Positive Behaviour Support and Restrictive Practices within the NDIS
Governance, Regulatory Architectures and Challenges
The implementation of Positive Behaviour Support (PBS) within Australia's National Disability Insurance Scheme (NDIS) is characterized in the literature as operating under a bifurcated regulatory structure where Commonwealth oversight intersects with state and territory legislative powers (Conway 2026).
At the federal level, the NDIS Quality and Safeguards Commission is responsible for regulating specialist behavior support providers and registering Behaviour Support Practitioners (BSPs), utilizing the NDIS PBS Capability Framework as a benchmark for suitability (Fisher et al. 2026).
Concurrently, state and territory jurisdictions retain independent authority over the legal authorization of restrictive practices, which researchers note can lead to operational variations across geographic borders (Conway 2026; Wheeler et al. 2026).
Children playing with plane and truck over a map
Conway (2026) argues that this dual-governance model places significant focus on compliance, monitoring, and administrative reporting of restrictive practices. A consequence of this structure, as identified by Conway (2026), is that the tracking of restrictive practices often becomes a primary metric of regulatory scrutiny, which can obscure broader clinical evaluations of overall support quality and participant outcomes.
The marketized, individualised funding model of the NDIS has also been evaluated in relation to its impact on participants with complex intellectual and developmental disabilities. Researchers suggest that individualised funding packages do not automatically guarantee rights-based or consistent clinical outcomes (Dreyfus et al. 2024; Wheeler et al. 2026).
In a national survey of informal supporters, Fisher et al. (2026) found that families and guardians frequently reported difficulties when attempting to locate and engage suitable practitioners. The survey data highlighted systemic challenges, such as extensive waitlists and limited provider availability, which respondents indicated often constrained their capacity to exercise true choice and control (Fisher et al. 2026). These access barriers were reported to be particularly pronounced in regional and remote areas, where a thin market can lead to a localized concentration of services (Fisher et al. 2026).
Furthermore, recent studies explore observations regarding workforce capability gaps within the NDIS behavior support sector. Stott et al. (2026) discuss concerns regarding the prevalence of underdeveloped behavior support plans, pointing to variability in practitioner education, training, and core behavioral competencies.
Survey data from Fisher et al. (2026) similarly indicates that many practicing clinicians lack specialized postgraduate qualifications in behavioral science or developmental disabilities, often entering the field with standalone allied health degrees or short-course training. Stott et al. (2026) suggest that this direct variation in specialized expertise can affect clinical fidelity, particularly when practitioners are required to conduct complex functional behavior assessments or design individualized environmental modifications.
Text Analysis of Behaviour Support Plans
Behavior support plans serve as central clinical and legal documentation within the NDIS ecosystem, directing daily support strategies and establishing the legal justification for the use of restrictive practices (Wheeler et al. 2026). To analyze the underlying text structures of these documents, Wheeler et al. (2026) developed a Decolonising Critical Discourse Analysis (DCDA) framework.
This framework integrates elements of critical discourse analysis, disability justice principles, and body politic theory to evaluate how language within human service documentation constructs service user identities and behavioral categories (Wheeler et al. 2026). The authors utilize this methodology to question the assumed neutrality of professional clinical writing and to explore how institutional frameworks influence plan authorship (Wheeler et al. 2026).
In their analysis of a sample of 16 registered behavior support plans, Wheeler et al. (2026) identified several distinct linguistic and thematic patterns. The researchers reported that the reviewed documentation frequently omitted explicit considerations of cultural identity, noting that cultural fields within standard templates were often marked as "N/A" (not applicable).
Wheeler et al. (2026) argue that this pattern effectively treats dominant Western frameworks as a neutral default, which can limit the integration of localized community care protocols or First Nations perspectives. Even when a participant's diverse background was formally noted in the sample, the authors observed that plans rarely incorporated specific cultural knowledges into their core behavioral recommendations (Wheeler et al. 2026).
