NDIS Safety and Quality Commission Practice Standards Review
November 2025
Introduction
Occupational Therapy Australia (OTA), as the peak body representing the occupational therapy profession nationally, welcomes the opportunity to provide feedback on the review of the NDIS Safety and Quality Commission’s Practice Standards. OTA participated in the recent Peak and Professional Bodies consultations hosted by KPMG in October and we appreciate the opportunity to contribute to the review via this submission.
Occupational Therapy Australia
OTA is the professional association and peak representative body for occupational therapists in Australia. There are more than 30,000 registered occupational therapists (OTs) working across the government, non-government, private and community sectors in Australia.¹ Occupational therapists are allied health professionals whose role is to enable their clients to engage in meaningful and productive activities.
Occupational therapy is a person-centred health profession concerned with promoting health and wellbeing through participation in occupation (activities). Occupational therapists achieve this by working with people with disability, including children with developmental delays and/or disability, to enhance their ability to engage in the occupations they want, need, or are expected to do; or by modifying the occupation or the environment to better support their occupational engagement. Occupational therapists provide services across both clinical and non-clinical settings across the lifespan and have a valuable role in supporting children with developmental disorders including physical, intellectual, chronic and/or progressive disability.
Occupational therapists have a critical role in providing services within the National Disability Insurance Scheme (NDIS), supporting people living with physical, intellectual, psychosocial and other disabilities. Occupational therapists work in a diverse range of settings within the NDIS as sole traders, small, medium and large private practices, as both registered and unregistered providers.
Occupational therapists help to unlock the value of the NDIS by working with scheme participants to identify goals and engage them with appropriate supports and services that promote independence, social connection, economic participation and protect and sustain physical and mental health. They deliver services including:
- functional capacity assessment;
- prescription and implementation of assistive technology and/or environmental modifications;
- positive behaviour support;
- driving assessments (when specifically trained to do so); and
- targeted, goal-focussed capacity building, for example, activities of daily living (ADL), or ADL training with participants with physical and/or psychosocial disability.
¹ Occupational Therapy Board of Australia (Australian Health Practitioner Regulation Agency), 2024; https://www.occupationaltherapyboard.gov.au/News/Annual-report.aspx
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Occupational therapists are highly skilled in assessing the degree to which a person’s disability affects their level of function in daily tasks. Based on these assessments, occupational therapists make recommendations for, and then deliver, interventions that enhance and maintain an individual’s functional capacity, and prescribe supports, aides and assistive technology that help everyday Australians live as engaged, valued and contributing members of society.
Occupational Therapists are registered health professionals who are subject to a range of stringent conditions and standards that are set by national law and regulated by the Australian Health Practitioner Regulation Agency (AHPRA) which provides a high degree of trust and protection for Australian consumers.
Recommendations
Recommendation 1: That the revised regulatory framework formally recognises AHPRA registration as meeting NDIS provider governance requirements for occupational therapists, as part of a risk-proportionate approach to registration and regulation.
Recommendation 2: That any changes to regulatory settings are subjected to a regulatory impact assessment to ensure that the costs of compliance are properly identified and that stakeholders have the opportunity to assess and comment on, prior to implementation.
Recommendation 3: That the Commission commit to ongoing engagement and consultation with Occupational Therapy Australia and Allied Health Professions Australia (AHPA) throughout the implementation of the revised Practice Standards, ensuring reforms are workable, proportionate, and aligned with existing professional regulation.
Recommendation 4: That the Commission provide dedicated funding to AHPA to co-design and maintain allied health specific guidance materials to support providers in meeting the revised Practice Standards.
Key Issues
Lack of clarity on future registration model
OTA is concerned that this review is being conducted in the absence of additional clarity from government on the future policy and regulatory settings that will apply to NDIS provider registration. The recommendation for a mandatory registration system for NDIS providers by the NDIS Independent Review could see a significant shift for the majority of OTs who currently operate unregistered under the NDIS.
An ideal state would be for government to confirm its future state for NDIS Registration to enable us to understand and assess the extent of the impact of any mandatory registration requirements, prior to commenting on the details of a future NDIS Practice Standards.
Proportionate regulation
OTA supports the intent of the Practice Standards to promote high-quality, safe, and rights-based support for NDIS participants. However, we are concerned that the current approach set out in the discussion paper will not adequately reflect the risk profile of occupational therapy practice and may contribute to additional regulatory burden without any additional quality or safety benefits.
The regulatory framework should recognise and leverage existing professional regulation and quality systems wherever possible. OTA supports the findings and recommendations of the NDIS Worker and Provider Registration Taskforce which noted in its final advice to Government on mandatory registration that “the registration of allied health professionals by AHPRA be recognised as registration for the purposes of NDIS where this can be achieved.”
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Occupational therapists already meet stringent professional requirements through AHPRA registration and continuous professional development. Any new NDIS-specific requirements must therefore be proportionate, non-duplicative, and fit for purpose, particularly for sole practitioners and small providers.
