committee when further developed, and to contribute to consideration of how Australia can build an integrated system that maintains access to evidence- based functional interventions as NDIS reform progresses.

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APPENDIX 1:

Mapping the I-CAN subdomains against the ICF and NDIS functional domains/activities, including gaps.

The mapping above should be understood as an analytical ICF examination rather than an official I-CAN-to-ICF coding schedule. The I-CAN is described as ICF-informed, but the practical constructs do not provide a one-to-one equivalent for every ICF activity or participation category. The mapping was completed by an ICAN-accredited assessor.

I-CAN subdomain	Primary ICF correspondence	NDIS functional domain(s)	Assessment gap / concern
Transferring and positioning	d410–d420	Mobility, self-care	Strong coverage of physical mobility; comparatively task-based and observable
Carrying, moving and handling objects	d430–d440	Mobility, self-care	Strong physical coverage; less explicit assessment of fatigue, motor planning or cognitive demands
Walking and moving	d450–d455	Mobility	Strong coverage of physical mobility; potential under-emphasis on endurance, fluctuating capacity and environmental barriers
Transport	d470–d489	Mobility, self-management, social participation	Does not necessarily capture planning, navigation, problem-solving, sensory load or executive demands of transport
Shopping	d620	Self-management, learning, mobility, social interaction	Highly cognitively complex activity; risk of being treated primarily as a practical task rather than an executive task
Cooking	d630	Self-care, self-management, learning	Requires planning, sequencing, initiation, attention, safety and working memory; these underlying functions are not separately identified
Cleaning and domestic tasks	d640	Self-management	Similar executive-function gap; performance may depend heavily on initiation, organisation and fatigue
Household maintenance	d650	Self-management, mobility	Captures task completion but not necessarily problem-solving or recognising when maintenance is required
Eating and drinking	d550–d560	Self-care	Strong basic activity coverage; may need more explicit consideration of

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Otsi Supplementary Submission NDIS JSC - 15 September 2026

• Personal care (d510–d520) - Self-care - Strong observable-task coverage
• Toileting (d530) - Self-care - Strong coverage of physical/personal-care needs
• Dressing (d540) - Self-care, mobility - Strong observable-task coverage
• Money and economic life (d860–d865) - Self-management, learning - Important area, but requires more explicit assessment of financial decision-making, vulnerability, scams, judgement and supported decision-making
• Community life (d910) - Social interaction, self-management, mobility - Broad and useful but potentially insufficiently granular for complex community participation
• Leisure and recreation (d920) - Social interaction, self-management - Captures participation but not necessarily initiation, motivation, sensory regulation or planning
• Advocacy (d940) - Communication, social interaction, self-management - Important inclusion; however, advocacy is not equivalent to supported decision-making or self-advocacy capacity
• Receiving basic communication (d310–d329) - Communication, learning - Needs differentiation between hearing/seeing language, processing information, comprehension and cognitive processing
• Expressing basic communication (d330–d349) - Communication - Potentially strong basic communication coverage; may undercapture AAC, processing and communication under stress
• Feelings and emotions (d710, d720; also d240) - Social interaction, self-management - Important but broad; does not necessarily capture emotional regulation as a functional support need
• Conversations and complex communication (d350) - Communication, social interaction - Good participation construct; requires consideration of processing speed, pragmatic communication and communication supports
• Learning new tasks (d155) - Learning - Captures learning outcome but not necessarily attention, working memory, processing speed or executive dysfunction
• Decision making (d177) - Self-management, learning - Significant inclusion, but insufficient by itself to capture supported decision-making
• Literacy and numeracy (d140–d150, d166, d172) - Learning, self-management - Useful but may conflate academic skills with broader cognitive functioning
• Understanding time (d230, d163) - Learning, self-management - Relevant but narrow compared with executive functioning
• Daily routines (d230) - Self-management - Important; should include planning,

Otsi Supplementary Submission NDIS JSC - 15 September 2026

• One of the strongest executive-function proxies in I-CAN, but remains a proxy rather than a comprehensive executive assessment
• Useful functional outcome; underlying cognition, memory, judgement and executive functioning are not necessarily differentiated
• Important but requires explicit assessment of vulnerability, judgement, risk recognition and exploitation
• Potentially captures higher-order cognition but is ambiguous and insufficiently granular
• Does not capture why preparation fails
• Important participation domain; may not distinguish cognitive, psychosocial, environmental and physical barriers
• Potentially useful for work/study participation but lacks clarity regarding the underlying functional mechanisms
• Important but broad; may disadvantage people whose social functioning is context-dependent
• Important support-related activity; risks conflating ability to recognise a need for assistance with willingness to seek it
• Reasonable coverage but limited explicit assessment of vulnerability, boundaries and relationship-related support
• Valuable inclusion; needs safeguards around vulnerability, consent, dependency and supported decision-making

Initiating and completing tasks

d210, d230 Self-management, learning

Managing medication

d570 Self-care, self-management

Safety and risk abuse

d240, d250; environmental factors Self-management, social interaction

Finding, choosing and applying

d155, d160–d177 Learning, self-management

Punctuality and preparation

d230, d210 Self-management, learning

Doing the job or participating in learning

d825–d859 Learning, self-management, social interaction

After hours

d850/d859 and participation Self-management, social participation

Social skills

d710–d729 Social interaction

Seeking assistance and cooperating

d710–d729; d660 Social interaction, self-management

Managing relationships

d750–d770 Social interaction

Intimate and dependent relationships

d770 Social interaction, self-management