DEFINITION OF “NDIS PROVIDER”

Department of Health, Disability and Ageing

27 February 2026

AFDO author and contact:

Matthew Hall
National Manager - Systemic Advocacy & Policy
matthew.hall@afdo.org.au

Reviewed and approved:

Ross Joyce
Chief Executive Officer

Contents

• Acknowledgements

• Language used in this document

• About AFDO

• 1. Acronyms and abbreviations

• 2. Executive summary

• 3. Background

  • 3.1 The NDIS Review

  • 3.2 The Taskforce

  • 3.3 Support types proposed by the Taskforce

• 4. Current definition

• 5. Consultation paper

  • 5.1 Concerns

  • 5.2 Responses to questions posed

Australian Federation of Disability Organisations (AFDO) Ltd is registered as a charity with the Australian Charities and Not for profit Commission. It is also a Public Benevolent Institution, endorsed by the Australian Taxation Office as a Deductible Gift Recipient. A donation of $2.00 or more is tax deductible.

Consent to publication: Australian Federation of Disability Organisations (AFDO) consents to the publication of this submission, including the names and contact details of AFDO staff. The relevant AFDO staff also give that consent.

© 2026, Australian Federation of Disability Organisations (AFDO) Ltd

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Acknowledgements

Aboriginal and Torres Strait Islander people

Australian Federation of Disability Organisations (AFDO) acknowledges Aboriginal and Torres Strait Islander people as the First Peoples and traditional custodians of the land now called Australia. We recognise their deep and continuing connection to Country and community. We pay our respects to the traditional custodians of Country where we work, connect, or meet, which always was, and always will be, Aboriginal land. We also pay our respects to Elders past, present, and emerging.

People with disability

AFDO acknowledges people with disability in all their diversity, particularly those individuals who have experienced or are continuing to experience violence, abuse, neglect, or exploitation. We also acknowledge their families, carers, supporters, and representative organisations and express our thanks for the continuing work done by the many people supporting, protecting, and advancing the rights of people with disability.

Language used in this document

AFDO has chosen to use person-first language (like “people with disability”) in this document. Person-first language puts the person before the disability and values the individual by seeing them as a person, not a condition. This aligns with the CRPD and matches the language used by all governments in Australia. Most other Australian disability peaks also use person-first language.

We recognise many people with disability prefer identity-first language. Disability is a part of their identity and shows a connection to their community and pride in disability. Views on language reflect people’s identities, experiences of disability, and community attitudes. It is a matter of individual choice and agency. AFDO respects everyone’s right to choose how to describe their identity and experiences.

About AFDO

Since 2003, the Australian Federation of Disability Organisations (AFDO) has been the pre-eminent national peak for people with disability, championing their rights through our extensive member organisation network uniquely representing both disability-specific and cross-disability communities with a reach of over 4.5 million Australians.

We are, firstly, a Disabled People’s Organisation (DPO), led, governed, and predominantly staffed by people with disability. We are also a Disability Representative Organisation (DRO) funded by the Australian government. The majority of our member organisations are DPOs, family led, or specific disability not for profits. This ensures that our work is informed by lived expertise and experience, truly representing our communities.

AFDO is a strong, trusted voice for the disability sector. We advocate on national policy, inquiries, and initiatives with the Federal and state and territory governments. We work to build a community where people with disability:

• have real participation in community life
• can build respectful, valued relationships
• participate socially and economically, and
• contribute as valued citizens.

Our vision

All people with disability can take part equally in all aspects of social, economic, political, and cultural life.

Our mission

Using the strength of our member organisations to harness the collective power of uniting people with disability to change society into a community where everyone is equal.

Our strategic objectives

• To represent the interests and united voice of our members and people with disability at a national and international level in all relevant forums.
• To build the capacity, profile, reputation, and sustainability of AFDO through the strength of our member organisations.

• To enhance the connection and influence in international disability initiatives by policy, advocacy, and engagement, focused on the Asia Pacific region.

Our members

AFDO’s member organisations contribute to the national policy agenda and address issues that impact the lives of people with disability in Australia. We understand that disability-specific organisations play a key role in the provision of information and peer support to people with disability and their families. This role keeps them closely connected to their grassroots communities. Each community has its peak organisation that uses its voice to advocate on issues.

Information about AFDO’s members can be found on [our website](our website).