Additionally, Wheeler et al. (2026) contend that the clinical language within their sample remained heavily aligned with diagnostic deficit models. The authors reported that natural behavioral traits, sensory preferences, or intense personal interests were frequently characterized as "atypical," "obsessive," or "impaired." From the perspective of the researchers, such framing reflects an institutional focus on neuronormative compliance and labor productivity rather than individual fulfillment (Wheeler et al. 2026).
Wheeler et al. (2026) also noted instances where plans sought to manage subtle emotional communication, such as directing care staff to actively discourage the use of a "baby voice" or specific emotional expressions, which the authors interpret as prioritising institutional convenience over authentic participant expression.
Practitioner Ethical Decision-Making and Restrictive Practices
The theoretical and ethical distinction between positive behavior support and restrictive practices is a key focus of current professional analysis (Conway 2026). Positive Behaviour Support is defined in the literature as a proactive, person-centred framework aimed at modifying environments, building adaptive functional skills, and improving a participant's overall lifestyle quality (Hagiliassis et al. 2026; Stott et al. 2026).
Conversely, restrictive practices are categorized as reactive, rights-restricting measures of last resort that are implemented primarily to manage risk or prevent imminent harm (Conway 2026; Wheeler et al. 2026). Conway (2026) emphasizes that while regulatory frameworks incorporate both elements into a single behavior support plan for authorization purposes, restrictive practices are fundamentally distinct from proactive PBS strategies. The author argues that conflating the two concepts can compromise the theoretical clarity of behavior support models (Conway 2026).
Through a multi-stage Delphi study and national survey, Conway (2026) developed an explanatory framework to map the diverse factors that shape practitioner decision-making regarding restrictive interventions. This framework identifies four primary layers of influence:
System Factors: These include navigating inconsistent state and territory authorization systems, meeting complex federal reporting requirements, and operating within fee-for-service funding constraints that can restrict available time for comprehensive clinical supervision (Conway 2026).
Service Provider Factors: These encompass organizational pressures from implementing providers, such as supported independent living networks, where challenges like high staff turnover, limited support worker training, and an institutional culture of risk aversion can create an operational reliance on containment strategies (Conway 2026).
Participant Factors: These involve evaluating acute safety risks, complex physical or cognitive impairments, severe communication barriers, trauma histories, and dynamic mental health co-morbidities (Conway 2026).
Personal Practitioner Factors: These include the individual clinician's disciplinary background, specialized capability level, access to formal mentoring, and engagement with collaborative professional communities of practice (Conway 2026).
The literature highlights that clinicians bear substantial evaluative responsibilities due to the documented physiological and psychological risks associated with bodily containment and restriction (Conway 2026). Conway (2026) notes that chemical restraint—particularly the use of psychotropic medications for behavior management—remains highly prevalent, despite associated risks of metabolic changes, over-sedation, and diagnostic overshadowing.
Similarly, physical and mechanical restraints are analyzed in terms of their immediate safety risks, including physical trauma, positional restriction, and psychological re-traumatisation, while seclusion and environmental limits are noted for their potential to increase social isolation or trigger behavioural regression (Conway 2026).
Co-Production, Lived Experience, and Rights-Based Collaboration
To establish human rights-aligned models of service provision, contemporary literature emphasizes the importance of aligning behavior support with the core values of the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD), particularly regarding individual autonomy, supported decision-making, and community inclusion (Hagiliassis et al. 2026).
Co-production is presented as a practical framework to achieve this alignment, defined as the meaningful and continuous involvement of individuals with disabilities in the design, implementation, and evaluation of their own support plans (Hagiliassis et al. 2026). Hagiliassis et al. (2026) conceptualize this process along a continuum of participation, moving progressively from informing and consulting to directly involving, collaborating, and empowering the individual. This collaborative model aims to shift clinical practice away from top-down compliance frameworks toward shared decision-making (Hagiliassis et al. 2026).
