NDIS Annual Pricing Review 2027-2028
October 2026
ECIA VIC/TAS acknowledges the traditional custodians of the lands and pays respect to elders past and present. We pay respects to Aboriginal and Torres Strait Islander children, their families, and we commit to creating a future where every child is valued, safe and an empowered member of their community.
About us
ECIA VIC/TAS welcomes the opportunity to contribute to the NDIS Annual Pricing Review.
Early Childhood Intervention Australia Victoria/Tasmana (ECIA VIC/TAS) champions best-practice early childhood intervention (ECI) for children from birth to nine years and their families, in line with the National Best Practice Framework for Early Childhood Intervention.
As a membership-based organisation with 500 members across Australia, we hear directly from professionals and services supporting children and families. Our membership includes large not-for-profit registered providers, small and medium multidisciplinary and transdisciplinary teams, and sole practitioners. Members work across a range of settings and frequently support families experiencing intersecting vulnerabilities, including risk of homelessness, food insecurity, involvement with child protection, and cost of living pressures.
This submission draws on member feedback about the impact of current NDIS Pricing Schedule. Their experiences demonstrate how pricing decisions affect not only provider viability, but also the availability, consistency and quality of supports children and families receive.
We urge the NDIA to ensure pricing arrangements enable best-practice Early Childhood Intervention, recognise the full cost of delivering services, provide financial sustainability for providers, and sustain a skilled workforce able to respond to children’s needs in everyday settings.
Priority Actions
We are calling on the NDIA to address these priority actions to ensure sustainable funding for providers to continue to deliver best practice ECI.
- Recognise Early Childhood as a unique life stage and structure funding to support children and family goals
- Fund the full cost of service delivery to retain providers and strengthen the workforce
- Ensure access pathways operate in a timely manner
- Ensure equity for children no matter where they live
- Professional evidence and clinical judgement must be valued and considered alongside family experience
- Ensure funding enables delivery of best practice as described in the National Best Practice Framework in Early Childhood Intervention
- Differentiated pricing that responds to different service delivery models
- Funding levels that respond to Fair Work Commission’s gender-based undervaluation review
- Reduce unfunded administration burden for families and providers
Early Childhood Intervention: outcomes that last
Children thrive when they can participate in learning and everyday life, access equitable opportunities, and develop within families who feel informed, confident and supported. Quality Early Childhood Intervention (ECI) contributes to these outcomes by working with the child, family and the people around them, building skills and confidence across home, early learning, school and community settings.
As a system steward the NDIS has a critical role in enabling children with developmental delay or disability and their families to access ECI services tailored to their circumstances.
Action is needed now. The 2024 Australian Early Development Census reinforces the urgency: 23.5% of children starting school were developmentally vulnerable on at least one domain, up from 22% in 2021, while 12.5% were vulnerable on two or more domains, up from 11.4%.
The evidence base continues to highlight the importance of acting early. The Front Project’s ‘The Cost of Late Intervention, and the Australian Early Development Census (AEDC) findings point to the human and economic consequences when children do not receive the right support at the right time. Pricing arrangements should reinforce, not undermine, the principles of early, family-centred and developmentally informed intervention.
ECIA VIC/TAS views current pricing and funding-period settings risk children and families not receiving the supports they need. As market steward, the NDIA can help correct this by funding the work that quality ECI actually requires.
Early Childhood as a unique life stage
What is needed
- The access decision-making process should recognise early childhood as a unique developmental life stage.
- It should account for the dynamic nature of children’s development, the influence of family and environmental contexts, and the importance of timely intervention.
- Decision-making should consider children’s functioning and participation across everyday environments and recognise the expertise of families and professionals who know the child well.
- Funding must include support for families not just the child
- Funding must recognise the compounding impacts on child and family functioning when there are intersecting vulnerabilities
Why change is needed
The existing NDIS principles are relevant to all people with disability, but they do not sufficiently articulate what is different about early childhood. The NDIS currently recognises early childhood as a distinct approach for children younger than nine years and their families. The National Best Practice Framework for Early Childhood Intervention provides an important foundation for understanding this context. Any future access and funding process should consider the child, family and environment, rather than treating functional capacity as an isolated characteristic of the individual child.