1 Acronyms and abbreviations

This list of terms may assist users of this document to understand what we mean when we use the following terms or abbreviations.

2 Executive summary

AFDO appreciates the Department’s invitation to help shape the important reform canvassed in the Consultation paper, through this opportunity to provide feedback to the Department on how a “NDIS provider” should be defined in the Act, as a necessary component of a new graduated risk proportionate regulatory model proposed by the NDIS Review, and further refined by the Taskforce.

In this submission we provide some analysis and feedback on certain matters raised in the Consultation paper and the Taskforce’s advice, viewed through the lens of human rights principles, and assessed from a systemic advocacy perspective that is centred on the rights and experiences of people with disability.

However, neither this submission, nor any other feedback you receive from this consultation process, is enough, or is what is required to achieve a definition (and a regulatory model) consistent with the Taskforce’s very clear advice. The shape of critical components of the proposed reform, including the definition of “NDIS provider”, the identification of types of support that require registration, and the primacy of the principle that each participant must exercise choice and control, are best determined by the people who are going to be most effected by the proposed model, that is people with disability.

In this, we have the same position as, and agree completely with, the advice of the Taskforce. We also agree with the Department of the Prime Minister and Cabinet that it is essential that the reform is planned, managed, and implemented in an holistic way, that recognises that each part of the model is connected to and may be dependent on, or effect the behaviour of, other parts of the model.

AFDO makes the following key recommendations:

1. The Government should accept the Taskforce’s recommendation and co-design a new definition of “NDIS provider” with people with disability and their representative organisations through a process that is participative, inclusive, respectful, centred on lived experience and lived expertise, iterative and outcomes focused.

2. The Government should accept the Taskforce’s advice that not all providers must be registered and co-design amendments to the Act with people with disability and their representative organisations that define:

   • (a) “NDIS provider”; and
   • (b) “registered NDIS provider”.

3. The Government should accept the Taskforce’s advice to include:

   • (a) a category of registration for participants who self-direct their supports, with appropriate processes for registration and audit; and
   • (b) Worker Registration Scheme for all “workers”.

4. The Government should co-design amendments to the Act with people with disability and their representative organisations that define:

   • (a) “self directed support registration”; and
   • (b) “worker”;

   and co-design the associated registration and audit processes for self-directed support registration.

5. The Department of Health Disability and Ageing should formally define and apply consistent terminology that distinguishes people with disability and our representative and peer led organisations from NDIS and other service providers and ensure that consultation processes intended to centre lived experience do not conflate these distinct groups.

6. The Government should adopt a genuine, collaborative co-design process with people with disability and their representative organisations as the primary mechanism for identifying missing supports, exclusions, secondary impacts and other matters raised in the Consultation paper.

3 Background

3.1 The NDIS Review

The NDIS Review recommended:

1. a “risk-proportionate model for the visibility and regulation of all providers and workers” in the Scheme³

2. a proposed model to regulate providers based around four broad categories of registration related to the risk associated with different types of supports and providers, with corresponding mandatory registration or enrolment requirements, namely:

   • (a) Advanced registration for all high-risk supports.
   • (b) General registration for all medium risk supports
   • (c) Basic registration for all lower risk supports, and
   • (d) Enrolment of all providers of lowest risk supports⁴

3. whilst recognising the NDIS was designed to offer choice and control to people with disability through a market-based system of supports⁵, the model should include mandatory registration or enrolment of all providers, including Navigators, Lead Practitioners and foundational support providers, and all other new supports and functions proposed in other recommendations⁶.

The Department proposes that the definition of “NDIS provider” in the Act will determine which providers will be required to register under a mandatory registration model.

3.2 The Taskforce

The Taskforce was tasked to give expert advice to the government on designing and setting up this new model to make sure it upholds the rights of people with disability to have choice and control.⁷

The Taskforce advice notes significant concerns with mandatory registration for all NDIS providers and considered that this would:

• (a) significantly impact on choice and control for NDIS participants without further design incorporating the current ways supports are managed

• (b) be costly or burdensome to providers, particularly smaller providers, causing some to leave the NDIS market, which will reduce the number of providers in the NDIS and cause further barriers to accessing quality supports within the Scheme that are right for people with disability
• (c) limit or stifle innovation and different models of supports NDIS participants and their families are exploring and using effectively.⁸

