OT Unplugged: Community of Practice Insights

From 1 October, new NDIS funding changes will affect how some participants can access funding for social, community and civic participation. The detail OTs have been waiting for around the safeguard for participants with high support needs has now been released.

The guidance provides a pathway for some participants whose funding reset leaves them without enough funding to maintain their 24-hour disability supports. But the eligibility criteria create a significant gap: needing 24-hour support is not necessarily enough. The participant must already receive 24-hour funded NDIS supports.

Who qualifies as a high support needs participant?

To access the new safeguard pathway, participants must meet specific criteria relating to their existing plan funding and support arrangements.

The guidance describes a high support needs participant as someone with a relevant total budget of at least $215,000 before the funding reset, who receives 24-hour funded NDIS supports for needs arising directly from their disability and receives those funded supports at a shared ratio of at least 1:3.

The wording around funded NDIS supports is particularly significant because it determines who can access the safeguard when their funding is reduced.

Required support and funded support are not the same thing

A participant may require support 24 hours a day without currently receiving 24 hours of formal NDIS-funded support.

Consider someone who cannot safely be left alone but lives with family. Support workers may assist with personal care in the morning, the participant may attend a day program and family may provide support during evenings and overnight.

Their disability-related need for support exists across the full 24 hours. The difference is that some of those hours are currently being provided by parents, partners or other informal supports rather than funded through the NDIS.

Under the new criteria, this distinction will determine whether the participant has access to the safeguard. The bad news? The above mentioned participants will not.

What happens if they don’t meet the criteria?

If community participation funding is reduced, participants relying partly on informal supports will find themselves in a difficult position.

They won't meet the High Support Needs criteria because they do not currently receive 24-hour funded NDIS supports, even though they cannot safely be left without support.

The funding reduction itself also does not necessarily represent a significant and ongoing change in functional capacity, support needs or circumstances that would provide another straightforward pathway to an unscheduled plan reassessment.

This leaves an important question about what happens when formal community supports are reduced and family is already providing the support required during the remaining hours. There are no clear answers to this.

For eligible participants, what does the safeguard actually provide?

The guidance provides an example of a participant whose social and community participation budget reduces from $150,000 to $75,000, leaving insufficient funding to maintain their previous 24-hour support arrangements.

Through the safeguard pathway, additional funding may be added to daily living supports to address the resulting support gap at home.

However, this does not necessarily restore the participant’s previous level of community participation. Instead, funding may be redirected towards the support required while the participant remains at home.

The safeguard therefore addresses a potential gap in 24-hour support, but it does not necessarily replace the community participation opportunities lost through the funding reduction.



The variation process could create another support gap

Timing creates a separate practical issue for participants who do qualify for the safeguard.

Participants have 90 days to request the variation. The Agency then has 21 days to determine whether the participant meets the High Support Needs definition. If they do, they have a further 21 days before a decision is made about varying the plan.

This creates the possibility of a gap between reduced funding taking effect and additional daily living funding becoming available.

For participants receiving SIL supports through monthly funding periods, this could also create practical difficulties for providers expected to maintain safe support arrangements while the variation is being considered.



The importance of early identification of participant criteria

Given the above timeframes and high risk to participant safety and well-being, timely provision of reporting to evidence eligibilty for the High Needs Support Safeguard is essential.

To aid Occupational Therapists in preparing reporting to address this, we have created an editable template to either insert into their current FCA reporting or provide as an addendum report.

Access the framework template here: INSERT LINK

Key takeaways for OTs

• The High Support Needs safeguard has specific eligibility criteria, including requirements around 24-hour funded NDIS supports

• Requiring 24-hour support and receiving 24-hour funded support are not the same thing

• Participants relying on family to provide part of their 24-hour support may fall outside the safeguard pathway

• For eligible participants, the safeguard may redirect funding towards daily living support rather than restoring previous community participation funding

• OT reporting should clearly distinguish actual disability-related support needs from the amount of formal support currently funded

• The timing of the variation process may create additional challenges for participants and providers while decisions are being made



Links

High Support Needs Safeguard Info, released 22rd September 2026: https://www.health.gov.au/resources/publications/ndis-funding-changes-high-support-needs-safeguards?language=en

