Submission to the Senate Community Affairs Legislation Committee
Submission to the
Senate Community Affairs Legislation Committee
inquiry into the National Disability Insurance Scheme Amendment(Securing the NDIS for Future Generations)\Bill 2026
Submitted by
an Occupational Therapy Provider in Private Practice Metropolitan Sydney, New South Wales Serving Participants in the local community in-person and nationally via telehealth 27 May 2026
About This Practice
We are a small private occupational therapy practice based in metropolitan Sydney, established in 2010 and operating \for over fifteen years. We joined NDIS during the pilot phase in 2017, and we work with neurodivergent children, adolescents, adults, and families navigating complex neurodevelopmental conditions.
The team deliberately rejects rigid medical models and time-limited therapy blocks. We deliver services focused\on therapeutic relationships, flexible service delivery, and a deep commitment to our guiding vision: providing
practical strategies that make daily life easier. We are structured with a high ratio of senior to graduate clinicians to\ensure quality of care.\
We do not raise these points to advocate for our business interests. As a small private practice, we have continued\to operate under extremely thin margins due to NDIS uncertainty, price freezes, and rising costs. We operate because\of our commitment to the families and participants we serve. We want a sustainable NDIS that delivers on disability rights aligned with the Human Rights of Disabled People. We write this submission with genuine concern\for our participants and for the future of a Scheme that has profoundly changed their lives for the better.\
This submission is made by an AHPRA-registered occupational therapist who holds OT Australia membership. We fully endorse the recommendations in the submission by Occupational Therapy Australia (OTA) to this Inquiry \and ask the Committee to adopt them in full. The purpose of this submission is not to restate that analysis, but to add the clinical perspective of a small private practice — grounded in direct daily work with NDIS participants — on four (4)\specific concerns the Bill raises for the people we serve.
1. Removing Children from the NDIS Before Thriving Kids Is Ready
The Bill proposes to transition children aged 0–8 to the Thriving Kids initiative before that program is operational or independently evaluated. We are deeply concerned about this for two compounding reasons specific to NSW.\
First, Thriving Kids in NSW is proposed to be delivered primarily through NGOs. The allied health workforce shortages currently affecting the private sector are equally acute in the community and not-for-profit sector, which does not yet have the staffing capacity to absorb early intervention caseloads at scale. Transitioning children now will not redirect them to equivalent support—it will place them on waitlists, or leave them without support entirely during the most time-sensitive developmental period.\
Second, the NSW Department of Education has simultaneously announced a reduced disability-related funding\and support within schools. Children being exited from the NDIS will therefore face reduced support both in the\community and in the classroom at the same time. The combined effect is a withdrawal of support from multiple directions simultaneously, with no coordinated system to fill the gap.\
Clinical continuity matters. Therapeutic relationships built over years cannot be transferred between providers \without substantial repetition of trust building. Disruption to these relationships, particularly for children with trauma histories, attachment difficulties, or complex neurodevelopmental profiles, can set developmental progress back substantially.
Case Study 1: Regression due to Funding Delay
A 7-year-old child transitioning to the full NDIS Plan had their eligibility initially reassessed as “not meeting permanency or functional threshold”. While the decision was successfully reviewed and they were accepted onto the full scheme, the administrative delays and the gap in funding persisted for six critical months. This immediate withdrawal of support caused a rapid regression of emerging skills that
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Submission 184
The required sustained therapy to build. The resulting intensification of the caring role led to higher family carer stress that took 12-18 months to recover from. Furthermore, the increased developmental gap between the child and their peers resulted in heightened and challenging behaviours in social situations. This example highlights the real-risks that service gaps create in early development.
Case Study 2: Exclusion and Lack of Alternatives
Anothechild with established functional deficits in learning, self-care, relationships/social, and communication had their NDIS eligibility cut following a funding reassessment. Their family is unable to afford the high costs of private therapy, leaving them with no viable alternatives for intensive support. Medicare bulk billing services are not designed or intended to cover the intensive, long-term disability services or early intervention required to address a child’s complex needs. This example highlights the lack of alternative funding models to adequately cover the service gaps when NDIS funding is removed.
Community Participation Supports Are Not Leisure — They Are an Essential Function
the proposed 50% reduction in social, civic, and community participation support reflects a mischaracterisation of how these funds are used. For many of our clients, community access funding supports activities that are not discretionary:
- Accessing a pharmacy, supermarket, or GP— tasks that require specific interpersonal support to navigate safely for people with psychosocial disability, cognitive disability, or significant anxiety
- Managing bills, Centrelink obligations, and community-based self-management tasks that are only possible with supported accompaniment
- Maintaining the social connections that, particularly for people with psychosocial disability, are themselves therapeutic and directly preventative of acute mental health deterioration
The last point has a strong evidence base. A systematic review commissioned by the NDIA (Giummarra et al., Frontiers in Rehabilitation Sciences, 2022), synthesising 522 studies across 57 systematic reviews, found that purposeful social and community participation produced meaningful improvements in wellbeing, self-esteem, autonomy, and psychosocial functioning for people with psychosocial and intellectual disability. For this population, access to community participation is not a lifestyle supplement— it is part of the clinical mechanism by which functioning is maintained.