The Taskforce made 11 recommendations, including that

Not all providers should be registered. Further consultation with the disability community and sector is needed on this. It is recommended that those who would not be registered would include, but are not limited to:

• unregistered providers who support participants who are self-directed
• goods bought off-the-shelf from mainstream providers.⁹

The Taskforce also recommended:

1. platform providers are registered¹⁰,

2. ways to support NDIS participants to register themselves for self-directed supports, including:

   • (a) having support providers automatically registered and visible to the Commission.
   • (b) putting self-directed supports in a new category, which are reviewed and audited to make sure people are safe and have quality supports
   • (c) people with disability co-designing the registration and audit processes¹¹

3. a worker registration scheme for all workers, with the disability community and sector co-designing the definition of ‘worker’¹²

4. the registration model must recognise any existing professional registrations that are held by providers, including allied health professionals¹³ (noting that within the legislative framework, there needs to be consideration of the recognition of other professional registration for allied health practitioners¹⁴, and

5. four types of registration, namely:

• (a) Advanced registration - providers who offer high-risk supports and services in high-risk settings, including daily living supports in closed settings like group homes.
• (b) General registration - providers who offer medium-risk supports like: high intensity daily personal activities, supports that need extra skills and training, and supports where there is a lot of one-on-one contact with people with disability
• (c) Self-directed support registration - participants, their guardian or legal representative who contract all their supports directly, and
• (d) Basic Registration - providers who offer lower-risk supports, such as sole traders or supports where social and community participation involves limited one-on-one contact with people with disability.¹⁵

The Taskforce identified a fifth category (goods or services from mainstream suppliers) for which registration is not required.

Whilst the Taskforce thought that the framework provided by the NDIS Review provides a useful framework for understanding risk, and it adopted three of the four categories of registration proposed¹⁶, the Taskforce’s recommendations differ from the NDIS Review in the following ways:

• (a) recognising the paramountcy of choice and control
• (b) accepting that not all providers need to be, nor should be, registered
• (c) including a self-directed support registration category
• (d) not adopting the concept of “enrolment” for lowest risk supports,
• (e) not categorising any risks as “lowest”,
• (f) specifically including platform providers, and
• (g) insisting the new definition of “NDIS provider” is co-designed by people with disability.

3.3 Support types proposed by the Taskforce

As the Consultation Paper notes, the Taskforce is “clear” that the following services and supports must be included in the registration model:

A support or service offered by a person or entity to people with disability, including a participant or prospective participant. A support that is described as one of the following:

• Provision of housing or home and living support

• Supports a person with disability to live independently, including with shared supports with other people with disability
• Provision of day programs in centre-based environments
• Employment support provided to people with disability to find work or obtain skills and readiness
• Australian Disability Enterprises [which is changed to “Supported Employment” in the consultation paper]
• Provision of accommodation on a short-term basis or for respite services
• Provision of in-home care and support services to a person to maintain their hygiene, mobility, social and economic participation
• Support to access the community or engage in social participation
• Intermediary services to support a person to manage their NDIS Plan, support services or financial management
• Manufacture or sale of equipment or assistive technology, including modifications
• Provision of disability-specific transportation services
• Allied health and therapeutic services
• Early childhood and early intervention services
• Positive behaviour support practitioner support and implementation
• Interpreter services
• Health services, such as paediatric support or optometry
• Capacity building support
• Peer support programs and initiatives
• Orientation and mobility services.

It is not clear from the drafting in the Taskforce’s advice or the Consultation paper if the two categories of a “support or service offered” to a person with disability and a “support that is described” are intended to be two separate conditions, alternate conditions, or cumulative conditions. We note, however, that if the “support or service offered” category is a separate, stand-alone condition, there will be no support types below the dotted line in Diagram 1. This must be clarified.

There are several other matters where clarification is needed, or more precise drafting would assist in determining and understanding the scope of the proposed types of support to be included in the registration model. We deal with those matters in section 5.2.

4 Current definition

The Act defines¹⁷ a “NDIS provider” as:

(a) a person (other than the Agency) who receives:

• (i) funding under the arrangements set out in Chapter 2; or
• (ii) NDIS amounts (other than as a participant); or

(b) a person or entity:

• (i) who provides supports or services to people with disability other than under the National Disability Insurance Scheme; and
• (ii) who is prescribed by the rules for the purposes of this subparagraph.