Fund the true cost of services
What is needed
- Review and increase rates for services delivered to children under the Early Childhood Approach so they reflect the real cost of providing quality support.
- Bring physiotherapy, music therapy and art therapy rates into appropriate alignment with occupational therapy and speech pathology rates
- Restore travel funding to 100% of eligible travel time for practitioners delivering supports in children’s natural environments.
- Funding periods for children 0-8years to be set at 6 months or 12 months to provide responsive services delivery and remove avoidable administration delays that interrupt service continuity.
- Support families to understand the benefits of funding the collaborative work that is essential to best practice
Why change is needed
Quality ECI is not simply a sequence of therapy appointments. It includes family coaching, preparation and follow-up, communication with educators and other practitioners, team planning, and adapting strategies to be used in a child’s everyday environments. These activities are central to effective intervention but are not adequately recognised by a transactional, hour-based pricing model.
The Independent Pricing Committee’s review highlighted the poor fit between current pricing structures and the full scope of ECI practice and identified differentiated pricing as one way to better support early intervention, family-centred approaches and long-term outcomes. The NDIS Review similarly emphasised evidence-based, developmentally informed and family-centred supports rather than a narrow focus on individual sessions.
ECI cannot be funded as though it were equivalent to episodic, centre-based health care. Disability support often requires longer appointments and sustained work with families and the child’s broader team. These differences are fundamental to the model and should be reflected in pricing.
Members continue to report rising salary and operating costs alongside rates that have not kept pace. Many providers are:
- closing or moving out of NDIS service delivery
- drawing down on reserves
- cross-subsidising NDIS services
- seeking philanthropic support to remain viable.
Others are reducing outreach or limiting the geographical areas they serve. These are more than business pressures; they reduce families’ real access to support, particularly in regional and rural areas and for families unable to travel to receive services.
A typical home- or community-based ECI appointment may last between 45 minutes and 90 minutes, with additional time needed for notes, follow-up, coordination and communication. Complexity such as child protection involvement, interpreter coordination or collaboration with multiple services adds to the work required. This work is largely unfunded, but mandated and the costs absorbed by practitioners.
Funding periods and the recent legislation changes with 10% reduction to Improve Daily Living budgets, add further complexity for families and providers. Families may struggle to track spending across several providers, while practitioners spend time checking balances, renegotiating service agreements and managing uncertainty about whether supports can continue. This can lead to interruptions at precisely the time children need consistency.
The NDIA should fund ECI according to the work required to achieve outcomes, rather than relying on a model that rewards face-to-face hours while leaving essential activities unfunded.
Unfunded admin
Generating Service agreements, mapping funding period spending, clinical supervision, unfunded travel, upskilling families on how NDIS works, support to manage budgets and avoid overspending, following up bad debts, follow-up with plan managers, management of cancellations and scheduling
Coordination with others
Child protection mandatory reporting, coordinating with education teams and care teams, coordinating interpreters
Access and funding
Case study from a member
‘Funding changes contribute to a significant reduction in parent coaching and working through with parents acceptance of where their child is at. Please understand that Early Intervention plays a significant role to support parents to understand what is happening, accept their joy and to establish attachment again without feeling guilt, sadness or the pressure for the child to meet milestones. Supporting parents to work towards a healthier mindsets, and an understanding of child development also leads to healthy expectations instead of demanding more funding all the time.’
What is needed:
- Access and funding decisions that consider the family context
- Children with significant and lifelong disability should not have to repeatedly prove eligibility
- Funding must respond to developmental changes
- Professional evidence and clinical judgement must be valued
Why change is needed:
Children with significant and lifelong disability should not have to repeatedly prove their eligibility.
Children with clear, significant and lifelong disability should not be required to repeatedly demonstrate their eligibility. Where appropriate evidence has already established that a child has a permanent impairment and substantial functional impact, access should ongoing. Requiring families to repeatedly produce evidence places an unnecessary burden on families and clinicians and diverts funding away from supporting children. A proportionate access process should distinguish between situations where eligibility is clear and those where further information is genuinely required.
