Australian Music Therapy Association response to
Independent Review of the place of Art and Music Therapy within
Australia’s National Disability Insurance Scheme
The Australian Music Therapy Association (AMTA) welcomes the report of the Independent Review of the place of Art and Music Therapy within Australia’s National Disability Insurance Scheme led by Dr Stephen Duckett AM (Duckett report). The former Minister for the NDIS, Bill Shorten, commissioned the independent review following a strong AMTA campaign against the removal of music therapy as a therapeutic support in November 2024.
AMTA welcomes the opportunity to provide the NDIA with a response to the Duckett report and the NDIA’s response to the review’s recommendations. We welcome this transparent approach and see this as a critical step toward developing a more collaborative relationship with the NDIA.
The report reaffirms music therapy as an effective and recognised therapeutic support under the National Disability Insurance Scheme (NDIS). AMTA welcomes the recognition of AMTA-certified registered music therapists (RMTs) as the allied health professionals exclusively eligible to deliver music therapy supports in the NDIS. This recognition aligns music therapy with other allied health professions such as speech pathology and dietetics, underscoring the profession’s standards and clinical expertise.
However, AMTA is deeply concerned by the misrepresentation of our profession’s regulatory requirements. AMTA is a member of Allied Health Professions Australia (AHPA) and the National Association for Self Regulating Health Professions (NASRHP). Music therapists registered with AMTA are required to comply with strict regulatory standards established by NASRHP to ensure consumer safety. NASRHP standards align closely with the Australian Health Practitioner Regulation Agency (AHPRA) regulatory standards, ensuring high standards of professional competency, ethical practice, and ongoing professional development across self-regulating allied health disciplines. Both frameworks require practitioners to meet rigorous entry-level education, adhere to professional codes of conduct, and engage in continuing professional education to maintain their credentials.
AMTA is also concerned by the pricing changes proposed by the NDIA. The new maximum hourly rate of $156 equates to a 20% reduction for providers. We believe this pricing rate has been informed by a misunderstanding of our qualifications and regulations, and has failed to recognise the impact of GST on the sustainability of music therapy practices. We are also concerned that this pricing rate has been informed by misleading “market data” skewed by non-RMT providers. This pricing reduction places services at risk of closure, impacting the RMT workforce, therapy supports market, and access for NDIS participants to high quality supports.
We include our response to each of the Duckett report recommendations on the following pages. We look forward to collaborating with the NDIA to ensure continuing access to music therapy - an effective, proven therapeutic intervention that can be life-changing for some NDIS participants.
Australian Music Therapy Association response to Independent Review of the place of Art and Music Therapy within Australia’s National Disability Insurance Scheme September 2025 1
| Recommendation | AMTA position | AMTA response | Action required |
|---|---|---|---|
| Recommendations for Evidence Advisory Committee | |||
| 1. Include an assessment of the evidence base for art and music therapy interventions in specific cohorts in its 2025-26 work plan (paragraph 162). | Support in principle, with genuine collaboration | AMTA supports Dr Duckett’s recommendations for more information regarding the evidence for music therapy at a cohort level, to inform participants and NDIA delegates in making informed decisions about the provision of music therapy. AMTA emphasises the importance of collaboration between the EAC and AMTA to ensure that the evidence base for music therapy is understood and accessed appropriately. Art therapy and music therapy are distinct allied health professions with distinct qualifications, research and evidence bases, therapeutic approaches, certifying bodies, and professional and regulatory standards. These differences impact on how we practice and the outcomes we achieve. AMTA strongly recommends the EAC consider art therapy and music therapy as distinct disciplines, as they would for physiotherapy and speech pathology. AMTA has previously raised concerns regarding the internal NDIA Rapid Review, which demonstrated limited understanding of music therapy as a specialist allied health profession, excluded music therapy journals, and included literature on interventions that are not considered music therapy and were not delivered by a music therapist. We strongly encourage collaboration to maximise time and accuracy. AMTA notes that our summary of relevant evidence submitted to the Independent Review was framed in relation to the NDIS Functional Impairment categories. AMTA has versions of the same summaries organised under diagnoses. We are prepared to share these with the EAC to assist in their review. AMTA seeks to understand whether other therapy supports will also undergo a similar review, in the interest of understanding parity between allied health disciplines. | Direct communication between AMTA and EAC is to be established to ensure genuine collaboration. We understand EAC will commence their review of music therapy in November 2025. We expect to be in contact with the EAC in October 2025. |