Pursuant to paragraph (b)(ii), rules prescribe as a “NDIS provider” a person or entity who is providing supports or services to older people with disability who are receiving continuity of support under the programs administered by the Commonwealth known as:

• (a) the Commonwealth Disability Support for Older Australians, and
• (b) the Commonwealth Continuity of Support Programme relating to Specialist Disability Services for Older People.¹⁸

The people receiving these supports and services were ineligible for the NDIS due to their age at the time of transition in their state or territory.

“NDIS amount” is an amount paid under the Scheme in respect of supports (other than general supports) funded under a participant’s plan.¹⁹ Otherwise, “supports” includes “general supports”.²⁰

A “general support”²¹ is:

• (a) a service provided by the Agency to a person or
• (b) an activity engaged in by the Agency in relation to a person,

that is in the nature of a coordination, strategic or referral service or activity, including a locally provided coordination, strategic or referral service or activity.

Funding under the arrangements in Chapter 2 is funding for persons or entities:

• (a) for the purposes of enabling those persons or entities to provide information in relation to disability and disability supports and services; or

• (aa) for the purposes of enabling those persons or entities to provide assistance in building capacity within the community in connection with the provision of goods and services to people with disability and their families and carers; or
• (ab) for the purposes of enabling those persons or entities to assist people with disability to realise their potential for physical, social, emotional and intellectual development; or
• (ac) for the purposes of enabling those persons or entities to assist people with disability, and their families and carers, to participate in social and economic life; or
• (b) otherwise in the performance of the Agency’s functions.²²

This includes NDIS community partners such as Local Area Coordinators²³ and Navigators.

5 Consultation paper

5.1 Concerns

We must register several significant concerns we have with the Consultation paper, particularly in regard to the strong impression the paper creates that the proposed scheme is the same as, or at least closely aligned to, the recommendations of the Taskforce. None of the significant differences are noted, and insufficiently precise language is used to create the impression of much closer alignment than is, in fact, the case.

We are very concerned that many participants (who may not have followed in detail the work of the NDIS Review or the Taskforce) will mistakenly think that the government is proposing to implement all the recommendations of the Taskforce. A very careful reading and analysis of the Consultation paper demonstrates this is not the case.

The Consultation paper ignores the Taskforce’s clear advice²⁴ that the definition must be co-designed by people with disability. We remind the Department that “consultation” is not “co-design”. The term co-design is

increasingly common in government discourse like this, yet a clear and shared definition is lacking. Like co-production, co-design has been ‘granted an influential role in the future of … public governance … Consequently, co-design risks being little more than a buzzword in the public sector²⁵

True “co-design” is

a design-led process, involving creative and participatory principles and tools to engage different kinds of people and knowledge in public problem-solving.²⁶

Central to co-design is recognition that it

goes beyond consultation by building and deepening equal collaboration between citizens affected by, or attempting to, resolve a particular challenge. A key tenet of co-design is that users, as ‘experts’ of their own experience, become central to the design process.²⁷

This requires the following three key elements:

• Process: an iterative, design-led approach oriented towards creation or innovation.
• Principles: participative, inclusive, equal collaboration, respectful, iterative and outcomes-focused values are at the heart of this approach
• Practice: creative and tangible methods for telling, enacting and making.²⁸

RECOMMENDATION 1

That the Government accept the Taskforce’s recommendation and co-design a new definition of “NDIA Provider” with people with disability and their representative organisations through a process that is participative, inclusive, respectful, centred on lived experience and lived expertise, iterative, and outcomes focused.

It is not clear to us if the government has accepted the Taskforce’s advice in relation to self-directed support registration, or that not all providers must be registered.

The Consultation paper states that “the Taskforce agreed with the NDIS Review that a mandatory provider regulatory model” is required.²⁹ This does not accurately represent the Taskforce’s work or recommendations. The use of “mandatory” makes it very unclear as to the government’s position. In one sense, any regulatory model is mandatory. That is the whole purpose of regulation. If, however, the use of mandatory is included as a reference to the NDIS Review’s model of requiring registration of all providers, the Taskforce does not agree with that position.