A blanket 50% cut does not distinguish between leisure activities and essential community functions. It will produce the same reduction for someone accessing a weekly social group as for someone who cannot safely get their medication without support. This is not individualised care — it is blunt fiscal reduction applied to people with complex needs.
Case Study 3: Community Access for Psychosocial Supports Are Essential
For a young person who lives alone, has a psychosocial disability and a complex, debilitating pain condition, these supports allow them to travel to essential therapy appointments, collect essential medications from the pharmacy, purchase groceries, and access family events or workplace activities. Based on times when this support has been unavailable due to staff illness or provider gaps, without these supports, the young person’s mental health deteriorates, their pain increases, and their ability to complete basic weekly tasks in the community disappears. The risks related to long-term loss of these fundedsupports will create realworld issues; increase therapeutic needs, and increase hospital admissions for this young person.
Broad Funding Cuts Harm Participants, Carers, and Community Systems
Blanket percentage reductions across support categories remove the individualisation that makes the NDIS work. The clinical risks of sudden, wide scale cuts to participants’ plans include:
Case Study 4: The Systemic Cost of Funding Cuts A young person living with a neurological disorder, which affects their planning and motor functioning, had their support funding drastically cut. The young person’s mother received a 2minute ‘checkin’ phone call, and a plan detailing a 70% reduction in funding was produced one day later. There was no opportunity to submit documentation, no consultation about functional needs or changes, and no direct conversation with the young person. The new plan also removed Support Coordination, forcing the family, already experiencing intense caregiver burden, to navigate the complex NDIS review process without professional paid support. The impacts of these sudden cuts include: the removal of all allied health support except for Occupational Therapy (pausing capacity building progress and likely leading to regression), retention of community access funding but without the necessary daily assistance in the home (making it impossible for the young person to adequately prepare for community participation), and a significant deterioration in their mental health.
National Disability Insurance Scheme Amendment (Securring the NDIS for Future Generations) Bill 2026
Submission 761 e Rapid regression of skills that required sustained therapy to build and require ongoing support to maintain e Social isolation, with links to deteriorating physical and mental health outcomes e Termination of support worker relationships as the caring role becomes unsustainable
This last consequence carries systemic risk that the Bill’s impact analysis does not adequately address. Australian research consistently shows that informal carers — 56% of whom experience social isolation according to the 2020 Carers NSW National Carer Survey (Poon et al., Health & Social Care in the Community, 2022) — face significant deterioration in their own physical and mental health as caring intensity increases. When NDIS funding is cut and formal supports are reduced, the caring burden transfers to families. This does not save money systemically: it shifts costs to health services, mental health systems, and lost workforce participation, predominantly for women.
We observe this in our practice. When funding gaps occur, it is invariably the primary carer, usually a mother, who absorbs the difference. The cost to her health, her employment, and her own capacity to sustain care over the long term is real, measurable, and absent from the Scheme’s accounting.
Functional Capacity Assessments: Retain the Clinical Standard, Improve Consistency
We support the retention of OT-led functional capacity assessments as the standard for NDIS planning decisions, and fully endorse OTA’s recommendation that assessments must incorporate environmental and personal context in line with the biopsychosocial model. Excluding context does not produce more objective assessments - it produces inaccurate ones.
however, we also recognise a legitimate concern that FCAs vary significantly in structure, depth, and usefulness for NDIA planners. We suggest the Committee consider a middle path: rather than replacing clinical assessments with standardised tools or administrative frameworks, the Government work with OTA to develop a structured FCA report template that:
- Standardises the information provided to the NDIA — including functional domains assessed, evidence sources, contextual factors, goals, and recommended supports — without prescribing the clinical method used to reach those conclusions
- Requires explicit clinical reasoning linking assessed functional limitations to recommended support types and quantities
- Includes a structured section documenting how environmental and personal factors affect the participant’s functional presentation, ensuring this context is formally captured rather than omitted
- Is co–designed with occupational therapists, participants, and the NDIA to ensure it serves planning decisions without reducing assessment quality
This approach would improve consistency and usefulness of assessments for planners, strengthen the evidentiary basis for funding decisions, and preserve the clinical judgement and individualised assessment that participants depend on—without the risks of algorithmic or administrative substitution.
Conclusion
We want to see a sustainable NDIS that delivers person-centred care and services to Disabled Australians.
We do not support sustainability achieved by removing children before alternatives exist, mischaracterising community access as leisure, transferring care costs onto families, or replacing clinical assessment with administrative tools to determine functional capacity. We ask the Committee to adopt OTA’s recommendations in full, aand specifically to: - Protect children aged 0–8 until Thriving Kids is independently verified as ready and workforce capable - Reverse the proposed reduction to community participation supports - Require that any funding reductions be individually assessed rather than applied by class,- Work with OT Australia to develop a structured FCA template that improves consistency without sacrificing clinical rigour.
We are open to providing more case study information and real world risks, should the Inquiry publicly or through OT Australia call for additional submissions.