Amid uncertain and challenging times for many of our members providing vital services within the NDIS, we offer some clarity on the efforts that have been made so far to try to prevent, or at least minimise, further detrimental impacts on both NDIS participants who rely on psychology services and our profession.
The National Disability Insurance Scheme (NDIS) is currently undergoing massive structural upheaval that represents one of the most disruptive periods our profession has faced in many years.
Across Australia, psychologists are navigating an environment filled with systemic uncertainty, administrative burden and shifting guidelines that threaten not only the viability of their practices but, most importantly, the wellbeing of the participants they support.
The APS acknowledges the profound distress, fatigue and despair that these rapid changes are causing on the ground. We know how challenging the current situation is, and we hear the urgent calls from members for guidance and a visible line of defense against reforms that risk writing psychology out of the disability support landscape.
We know that for too long, the contribution of psychologists within the NDIS has been misunderstood. For years now, NDIS advocacy has been a key focus for the APS.
However, the pace and impact of the current legislative changes have created a climate that many of our members feel is no longer psychologically safe for providers or participants.
We are seeing passionate, experienced psychologists forced to consider whether they can afford to keep their doors open, while participants face the terrifying prospect of losing ongoing support from trusted providers who understand the challenges they face, and their ongoing needs.
The APS is deeply disappointed by the forceful manner in which the Federal Government is proceeding with these reforms, often ceding evidence-based professional reasoning to administrative cost-containment.
Our response will not be one of passive retreat. While we are under no illusions about the scale of the challenge, we are actively working to limit the fall-out and maintain the indispensable role that psychologists play in assessment and supports.
The APS is aware of the high levels of uncertainty being experienced by participants and providers, and we are committed to ensuring recognition for the vital role of psychology as the new NDIS architecture takes shape.
The shift to independent assessments
The National Disability Insurance Agency (NDIA) is transitioning away from a model where participants gather information from their own therapy and behaviour support providers toward a framework where an agency-engaged assessor conducts a structured needs assessment using the Instrument for the Classification and Assessment of Support Needs (I-CAN) version 6 tool for participants aged 16 and over.
On face value, and in the absence of further detail, the stated policy intent may appear reasonable: the Government argues this will reduce the equity gap.
However, in consultation with members of our NDIS Working Group, we know members will have concerns across two areas in particular.
The first is the competence of the person administering the assessment. Disability presents through an enormous range of variables, and reading those variables accurately is a highly trained skill, not an algorithmic outcome that a standardised digital checklist can supply.
When an experienced psychologist conducts a functional assessment, they do not simply read from a script or follow a formula to write a report. They are continuously performing a mental state examination in the background. They are evaluating presentation, affect, cognition, insight, fatigue and the critical gap between what a person says they can do and what is observed.
This professional observation is where the real, defensible information sits. A brief, scripted conversation-based assessment is more than likely to miss these details.
Systemic blind spots matter most for the highly complex participants the Scheme was originally built to protect. For example, individuals with intellectual disabilities or significant cognitive impairment frequently over-report their level of day-to-day independence. They do not do this to mislead, but because limited cognitive insight can be an inherent part of the disability itself.
Accepting a participant's positive self-report at face value and returning a neat, computerised score completely misrepresents the person's functional reality.
So much goes wrong in a scenario like this: the individual won't receive adequate support in their home, they could be driven to disengage from work or education, and they are at higher risk of entering a state of crisis or facing avoidable hospital presentations.
Ironically, this ends up costing the Scheme far more in the long run than a rigorous, psychologically sound assessment would have.
Whether dealing with episodic mental health conditions or degenerative physical disorders, relying on a brief snapshot performance risks under-capturing complexity precisely where the need for sustainable support is greatest.
We only need to look to the recent example of the Government’s algorithmic Integrated Assessment Tool (IAT) in the aged care setting resulting in hundreds of complaints, described by assessors as “cruel and inhuman”, according to reports.
The treating professional model, for all its structural inconsistencies, at least carried long-term knowledge of the participant. That practitioner lens is the critical gap our profession fills. This is a non-negotiable inclusion and something that the APS will always defend to the Government.
The second risk we know members are concerned about is the structural tensions within the new design.
