SUBMISSION TO THE JOINT COMMITTEE OF PUBLIC ACCOUNTS AND AUDIT

Submitted by: Compass House Pty Ltd
redacted
Date: 2 December 2025

Note: Contact details including name, address, email and phone number are provided in the accompanying cover letter as requested.

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Executive Summary

About Compass House

Key Issues

1. Absence of Accountability

2. Administrative Barriers and Lack of Specialist Expertise

3. Financial Sustainability

4. Provider Compliance

5. Performance Measurement

6. Regulatory Performance

Conclusion

References

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EXECUTIVE SUMMARY

Compass House is a small NDIS provider in regional Queensland delivering exceptional outcomes for 24 participants with complex psychosocial disabilities. We have achieved zero psychiatric hospital admissions over five years, demonstrating annual crisis cost savings of $100,000-$229,000 per participant.

Despite these outcomes, we face insolvency over NDIA payment disputes exceeding $255,000 for supports already acknowledged as reasonable and necessary at Administrative Appeals Tribunal conference. This submission identifies six systemic failures in NDIA administration:

Complete absence of accountability at all levels, with no consequences for decision-maker errors and no executive accountability despite participant harm
Inaccessible decision-making hidden behind an impenetrable call centre, with organisational silos and lack of specialist disability expertise in planners and delegates
Payment dispute processes creating provider cash flow crises while the NDIA spends tens of millions on legal fees
Pricing structures that fail to recognise the higher costs of quality psychosocial support
Performance frameworks emphasising process compliance over participant outcomes
Regulatory approaches creating administrative burden without quality improvement

These failures mirror the Robodebt scheme’s pattern of inaccessible decision-makers, administrative dysfunction, and absence of accountability. Without intervention, the NDIS risks following the same trajectory toward systemic failure at massive taxpayer cost.

This submission makes 15 recommendations to restore accountability, accessibility, specialist expertise, financial sustainability, and outcome-focused performance measurement to NDIS administration.

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ABOUT COMPASS HOUSE

Compass House is an NDIS-registered provider in Rockhampton, Queensland, supporting approximately 24 participants at any one time, with complex psychosocial disabilities using a small-team, high-support model grounded in trauma-informed practice. Established in 2020, we have achieved zero psychiatric hospital admissions over five years for participants receiving full daily support - demonstrating measurable outcomes in one of the NDIS’s most challenging participant cohorts.

KEY ISSUES

1. ABSENCE OF ACCOUNTABILITY: SYSTEMIC FAILURE OF TAXPAYER-FUNDED ADMINISTRATION

The NDIA operates without meaningful accountability at any level, creating a system where errors have no consequences, participants and providers bear all risk, and taxpayer funds are squandered on administrative dysfunction rather than participant support.

No accountability for decision-maker errors: When NDIA planners or delegates make mistakes or misinterpret information, there is no mechanism for direct conversation to resolve the issue. The only recourse is internal review (often by the same team), external review (adding many months of delay), or Administrative Appeals Tribunal or ART (requiring unrepresented participants/supporters to go against government paid legal representation and months to years of process). There is no ability to speak directly with the decision-maker to clarify information or correct misunderstandings.

This stands in stark contrast to comparable government agencies. The Australian Taxation Office, despite making decisions many people disagree with, provides direct access to case officers who can discuss files, explain decisions, and resolve misunderstandings. NDIA participants and providers have no equivalent access.

Disproportionate legal costs shield accountability: The NDIA’s legal expenditure on AAT matters has escalated dramatically. In 2020-21, the Agency spent $34.8 million on AAT matters with $17.3 million paid to external law firms (Team DSC, 2021). By 2022-23, external legal spending had increased to $29 million (Senate estimates, 2023). In March 2025, the Attorney-General approved a 43% pay increase for government barristers, raising senior counsel rates from $3,500 to $5,000 per day and junior barristers from $2,300 to $3,300 per day - ending a 14-year freeze (Lawyerly, 2025). The NDIA now deploys legal resources averaging approximately $30,000 per case, with complex cases reaching $50,000-$100,000+. Meanwhile, participants and small

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providers struggle to afford representation, creating a strong disincentive to challenge even clearly incorrect decisions.

More recent figures for 2023-24 and 2024-25 have not been released despite multiple Freedom of Information requests, demonstrating the Agency’s lack of transparency about legal expenditure even as both AAT case numbers and barrister rates continue to rise.

The contrast is stark: Government lawyers receive a 43% pay increase while Compass House waits for payment of $255,000 for supports already acknowledged as reasonable and necessary at AAT conference. If NDIA legal representation were capped at $3,000 per tribunal matter, the Agency would be incentivised to make correct decisions in the first instance rather than relying on overwhelming legal expenditure to defend errors.