Access and funding decisions must consider the family context. For young children, disability cannot be considered in isolation from the family and environment in which the child lives. The NDIS Person-Centred Principle, does not adequately represent a child in the context of family. Family circumstances should be considered in access decision-making, particularly where there are risks to child or family safety, family breakdown or the sustainability of informal supports. Additionally, the identification of need and subsequent building of budgets must recongise the family unit needs not just the child’s needs.
This includes situations where:
- families are supporting multiple children with disability or developmental needs;
- a parent or carer also has disability-related support needs;
- families have limited informal support networks;
- caring responsibilities are placing significant pressure on family functioning; or
- the child’s support needs are contributing to risks to the safety or wellbeing of the child or family.
Funding must respond to developmental change. Early childhood is characterised by rapid development. A child’s functioning and support needs will change considerably as they develop, participate in new environments and transition between settings.
Plan structures and budgets need sufficient flexibility to respond to significant developmental and life transitions, including transitions into or between early childhood education, school and other environments.
Early intervention must not become “wait and see”. ECIA VIC/TAS is particularly concerned about approaches that require children and families to wait until functional difficulties become sufficiently significant before support is provided. The NDIS must avoid a “wait and see” or “wait and fail” approach. For children with significant disability there is often a clear trajectory towards significant and lifelong disability. Early access to appropriate intervention should be enabled rather than delayed while families wait for further functional deterioration or for a child to fail to meet developmental expectations.
Early childhood professionals have specialist expertise in recognising developmental trajectories and when they are unlikely to be met. Their professional judgement and evidence should be considered alongside formal assessment results and family reporting. There must be a clear pathway for children with significant disability to access the NDIS without being required to cycle through lower-intensity systems before they can demonstrate a level of impairment that was foreseeable.
Professional evidence and clinical judgement must be valued. The professionals who work with children and families over time have an important role in describing functional capacity and support needs.
This may include:
- paediatricians and other medical specialists
- allied health professionals
- early childhood intervention practitioners
- early childhood educators
- specialist teachers
- early childhood partners
These professionals can provide information about the child’s functioning over time and across settings, including information that may not be evident during a single assessment.
ECIA VIC/TAS recommends that the NDIA clearly articulate what assessment and screening evidence will be accepted and how professional evidence will be weighted. This would enable families and practitioners to gather appropriate evidence without unnecessary duplication and efficient use of NDIS funding.
Case Studies from members, ‘Clinic sessions do not show or reflect child’s behaviour and responses at home, more time is spent to discuss about their behaviours. When sessions are conducted in natural environments, we can observer and quickly identify areas of concerns or suggestions to parents on the spot so they can built it into their routine immediately.’
‘Families are not even aware of tracking their funding periods. They often go without services for weeks, and each re-start is actually causing more problems and more time consuming for therapy to progress.’
Quality is a baseline, not a premium service
What is needed
- Pricing that recognises the qualifications, years of relevant experience and responsibilities of the workforce delivering support, including senior clinical, specialist, supervisory and mentoring roles
- Ensure every child and family can expect services to meet the National Best Practice Framework for Early Childhood Intervention, regardless of provider price or funding level
- Fund the essential activities that enable safe, effective practice, including collaboration, family coaching, supervision, professional development and delivery in natural settings.
- Keep quality assurance and provider oversight transparent and proportionate, without creating a market in which families are led to believe that better quality is only available at a higher price
- Additional funding for providers who choose to register with the Quality and Safeguarding Commission to cover the additional associated costs
Why change is needed
ECIA VIC/TAS is concerned that the term ‘quality’ could be interpreted in a pricing framework as meaning families must pay more to receive a higher-quality service. That is not the intention. Quality ECI should be the expected standard across the sector, not a premium option available only to a cohort of families.
The NDIA needs to fund a model that ensures best practice is everyday practice.