When the same agency is responsible for assessing functional needs and managing the fiscal incentive to contain costs, it sits uncomfortably close to the assessment process itself.
This is precisely why robust, independent, external treating professional evidence must keep its place in the assessment phase.
Reasserting the role of Functional Capacity Assessments
We've had an influx of questions from our members seeking guidance and support around the myriad of NDIS changes happening concurrently. One of the most common has been around what psychologists need to know about Functional Capacity Assessments (FCA).
While we won't have a clear picture of the new approach to FCAs under the Bill for some time, our NDIS Working Group has been invaluable in providing useful advice regarding what we know effective FCA looks like based on ethical, evidence-based and participant-focused practice.
We would like to particularly thank Working Group member Jeni Langdon MAPS, who has provided robust practical advice on this topic to support her fellow psychologists.
While we are aware that the majority of our members who provide NDIS services are deeply familiar with the architecture of a FCA, it's worth briefly restating its core purpose under the changing Scheme.
An FCA serves as a structured evaluation (not a diagnostic tool) to understand how a participant's specific disability manifests in their everyday life.
It systematically maps out capacity across critical domains, including self-care, mobility, communication, social interaction, learning and home or community participation.
In practice, its role is to clearly articulate what an individual can achieve independently, precisely where their capacity breaks down, and what targeted supports will meaningfully improve their social and economic participation.
Essentially, it translates impairment into measurable functional impact in a format the NDIA can directly act upon. Depending on the layer of systemic complexity involved, the assessment process can range from a brief one-hour consultation to a comprehensive full-day evaluation, with the final formulation and report delivered over subsequent weeks.
A key point to highlight is that the NDIA has signaled that participants with highly complex or fluctuating needs may still require corroborating documentation. However, the strategic question for our profession is no longer how we write a higher volume of generic reports, but rather where psychological assessment achieves something that an administrative I-CAN conversation structurally cannot.
The reports that will retain significant weight are those that move away from simple diagnostic lists or generalised statements of need. Instead, they must lean heavily into rigorous, psychometrically grounded evidence that explicitly links an underlying cognitive or neurodevelopmental impairment directly to its functional consequence, mapping out exactly why a disability produces a specific support need in an observable, measurable chain of reasoning.
Multidisciplinary collaboration will also remain critical. No single discipline holds the entire picture for a highly complex participant. While other vital disciplines such as occupational therapy excel at mapping physical environments and daily living tasks, psychology explains the cognitive, emotional regulation and executive underpinnings of why a functional breakdown occurs.
Complex FCAs should be viewed through this collaborative lens, being explicit in reports about the boundaries of their scope and proactive in recommending cross-disciplinary referrals. This ultimately protects both the participant and the psychologist’s professional standing.
International precedents show that systems moving entirely to brief administrative interviews conducted by non-clinical staff consistently result in systemic failure, accurately capturing only the most articulate and well-supported individuals while misreading everyone else.
Conversely, comparable international schemes that function effectively, such as those in parts of Europe, explicitly retain a sophisticated clinical and multidisciplinary layer to handle complexity.
The lesson is that tool-based assessment is not inherently flawed, but it must be paired with professional oversight to prevent poor, high-risk decisions being made about the people who can least afford them.
For more advice, read this article featuring other members of our NDIS Working Group – Dr David Hammer MAPS and Renee Dela Cruz MAPS – which outlines important considerations when writing an effective NDIS report.
Mandatory NDIS provider registration
Another common question from our members pertains to the suggested requirement for psychologists to become formally registered NDIS providers.
This would change the current system where psychologists and other allied health professionals can provide relevant services as unregistered providers. Indeed, most psychologists currently operate as unregistered providers. In this context, the language of being ‘unregistered’ is also misleading, as the psychology profession is already subject to high levels of regulatory oversight and professional standards.
The specific rules for dictating who must register and who is exempt have not yet been written and will be included as part of the impending Bill.
While the APS is generally supportive of NDIS registration for non-regulated professionals, we have maintained an unwavering position throughout our submissions: psychologists are already highly regulated and are registered through Ahpra.
Duplicating this process via a parallel NDIS registration pathway is completely unnecessary.
It adds massive administrative burden without improving participant safety and will drive independent sole practitioners out of the disability sector entirely.