The Consultation paper also states (in connection with the purpose of the current consultation)

The Taskforce also recommended a category of registration for participants who self-direct their supports. Participants who register to self-direct would continue to use unregistered NDIS providers, as their arrangements would be visible to the NDIS Commission under their own registration. From 29 November 2024 to 7 February 2025 the Department of Social Services conducted a public consultation on self-directed supports, and the Government is carefully considering the submissions to this consultation alongside the Taskforce Advice.³⁰ (our emphasis)

AFDO is concerned that the current consultation does not fix a position on this very important aspect of the Taskforce’s recommendations, nor does it seek any input from people with disability and their representative organisations on the co-design of the registration and audit processes. The regulatory model must be designed and considered holistically, and not in the piecemeal, fragmented way that the Department appears to have adopted. This must also include the Taskforce’s recommendations in relation to a workforce registration system, and the definition of “worker”.³¹ We also note that the need to take an holistic approach is consistent with the government’s approach (as published by the Department of the Prime Minister and Cabinet) to achieving the Government’s vision and goals for the care and support economy, in which an “holistic, harmonised approach to the implementation of these reforms is vital”.³²

It is correct (as the Consultation paper notes, when referring to Diagram 1) that Taskforce recommended providers of services above the dotted line would require registration in any new model,³³ but it is not accurate. This statement omits any reference to the Taskforce’s recommendation that self-directed support registration is also above that dotted line.

The Consultation paper does not seek any response to whether the new definition needs to capture entities that are not incorporated, recognised or operating in Australia, with the Taskforce noting that it

heard that participants use providers overseas for consumables or therapies but also that some intermediary services are taken offshore so need to be covered by the regulatory framework. ³⁴

RECOMMENDATION 2

That the Government accept the Taskforce’s advice that not all providers must be registered and co-design amendments to the Act with people with disability and their representative organisations amendments that define:

• “NDIS provider”, and
• “registered NDIS provider”.

RECOMMENDATION 3

That the Government accept the Taskforce’s advice to include:

(a) a category of registration for participants who self-direct their supports and provide for processes for registration and audit, and

(b) a Worker Registration Scheme for all “workers”.

RECOMMENDATION 4

That the government co-designs with people with disability and their representative organisations amendments to the Act that define:

(a) “self directed support registration”; and (b) “worker”; and co-design the associated registration and audit processes for self directed support registration.

AFDO is also concerned by the Department’s categorisation of NDIS providers as members of the “disability community”.³⁵ NDIS providers are a recognised and essential part of the disability sector (the ecosystem of organisations, governments, and providers involved in delivering disability supports). They are not, and should not be described as, part of the “disability community”.

Our disability community is made up of:

• people with disability and our families and kin, who share common experiences of disability, rights, barriers, advocacy, and identity, and
• peer-based and lived-experience for purpose organisations and community groups involved in advocacy, culture, rights, and community.

Describing NDIS providers as part of the “disability community” is inaccurate and inappropriate. In doing so, the Department blurs the distinction between lived experience and service delivery, and whether intentionally or not, centres providers in conversations that are meant to prioritise people with disability. It also conflicts with policy language that consistently separates community supports such as belonging and participation from NDIS service provision, and is inconsistent with the framing of the NDIS as a market-based system of disability supports.

RECOMMENDATION 5

That the Department of Health, Disability and Ageing formally defines and applies consistent terminology that distinguishes people with disability and our representative and peer led organisations from NDIS or other service providers, and ensures that consultation processes that are intended to centre lived experience do not conflate these distinct groups.

5.2 Responses to questions posed

The Consultation paper seeks responses to the following specific questions:

1. Are there any supports or services missing from the list at Table 2 that you think should be included in an amended definition of “an NDIS provider”?
2. Are there any supports or services that you would exclude from the definition in Table 2?
3. What issues should Government consider when amending the definition of NDIS provider to maintain flexibility and responsiveness to NDIS participants needs?
4. Are there factors, other than the type of support delivered, which should be considered in a new definition of “an NDIS provider”?
5. Are there supports you currently access which may be disrupted or result in secondary impacts if they are included or excluded in a new definition of “an NDIS provider”?
6. Are there opportunities to ensure a new definition of “an NDIS provider” supports productivity and sustainability across the care and support economy?

Whilst we make some suggestions to improve and clarify the list in Table 2, we maintain that the best and most efficient way to identify any missing supports,

supports that should be excluded, any potential secondary impacts, and all other matters that the questions in the Consultation paper seek to address is by an effective, collaborative co-design process involving people with disability and their representative organisations.