Australian Music Therapy Association response to Independent Review of the place of Art and Music Therapy within Australia’s National Disability Insurance Scheme September 2025 2
| Recommendation | AMTA position | AMTA response | Action required |
|---|---|---|---|
| 2. Consider the concept of a minimal clinically important difference in making its recommendations (paragraph 142). | Support in principle with genuine collaboration | AMTA welcomes this recommendation, as it acknowledges that for many participants with complex disabilities and functional needs, that minimal clinically important differences (MCIDs) are crucial in understanding benefits that are too sensitive to show on standardised outcome measures. AMTA highlights the importance of collaboration with the EAC to assist the committee to understand what MCIDs look like in music therapy contexts. AMTA emphasises the importance of collaboration with participants with lived experience to ensure their perspectives and opinions are equally represented. | Direct communication between AMTA and EAC to be established to ensure genuine collaboration. We understand EAC will commence their review of music therapy in November 2025. We expect to be in contact with the EAC in October 2025. |
| 3. Develop explicit processes for making decisions about provision of therapeutic support in populations where there is a poorly developed evidence base (paragraph 168). | Support in principle with genuine collaboration | AMTA welcomes Dr Duckett’s acknowledgement that for many diagnostic groups, the evidence is underdeveloped due to a myriad of systemic reasons (such as lack of research funding, low sample sizes due to low incidences, and complexity of variables). AMTA again highlights the importance of collaboration with the EAC to support understanding and interpretation of research and clinical outcomes for these populations. | Direct communication between AMTA and EAC to be established to ensure genuine collaboration. We understand EAC will commence their review of music therapy in November 2025. We expect to be in contact with the EAC in October 2025. |
| Recommendations for NDIA | |||
| 4. Consider ways in which better information can be | Support | AMTA is equipped and prepared to collaborate with the NDIA to ensure participants and their families have access to high-quality information about | We welcome the opportunity to work with |
Australian Music Therapy Association response to Independent Review of the place of Art and Music Therapy within Australia’s National Disability Insurance Scheme September 2025 3
| Recommendation | AMTA position | AMTA response | Action required |
|---|---|---|---|
| provided to participants to assist them to make informed choices about whether particular therapeutic supports could be a useful, evidence-based inclusion in their plans. | music therapy supports. It’s critical that AMTA work with the NDIA on participant information to ensure accurate representation and communication of the evidence and the profession. | the NDIA on this immediately. | |
| 5. Messaging about evidence should emphasise the benefits to a cohort of participants receiving an art or music therapy intervention, distinguishing that from generic advice about any intervention provided by art or music therapists. | Support | AMTA cautions the NDIA against restricting access to an appropriate and effective support on the basis of one form of evidence. The Duckett Report outlines the challenges associated with balancing the various forms of evidence to determine if an intervention is appropriate to fund via the NDIS. AMTA strongly recommends AMTA is involved in the development of a decision support tool to enable appropriate access to music therapy for participants. AMTA asserts the critical nature of AMTA collaboration in determining the scope of the review by the EAC and in actively participating in its review. We note that while the EAC has been selected for its expertise in evidence analysis and translation into policy, the AMTA offers significant research and clinical expertise to inform the process. AMTA should be engaged to work with the NDIA and EAC on messaging as the evidence base for specific cohorts is determined. AMTA offers specific expertise to inform the translation of this evidence into decision support tools and training for NDIA staff about the value and benefits of music therapy. | AMTA collaboration with the Technical Advice and Practice Improvement Branch on a decision support tool for access to music therapy immediately. AMTA engagement with the EAC to determine the scope and key questions of the EAC review. AMTA collaboration on evidence base messaging with the NDIA. AMTA offers education and training to NDIA decision makers immediately and over the longer term. |
| 6. Strengthen oversight of plans to ensure that all therapeutic support approved - not only in art or music therapy - has a robust evidence base. | Support in principle, with genuine collaboration | Until the outcomes of the EAC review are finalised, the NDIA must support music therapy access for participants. AMTA is best placed to support the NDIA’s development of appropriate decision support tools to support NDIA | AMTA collaboration with the Technical Advice and Practice Improvement Branch on a decision |
Australian Music Therapy Association response to Independent Review of the place of Art and Music Therapy within Australia’s National Disability Insurance Scheme September 2025 4
| Recommendation | AMTA position | AMTA response | Action required |
|---|---|---|---|