High Support Needs Safeguard Info, released 23rd September 2026: https://www.health.gov.au/our-work/ndis-legislation-changes/amendments/funding-changes-for-ndis-supports?language=en&fbclid=IwdGRleAUgLjRwZG9mBWZkaWQWUO88wjK41vlh4a2RhNo7m1ODdX5SmWV4dG4DYWVtAjExAHNydGMGYXBwX2lkCjY2Mjg1NjgzNzkAAR71jgOkSuL5QanyhR8LgE-8ZBblHA27CnQkyxSwU4kKG_E7uzTQhDmeiySy9w_aem_aV9hx-NIV-kXaE_OlzzaEQ

Some moments in your OT career stay with you. A decision, a client or even a comment from someone else can change the direction of your career or the way you think about your role.

This week, Sarah, Alyce and Nikki share some of their own ‘sliding doors’ moments, from career decisions that changed their direction to clinical experiences that reshaped how they understood their role as OTs. They also unpack recent NDIS developments around students on placement, functional capacity and changes approaching from 1 October.

The career decisions that change everything

Sometimes a career-defining decision starts with realising it is time to leave. Sarah reflects on the workplace experience that ultimately gave her the push to step away from a role she once thought she would never leave and start Verve OT.

Alyce shares turning points of her own, including professional development that challenged the way she thought about clinical intervention and a period away from Occupational Therapy that ultimately led her back to the profession and into building her own practice.

Looking back, neither could have known exactly where those decisions would lead. Sometimes it is only years later that you can see how one choice changed the trajectory of your career.

When you can’t change the outcome

Nikki shares the story of a man with rapidly progressing motor neurone disease who desperately wanted to leave hospital and return home. After considerable work to organise equipment and make his discharge possible, he made it home on a Friday afternoon and died the following day.

At first, Nikki felt that everything they had done had made no difference. Her manager helped her see it differently: they could not change the fact that he was dying, but they had changed his experience by helping him spend that final time at home.

That moment changed Nikki’s understanding of what making a difference can look like and influenced her later work in palliative and end-of-life care. It also highlights the role good supervision can play in helping OTs process difficult experiences and make sense of what they mean for their practice.

The small things can be the big things

Not every meaningful OT outcome looks impressive on paper. Nikki shares how one family still considers a simple toilet rail one of the most valuable things she has done for them, despite years of other intervention.

Sarah recalls a client telling her that the biggest thing she had provided through a home modification process wasn’t the modification itself. It was hope that life might become easier.

These moments are a reminder that OTs don’t always know which part of their work will matter most to someone. Particularly as service systems and funding models change, recognising these smaller wins can help keep the focus on what can make a meaningful difference for the person in front of us.

Can you bill for students on placement under the NDIS?

New NDIS guidance has raised fresh questions about students on placement. Earlier guidance stated that allied health students could deliver specific supports under supervision but that their work could not be directly claimed because placements were unpaid educational opportunities.

The current NDIS guidance says allied health students and provisional psychologists can provide services under the supervision of a qualified allied health provider, with participant agreement. It also says service agreements should outline how the arrangement could provide greater flexibility, such as a lower hourly rate or additional service hours.

What remains less clear is exactly how those services should be billed. The wording appears to have shifted again, but there is still enough ambiguity that providers will need to consider how they interpret and apply the guidance in practice.

A changing definition of functional capacity

A recent SDA matter prompted questions about how the amended definition of functional capacity is already being applied under the NDIS.

The definition considers a person’s ability to undertake an activity without assistance from other people or assistive technology, with particular provisions around commonly used AT and assistance for children. This raises questions about what the definition could mean when considering the functional impact of disability.

There is still more to unpack about how this will be applied in practice, particularly for OTs completing functional capacity assessments. It is an area to watch as further information becomes available.

What’s changing from 1 October?

There is plenty for allied health providers to have on their radar as 1 October approaches, including changes to classifications under the Health Professionals and Support Services Award and the upcoming ban on card surcharges.

Thriving Kids activity is also expected to begin in New South Wales, although there are still questions around exactly how and when service pathways will roll out.