The current registration process presents a substantial regulatory and financial burden for many OTs, often acting as a deterrent to registration. The NDIS Registration Taskforce identified similar concerns, noting that current processes can be overly complex and costly without necessarily improving service quality or participant outcomes. Any changes to the Practice Standards must avoid adding unnecessary administrative burden that could further limit service availability, particularly in thin markets and rural areas already facing workforce shortages, and in the current environment where OTs report significant issues with financial sustainability due to the continuing freeze on therapy support pricing for OTs, and the halving of therapy support travel rates.
The provision of occupational therapy services are low-risk NDIS services, due to the nature of the limited services they provide under NDIS, the minimum qualifications and competencies that are required through mandatory professional registration through the AHPRA scheme which provide strong protection regarding patient or client safety, and the low rate of regulatory actions taken by AHPRA as part of its ongoing regulatory oversight of all occupational therapists practising in Australia.
Occupational therapists are required by law to only provide occupational therapy services in Australia if they are registered by AHPRA under the National Registration and Accreditation Scheme (NRAS). Through the AHPRA scheme, occupational therapists can only obtain registration if they meet a range of standards including minimum academic qualifications, language proficiency, criminal history check, compliance with the AHPRA Code of Practice, specific professional standards, continuing professional development, recency of practice and insurance requirements.
Occupational therapists are required to self-attest against AHPRA standards every year when they seek renewal of their registration, and are subject to mandatory notification requirements, random auditing and a safety complaints scheme which is administered by AHPRA.
OTA is of the view that the AHPRA scheme provides a strong foundation that supports the provision of safe and quality allied health services in Australia. AHPRA registration is the minimum requirement to enable occupational therapists to deliver services is a range of settings including under Medicare, the Department of Veterans’ Affairs Scheme, a range of state and territory compensation schemes, and in private practice.
We note that occupational therapists are subjected to an extremely low number of complaints and regulatory actions by AHPRA. In 2023-24, the Occupational Therapy Board of Australia (the board) reported that there were 176 notifications (complaints) about 148 occupational therapists made Australia-wide, including those received by AHPRA, the Health Professional Councils Authority (the administrative body that supports the health professional councils in NSW) and the Office of the Health Ombudsman (the Queensland health service complaints agency) (AHPRA 2024).
Cumulatively this complaint rate represents 0.5% of the occupational therapy profession Australia-wide. This is very low when compared to the proportional complaint rates for other regulated professions, for example, Medical Practitioners (5.9%), Dental Practitioners (3.8%), Psychologists (2.2%), Pharmacists (1.7%) and Podiatrists (1.3%).
It is important to consider that this AHPRA complaint rate reflects all sectors within which OTs operate within Australia, not just NDIS. To provide insight into the rate of complaints specific to the NDIS, while public data is not available, we note that in a submission to the NDIS Independent Review in 2023, the Occupational Therapy Board noted that from
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January 2019 to mid 2023, the Board received 48 complaints that involved the NDIS as an element of the notification.³ This is a rate of around 11 matters per year, and represents 0.04% of total registered occupational therapists (in 2023 when the report was provided).
Based on this data, OTA considers that occupational therapists present a low risk in the context of NDIS service delivery, and recommends that practitioners and providers who supply only occupational therapy services are able to attest to their AHPRA registration as the only registration requirement.
OTA acknowledges that there are a range of supports and settings, and workforces which require more stringent regulation due to the higher risk they present to participant safety. Where a provider is providing a range of NDIS services, including higher risk services, it is appropriate that their registration and regulation level reflects the highest risk of service they provide.
Pricing and market pressures
Given that many allied health providers work as sole traders and service limited numbers of NDIS participants, the regulatory framework must apply a proportionate approach to ensure that this Framework, particularly in the event of universal mandatory registration, does not limit access to allied health services for participants, especially given the current pressures that NDIS providers are facing, on top of already thin markets.
Currently a significant proportion of OTs are not registered with the NDIS Commission, with many reporting that the current regulatory approach does not cater to smaller providers and is too complex and costly to meet. We are concerned that a future registration model, and quality framework that presents disproportionate regulatory burden will lead to significant withdrawal from NDIS services as unregistered providers are unable to meet the costs and complexity of new requirements.
The therapy market is dominated by small scale providers, with just under half of all therapy providers supporting one or two participants, and 65% of all therapy providers supporting five or fewer participants (however we note that larger providers supply a higher volume of services/payments).
Following the 2025 NDIA Annual Pricing Decision, OTA undertook an NDIS Provider Survey which attracted strong engagement from 600 occupational therapists across Australia. This data gives us valuable insights into how the OT sector is faring and the insights were deeply concerning, raising questions about the future access to occupational therapy and the disturbing prospect of reduced services and practice closures affecting thousands of participants across Australia. Key insights from OTA’s 2025 NDIS Provider Survey included:
- 39% of OTs do not expect to remain profitable under the new pricing arrangements and a further 43% are unsure of their future business prospects.
- 55% report that they made no profit in 2024–25.
- 14% plan to exit the NDIS within 1–3 years and a further 51% are considering it.