| staff to make recommendations about the appropriateness of AMTA inclusion in NDIS plans. We welcome the opportunity to collaborate with the NDIA’s Technical Advice and Practice Improvement Branch to provide evidence tables/summaries, training, capability development, and support in music therapy knowledge and decision-making. AMTA notes the NDIA’s commitment to “reviewing and proactively engaging with professional associations on evidence for a range of therapies.” We welcome this commitment. | support tool for access to music therapy immediately. AMTA offers education and training to NDIA decision makers immediately and over the longer term. AMTA can also source specialist decision-making support for more complex decisions. We welcome the opportunity to work with the NDIA. | ||
| 7. Systematise its collection of data from providers about the effectiveness and outcomes of therapy interventions for participants, including development of consistent definitions of interventions aligned to a robust participant outcomes framework. | Support in principle, with genuine collaboration | AMTA supports a greater focus on outcome and impact evaluation in the scheme; however, this will require digital infrastructure investments for many providers. To obtain further information and evidence about music therapy interventions and outcomes, AMTA strongly recommends AMTA provide expertise to NDIA on more specific classifications of RMT music therapy interventions that could be included in reporting and associated with the use of an outcomes framework. This work could only be completed with the support of AMTA, our academics and clinical experts. AMTA cautions against tying funding or perceived provider value to participant-level outcomes due to the potential for access impacts for more complex participants. We note the proposal to provide PIP-like incentive payments to larger providers who are providing student placements and engaging in outcome measurement. AMTA notes the essential role of small and sole providers in providing student placements, supervision and continuing professional | AMTA strongly asserts the critical role of allied health in this work. NDIA should design this approach in collaboration with AHPA members during its early design stages. AMTA asserts our role as experts in the delivery of music therapy and offers our support to clarify music therapy interventions and determine appropriate measures for music therapy outcomes. |
Australian Music Therapy Association response to Independent Review of the place of Art and Music Therapy within Australia’s National Disability Insurance Scheme September 2025 5
| Recommendation | AMTA position | AMTA response | Action required |
|---|---|---|---|
| development in the more specialised, smaller allied health professions. Any approaches to incentive payments should be developed in consultation with the AHPA Disability Working Group, of which AMTA is a member. We welcome the opportunity to contribute to the in-development NDIS Outcomes Framework and suggest this work be taken to the AHPA Disability Working Group, of which AMTA is a member, for genuine engagement, advice and consultation on therapy outcomes. | |||
| 8. Ensure that data collected by the NDIA is collated and analysed to ensure that the therapeutic support provided actually achieves a result for the condition for this participant with this provider. | Support in principle | AMTA cautions against tying funding or perceived provider value to individual participant-level outcomes due to the potential for access impacts for more complex participants. Whilst some standardised outcomes will provide participants, providers and the NDIA with information about the value of therapies, the nature of some disabilities means personalised outcome measures will be necessary. For example, for some participants, establishing and maintaining safety is a primary goal (and impacts on achievement of basic needs and human rights). Safety and the attainment of rights and basic needs must be able to be reflected by the outcome measures selected. The NDIA must provide clearly defined data and reporting requirements for providers. These must be developed in collaboration with AHPA Disability Working Group and the relevant professional associations when relating to specific therapies. | We welcome the opportunity to work with the NDIA. |
| 9. Set rate maxima for art and music therapists on the basis that these are distinct professions, providing evidence-based therapy, not simply supervising art or music activities. | Support | AMTA welcomes the inclusion of music therapy as a therapeutic support, and is pleased to see RMTs appropriately recognised as the only professional group qualified, certified and regulated to provide music therapy. The Duckett Review mistakenly notes that RMTs are not nationally regulated. This is factually incorrect. AMTA is a full member of NASRHP. This regulation must be considered in relation to pricing. Music therapy is fully NASRHP regulated, alongside speech pathology and dietetics. | AMTA will work with NDIA to align the maximum payment limit with comparable, nationally regulated allied health professions immediately. |
Australian Music Therapy Association response to Independent Review of the place of Art and Music Therapy within Australia’s National Disability Insurance Scheme September 2025 6
| Recommendation | AMTA position | AMTA response | Action required |
|---|---|---|---|
| 10. Align the maximum payment limit for art and music therapy with the maximum payment limit for counsellors. | Reject | RMT qualifications |
If funding and pricing for therapy supports is being differentiated on the basis of professional group or qualifications, the NDIA must differentiate between music therapy and less qualified providers in the NDIS.