For NDIS providers, there is also uncertainty around upcoming support determinations and what the high needs pathway will look like. With several changes happening at once, OTs and business owners will need to stay across further guidance as it becomes available.

Key takeaways

• Career-defining moments can come from unexpected decisions, challenges and clinical experiences
• Good supervision can help OTs reflect on difficult experiences and shape their future practice
• Small interventions can have a significant impact, even when they seem simple from an OT perspective
• NDIS guidance around students on placement has changed again, but questions remain about how services can be billed
• Changes to the definition of functional capacity may have implications for OTs completing functional capacity assessments
• Several changes are approaching from 1 October, including award classifications, card surcharges and NDIS support determinations

Links

Guide to working as an allied health provider: https://www.ndis.gov.au/providers/working-participants/allied-health-professionals/guide-working-allied-health-provider

The NDIS support lists have only been in place since October 2024, but another significant change may already be on the horizon.

A new consultation is considering how NDIS supports should be defined, including proposals to reduce the number of support categories, simplify their descriptions and remove the replacement supports process.

For OTs, some changes could make the rules easier to interpret. Others raise questions about what happens when an everyday product is also the simplest solution to a disability-related functional need.

Why is the NDIS support list changing?

The current support lists were introduced in October 2024 as transitional rules defining what participants can and cannot generally spend NDIS funding on.

Feedback has highlighted several problems, including confusing categories, unclear descriptions and difficulties understanding replacement supports.

The proposal is to reduce 36 support categories to 18 broader categories, with simpler purpose-based descriptions and examples. These categories are also being developed to align with new framework planning and the introduction of support needs assessments.

Replacement supports could disappear

One of the biggest proposed changes is the removal of the replacement supports process.

Tablets, smartphones, smartwatches and accessibility or communication apps have been among the most commonly requested replacement supports. The proposal is for these types of supports to instead become stated supports where the relevant requirements are met.

This could create a clearer pathway for some disability-related technology. The bigger question is what happens to other products currently considered through replacement supports.

What happens to everyday products that solve disability-related problems?

Mainstream products do not always have mainstream purposes.

Consider a person with a spinal cord injury who can put clothing into a top-loading washing machine but cannot independently retrieve it. A front-loading machine could remove that functional barrier and allow them to complete their washing independently.

Similar questions arise with robotic vacuum cleaners, food preparation appliances and other household products. Sometimes a readily available mainstream product is the simplest and most cost-effective way to address a functional need.

Removing replacement supports could therefore have consequences beyond simplifying an administrative process. The detail of what remains fundable, and through which pathway, will matter.

Some disputed supports could move firmly onto the ‘out’ list

The consultation also identifies products and services where there has reportedly been confusion about whether they are NDIS supports.

These include electronic noise-cancelling headphones, fencing and gates, hairstyling tools, hydrogen fuel and electric vehicle charging costs and scuba therapy. The proposal is to specifically exclude them.

Noise-cancelling headphones are particularly relevant to OTs because they may be recommended to address sensory needs and support functional participation.

This also highlights why looking only at the proposed funded categories does not tell us everything. A product might appear to fit within a broad support definition but still be unavailable if it is specifically excluded elsewhere.

The new categories could make some OT roles clearer

There are areas where the proposed definitions provide welcome clarity.

The proposed therapy supports category specifically includes assessment by allied health professionals for support planning and review. It also captures assessment, prescription, implementation, adjustment and training in the use of assistive technology where required to support functional outcomes.

Home modifications similarly include the design, planning, implementation and review of modifications, alongside maintenance and repair of disability-specific fixtures and modifications.

Assistive technology categories are also being consolidated. While there would be fewer overarching categories, detailed descriptions would continue to sit beneath them, so fewer categories will not necessarily mean less complexity.

These changes are part of a much bigger planning reform

The support list changes cannot be considered separately from new framework planning.

Under the future model, a support needs assessment will play a central role in determining a participant’s budget. The proposed support categories are being designed to align with this new approach.

This means the practical impact of the support list will depend on more than which category a support sits within. It will also depend on how needs are assessed, how budgets are determined and how participants can use those budgets.