Consistent with our advocacy, the NDIS Provider and Worker Registration Taskforce also reflected this recommendation in its 2024 report, yet the Government has remained silent about how it intends to proceed.
Proactive advocacy: What the APS is doing
We want to assure our members that our advocacy efforts in this space have significantly escalated since 2023. We are working continuously to correct the record and push back against the erosion of psychology supports within NDIS plans.
In addition to the many submissions we’ve written in response to numerous NDIS-related consultations over the past four years, our advocacy efforts are structured around high-level systemic intervention and strategic alliances, including:
- Correcting the funding record: We have repeatedly put the realities of plan erosion and misconceptions about the funding of psychology directly to the highest levels of the NDIA.
While agency officials frequently deny that any fundamental changes to psychology funding are occurring, we know the ground-level reality is entirely different.
To combat the systemic misunderstandings held by NDIS planners, we worked together with the Australian Association of Psychologists (AAPi) to correct and extend the NDIA’s ‘Would we fund it?’ guide for NDIS psychology supports, as part of our membership of the NDIS National Mental Health Sector Reference Group.
- The Technical Advisory Group campaign: When the Government announced the formation of a Technical Advisory Group to guide the development of functional capacity assessment rules, it provided no transparent process for how members of this group would be appointed.
In response, we worked directly through AHPA to nominate three of our experienced NDIS Working Group members.
While this hasn’t been formally taken up, we will continue showcasing the leadership and expertise of psychologists in informing the future direction of FCAs to Government and other NDIS stakeholders.
- NDIS Working Group subcommittees: To ensure our advocacy is as member-centric, topical, practice-informed, and evidence-based as possible, our overarching NDIS Working Group has established five dedicated subcommittees, including a newly minted subcommittee for Psychosocial Disability to address specific vulnerabilities in mental health, and a Workforce Issues subcommittee.
- Allied Health Professions Australia (AHPA) coalition: The APS is an active member of AHPA, contributing to and supporting a unified allied health advocacy front. This peak-body coalition gives us the combined infrastructure to lobby effectively at both federal and state levels, providing a far greater capacity to influence complex legislative committees than any single discipline could achieve alone.
APS CEO Dr Zena Burgess was recently appointed as a board member of AHPA, providing further opportunity to work collaboratively across the sector.
- Advocating for an expansion of MBS items related to the assessment of Complex Neurodevelopmental Disorders and eligible disabilities
As the landscape for disability funding shifts back to states and territories, particularly through Thriving Kids, a critical component of our current strategic advocacy involves reinforcing the Federal Government’s ongoing role to provide much needed services through Medicare.
As the Government pushes the funding and operational responsibility for children under eight with developmental delays and/or neurodevelopmental differences (such as autism) back to the states and territories, the risk of extreme regional discrepancy and service fragmentation becomes a stark reality.
In our recent APS pre-budget submission, we have called for the streamlining of MBS items related to the Assessment of Complex Neurodevelopmental Disorders.
The APS, along with other allied health peaks, is working with AHPA to advocate for an expansion of these MBS items. Because Medicare remains exclusively within the Federal Government's remit, expanding these items ensures a critical layer of ongoing national continuity and structural stability.
Standing together through systemic upheaval
There is no sugarcoating the reality facing us: the landscape of disability support in Australia is in a state of volatile transition, and the decisions coming out of Canberra are placing unprecedented strain on workflows and the financial viability of psychological practices.
Amid this profound disruption, it's vital to remember that our fundamental skills and competencies and the distinct value of our training do not depreciate. What is changing is where those skills and competencies are applied and how our professional reasoning must be evidenced to satisfy an increasingly rigid bureaucratic framework.
We are committed to providing members with real-time policy updates about the changing landscape of the NDIS. We encourage members to lean into the peer networks available within the APS, including numerous Interest Groups which focus on disability-related and developmental matters.
This includes:
Additionally, the APS will be exhibiting at the DSC Annual NDIS Conference in August, showcasing the vital role psychologists play in supporting people with disability. We are continuing our grass roots advocacy while still focusing on top-down efforts to influence government policy and reform.
We will continue to work to ensure that the voice of psychology is a central pillar of the disability sector in Australia.
The release of the report of the Senate Committee’s Inquiry into the NDIS Bill has been delayed to Friday 19 June 2026.