Music therapy is an allied health profession recognised by AHPA. AHPA defines an allied health professional as:
- a direct patient care role and may have application to broader public health outcomes
- a national professional organisation with a code of ethics/conduct and clearly defined membership requirements
- university health sciences courses (not medical, dental or nursing) at AQF Level 7 or higher, accredited by their relevant national accreditation body
- clearly articulated national entry-level competency standards and assessment procedures
- a defined core scope of practice
- robust and enforceable regulatory mechanisms
- practices within an evidence-based paradigm.
Music therapy’s pricing rate has been aligned with the maximum payment limit available to providers who are AQF-5 qualified and who would not be considered allied health professionals. Current RMT graduates have AQF7-9 qualifications, with all current programs graduating to AQF9 level.
RMT regulation
The Duckett Review mistakenly notes that RMTs are not nationally regulated. This is factually incorrect. RMTs are fully NASRHP-regulated, as are speech pathology and dietetics.
If funding and pricing for allied health is being differentiated on the basis of regulation, the NDIA must differentiate between the regulatory standards of music therapy and other providers in the scheme. AMTA notes in terms of | AMTA will work with NDIA to align the maximum payment limit with comparable, nationally regulated allied health professions immediately. |
Australian Music Therapy Association response to Independent Review of the place of Art and Music Therapy within Australia’s National Disability Insurance Scheme September 2025 7
| Recommendation | AMTA position | AMTA response | Action required |
|---|---|---|---|
| qualification levels and regulation, a more appropriate comparator for music therapy pricing limits would be speech pathology. |
Market data
AMTA also raises concerns about the sources of ‘market data’ about pricing noted in the Duckett report. This ‘market data’ is likely to have been significantly skewed by non-RMT providers charging against the music therapy line item. AMTA would welcome the opportunity to work with the NDIA to obtain more accurate information from RMTs.
Goods and Services Tax (GST)
GST has a significant impact on RMT pricing – music therapy is not GST exempt in the NDIS, except when delivering early intervention supports or supports in residential care services.
AMTA has been advocating to the Commonwealth to review the GST status of music therapy services since 2020. RMTs provide similar services and require equivalent qualifications to the Other Health Services listed under s38-10 of Division 38 of the GST Act and meet the other requirements within the Act.
Music therapy services are not included within GST-exempt health service within the Other Health Services listed under s38-10 of Division 38 of the GST Act due to an historical omission in 2010.
RMTs’ GST status impacts on costs and pricing in the NDIS, with the hourly music therapy price being GST-inclusive. As RMTs are not GST-exempt, if RMT maximum pricing does reduce to match counsellor rates of $156.16, RMTs will have a real maximum price of $141.96.