Further consultation on the new framework planning rules should provide more detail about how these pieces will work together.

Why OT input into the consultation matters

Funding rules can appear straightforward on paper but work very differently when applied to someone’s actual function, environment and daily occupations.

OTs regularly see where a mainstream product becomes an assistive solution, where a seemingly clear category creates ambiguity and where funding rules affect the practical options available to a participant.

That experience can help identify unintended consequences before proposed rules become established practice.

The consultation provides several ways to contribute, including making a submission, providing a video response, responding by email or requesting a phone call.

Key takeaways for OTs

* The NDIS is proposing to reduce 36 support categories to 18 broader categories
* The replacement supports process could be removed
* Some commonly requested technology may instead become stated supports where requirements are met
* The future of other mainstream household products currently considered through replacement supports needs close attention
* Electronic noise-cancelling headphones are among the supports proposed for specific exclusion
* The new support list is being developed alongside new framework planning and support needs assessments

These are still proposed changes. For OTs, now is the time to look beyond whether the new categories appear simpler and consider how they could work when applied to real functional needs and everyday recommendations.

New Framework Planning and NDIS Supports Consultation: https://consultations.health.gov.au/disability-and-carers-group/nfp-ndis-supports/

OT Unplugged Competition Entry Form: https://www.verveotlearning.com.au/ot-unplugged-competition-sit-at-our-table

NDIS reporting is changing, but one question remains fundamental for Occupational Therapists: why are we including this information?

Longer reports and more assessments do not automatically create stronger evidence. A useful NDIS OT report needs to demonstrate a participant’s functional needs, connect those needs to their goals and clearly explain why recommended supports are required.

This means moving beyond clinical terminology and assessment scores towards evidence that helps the reader understand what everyday life actually looks like for the participant.

Understand why the report is needed

Before beginning an assessment, Occupational Therapists need to understand why the report has been requested and what decision it is intended to inform.

A plan reassessment based on a change in circumstances requires evidence of a significant and ongoing change. This may involve changes to functional capacity, informal supports or broader life circumstances.

That is different from a situation where a participant believes their existing plan was underfunded. Understanding this distinction early can help avoid spending valuable participant funding on a comprehensive assessment that does not address the issue at hand.

Good onboarding is essential. Clarify what the report is for, what evidence already exists, who else is involved and what information is actually required.

Show what function looks like in everyday life

Once the purpose of the report is clear, the next priority is showing what the participant’s functional needs actually look like.

Occupational Therapists understand terms such as dysregulation, co-regulation, executive functioning and fine motor difficulties. The person reading an NDIS report may not interpret those terms in the same way, so clinical terminology needs to be connected to specific, functional examples.

If a participant became dysregulated during an assessment, what did that look like? What happened and what support did they require? If they have reduced fine motor coordination, how does this affect dressing, eating, handwriting or another meaningful activity?

This is where both top-down and bottom-up thinking have a place. Identifying an impairment such as reduced grip strength, balance or fine motor coordination can provide valuable clinical evidence, but the report also needs to explain what that impairment means for everyday participation.

Functional examples bring the reader into the assessment and make the impact of disability easier to understand.

Choose assessments that add meaningful evidence

With the functional picture established, consider what additional evidence is actually needed to support your clinical reasoning.

Standardised assessments remain an important part of Occupational Therapy practice, but not every available assessment belongs in every NDIS report. Ask: what additional evidence will this assessment provide?

A standardised assessment may validate observations, establish a baseline, support clinical reasoning or provide an outcome measure. In those circumstances, it can be extremely valuable.

However, completing multiple assessments can consume significant participant funding without necessarily changing the recommendations.

The same principle applies to presenting results. Pages of graphs, tables and scores can make a report longer without making it clearer. Often, the Occupational Therapist’s interpretation is more valuable.

Explain what the assessment showed, whether it aligned with other evidence and how the findings informed your recommendations.

Consider value for money

Being selective about assessment also means considering how participant funding is being used.

A useful question is whether you would feel comfortable asking someone to pay privately for everything you are proposing.

This does not mean compromising evidence-based practice or avoiding comprehensive assessment when it is genuinely required. It means being intentional about what each component contributes.