Missing supports or services

The list in Table 2 in the Consultation paper must expressly include:

1. supports or services to older people with disability who are receiving continuity of support under the programs administered by the Commonwealth and known as:

   • (a) the Commonwealth Disability Support for Older Australians, and
   • (b) the Commonwealth Continuity of Support Programme relating to Specialist Disability Services for Older People

2. platform providers

3. Local Area Coordinators, Navigators and all other new supports and functions proposed in other recommendations of the NDIS Review

4. Other providers of “general supports”

Clarifications, amendments and exclusions

5. Provision of day programs in centre-based environments

   Applying the Taskforce’s reasoning of the need to focus on the support type, and not the method or place of delivery,³⁶ we see no valid reason for limiting registration of “day programs” to those in “centre-based environments”.

6. Employment support provided to people with disability to find work or obtain skills and readiness

   We recommend that this item includes services provided to students with disability, who may not be seeking to enter the employment market immediately.

   We query whether, and if so, how, person with disability (or anyone else) “obtains” readiness. The concept may be better expressed as to “obtain general or specific employment related or job readiness skills or capacity”.

7. Provision of in-home care and support services to a person to maintain their hygiene, mobility, social and economic participation

   The drafting of this item is ambiguous.

Applying the Taskforce’s reasoning of the need to focus on the support type, and not the method or place of delivery,³⁷ we see no valid reason for limiting registration of support services to a person to maintain their hygiene, mobility, social and economic participation to “in-home care”.

We recognise that “in-home care” is an environment in which a person with disability may be more exposed to risks of abuse, neglect, harm or exploitation.

We do not think that registration of services provided in a person’s home should be limited to services directed to maintaining “hygiene, mobility, social and economic participation”.

We suggest separating this item into two separate items:

• (a) Provision of in-home care, and
• (b) Provision of support services to a person with disability to maintain or improve hygiene, mobility, and social and economic participation.

8. Manufacture or sale of equipment or assistive technology, including modifications

We recommend that this item is amended to include importers of equipment and assistive technology, aligning registration with the importer’s liability under the Australian Consumer Law³⁸, as a local manufacturer for product safety, defects, and consumer guarantees.

9. Provision of disability-specific transportation services

We query whether the government intends to require:

• (a) drivers of taxis that are modified to carry passengers using wheelchairs
• (b) following the implementation of the proposed aviation-specific disability transport standards³⁹, airlines and airports that comply with their obligations under that standard, or
• (c) public transport providers that comply with their obligations under the Public Transport Disability Standards⁴⁰

to be registered NDIS providers, as providing “disability-specific transportation services”?

This needs to be clarified.

In addition, AFDO considers the current drafting of “disability-specific transportation services” is broad enough to include the various taxi subsidy schemes for people with disability in each of the states and territories. Each scheme is only available to people with disability who are unable to use public transport because of their disability and, consequently, is a “disability-specific transportation service”. We expect this is an unintended consequence. These providers would be visible to the NDIA via enhancements to the payment system.41

This needs to be clarified in the drafting of this item.

10. Allied health and therapeutic services

Subject to:

• (a) the government accepting the Taskforce’s recommendation that practitioners, including allied health practitioners, who hold professional registration, may have that registration recognised to avoid duplication and administrative burden,42
• (b) any difference that may arise between the professional registration and the recommended NDIS Provider and Worker Registration Scheme43 (which is another reason why we urge the government to take an holistic approach to the implementation of the regulatory model44),

we do not have any further comment on this item.

11. Positive behaviour support practitioner support and implementation

This item is ambiguous. It is not clear whether it is seeking to capture:

• (a) Positive behaviour support practitioners
• (b) Supports provided by positive behaviour support practitioners, or
• (c) Supports provided to positive behaviour support practitioners.

We do not know, and cannot comment on what is intended to be covered by “and implementation”.

These matters need to be clarified.

12. Interpreter services

We query whether the government intends all interpretation services, interpreting any other language into English, or from English into any other language, will need to be provided by registered NDIS providers?

We recommend that this item is limited to Auslan and tactile signing interpretation services. Providers of other interpretation services would be visible to the NDIA via enhancements to the payment system.45

13. Health services, such as paediatric support or optometry

Subject to:

• (a) the government accepting the Taskforce’s recommendation that practitioners who hold professional registration, may have that registration recognised to avoid duplication and administrative burden,46
• (b) any difference that may arise between the professional registration and the recommended NDIS Provider and Worker Registration Scheme47 (which is another reason why we urge the government to take an holistic approach to the implementation of the regulatory model48),

we do not have any further comment on this item.