AMTA presents three options for amendment:
- Amend Other Health Services listed under s38-10 of Division 38 of the GST Act
- Issue a new Determination updating GST exemption within the NDIS (similar to A New Tax System (Goods and Services Tax) (GST‑free Supply—National Disability Insurance Scheme Supports) Determination 2021)
- Implement off-plan payment options for GST. | |
Australian Music Therapy Association response to Independent Review of the place of Art and Music Therapy within Australia’s National Disability Insurance Scheme September 2025 8
| Recommendation | AMTA position | AMTA response | Action required |
|---|---|---|---|
| Off-plan payment options were cited in Recommendation 15 of the NDIS Pricing Review 2021-22. |
Alternatively, the NDIA could apply an upward adjustment of the music therapy pricing limit to adjust for inclusion of the GST in music therapy pricing.
This pricing will result in thinning and/or failure of a valued, specialist and small market of professionals. A recent voluntary survey of members indicated that 35% RMTs are already considering leaving the NDIS. 33% RMTs are unsure if they will continue. This totals 68% RMTs with an uncertain future in the NDIS. | | | 11. Explore establishing differentials within the allied health professionals’ scales to recognise different capacity to provide services and/or to recognise levels of skills and experience. | Reject | Nationally-regulated allied health professions are recognised as being the same value across various national and state industrial awards.
AMTA expects as part of the NDIS ‘pricing deep dive’ over the next three years, that NDIA will work with AHPA and its members to define ‘capacity to provide services’ and ‘levels of skills and experience’. Regulated allied health professions enter the paid workforce as ‘entry-level’ practitioners recognised as being equivalent across other sectors. This process may have industrial impacts. | Ongoing | | 12. Expand its capacity to monitor market dynamics to assess supply of, and the demand for, art and music therapy and therapists. | Support | AMTA welcomes the NDIA’s commitment to monitoring the NDIS provider market. However, this monitoring will likely come too late to sustain a market under significant pressure.
AMTA has already raised with the NDIA that actions since November 2024 have resulted in drops in music therapy inclusion in participant plans.
We have raised with the NDIA that the reduction in music therapy approvals have resulted in job losses and clinic closures. AMTA is tracking data from RMTs demonstrating the impacts of various NDIA actions on participants and the market. We note that over 500 participants have already lost access to MT supports (delivered by RMTs) from their plan, with anticipated 800 further at risk (based on n=69 RMT respondents) from November 2024 – September 2025. We are able to share this deidentified data with the NDIA. | Ongoing |
Australian Music Therapy Association response to Independent Review of the place of Art and Music Therapy within Australia’s National Disability Insurance Scheme September 2025 9
| Recommendation | AMTA position | AMTA response | Action required |
|---|---|---|---|
| AMTA has also demonstrated the limitations of current pricing place on RMT businesses. |
AMTA is concerned that as confusion about music therapy accessibility in the NDIS continues, and pricing impacts providers, practices will become less available to participants, planners and coordinators (being aware of less available services) will not encourage music therapy in plans, participants will be less likely to select music therapy as a support, and we will have less evidence available to demonstrate the value of music therapy.
AMTA also highlights that ‘market data’ relating to pricing may have been significantly skewed by the non-RMT providers charging against the music therapy support code. | | | 13. In the medium term, set payment limits for art and music therapy that take account of their labour market monitoring and the need to ensure there is an adequate supply of art and music therapists for evidence-based provision of art and music therapy. | Support in principle | AMTA again highlights that ‘market data’ relating to pricing may have been significantly skewed by the non-RMT providers charging against the music therapy support code.
We have noted that pricing differentiation should take into account qualifications, regulatory standards and the impact of the GST.
AMTA welcomes the NDIA’s commitment to monitoring the NDIS provider market. However, this monitoring will likely come too late.
AMTA has already raised with the NDIA that actions since November 2024 have resulted in significant drops in music therapy inclusion in participant plans.
We have raised with the NDIA that the reduction in music therapy approvals has resulted in job losses and clinic closures. AMTA is tracking data from RMTs demonstrating the impacts of various NDIA actions on participants and the market. We note that between November 2024-September 2025, over 500 participants have had music therapy supports (delivered by RMTs) removed from their plan. Of those participants no longer receiving music therapy supports (delivered by RMTs), nearly 20% participants have lost access to music therapy due to business downsizing, due to uncertainty (market losses).
