Submission to the Senate Community Affairs Legislation Committee

This submission is made by a Melbourne-based paediatric speech pathology provider operating both a multidisciplinary clinic and a high-volume 1:1 speech pathology caseload supporting children and adolescents with Autism Spectrum Disorder (ASD), developmental language disorder, intellectual disability, social communication difficulties, emotional regulation challenges and complex functional communication needs. The purpose of this submission is not to oppose reform of the NDIS. Reform is necessary to ensure long-term sustainability, accountability and equitable access. However, we hold significant concerns regarding the practical implementation, timing and downstream consequences of the proposed reforms, particularly in relation to paediatric participants and the current lack of equivalent foundational supports outside the NDIS.

Clinical Reality of the Current Caseload

our caseload consists predominantly of children and adolescents with substantial functional impairments affecting communication, learning, emotional regulation, social participation, independence and behaviour. Many presentation: Attend special schools or require significant educational adjustments Present with severe receptive and expressive language difficulties Require ongoing support to safely participate at school and in the community Experience emotional dysregulation, rigidity and behavioural escalation Have co-occurring mental health, sensory or behavioral complexities Require extensive parent, school and multidisciplinary collaboration In our clinical experience, many children who appear “mild” on paper still experience profound functional impacts across literacy, social participation, emotional wellbeing and long-term independence.

Concerns Regarding Children Under 9

We are particularly concerned about the impact of reforms on children under 9 years old, many of whom are currently receiving early intervention supports through the NDIS. In our experience, many young children accessing speech pathology services: Are minimally verbal or significantly language delayed; Require intensive support across home, kindergarten and school settings; present with behavioral dysregulation linked to communication difficulties; experience substantial participation difficulties despite appearing ‘capable’ in brief structured settings; require consistent support over multiple years rather than short term intervention blocks We are concerned that many children may no longer meet narrower thresholds despite ongoing functional impairments that significantly affect daily life and educational participation.

We are also concerned that the proposed foundational support systems and Thriving Kids framework are not yet operationally ready to provide equivalent levels of support, intensity, coordination or continuity of care currently available under the NDIS. Many families already face: Long public health waitlists Limited school based therapy access Financial barriers to private therapy Difficulty accessing clinicians with paediatric neurodevelopmental expertise Without a mature replacement system there is risk that children lose support during critical developmental periods In our clinical experience delayed intervention often results worsening education behavioural social and emotion outcomes overtime potentially increasing longterm support needs reducing them.

Concerns Regarding Functional Capacity Assessments

we acknowledge need for stronger functional framework within NDIS However we concerned about functional capacity assessments becoming overly reductionist inconsistently applied particularly autistic

Capacity Building Supports

The proposed reduction in Capacity Building Daily Activities (CBDA) budgets is of significant concern to allied health providers and families. While safeguards against over-servicing are appropriate, the overwhelming majority of therapy delivered within our practice is clinically justified and functionally focused. Therapy involves substantially more than direct sessions alone. Significant time is already spent on:

• School liaison and teacher collaboration
• Parent coaching and home support planning
• Functional documentation and reports
• Behaviour support and communication planning
• Multidisciplinary collaboration Educational access support We are concerned that reductions in CBDA budgets may disproportionately affect participants with ongoing communication, emotional regulation and adaptive functioning needs who require consistent long-term therapy rather than short-term intervention blocks. In practice, many families may respond to reduced budgets by:
• Reducing therapy frequency below clinically appropriate levels Ceasing school collaboration and parent coaching supports Delaying reassessments or functional reporting Prioritising crisis management rather than preventative intervention For high-needs children, reduced therapy intensity may increase downstream costs elsewhere including school disengagement, behavioural escalation, family burnout and mental health deterioration.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission 64

We respectfully recommend the Committee consider:

• Slower and staged implementation of reforms
• Clear transitional safeguards for children under 9 and high-needs participants
• Protection of continuity of care during reassessment periods
• Ensuring foundational supports are fully operational before participant diversion occurs
• Maintaining appropriate therapy access for participants with substantial functional impairments
• Consultation with frontline clinicians, schools and families during implementation
• Recognition that many developmental and communication disabilities require long-term support rather than short-term intervention blocks
• Mechanisms for experienced private providers to participate within foundational support systems

8. Closing Statement

We support sustainable reform of the NDIS. However, reform must be implemented safely, gradually and with genuine recognition of the realities faced by disabled children, their families and frontline providers. From our clinical experience, many participants currently supported through the NDIS would not have access to equivalent services outside the scheme at this point in time. We respectfully urge the Committee to prioritise continuity of care, implementation readiness and participant wellbeing as reforms progress.

Submitted May 2026