Submission to the Joint Committee of Public Accounts and Audit

Submitted by: Support Collective
Role: NDIS Registered Support Coordination Provider
Location: Maitland, NSW

1. Introduction

Support Collective welcomes the opportunity to contribute to the Joint Committee of Public Accounts and Audit inquiry into the administration of the National Disability Insurance Scheme.

We are a regionally based, NDIS registered support coordination provider working with participants with complex, psychosocial, cognitive and high support needs. Our role places us at the intersection of participants, providers, the NDIA, and the NDIS Quality and Safeguards Commission. As a result, we experience directly how administrative design, policy decisions, compliance settings, and data systems operate in practice.

This submission focuses on systemic and structural issues. The concerns outlined below are not driven by widespread provider non-compliance. They arise from NDIA system design choices, weak governance, opaque data practices, and fragmented oversight arrangements that have progressively shifted risk onto participants and providers.

2. NDIA Delivery of the NDIS and the Impact on Support Coordination

Support coordination is uniquely exposed to failures in NDIA administration. Coordinators are required to translate NDIA decisions into workable supports, explain complex and shifting rules to participants, manage compliance risk, and stabilise service arrangements when systems fail. The issues outlined below have a direct and disproportionate impact on the effectiveness and sustainability of support coordination.

2.1 Financial Sustainability Risks: Misplaced Focus and Downstream Impact on Support Coordination

From a frontline perspective, the NDIA’s approach to managing financial sustainability risks is misdirected. While public discourse and compliance activity have increasingly

focused on participant expenditure and provider claiming behaviour, Auditor-General reporting demonstrates that significant sustainability risks sit within the NDIA’s own governance, administration, and internal cost structures.

The Australian National Audit Office has classified the NDIA as a high-risk audit engagement, citing the complexity of Scheme administration, the immaturity of compliance systems, unresolved internal control weaknesses, and reliance on a complex and partially outsourced ICT environment. Across multiple audit cycles, the ANAO has identified recurring and unresolved findings relating to business assurance over participant plan approvals, management of historical scheme debt, privileged user access within core payment systems, and weaknesses in change management and data integrity.

Financial reporting shows that participant plan expenditure growth has been substantially offset by increased government contributions, resulting in a reported surplus attributable to the Australian Government. This indicates that Scheme sustainability is being maintained through additional funding rather than through demonstrable improvements in administrative efficiency or internal cost control.

At the same time, NDIA internal operating expenses have increased significantly. Publicly reported figures show internal administration costs exceeding $2.5 billion per year, with forward estimates projecting further substantial growth. The ANAO has also identified legislative breaches and governance weaknesses relating to executive remuneration, as well as high-risk procurement and ICT investment activity involving repeated redesign, consultant reliance, and cost escalation.

Despite this evidence, sustainability responses have disproportionately targeted participant plans and market-facing controls. For support coordinators, this has translated into increased plan instability, repeated reviews, service gaps, and significant unfunded administrative effort to mitigate the downstream impacts of under-resourced plans.

Pricing has also not been used as a stabilising mechanism. For support coordination, pricing constraints and freezes have narrowed scope, reduced provider capacity to take on complex participants, and increased pressure to perform compliance and risk-management functions without corresponding funding. Pricing decisions and freezes have contributed to provider withdrawal, service gaps, and market instability, particularly in regional areas. In practice, pricing has functioned as a blunt cost-containment tool rather than a lever to sustain a viable, safe and responsive market.

2.2 Claimant and Provider Compliance: Unclear Rules and the Burden Placed on Support Coordination

Compliance within the NDIS is fundamentally undermined by the absence of clear, consistent and accessible rules.

There is no single, plain-English source of truth explaining claiming requirements. Participants, many of whom have cognitive or psychosocial impairments, are expected to

comply with fragmented and highly technical guidance spread across the NDIS Act, Operational Guidelines, Price Guides, Practice Standards and informal NDIA communications.

Even providers struggle to interpret requirements due to: - Inconsistencies between formal instruments - Frequent policy and interpretation changes without clear notice - Different interpretations applied by different NDIA staff

This creates a compliance environment where non-compliance is often the product of ambiguity and system complexity rather than deliberate misuse. Support coordinators are left to bridge this gap by interpreting unclear rules, managing participant anxiety, and absorbing risk on behalf of the system. It is unreasonable to hold participants and providers to standards that are neither clearly articulated nor consistently applied by the NDIA itself.

3. Payment Integrity, System Design Failure and the Role of Support Coordination

3.1 Rapid Payments and Post-Payment Compliance

A foundational design flaw in the NDIS is the expectation of near-immediate claim payment, often within 24 to 48 hours. This standard is highly unusual compared with other government and commercial payment systems, which typically operate on 14- or 30-day payment cycles.

By prioritising speed of payment, the NDIA embedded minimal pre-payment validation and shifted integrity activity almost entirely into post-payment reviews. Multiple reviews and audits across government have highlighted weaknesses in preventative controls and an over-reliance on retrospective compliance action.

The consequences include, particularly for support coordination:

• Limited preventative safeguards
• Heavy reliance on retrospective audits, debt recovery and payment suspensions
• Significant administrative cost and disruption for participants and providers

This approach transferred integrity risk from the administrator to the market and is now being reframed as provider non-compliance rather than acknowledged as a design failure.

3.2 Compliance Activity Is Reactive and Poorly Targeted

Support Collective has operated since 2020 and has been subject to only one payment integrity review involving a small sample of claims. This review did not arise from identified risk indicators or intelligence-led analysis. It occurred only after we queried exclusion from a support coordination quality initiative, following which we were selected for a payment integrity review and rendered ineligible to participate.