Pricing should instead recognise the real cost of employing and retaining practitioners with different qualifications, years of experience and levels of responsibility. Experienced clinicians bring accumulated knowledge, professional judgement and the ability to support complex needs, supervise colleagues and strengthen practice across teams. These contributions need to be reflected in sustainable pricing. The current pricing structure does not reflect the hours needed to support team development, particularly the capability building of early career professionals. To attract early career professionals to the ECI sector, they are asking to be supported as they learn.
The National Best Practice Framework for Early Childhood Intervention sets out the practice principles that should guide ECI. Providers need adequate funding to apply those principles consistently.
Members report that current pricing does not enable the delivery of the principles and can leave insufficient time and resources for essential activities. When supervision, collaboration, professional learning and outreach are not properly funded, providers are forced to reduce commitments or absorb unsustainable costs.
Differentiated pricing
Case study from a member
‘Families are expecting more sessions, weekly. When fortnightly is mostly sufficient when parents are on board with coaching and practicing some of the things in-between sessions. Since it is weekly sessions, parents are expecting therapist to do it all. I am doing lots more pre-screening phone calls to ensure parents understands expectations. However, most have been told they can have weekly clinic sessions, so they are expecting that. A fortnightly hourly session plus travel is actually more cost efficient and sets the correct expectations for parents to understand that they need to be more hands on and build their capacity.’
What is needed
- Introduce differentiated pricing that recognises the additional costs incurred by registered providers, including governance, safeguarding, auditing and compliance.
- Provide appropriate loadings for Key Worker services delivered in natural settings.
- Recognise the additional work involved in best-practice Key Worker models, including team-around-the-child approaches, family capacity building and collaboration across settings.
- Introduce a registration bonus for registered providers to help offset the costs of registration, quality systems, governance and ongoing compliance
- Co-design pricing changes with providers and peak bodies and test their impact on access, quality and provider sustainability.
Why change is needed
Not all NDIS services have the same delivery costs or undertake the same work. Providers delivering comprehensive ECI, particularly in home, early learning and community settings, carry responsibilities that are not adequately captured by a uniform hourly rate.
Key Workers help connect the people and settings around a child, support families to use strategies in everyday routines, and promote consistent goals across home and education environments. This coordination is often the ‘glue’ that makes intervention coherent and reduces the burden on families. It is a core part of quality practice, not an optional extra.
Without differentiated pricing, providers that invest in collaboration, family coaching, outreach and quality systems are disadvantaged. As the Independent Pricing Committee noted, a single pricing approach can overcompensate providers undertaking less comprehensive work while undercompensating those delivering the broader activities required for ECI.
The impact is already visible in member feedback: fewer home and community visits, greater reliance on clinic-based or virtual appointments, reduced service reach and more cautious caseload planning.
A registration bonus would be a practical incentive for providers to enter or remain in the registered market and help meet the upfront costs of establishing and maintaining the required systems. It should complement, rather than replace, sustainable ongoing pricing and proportionate quality oversight.
Differentiated pricing is an opportunity to protect the range of providers and service models’ children need.
Workforce
Case study from a member
‘As funding has been cut for some of the past participants, the valuable service I provided, I can no longer. 1 hour cap on Provider Travel for practitioners, has depleted my earning power as it has also impacted on how far I travel or how long it will take, when stuck in traffic. With all the cuts, restrictions and uncertainty with NDIS, parents are not willing to engage openly with therapists. There is definitely a greater feeling of dissatisfaction, morale is low.’
What is needed
- Provide targeted payments to support recruitment, induction and development of graduates and early-career practitioners.
- Fund the real cost of clinical supervision, mentoring and professional development outside standard hourly service rates.
- Recognise and support organisations that provide student placements and develop the future workforce.
- Introduce appropriate rural and remote loadings that account for travel, cancellations and the practical challenges of delivering services across geographical large areas.
- Fully fund travel for allied health assistants and invest in their training and development to improve access in underserved communities.
Why change is needed
Children and families need a skilled, stable and responsive workforce. However, members report that current pricing makes it increasingly difficult to recruit, retain and develop practitioners.
