S11 E04 - Who is Keeping Up with the NDIS Changes?

Keeping up with NDIS reforms is becoming increasingly challenging for OTs, particularly when changes to funding, planning and evidence requirements have significant implications for clinical practice. But who is responsible for ensuring clinicians understand these changes and can apply them appropriately?

From maintaining professional knowledge and strengthening clinical evidence to navigating the latest NDIS funding reductions, there are important questions about how we support informed decision-making and advocate for the people who rely on the scheme.

Who is responsible for keeping OTs informed about NDIS changes?

With NDIS legislation and operational guidance continuing to evolve, maintaining current knowledge is an ongoing responsibility for clinicians working within the scheme. However, the volume and complexity of information can make this difficult to manage independently.

Within OT practices, responsibility for monitoring and interpreting changes needs to be clearly allocated. This may sit with a practice owner, clinical leader or another designated team member who can translate relevant developments into practical guidance for clinicians.

Regular updates and opportunities to discuss clinical scenarios can help teams apply new information confidently. Without these systems, supervision may become focused on explaining basic NDIS requirements rather than developing clinical reasoning and professional skills.

Making professional development meaningful

With AHPRA registration renewal approaching, understanding continuing professional development (CPD) requirements is particularly relevant. OTs are required to complete at least 20 hours of CPD annually, including a minimum of five hours of interactive learning with other practitioners.

Questions remain about how supervision relates to CPD requirements. While supervision can support professional learning, reflective practice and clinical development, it should not automatically be assumed that all supervision activities qualify as CPD. The nature of the activity and how it meets the Occupational Therapy Board’s requirements need to be considered.

Professional development is most valuable when it is planned around identified learning needs rather than simply accumulating hours. Supervision can play a useful role in identifying development priorities and helping clinicians translate new knowledge into meaningful changes in practice.

Can your therapy recommendations stand up to scrutiny?

Recommending therapy under the NDIS requires more than identifying a participant’s goals and proposing a schedule of intervention. OTs need to demonstrate why the recommended frequency, intensity and duration are appropriate, what outcomes are anticipated and how the intervention will address identified functional needs.

Recent ART matters have raised questions about the strength of evidence supporting therapy recommendations. Some clinicians have also been called upon to defend their recommendations through cross-examination, highlighting the importance of being able to clearly articulate the clinical reasoning behind proposed supports.

This can be particularly challenging in paediatric practice, where research does not always provide clear guidance on intervention dosage. Rather than relying on established patterns of weekly or fortnightly therapy, recommendations need to reflect individual circumstances, available evidence and professional judgement.

Are our OT reports communicating the evidence clearly enough?

Detailed clinical descriptions do not always translate into a clear understanding of a participant’s functional capacity, particularly when reports are reviewed by people without a clinical background. Technical terminology and broad descriptions can leave important questions unanswered.

Another recent ART matter involving a participant with significant physical impairment demonstrated how photographs could have strengthened the original assessment report. While the clinical descriptions documented substantial limitations, the absence of visual evidence may have made it harder for decision-makers to appreciate the severity of the participant’s functional needs.

Clear, specific language and appropriately selected visual evidence can help communicate the practical consequences of impairment. The focus should be on making the evidence meaningful and accessible rather than increasing the volume of information included in a report.

When the NDIS safeguards don’t provide the protection you hoped for

The introduction of the NDIS Support Determination has created concerns about participants who may experience substantial funding reductions but do not qualify for the available safeguards. For participants with significant support needs, the consequences may not become apparent until their plans are reassessed.

A recent case involving a participant with a Positive Behaviour Support Plan and approximately 70 documented behavioural incidents illustrates this challenge. An attempt to have their supports recognised as intensive and complex behaviour supports was unsuccessful, with the NDIA determining that the threshold had not been met. The NDIA also advised that the requested change could not be made through a plan variation.

An agreement reached through the Administrative Review Tribunal (ART) process has allowed the participant’s existing plan to be varied without a full reassessment. While this provides some immediate protection, the potential 50% reduction to community participation funding remains a concern when the plan is eventually reassessed.

An opportunity to challenge the NDIS funding reductions

A Senate disallowance motion concerning the new NDIS funding rules presents an opportunity for the sector to raise concerns about their potential impact. However, with the reforms only recently introduced, there may not yet be enough real-world examples to demonstrate the full consequences.

The 50% reduction to social, economic and community participation funding is particularly concerning for participants who rely on substantial daily support. Meanwhile, the 10% reduction to Improved Daily Living Skills funding may be harder to identify, especially where therapy recommendations were already being funded below the amounts requested.

Advocacy remains an opportunity for OTs and other stakeholders to communicate the potential consequences of these changes. Sharing specific clinical experiences and examples of participants who may fall outside the safeguards can help demonstrate where the reforms may create unintended outcomes.

Key takeaways
• OT practices should establish clear responsibility for monitoring NDIS changes and supporting clinicians to apply them
• Supervision should not automatically be counted towards CPD without considering the requirements of the relevant professional standard
• Planning professional development throughout the year supports more meaningful learning than simply meeting registration requirements
• Therapy recommendations should clearly justify the proposed intervention frequency, intensity and expected functional outcomes
• OT reports need to communicate functional limitations in language that non-clinical decision-makers can understand
• Participants with substantial support needs may still fall outside the NDIS funding safeguards, creating concerns about future plan reductions
• The Senate disallowance process provides an opportunity to communicate concerns about the potential consequences of the new funding rules