Contrast with Robodebt accountability: The Robodebt Royal Commission found that an unlawful scheme harmed hundreds of thousands of Australians and cost taxpayers over $1.8 billion in settlements and refunds (Royal Commission into the Robodebt Scheme, 2023). The Royal Commission referred individuals for investigation, resulting in 12 public servants found to have breached the Code of Conduct on 97 occasions (APSC, 2024). The scheme demonstrated what happens when public servants operate without accountability - yet the NDIS exhibits identical patterns of unchecked decision-making, inaccessible officials, and participant harm, with zero accountability mechanisms.

No executive accountability despite participant harm: In 2023, the CEO of Optus resigned following a Senate inquiry into a triple-zero outage that left over 2,000 people unable to reach emergency services. The company faced a $12 million fine from the Australian Communications and Media Authority (ACMA, 2024). Yet NDIA decisions routinely result in participant harm - including preventable deaths from lack of appropriate support - with no accountability for executive leadership, no resignations, no fines, and no consequences. The Agency’s Board and executive are completely insulated from the outcomes of systematic failures in planning, payment, and service coordination.

Taxpayer funds squandered while providers face insolvency: The NDIA’s Salesforce IT system exceeded its budget by over $200 million (Physical Disability Australia, 2024). The scheme is projected to cost $92.7 billion annually by 2033-34 (NDIA Annual Financial Sustainability Report, 2024). Yet the Agency cannot pay providers for legitimate, AAT-acknowledged supports.

Compass House is currently owed over $255,000 for supports provided to a participant, despite AAT conference acknowledgment that supports were reasonable and necessary. This payment dispute represents the absurdity: taxpayers fund a scheme approaching $50 billion annually that spends tens of millions on legal fees and approves 43% pay increases for government barristers,

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while refusing to pay $255,000 for supports already acknowledged as reasonable and necessary. A single conversation with the payment decision-maker could have resolved this in hours.

Compass House delivers $100,000-$229,000 in annual crisis cost savings per participant through zero hospital admissions. We should be funded and studied. Instead, we face potential insolvency over payment disputes while the NDIA spends hundreds of millions on IT overruns and legal fees. This is not stewardship of taxpayer funds - it is administrative failure on the scale of Robodebt.

Recommendation 1: Establish direct conversation pathways between NDIA decision-makers and providers/participants when errors or misinterpretations occur, enabling resolution without formal review processes.

Recommendation 2: Cap NDIA legal representation costs at AAT hearings to $3,000 per matter, incentivising accurate first-instance decision-making over legal defense of errors.

Recommendation 3: Implement executive accountability mechanisms linking NDIA Board and CEO performance metrics to participant safety outcomes, including preventable hospitalisations, deaths, and provider financial sustainability.

Recommendation 4: Require NDIA to match ATO accessibility standards: participants and providers must be able to speak directly with case officers who have authority to discuss files and make or escalate decisions.

2. ADMINISTRATIVE BARRIERS AND LACK OF SPECIALIST EXPERTISE

The NDIA’s organisational structure creates impenetrable barriers to resolving operational issues, compounded by the absence of specialist disability expertise in decision-makers. Four critical failures characterise this dysfunction:

Organisational silos: The NDIA operates in departmental silos that do not communicate with each other. Providers experience:

Payment teams cannot access information from delegates/planner teams and vice versa
Call centre staff cannot communicate with decision-makers in specialist areas
Provider enquiries are transferred repeatedly between departments without resolution
No single point of accountability for complex cross-functional issues

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Call centre skill gaps: The contact centre operates as the sole gateway to the NDIA but staff lack:

Authority to make decisions or escalate effectively
Access to complete participant or provider files
Specialist knowledge of complex psychosocial support requirements
Ability to provide definitive answers on payment disputes, plan interpretation, or compliance matters
Call centre limited to scripted responses that cannot address complex issues, providing generic answers like ‘we’ll escalate this’ or ‘a planner will contact you’ without timeframes or accountability

No access to decision-makers: All communication is filtered through the call centre, which cannot resolve substantive issues. Decision-makers with actual authority are completely inaccessible. This creates:

Months of delays for issues requiring specialist assessment
Repeated explanations of complex cases to different call centre staff
No accountability when issues remain unresolved
Documentation without action - notes are taken but nothing changes

Lack of specialist expertise in disability-specific decision-making: Planners, delegates, and NDIA staff making decisions about complex disability supports lack specialist training and expertise in the specific disability types they are managing. This creates:

Planners without psychosocial disability expertise making funding decisions for participants with severe mental health conditions
Stigma and lack of empathy/understanding around invisible disabilities leading to decisions that minimise psychosocial support needs based on visible presentation rather than clinical reality, with reviewers concluding ‘they seem fine’ without recognising that stability is achieved through the very supports under review
Delegates approving or rejecting support without understanding trauma-informed practice requirements or evidence-based psychosocial interventions
Generic call centre staff unable to understand the complexity of psychosocial support needs or why certain approaches are clinically necessary for people to maintain or improve skills
Decision-makers who cannot distinguish between appropriate specialist interventions and unnecessary spending
Plan reviews that reduce funding because reviewers lack understanding of what maintains stability in complex mental health presentations

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This lack of specialist expertise is a primary driver of decision-making errors, payment disputes, and AAT appeals. When planners do not understand the clinical and practical requirements of psychosocial support, they make decisions that appear cost-saving on paper but result in participant deterioration, crisis interventions, and ultimately higher system costs. The expertise gap also means the NDIA cannot identify high-quality providers delivering exceptional outcomes versus those delivering poor-quality supports at similar prices.

Compass House’s zero hospital admission rate over five years is achieved through evidence-based trauma-informed practice, polyvagal theory application, and environmental design principles. NDIA planners without psychosocial expertise cannot assess whether our approach represents best practice or unnecessary cost - leading to funding disputes despite demonstrated outcomes and professional evidence showing need and results.

Recommendation 5: Establish direct contact pathways for registered providers to reach decision-makers for payment disputes, plan interpretation, and complex support matters, bypassing the call centre for substantive issues.

Recommendation 6: Implement cross-functional case management systems enabling all NDIA staff to access complete participant and provider information, eliminating silos.

Recommendation 7: Create mandatory escalation protocols with defined timeframes: if call centre cannot resolve an issue within 48 hours, automatic escalation to specialist decision-maker with 5-business-day response requirement.

Recommendation 8: Require planners, delegates, and decision-makers to hold specialist qualifications and training in the disability types they manage. Establish dedicated psychosocial disability expertise teams for participants with mental health conditions, staffed by professionals with clinical qualifications in mental health, trauma-informed practice, and evidence-based psychosocial interventions.

3. FINANCIAL SUSTAINABILITY: PAYMENT DISPUTES THREATENING PROVIDER VIABILITY

The NDIA’s payment dispute resolution processes create severe cash flow crises for small providers delivering essential supports.

Current case example: Compass House is owed over $255,000 by the NDIA for supports provided to a participant, despite:

AAT conference acknowledgment that supports were reasonable and necessary
The plan has been consistently inadequate and under constant review since 2021
No dispute regarding service quality or delivery

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This outstanding debt represents significant financial exposure for a small provider supporting 24 participants. Payment delays force providers to carry substantial accounts receivable, continue delivering supports while awaiting payment (to avoid participant harm), divert management resources to dispute resolution, and consider ceasing support due to financial unsustainability.

Recommendation 9: Establish mandatory ‘roundtable’ processes enabling direct dialogue between providers, participants, and NDIA decision-makers to resolve payment disputes and plan adequacy issues, replacing the current ‘no-reply’ service model where providers submit information into a void with no meaningful engagement or response.

Recommendation 10: Establish an independent rapid payment dispute resolution mechanism with binding authority and maximum 60-day resolution timeframes.

4. PROVIDER COMPLIANCE: DISPROPORTIONATE BURDEN ON SPECIALIST PSYCHOSOCIAL PROVIDERS

Current NDIS pricing and compliance frameworks fail to recognise the significantly higher costs of delivering quality psychosocial support:

Mandatory trauma-informed training and ongoing professional development
Increased training costs and specialised training requirements for trauma-informed practice
Increased stakeholder engagement required with psychiatrists, psychologists, occupational therapists, behavior support practitioners, and other clinical professionals
Higher insurance premiums reflecting complex risk profiles
Increased exposure to workers compensation claims from vicarious trauma and re-triggering of staff
Increased incident reporting and documentation requirements
More intensive support coordination needs

Despite these higher costs, psychosocial support is priced comparably to general disability support, creating financial pressure to reduce quality or exit the market.

Recommendation 11: Commission independent costing study of psychosocial support delivery with pricing adjustments to reflect actual costs of evidence-based practice.

Recommendation 12: Streamline compliance reporting for providers demonstrating consistent quality outcomes.