The Fair Work Commission’s gender-based undervaluation review has recognised that work in female-dominated areas—including allied health professionals and support services, social and community services, and children’s services—has historically been undervalued, and that changes to award rates are justified on work-value grounds. Separately, the Commission’s 2026 Annual Wage Review increased the modern award minimum wages by 4.75% from 1 July 2026. Neither of these changes are reflected in the current NDIS pricing.
These decisions reflect the need to value the workforce now and into the future. The NDIA must raise pricing rates across the board to keep pace with the actual cost of employing and retaining a skilled workforce. Without a workforce, children languish on waitlists.
NDIS rates no longer reflect the time leaders dedicate to supervision and mentoring of all staff, to ensure compliance with each discipline’s registration body. This creates a risk of reduced quantity and quality in clinical practice and contributes to staff turnover, as clinicians move between roles seeking better support and professional development opportunities.
Supervision, mentoring and student placements take time and expertise. When this work is not funded, organisations are left to absorb the cost or stop taking students. Members report scaling back and ceasing student placements and graduate recruitment.
Practitioners also describe growing administrative demands, pressure to meet utilisation targets, and reduced time for clinical reflection and collaboration. These pressures contribute to burnout, lower job
satisfaction and turnover. Leaders face a difficult balance between maintaining financial viability and providing supervision and support needed for safe, effective practice.
Travel funding changes have particular consequences outside metropolitan areas. One regional provider reported redesigning its allied health assistant model because travelling to support families in the community was no longer financially viable. Children who had previously received support locally, now have to travel long distances to a clinic, sometimes missing a day of education.
Reinstating the ability to charge for all travel time, particularly for rural and remote areas for allied health assistants is one strategy to address the therapy desserts that exist in regional areas. Regional providers already use practical approaches including clustering families in geographical locations to make the best use of travel time and cost, and combinations of virtual and in person supports. Under the current Pricing Schedule they are no longer possible, the financial burden is too great.
Current and emerging risks
Case studies from a members.
‘My earning has reduced by a third due to travel being cut by 50%.’
‘There are still lots of areas that continue to lack therapist servicing their area. The only way for these families to access service is to travel to services and again the cycle of not having a productive session and hence taking longer time to brainstorm or discuss about issues that arises in-between sessions.’
‘If the NDIS recognised Transdisciplinary Key Worker Model in Early Childhood Intervention they could have saved up to 75% in some cases. The NDIS funding model in ECIS has lead to a siloing of services and an unnecessarily busy and exhausting schedule for families.’
What is needed
- Implement differentiated pricing that reflects the cost of quality ECI.
- Ensure rates across relevant disciplines are equitable and sustainable.
- Restore full funding for travel so services can be delivered in natural settings, including regional and remote communities.
- Fund workforce development, supervision, mentoring and student placements.
- Align pricing and delivery expectations with best practice in ECI
- Reduce avoidable administrative complexity and improve families’ ability to understand and manage funding.
Why change is needed
The central risk is that providers will continue to withdraw from NDIS-funded service delivery, reduce outreach or close services altogether. If providers cannot cover the cost of delivering quality support, children and families may face longer waits, reduced choice, disrupted relationships or no service at all.
Delayed or inconsistent intervention can affect children’s development, participation and transitions through early learning and school. It can also increase family stress and shift costs to other systems over time, including health, mental health, education and justice. By contrast, timely, high-quality ECI can support children to participate in their communities, strengthen family confidence, and contribute to a skilled and sustainable workforce.
The phrase ‘early intervention delayed is early intervention denied’ captures the stakes. Pricing decisions made now will shape which providers remain in the market, where services are available and whether families can access support in the settings where it is most useful.
ECIA VIC/TAS urges the NDIA to use the Annual Pricing Review to move beyond a transactional model and establish pricing that supports the full range of activities required for quality EC]. We welcome continued engagement with the NDIA and other stakeholders to help develop and test practical reforms.
References:
- The Cost of Late Intervention
- 2024 AEDC National Report
- Independent Pricing Committee | NDIS
- Working together to deliver the NDIS | NDIS Review
- National Best Practice Framework for Early Childhood Intervention | Australian Government Department of Health, Disability and Ageing
- Independent Pricing Committee | NDIS
- Working together to deliver the NDIS | NDIS Review