RECOMMENDATION 6

That the Government adopt a genuine, collaborative co-design process with people with disability and their representative organisations as the primary mechanism for identifying missing supports, exclusions, secondary impacts and other matters raised in the Consultation paper.

Endnotes

1 Department of Health, Disability and Ageing, “Getting It Right: A New Definition for NDIS Providers”, Commonwealth of Australia, 19 December 2025, retrieved from https://consultations.health.gov.au/disability-and-carers-group/ndis-provider-definition-consultation/, accessed 7 January 2026.

2 United Nations Convention on the Rights of Persons with Disabilities, 2515 UNTS 3 (entered into force 3 May 2008), retrieved from https://social.desa.un.org/issues/disability/crpd/convention-on-the-rights-of-persons-with-disabilities-crpd, accessed 7 January 2026.

3 Independent Review into the National Disability Insurance Scheme, Working together to deliver the NDIS, Final Report, Commonwealth of Australia, October 2023, recommendation 17, p. 21, retrieved from https://www.ndisreview.gov.au/resources/reports/working-together-deliver-ndis/, accessed 9 January 2026.

4 Note 3, pp. 178-179.

5 Note 3, p. 49.

6 Note 3, p. 186.

7 NDIS Provider and Worker Registration Taskforce, NDIS Provider and Worker Registration Taskforce Advice, Commonwealth of Australia, 2025, p.11, retrieved from https://www.health.gov.au/sites/default/files/2025-07/ndis-provider-and-worker-registration-taskforce-advice.pdf, accessed 3 February 2026.

8 Note 7, p. 13.

9 Note 7, recommendation 1, p. 5.

10 Note 7, recommendation 4, p.5

11 Note 7, recommendation 6, p.6

12 Note 7, recommendation 10, p. 8.

13 Note 12, recommendation 11.

14 Note 7, p. 9.

15 Note 7, recommendation 3, p.5 and Table 1 (Annexure A), p. 109.

16 Note 15.

17 Section 9.

18 Rule 5, National Disability Insurance Scheme (NDIS Provider Definition) Rule 2018, retrieved from https://www.legislation.gov.au/F2018L00628/latest/text, accessed 20 February 2026.

19 Note 17.

20 Note 17.

21 Section 13(2).

22 Section 14(1).

23 NDIS Quality and Safeguards Commission, The NDIS Code of Conduct, Commonwealth of Australia, September 2023, p. 4, retrieved from https://www.ndiscommission.gov.au/sites/default/files/2023-09/Code-conduct-providers-Updated%20September%202023.pdf, accessed 20 February 2026.

24 Note 7, p. 23.

25 Blomkamp, E. (2018), The Promise of Co-Design for Public Policy. Australian Journal of Public Administration, 77: 729-743, retrieved from https://doi.org/10.1111/1467-8500.12310, accessed 20 February 2026.

26 Note 25.

27 Design for Europe, quoted in Sunlight foundation, Guide to co-design, Learn how to create a participatory design process, retrieved from https://communities.sunlightfoundation.com/action/codesign/, accessed 20 February 2026.

28 Blomkamp, E. What is co-design? Understanding the process, principles and practice, retrieved from https://www.newknow.how/resources/define-co-design, accessed 20 February 2026.

29 Note 1, p. 6.

30 Note 1, p.2

31 Note 12.

32 Department of the Prime Minister and Cabinet, Care and support economy – state of play, 28 May 2024, retrieved from https://www.pmc.gov.au/resources/care-and-support-economy-state-play, accessed 24 February 2026.

33 Note 1, p. 8.

34 Note 1, p. 23.

35 Note 1, p.9.

36 Note 10.

37 Note 10.

38 Schedule 2, Competition and Consumer Act 2010.

39 See https://www.infrastructure.gov.au/infrastructure-transport-vehicles/transport-accessibility/aviation-accessibility, accessed 6 February 2026.

40 Disability Standards for Accessible Public Transport 2002.

41 Note 1, p. 7.

42 Note 13.

43 Note 12.

44 Note 31.

45 Note 1, p. 7.

46 Note 13.

47 Note 12.

48 Note 31.