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5. PERFORMANCE MEASUREMENT: OUTCOMES VS PROCESS COMPLIANCE

NDIA performance monitoring emphasises process compliance over participant outcomes. Compass House’s achievement - zero psychiatric admissions over five years while supporting participants with severe mental health conditions - demonstrates potential system savings of $100,000-$229,000 per participant annually in avoided crisis costs.

Yet current NDIA performance frameworks do not systematically track or reward outcome achievement, adjust pricing to reflect demonstrated value, recognise innovation in service delivery models, or use provider outcome data to inform best practice.

Recommendation 13: Implement outcome-based performance frameworks that track hospital admission rates, participant goal achievement, community participation levels, reduction in crisis interventions, and participant-reported quality of life measures.

Recommendation 14: Establish innovation funding streams for providers demonstrating superior outcomes, enabling research and replication of effective models.

6. REGULATORY PERFORMANCE: NDIS QUALITY AND SAFEGUARDS COMMISSION

The NDIS Commission’s regulatory approach focuses predominantly on compliance auditing rather than quality improvement partnerships. For providers achieving strong outcomes, the current framework creates administrative burden without corresponding quality improvement, duplicates reporting across multiple frameworks, does not differentiate between high-performing and problematic providers, and lacks mechanisms for sharing best practice across the sector.

Recommendation 15: Implement risk-based regulatory approach with reduced audit frequency for providers demonstrating consistent quality outcomes and participant satisfaction.

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CONCLUSION

The NDIS was designed to empower people with disability. Instead, the NDIA has created an accountability-free zone where mistakes have no consequences, decision-makers lack specialist expertise and are inaccessible, and providers delivering exceptional outcomes face financial ruin over payment disputes while taxpayer funds are squandered on IT overruns and legal fees.

The Robodebt Royal Commission exposed how unchecked administrative power and lack of accountability can harm hundreds of thousands of Australians at enormous taxpayer cost. The NDIA exhibits identical patterns - inaccessible decision-makers, payment disputes over legitimate supports, absence of specialist expertise, and zero executive accountability despite participant harm. Without intervention, the NDIS risks following the same trajectory toward systemic failure.

Compass House has proven that small, specialist providers with appropriate expertise can achieve zero psychiatric hospital admissions while supporting Australia’s most vulnerable citizens with complex psychosocial disabilities, delivering annual crisis cost savings of $100,000-$229,000 per participant. We should be funded and replicated. Instead, we are owed over $255,000, cannot speak to anyone with authority to resolve it, and face potential insolvency while continuing to keep people out of hospital.

The Committee’s inquiry provides an opportunity to prevent another Robodebt-scale failure by establishing genuine accountability at all levels of the NDIA, ensuring decision-makers have specialist disability expertise, dismantling organisational silos that prevent problem-solving, implementing payment processes that enable provider sustainability, aligning pricing with actual costs of quality support, orienting performance measurement toward outcomes, and adopting risk-based regulation that supports rather than burdens high-performing providers.

We welcome the opportunity to provide further evidence to the Committee and remain available for additional consultation.

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REFERENCES

Australian Communications and Media Authority (ACMA) (2024). Optus pays $12m for one-day outage. Available at: https://www.acma.gov.au/

Australian Public Service Commission (APSC) (2024). Statement by the Australian Public Service Commissioner on the Robodebt Centralised Code of Conduct Inquiry. Available at: https://www.apsc.gov.au/about-us/working-commission/who-we-are/media-releases-and-statements/statement-australian-public-service-commissioner-robodebt-centralised-code-conduct-inquiry

Lawyerly (2025). Silks get 43% pay bump for government work. Available at: https://www.lawyerly.com.au/silks-get-43-pay-bump-for-government-work/

National Disability Insurance Agency (NDIA) (2024). Annual Financial Sustainability Report 2024. Available at: https://www.ndis.gov.au/

Physical Disability Australia (2024). Response to John Kehoe’s AFR article on NDIS cost blowout. Available at: https://www.pda.org.au/2024/09/27/

Royal Commission into the Robodebt Scheme (2023). Report of the Royal Commission into the Robodebt Scheme. Available at: https://robodebt.royalcommission.gov.au/publications/report

Senate Estimates (2023). NDIA legal expenditure. November 2023.

Team DSC (2021). At What Cost? Analysis of NDIA AAT expenditure. Available at: https://teamdsc.com.au/resources/at-what-cost

Note: This submission is prepared solely for the purposes of this inquiry and has not been published elsewhere. Compass House consents to public publication of this submission with personal contact details removed. We are available to provide supplementary evidence or testimony as required by the Committee.

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Administration of the National Disability Insurance Scheme