In a qualitative study exploring practitioner perspectives, Hagiliassis et al. (2026) identified several clinical strategies utilized by behavior support practitioners to facilitate authentic co-production, especially when working alongside individuals with complex cognitive or communication needs. These enablers include:
Accessible Plan Design: Translating complex clinical documentation into accessible formats, such as utilizing plain language, visual tools, customized social stories, or digital applications that directly reflect the participant's own words and daily context (Hagiliassis et al. 2026).
Alternative Expressions of Voice: Actively observing and interpreting non-verbal cues, behavioral changes, and personal choices as valid indicators of preference, often supported by structured communication frameworks like Talking Mats or Augmentative and Alternative Communication (AAC) systems (Hagiliassis et al. 2026).
Supported Decision-Making Frameworks: Implementing structured relational tools that visually organize and explore life choices, thereby assisting participants to expand their awareness of available possibilities and retain personal autonomy (Hagiliassis et al. 2026).
Relational Engagement: Investing substantial time within the participant's natural daily environment to build mutual trust and understand their unique context prior to initiating formal behavioral assessments (Hagiliassis et al. 2026).
Lived experience perspectives from self-advocates and informal supporters reinforce the assertion that collaborative planning is a core ethical standard (Fisher et al. 2026; Hagiliassis et al. 2026). Family members and participants emphasize that maintaining a commitment to inclusion requires practitioner persistence, particularly when communication barriers make collaboration complex (Hagiliassis et al. 2026).
Furthermore, when restrictive interventions are under consideration, stakeholder feedback underscores the necessity of complete transparency, independent governmental review, and explicit consultation to ensure participant safety and trust (Fisher et al. 2026; Hagiliassis et al. 2026).
Finally, Hagiliassis et al. (2026) note that practitioners must carefully balance active consultation with the participant's psychological safety. In scenarios where discussing behavioral challenges or past restrictive interventions causes significant anxiety or distress, clinicians may choose to modify the directness of the consultation, provided that the clinical rationale for doing so is clearly documented and guided by formal professional supervision (Hagiliassis et al. 2026).
References
Conway, P. 2026, The dilemmas of restrictive practices and the work of Behaviour Support Practitioners: A way forward, Professional Doctorate Thesis, School of Social Sciences, Faculty of Arts, Design & Architecture, University of New South Wales.
Dreyfus, S., Nolan, A. & Randle, M. 2024, 'Challenges to accessing behaviour support services for people with intellectual disability before and after the NDIS', Journal of Intellectual & Developmental Disability, vol. 49, no. 2, pp. 199–214.
Fisher, A., Nicoll, D.P., Belperio, I., Clissold, M., Osborne, A., Fox, R., Leif, E. & McVilly, K. 2026, 'A National Survey of Informal Supporters' Experiences and Views of Behaviour Support Practitioners in the National Disability Insurance Scheme', Australian Journal of Social Issues, pp. 1–13.
Hagiliassis, N., Di Marco, M., Fowler, S., Koritsas, S. & Plush, M. 2026, 'Navigating Co-production in Behaviour Support: Perspectives from the Field', Advances in Neurodevelopmental Disorders, pp. 1–8.
Stott, C., Thirumanickam, A., Hayward, B., Farrar, L. & Attrill, S. 2026, 'Beyond Behaviour: Exploring How Positive Behaviour Support Might Work for Autistic Children Within Australia's NDIS', Australian Journal of Social Issues, pp. 1–14.
Wheeler, A., Farwa, A., Russ-Smith, J., Margaret, L. & Wray, S. 2026, 'A Decolonising Critical Discourse Analysis Framework for Positive Behaviour Support Plans', Australian Social Work, vol. 79, no. 1, pp. 17–31.
‘Jo’ Bowers PhD is a Senior Specialist Behaviour Support Practitioner who is registered with the NDIS Commission. To contact and inquire for service go to home page, scroll down to the form and send us a hello. Kind regards.