We are able to share more detailed, deidentified data with the NDIA. | Ongoing to meet the requirement for evidence-based provision of art and music therapy. |
Australian Music Therapy Association response to Independent Review of the place of Art and Music Therapy within Australia’s National Disability Insurance Scheme September 2025 10
| Recommendation | AMTA position | AMTA response | Action required |
|---|---|---|---|
| AMTA has also demonstrated the limitations of current pricing place on RMT businesses. |
AMTA is concerned that as confusion about music therapy accessibility in the NDIS continues, and as pricing impacts providers, practices will become less available to participants. If fewer services are available, there is a risk that planners and coordinators will not encourage music therapy in plans, and that participants will be less likely to select or access music therapy as a support.
If this occurs, AMTA notes there will be fewer opportunities to provide practice-based evidence to demonstrate the value of music therapy. AMTA welcomes the opportunity to collaborate with the NDIA on RMT supply and market sustainability.
The current pricing limit is inappropriate on the basis of qualifications, regulation, RMTs’ position as allied health professionals, the impact of the GST and the costs associated with providing high-quality supports in the NDIS. | | | 14. Consider alternative methods for funding early intervention services which are consistent with best practice guidelines and any future agreed early childhood intervention best practice frameworks, which encourage holistic evidence-based and outcomes-provision consistent with the early childhood approach. | Support in principle | AMTA welcomes a greater focus on early intervention and team approaches to supports for children. AMTA notes that ‘duplication of supports’ continues to be used by the NDIA to deny or limit access to appropriate and effective supports for participants, where the evidence clearly describes the benefits of multidisciplinary team approaches in early intervention. We would welcome the opportunity to engage in the design of Thriving Kids.
AMTA notes the challenges associated with caseload ‘absorption’ by existing early intervention services currently delivered by state-based public-funded providers (e.g. via health and hospital networks and districts, and community health providers). These providers have significant, existing waitlists that will not allow accessible or timely services for children with developmental concerns or disabilities.
AMTA also raises concerns about workforce capability and specialisation. Many allied health professionals (including RMTs) have developed significant and specialist expertise in disability, which is often not represented in the state-funded health workforce. This capability gap has the potential to impact | From 2025 |
Australian Music Therapy Association response to Independent Review of the place of Art and Music Therapy within Australia’s National Disability Insurance Scheme September 2025 11
| Recommendation | AMTA position | AMTA response | Action required |
|---|---|---|---|
| significantly the quality of supports and services for children requiring early childhood support. | |||
| 15. Consider a different payment and funding approach, particularly for large organisational providers. | Question | AMTA agrees with the NDIA’s proposal to collaborate with allied health professional peak bodies to identify options for funding within the Pricing Workplan, that would support access and value for participants, and be sustainable for the NDIS. We recommend the NDIA approach the AHPA Disability Working Group for collaboration. |
AMTA notes that the Duckett report raised the question of different payments for ‘larger providers’ which he describes as those providers receiving more than $100,000 of total NDIS revenue in 2023-24. For AMTA-certified RMTs, these payments could be received by a sole practitioner /sole trader.
Duckett’s definition of ‘larger organisational providers’ is inconsistent with the Australian Bureau of Statistics definition of ‘small business’ or the Australian Commission on Safety and Quality in Health Care’s definition of a small medical practice.
The definition of ‘large organisational providers’, will have significant impacts on the music therapy workforce and ‘market’ particularly if tied to recognition of the role of smaller and sole providers, or tied to pricing incentives for ‘larger providers’.