This data reflects feedback from both registered and unregistered providers. We are concerned that any changes that require mandatory registration and increase regulatory burden to those who are currently unregistered, or those who are registered by struggling financially, will see many decide to exit the NDIS altogether. For this reason, we support a proportionate, risk-based approach that appropriately recognises AHPRA requirements and limits additional compliance burden for those wanting to work in the NDIS.
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Specific responses to discussion paper
Below outlines OTA’s additional feedback on the focus areas outlined in the discussion paper.
Focus Area 1: Reviewing and revising the Practice Standards
Changes/uplifts for Practice Standards
OTA is generally supportive of the direction and intent of the four domains outlined in the paper, however we request additional detail for stakeholders on the ways in which these will apply in practice, as it is unclear if it providers will be require additional time or resources to attest to 4 separate domains rather than 1 core.
Replace the existing Supplementary Modules with Supplementary Quality Standards
Supportive in principle however OTA seeks more clarity on whether the uplift of modules to standards will change the compliance burden for providers
Adjustment to the Verification Module
OTA requests more specific detail on whether the move to introduce specific conditions for registration for lower risk providers will apply in practice. We note OTs are already regulated under the AHPRA scheme and recommend that registration conditions consider AHPRA registration as a criteria to establish and maintain NDIS provider registration, and additional consultation in undertaken with allied health providers to ensure this is applied proportionately.
Revised structure for Practice Standards
OTA recommends that wherever possible, that reflective questions and additional information is placed into guidance to ensure that only core requirements are reflected in standards, to ensure they do not unduly increase provider compliance burden.
Focus Area 2: A new quality framework
OTA broadly supports the development of a quality framework that defines requirements, assessment processes, evidence inputs and ongoing monitoring to provide a systemic approach and clarify for all NDIS providers. This framework should support safe and quality service provision, without adding undue regulatory burden for providers. OTA requests further detail and regulatory assessment of the quality framework that is mapped against the current requirements to ensure that it provides a proportionate approach. OTA recommends that the quality framework assessment approach is further developed and specific services and provider types are mapped against this so that stakeholders can understand the potential regulatory implications and comment more fulsomely on this.
We note that the new assessment approach provides an opportunity for the Commission to support a risk proportional approach that recognises the AHPRA scheme when determining the type of assessment and level of evidence that is required for occupational therapists.
Quality Assessment Process
OTA notes that the self-reflection process is a new addition and potentially adds additionally regulatory burden for allied health providers. Many allied health providers already have reflective practice mechanisms built into their profession specific regulatory processes. OTA also queries whether self-reflection will enable providers to cherry pick the standards
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they want to use, which may not address key quality or safety issues inherent within a service, leading to questions of whether this will drive quality outcomes especially for providers who are struggling with costs and compliance generally.
Evidence Categories
OTA recognises the value of a broader range of evidence and input to assess provider safety and quality. We note that the evidence requirements proposed under the new quality Framework may offer additional points of data that go beyond a more typical desk top audit. The proposed collection of feedback and observation by auditors as part of the evidence base may have significant cost implications for providers, especially in regional, rural and remote locations, given the cost of travel and accommodation for auditors to physically attend a service. OTA recommends that specific assessment levels, and corresponding evidence types that will be sought are mapped out to provide additional clarity for stakeholders to comment on. OTA supports the use of cross regulation information as a source of evidence, including information from AHPRA and the aged care system.
Focus Area 3: Guidance material
OTA has found that current guidance material from the NDIS Commission is not specific or fit for purpose for the allied health sector, or for smaller providers or sole providers. There is a need for easy-to-follow, practical guidance that can support providers to gain and maintain registration, and for sector specific guidance for allied health providers and smaller and sole providers.
OTA supports more engagement with the allied health sector and particularly AHPA to support this process. We note that AHPA previously received funding to develop and host NDIS registration resources on a website specific for allied health professionals. This included practical checklists, advice and templates. AHPA’s usage statistics demonstrated significant demand for this information and AHPA received feedback that this site was very helpful for providers navigating the registration process. Unfortunately, ongoing funding was not provided to update and host these resources, and this material is no longer available. As the peak body for the allied health sector AHPA is well placed to develop future guidance material for the revised regulatory framework, with appropriate funding to create, maintain and host these resources.
Conclusion
OTA welcomes the opportunity to provide input to the review of NDIS Practice Standards. If you would like to discuss our submission please contact OTA on policy@otaus.com.au.
References
Australian Health Practitioner Regulation Agency (2024) AHPRA Annual Report 2023-2024 (Accessed 10 Nov 2025) https://www.ahpra.gov.au/Publications/Annual-reports/Annual-report-2024.aspx
Occupational Therapy Australia (2025) NDIS Provider Survey Final report (Accessed 10 Nov 2025) < https://ota-directus-prod-fedmhjdvaceqf3g7.australiasoutheast-01.azurewebsites.net/assets/6a9699dc-ec86-4ee6-8>
Wade, N., Fels, A., O’Halloran, V. and Borowick, M. (2024) NDIS Provider and Worker Registration Taskforce Report (Accessed 10 Nov 2025) https://www.health.gov.au/sites/default/files/2025-07/ndis-provider-and-worker-registration-taskforce-advice.pdf
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