COMPASS HOUSE PTY LTD

NDIS Registration 4050043076 · ABN 89 647 276 831 · SUBMISSION Joint Standing Committee on the National Disability Insurance Scheme

1. Introduction

Compass House Pty Ltd is a small, NDIS-registered psychosocial support provider based in Rockhampton, Central Queensland. We make this submission to the Committee’s Annual Report No. 2 inquiry to inform its examination of the implementation, performance, governance, administration and expenditure of the NDIS, including its consideration of the NDIA’s and NDIS Quality and Safeguards Commission’s annual reports.

This submission updates and expands one previously provided to the Committee’s Inquiry into the Integrity of the NDIS. We understand that inquiry has now concluded and reported (2 July 2026), and that this submission is being made to the Annual Report No. 2 inquiry instead, at the Committee Secretariat’s invitation.

We wish to be clear, consistent with the Committee’s published guidance, that we do not ask the Committee to resolve this individual’s circumstances, and we understand it has no power to do so. We offer this case study, ow involving two related matters and updated evidence, because we believe it demonstrates a systemic issue with implications well beyond one participant.

For the reasons explained in Section 6, we have referred to NDIA staff and plan manager staff by role rather than by name throughout this submission.

2. Summary

The central issue in this submission is neglect, not malice: no NDIA representative directly met this participant, or sought to properly clarify her needs, at any point from 2021 until July 2026. Every plan and every plan review made for her in that period was decided without that direct engagement.
This neglect produced two distinct, costly consequences. First, plan after plan was grossly underfunded relative to her actual needs, because no one ever engaged directly enough to understand them — resulting in $223,977.04 currently outstanding for support delivered outside what successive plans funded. Second, in 2026, Payment Integrity reviews — conducted the same way, on paper, without direct contact — misread the participant’s disability as a compliance problem on two separate grounds: mistaking her own documented alters for other people and treating her choice to rest during an unwell shift as an inconsistent claim. Together, these resulted in a further $31,431.31 or more in declined claims.
Combined, $255,408.35 or more is currently withheld from this small provider, as a direct consequence of the same underlying failure.
This participant had never been met directly by any NDIA representative in over five years of Scheme involvement, until a planning meeting in July 2026, at which the planner stated on the record that she had never handled a case of this complexity, and needed to escalate to senior planners before she could determine what could be included in the plan. A Support Coordinator on the same call, a former NDIA complex planner of six years, independently confirmed the same.
This is not the first time a decision-maker properly engaging with this case has reacted this way. At an Administrative Appeals Tribunal hearing in 2024, the Tribunal — an independent body, separate from the NDIA — commented that it was overwhelmed by the extent of the participant’s needs, before awarding the full level of support she had been seeking since 2021. It would be a further two years before any NDIA representative engaged with her directly.

The neglect began even earlier, and at the most basic level of contact. In 2022, an NDIA call centre operator suggested the participant be dropped at a hospital Emergency Department and her care relinquished — an option her own treating team had already ruled out as clinically unsafe.
Neither Payment Integrity reviewers nor planners are contactable by phone, for the participant, the provider, or even the plan manager acting on the provider’s behalf. Repeated requests for a call back have not been returned.
We submit that the Committee’s own Integrity report, tabled 2 July 2026, does not yet address the systemic issue this case demonstrates, and we propose a further recommendation (Section 7): a guaranteed, direct contact pathway to Payment Integrity decision-makers and planners, available before a decision is finalised.

Consequence one: plan after plan, grossly underfunded

The direct result of this neglect was that successive plans, and successive plan reviews did not fund the level of support the participant actually required. Compass House has continued to deliver 24/7 1:1 AWAKE support throughout this period regardless, because the alternative - reducing support to whatever level the plan happened to fund at any given time - was not a safe option for this participant or the support workers, for the reasons set out in Section 3.1, and as evidenced by numerous professional reports produced between 2021 and 2026.

This has resulted in $223,977.04 in outstanding invoices for the 1:1 day shifts and ACTIVE AWAKE overnight support component of the participant’s care. The plan funded and approved 1:1 support for all shifts, including overnight - but funded the overnight shift as sleepover support, not the Active AWAKE overnight support Compass House delivered. This was the only component of the participant’s support that fell outside what the plan funded at the time. This is not a Payment Integrity matter in the sense described in Section 3.4 below - it has not been challenged as fraudulent or as claimed against the wrong participant. It is, rather, the direct financial consequence of plan after plan being assessed without the direct engagement described in Section 3.2, notwithstanding an independent Tribunal having already found otherwise in September 2024.