RMTs in sole practices provide student placements, continuing professional development and supervision, as do larger practices. With up to 40% RMTs in the NDIS operating as sole traders, disincentivising these professional contributions will have impacts on the RMT workforce pipeline and supply. Due to the distribution of sole practices, these impacts will have disproportionately negative impacts on rural and regional areas. | Ongoing | | 16. Specify in its Pricing Arrangements and Price Limits, that art and music therapy cannot be claimed under ‘other professional’ | Question | AMTA supports RMTs claiming against the music therapy code. | AMTA will immediately work with NDIA to resolve |
Australian Music Therapy Association response to Independent Review of the place of Art and Music Therapy within Australia’s National Disability Insurance Scheme September 2025 12
| Recommendation | AMTA position | AMTA response | Action required |
|---|---|---|---|
| However, AMTA has serious concerns about who is claiming under ‘Other Professional’ and how these providers have been determined to be ‘higher value’ than qualified and regulated allied health professionals, such as RMTs. |
AMTA expects that those fraudulent providers claiming music therapy could now claim against ‘other professional’ and claim a higher rate than qualified and regulated RMTs.
AMTA is concerned that the PAPL is being rushed for release in September 2025 when changes are not expected to be implemented until November 2025. Our experience is that communications from NDIA often cause confusion among planners, support coordinators and plan managers, and will result in RMTs being paid incorrectly in the coming months. This is an existing issue that RMTs have experienced since the November 2024 announcement, with implications for RMT administration costs and sustainability.
AMTA is also concerned about the lack of clarity regarding how Stated Supports work within the new PACE system. Since the introduction of PACE, there has been confusion regarding whether Stated Supports are at the category or item line level. A clearer directive on this is needed from the agency to ensure that participants can exercise their choice and control when utilising Capacity Building funding.
AMTA strongly recommends release of the PAPL is delayed until November 2025. | concerns about pricing and timelines for implementation. | | 17. Ensure that funding for art and music therapy as a Therapeutic Support for self-managed participants be limited to supports provided by appropriately trained art and music therapists as defined by NDIA who meet the requirements of NDIS Quality and Safety Commission registration. In other circumstances, art or music activities should be classified as Participation in Community, Social and Civic Activities and funded accordingly. | Support in principle | AMTA supports the recommendation that only music therapy interventions, delivered by RMTs, can be claimed using the Music Therapy line item.
We seek clarification on “who meet the requirements of NDIS Quality and Safety Commission registration”. AMTA has previously voiced concerns regarding the prohibitive cost associated with becoming a registered NDIS provider, and joins AHPA in advocating for a mutual recognition model, recognising professional body certification and a tiered system proportionate to risk. We agree with Dr Duckett’s recommendation that participants should be able to access quality community-based music activities that can support their wellbeing more broadly. We acknowledge that few mainstream community- | 2025-26 |
Australian Music Therapy Association response to Independent Review of the place of Art and Music Therapy within Australia’s National Disability Insurance Scheme September 2025 13
| Recommendation | AMTA position | AMTA response | Action required |
|---|---|---|---|
| based activities are accessible for participants with complex needs, and therefore recommend that in some cases, participants should be able to access these using NDIS Community Participation funding. | |||
| 18. Enhance invoice verification process to ensure that only eligible providers are reimbursed under the art or music therapy item numbers. | Support | AMTA has had a process in place with the Fraud Fusion Taskforce since October 2024, to support the NDIA to minimise fraud on the music therapy item numbers. RMTs already have a unique ID provided by AMTA to reinforce their status as a registered music therapist certified by the AMTA. AMTA cautions the NDIA against introducing additional duplicative registration requirements for providers, which only add to the administrative burdens within the scheme. | AMTA and NDIA to confirm invoicing processes by RMTs |
| Recommendation for NDIS Quality and Safeguards Commission | |||
| 19. Consider introducing an ongoing mechanism to review the verification requirements for recognition as an art or music therapist (paragraph 67). | Support | AMTA has worked with the NDIA Fraud Fusion Taskforce to clarify RMT certification requirements. We would welcome the opportunity to work with the Commission to clarify verification approaches to ensure only appropriately qualified, certified and regulated music therapists are providers in the scheme. |
AMTA supports AHPA in advocating for a mutual recognition model, recognising professional body certification as sufficient verification within the scheme. | AMTA to collaborate with the Commission on appropriate verification approaches that provider quality safeguards for participants, and are not duplicative or result in high administrative costs for providers. |
Australian Music Therapy Association response to Independent Review of the place of Art and Music Therapy within Australia’s National Disability Insurance Scheme September 2025 14