If observation, interview, existing reports and one carefully selected assessment provide sufficient evidence, adding several more assessments may not improve the outcome.

Good clinical reasoning is demonstrated by choosing the right assessment methods and interpreting them well, not by using the greatest number of tools.

Make recommendations specific and defensible

The evidence gathered throughout the assessment should lead logically into clear recommendations.

Simply stating that a participant requires a certain number of support worker hours leaves important questions unanswered. What will the support worker assist with? When is the assistance required? Is the support needed at home or in the community? Is it required during weekdays, evenings or weekends?

These details demonstrate how the recommendation was calculated and why the support is necessary.

Recommendations should also reflect the participant’s assessed needs rather than a provider’s rostering arrangements. If a participant requires one hour of assistance, the Occupational Therapist’s recommendation should reflect that need rather than being increased because of a provider’s minimum shift requirements.

The aim is to make the connection between functional need, required support and recommendation as clear as possible.

Stay within Occupational Therapy scope

Specific recommendations also require Occupational Therapists to be clear about where their professional scope begins and ends.

If an Occupational Therapist identifies a likely need for physiotherapy, speech pathology or another discipline and that professional is not yet involved, it may be appropriate to recommend funding for an assessment.

Prescribing another profession’s ongoing therapy hours without their assessment is different.

Support worker recommendations sit more directly within Occupational Therapy scope because assessing the assistance a participant requires to complete everyday activities is a core part of functional assessment.

Know when a full reassessment isn’t necessary

Providing strong evidence does not always mean completing another functional capacity assessment from scratch.

If a comprehensive assessment was completed relatively recently and most of the participant’s function remains unchanged, an addendum or supplementary report may provide what is needed.

The Occupational Therapist can explain what has been reassessed, identify what has changed and confirm which previous findings remain current. The original report can then accompany the supplementary evidence.

This can provide the required information without unnecessarily using participant funding or repeating work that has already been completed.

Better reports are not necessarily longer

Every assessment, paragraph, graph and recommendation should earn its place in an NDIS OT report.

Ask whether it helps explain the participant’s function, strengthens the evidence or supports the clinical reasoning behind a recommendation.

The goal is not to create the longest report possible. It is to give the reader a clear and accurate picture of the participant’s everyday life and make the reasoning behind each recommendation easy to understand.

Key takeaways for OTs

◆ Clarify why the report is being requested before beginning the assessment
◆ Keep everyday function at the centre of your evidence
◆ Use specific examples to translate clinical terminology into functional impact
◆ Choose assessments according to the meaningful evidence they add
◆ Interpret assessment findings rather than relying on pages of scores and graphs
◆ Make recommendations specific about what support is required, when and why
◆ Recommend according to the participant’s assessed needs rather than provider rostering requirements
◆ Stay within Occupational Therapy scope when discussing other health professionals’ services
◆ Consider an addendum or supplementary report when a full reassessment is unnecessary

Links

OT Unplugged Competition Entry Form: https://www.verveotlearning.com.au/ot-unplugged-competition-sit-at-our-table

Australian Assistive Technology Conference (11 Nov - 13 Nov) https://www.arata.org.au/aatc/aatc-2026/

Recent NDIS legislative changes are creating new considerations for OTs, particularly around plan reassessments and how participants may be able to use their funding. While some implementation details are still emerging, the potential impact on participants could be significant.

For OTs, the priority is understanding what these changes mean in practice. That includes knowing when a reassessment may be possible, clearly documenting support needs and identifying what could happen if recommended supports aren’t available.

As further guidance is released, practices will also need to review their clinical processes and reporting templates. The aim isn’t to predict every funding decision, but to make sure the participant’s needs and risks are clearly documented.

Changes to plan reassessments

Changes to unscheduled plan reassessments include a longer timeframe for the NDIA to decide whether a reassessment will occur. The timeframe discussed has increased from 21 days to 90 days, which could mean participants wait considerably longer for a decision.

There is also a higher threshold for an unscheduled reassessment. The change generally needs to be significant and ongoing, relating to the participant’s functional capacity, personal circumstances, environment or informal supports.