Response to the Integrity Report (tabled 2 July 2026)

Having reviewed the Committee’s Integrity report in full, we note that its twelve recommendations address only one side of the integrity problem. Each recommendation strengthens the Agency’s ability to detect, verify, penalise, or share information about non-compliance and fraud. None addresses the opposite risk this submission demonstrates: a genuine, complex participant being mistaken for a fraud indicator, with direct financial consequences for a compliant small provider and direct service consequences for the participant.

If implemented as recommended, several of the report’s recommendations — particularly those strengthening identity verification and inter-agency data-sharing (Recommendations 1–5) — would increase the volume and reach of exactly the kind of review that produced the outcome described in Section 3.4, without any corresponding safeguard against it recurring.

This pattern also carries a significant and avoidable cost to the Scheme itself. Each declined claim proceeds through review, correspondence, and formal appeal across multiple staff, plan managers, and Agency teams — and, in the most serious cases, through Administrative Appeals Tribunal proceedings, as occurred in this case in 2024, involving legal representation funded by the Agency. A single phone call, made before a decision is handed down, could resolve the kind of misunderstanding described in Section 3.4 in minutes, at negligible cost. Instead, the current process generates repeated written correspondence, formal appeals, and, where matters escalate far enough, tribunal proceedings — all funded by the taxpayer, to correct an error that direct contact beforehand could have prevented entirely.

Impact

On the participant: this pattern of neglect caused sustained, serious fear — that her needs were not understood, that funding would not continue, and that she would not survive without it. For a participant whose safety, and the safety of those around her, depends on the continuity of 24/7 AWAKE support, this was not an abstract administrative concern. It was experienced as a direct threat to her life.
On the provider: Compass House is a small provider with a strong record of outcomes for its participants, including zero unplanned psychiatric hospital admissions for this participant since 2020. Compass House is currently operating on significantly reduced cash flow, with $255,408.35 or more currently withheld — not because any claim has been found fraudulent, but because of a sustained pattern of misunderstanding on the Agency’s part, comprising $223,977.04 from a plan that was never funded to reflect the participant’s actual needs, and $31,431.31 or more from Payment Integrity claims declined on the mistaken bases described in Section 3.4.
The cost to Compass House has not been financial alone. Compass House’s CEO estimates she has personally spent between 500 and 800 hours collectively fighting for payment already properly owed — collating evidence, resubmitting claims, on calls with the NDIA call centre, and attending meetings with Ministerial offices and government officials. Every government official who has engaged with this matter directly, including those who have since met the participant face to face, has agreed that her needs have been genuinely met by Compass House, and that the level of support delivered was not inflated out of provider self-interest. It reflects the participant’s need to remain alive, and to keep those around her safe.

6. A note on adverse comment

Consistent with the Committee’s guidance, we have referred to NDIA and plan manager staff involved in this matter by role rather than by name throughout this submission. Our concern is with the systemic conditions that produced these outcomes — training, escalation pathways, integrity-review methodology, and contactability — not with the conduct of any individual staff member, each of whom appears to have been operating within the system as it currently exists.

7. Recommendations

1. Complexity-recognition training and escalation pathways for Payment Integrity reviewers, specifically addressing dissociative presentations, so that multiple names in a single participant’s records are not treated as a default indicator of ratio non-compliance without first checking against the participant’s documented clinical profile.
1. A requirement for direct provider or participant contact before an integrity claim is declined in cases involving a complex psychosocial disability, rather than decisions being made on documentary review alone.
1. A minimum standard for direct participant engagement in complex cases, particularly at initial planning and at any point a participant’s complexity is reassessed, so that funding decisions are not made for extended periods without anyone from the Agency having met the participant.
1. Clearer guidance, developed with clinical input, distinguishing legitimate documentation of dissociative identity presentations from indicators of support-ratio fraud, for use by both providers and Payment Integrity staff.
1. A guaranteed, direct contact pathway to Payment Integrity decision-makers and planners, available before a decision is finalised, for providers and participants, so that claims affecting a small business’s viability are not managed entirely through a call centre with no means of escalation or follow- up (see Section 4 on the cost of the alternative).

8. Conclusion

We make this submission to inform the Committee’s understanding of a systemic issue that we believe the Integrity report’s recommendations, as currently framed, do not address. We would welcome the opportunity to provide further information if that would assist the Committee’s inquiry.

Susan McHugh CEO & Co-Founder, Compass House Pty Ltd

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