This experience is consistent with broader findings that compliance activity is sporadic and reactive, rather than systematic, transparent or risk-based. It does not support claims that the NDIA is effectively managing sustainability risks through targeted compliance oversight.

3.3 Support Coordination as a De Facto Integrity and Stabilisation Function

In practice, support coordination has become one of the NDIS’s primary frontline integrity and stabilisation mechanisms. Coordinators are routinely required to interpret unclear NDIA rules, prevent inappropriate claiming, manage payment disruptions, respond to retrospective compliance action, and stabilise participant supports when NDIA systems or regulatory responses fail.

These functions go well beyond the original intent of support coordination as a capacity-building and service-connection role. They represent de facto administrative, compliance, and risk-management work performed on behalf of the Scheme.

Despite this, support coordination pricing has not kept pace with the expanded scope, complexity, and risk exposure now inherent in the role. Coordinators are increasingly required to absorb unfunded administrative work, manage safeguarding risks without authority, and prevent escalation into crisis responses that would otherwise generate higher downstream costs for the NDIA.

Failure to appropriately value support coordination as a system safeguard risks further provider exit, reduced capacity to support participants with complex needs, and increased reliance on reactive NDIA and regulatory interventions.

4. Monitoring, Measurement and Reporting of NDIA Performance: Implications for Support Coordination

4.1 Selective Transparency and Withheld Data

The NDIA’s monitoring and reporting practices lack transparency and completeness. Public reporting under the Participant Service Guarantee is partial and inconsistent, with significant performance data retained internally.

Participant spend datasets have been withheld for extended periods and, when released, contain acknowledged redactions, missing data, unexplained adjustments and regional suppression rules that materially understate total expenditure. Independent analysis of NDIA datasets has identified errors and anomalies that require substantial cleaning before the data can be meaningfully interpreted.

These practices undermine confidence in NDIA claims regarding financial sustainability and performance management. Support coordinators rely on NDIA data to plan services, advise participants, and manage risk. When data is incomplete or unreliable, coordinators are forced to operate without a stable evidence base. Effective governance requires timely, complete and intelligible disclosure, not curated or selectively released information.

5. Regulatory Performance of the NDIS Quality and Safeguards Commission and the Impact on Support Coordination

Independent audit activity has assessed the NDIS Quality and Safeguards Commission as only partly effective in exercising its regulatory functions. This aligns with our frontline experience.

We have lodged multiple complaints supported by clear evidence, including matters involving abuse, coercion and suspected fraud. In one case involving a SIL provider attempting to have a participant hospitalised to prevent them moving services, the Commission took approximately two years to make contact.

Such delays are incompatible with the Commission’s safeguarding mandate. In the absence of timely regulatory action, support coordinators are often left managing active risk, conflict, and participant safety concerns without authority or enforcement powers. When serious matters are not addressed in a timely way, participants remain exposed to harm and confidence in the regulatory framework is undermined.

6. Department of Health, Disability and Ageing Policy Oversight and System Escalation Failures

The Department of Health, Disability and Ageing plays a critical policy and oversight role, yet appears disconnected from the practical administration of the NDIS.

When the NDIA applies policy inconsistently or fails to follow its own rules, there is limited evidence of effective departmental intervention. Engagement with Ministers’ offices rarely results in practical resolution or clarification, leaving participants and providers without a meaningful escalation pathway.

This creates a governance gap in which administrative failure persists without corrective action.

7. Recommendations

Support Collective recommends that the Committee:

1. Recognise that current integrity and sustainability challenges are primarily the result of NDIA system design and governance failures, not widespread provider non-compliance.
2. Require detailed scrutiny of NDIA internal expenditure, including executive remuneration, ICT investments, procurement practices and consultant reliance.
3. Mandate clear, plain-English claiming guidance suitable for participants with cognitive and psychosocial impairments.
4. Rebalance payment speed with proportionate pre-payment validation and preventative integrity controls.
5. Improve the transparency, accuracy and completeness of NDIA performance and expenditure reporting.
6. Strengthen the accountability and responsiveness of the NDIS Quality and Safeguards Commission in relation to serious misconduct.
7. Clarify and reinforce the Department of Health, Disability and Ageing’s oversight role where NDIA administration departs from policy or legislative intent.
8. Explicitly review and increase the support coordination price to reflect the expanded scope, risk exposure, and system-stabilising functions now routinely performed by support coordinators.

Support coordination is increasingly relied upon to interpret NDIA decisions, manage plan instability, mitigate compliance and safeguarding risks, respond to payment and system failures, and stabilise service arrangements in the absence of timely NDIA or regulatory action. These functions represent de facto integrity, risk-management, and administrative work on behalf of the Scheme.

Maintaining support coordination pricing at levels that do not reflect this reality risks further provider exit, reduced capacity to support participants with complex needs, increased participant harm, and higher downstream costs to the NDIA through crisis responses, reviews, and regulatory intervention.

8. Closing Statement

The challenges facing the NDIS are not the result of isolated bad actors. They are the predictable outcome of administrative design choices that prioritised speed, opacity and discretion over governance, clarity and accountability.

If this inquiry is to strengthen the Scheme and protect participants, it must address these structural failures directly rather than reinforcing narratives that misplace responsibility.

Submitted by:
Angela Forrester
Letisha Malloy
Directors, Support Collective