This distinction matters. A permanent change to a participant’s support network may meet the threshold for reassessment, while a temporary situation may be more appropriately addressed through a plan variation.

What this means for OTs

There is still uncertainty about how some of these changes will work in practice. OTs don’t need to predict every decision the NDIA might make, but we do need to understand how the changes could affect the people we support.

Our role is to clearly document what a participant needs to function safely and participate in everyday life. Recommendations should connect directly to functional evidence, risks and the likely consequences if those supports aren’t available.

That clinical reasoning becomes particularly important when considering support determinations and the possibility that participants may not be able to access all of the funding identified in their plan.

Understanding support determinations

The changes also introduce support determinations that may limit how much of particular NDIS budgets participants can use. The areas discussed include social, economic and community participation and improved daily living.

This could create situations where a participant’s reasonable and necessary supports are identified, but a proportion of the relevant budget is subsequently unavailable to spend. The exact impact will depend on the final support determination and how it is implemented.

OTs should therefore avoid assuming a particular percentage reduction before those details are confirmed. Instead, our reports need to clearly explain what the participant actually requires and why.

Make the impact of reduced support clear

Reduced community participation funding doesn’t necessarily mean a participant can simply spend more time at home independently. Some participants require support regardless of whether they are at home or in the community.

If a participant cannot safely remain home alone, this needs to be explicit in their functional assessment. Reports should explain their supervision requirements, why that support is needed and what happens when it isn’t available.

This may include increased vulnerability, exploitation, safety concerns, behavioural escalation or unsustainable pressure on informal supports. The important point is to connect any potential reduction in support with its real-world functional consequences.

Keep recommendations evidence-based

Knowing that funding may be reduced doesn’t mean OTs should increase recommendations to compensate. If the evidence supports 15 hours of assistance, recommending 30 hours in anticipation of a reduction isn’t clinically defensible.

Instead, document the actual level of support required and clearly explain the evidence behind it. Then describe what is reasonably likely to happen if that support isn’t provided.

Our role is to provide strong clinical evidence, not find ways around funding decisions. Clear, individualised recommendations give decision-makers a much better understanding of what the participant genuinely needs.

Consider the impact on therapy funding

Improved daily living funding may also be affected by support determinations. This could reduce the funding available for OT and other allied health services.

That becomes particularly challenging when a participant has limited funding for specific work, such as a functional capacity assessment. OTs still need enough time to complete assessments and reports to an appropriate professional standard.

Review AT and home modification pathways

Changes to reassessment processes may also affect assistive technology and home modification requests. Participants may become hesitant to request changes if they are concerned about what a reassessment could mean for other areas of their plan.

OTs should understand whether a participant’s circumstances require a reassessment or whether a plan variation may be appropriate. Choosing the correct pathway could become increasingly important as these changes take effect.

Clear communication matters here. Participants need practical information about their options without creating unnecessary fear about requesting essential equipment or supports.

Prepare your OT practice now

OT practices shouldn’t assume every clinician is keeping up with NDIS changes independently. Regular team discussions can help everyone understand what has changed, what remains uncertain and what needs to happen clinically.

Now is also a good time to review FCA templates. Consider whether reports clearly explain supervision requirements, foreseeable risks, informal support capacity and what happens if recommended supports aren’t provided.

At the same time, avoid changing templates based on speculation. Update them as confirmed information becomes available and make sure any new wording remains specific to the individual participant rather than becoming generic boilerplate.

Key takeaways for OTs
• Understand the new reassessment thresholds and longer decision timeframes.
• Keep recommendations grounded in the participant’s actual functional needs.
• Clearly explain what happens if recommended supports aren’t available.
• Identify safety, vulnerability and informal support risks where relevant.
• Don’t increase recommendations simply to compensate for anticipated funding reductions.
• Understand when a plan variation may be appropriate instead of a reassessment.
• Review FCA templates as confirmed NDIS guidance becomes available.
• Keep your clinical team regularly updated as implementation develops.



OT UNPLUGGED COMPETITION ENTRY FORM: https://www.verveotlearning.com.au/ot-unplugged-competition-sit-at-our-table