Submission to the Joint Committee of Public Accounts and Audit
Submitted by: Communication eXtra
Submission type: Public submission
Prepared solely for the purposes of this inquiry
Executive Summary
Communication eXtra welcomes the opportunity to contribute to the Joint Committee of Public Accounts and Audit inquiry into the administration of the National Disability Insurance Scheme (NDIS).
This submission focuses on administrative inefficiencies within the National Disability Insurance Agency (NDIA) that generate avoidable costs for both specialist providers and the Scheme itself. Communication eXtra draws on its operational experience employing and supporting people who are Deaf, non-verbal, or who experience significant communication barriers, to demonstrate how current administrative systems:
- increase NDIA handling time and internal workload
- drive duplicated processes and repeated rework
- increase compliance and escalation activity without improving safety
- undermine consistent decision-making and performance reporting
The issues outlined are systemic in nature. They are not attributable to individual staff, but rather to administrative design, workflow fragmentation, and insufficient embedding of communication access principles into NDIA operations.
Addressing these issues would reduce administrative costs, improve NDIA performance, and support the long- term financial sustainability of the Scheme without increasing participant plan expenditure.
The administrative issues outlined in this submission are consistent with themes identified in recent Auditor- General reporting regarding governance, performance measurement, compliance effectiveness and the need for fit-for-purpose administrative systems across the NDIS.
1. About Communication eXtra
Communication eXtra is a specialist service provider employing and supporting people who experience significant communication barriers, including people who are Deaf, non-verbal, or who rely on Auslan, augmentative and alternative communication (AAC), or other non-spoken communication methods.
Through its work, Communication eXtra regularly interacts with NDIA systems, call centres, planners, and compliance processes. This provides direct insight into how administrative design choices affect efficiency, cost, and performance across the Scheme.
2. Relevance to the Terms of Reference
This submission addresses the Committee’s Terms of Reference by examining:
- NDIA delivery of the NDIS with reference to financial sustainability risks
- claimant and provider compliance with NDIS claim requirements
- monitoring, measurement and reporting of NDIA performance
- the regulatory environment as it intersects with NDIA administrative practice
3. Administrative Inefficiencies as a Cost Driver
3.1 Communication Access Failures Increase Administrative Rework
NDIA administrative processes often default to spoken English and telephone-based engagement. In practice, this creates barriers for providers and participants where communication needs differ.
Common administrative impacts include:
- assumptions that all provider staff can easily utilise the National Relay Service
- repeated failed contact attempts where communication access needs are not recognised
- increased follow-up calls, emails, and escalations
- data health errors or failure to recognise communication requirements and using default methods without investigation which is followed by notes that reflect unresponsiveness
These failures result in duplicated handling by NDIA staff and providers, increasing administrative workload without improving outcomes and real-life impacts for participants.
3.2 Inconsistent Advice Drives Compliance Risk and Appeals
Communication eXtra regularly observes inconsistent administrative advice being provided across different NDIA contact points. This includes differing interpretations of process, documentation requirements, and next steps for identical issues.
The impact of this inconsistency includes:
- providers acting in good faith on advice later contradicted
- increased corrections, rework, and compliance follow-up
- avoidable reviews and escalations
From an administrative perspective, inconsistency directly increases internal NDIA workload and undermines performance reliability.
3.3 Fragmented Identity and Endorsement Systems Create Duplication
Current arrangements for:
- PRODA registration
- NDIS Commission worker endorsement
- provider role verification
operate across multiple systems that do not integrate effectively. This fragmentation requires repeated submission of information and manual verification.
The result is:
- delayed staff onboarding
- repeated verification requests
- additional NDIA processing time
- increased provider administrative burden
Unclear administrative ownership across departments results in circular referrals, duplicated handling, and delayed resolution of provider and participant matters.
This represents cost-shifting from the Agency to providers rather than efficient administration.
3.4 Poor Document Visibility Increases Handling Time
Providers frequently experience situations where consent or authority documentation has already been supplied yet cannot be readily located by NDIA staff.
This leads to:
- repeat requests for existing documents
- delayed decision-making
- increased call volumes
Improved document visibility would reduce duplication and handling time across the system.
3.5 Lack of Case Ownership Drives Inefficiency
NDIA administrative interactions rarely provide continuity of contact. Providers often engage with a different staff member at each interaction, requiring repeated explanation of context and issues.
This absence of end-to-end ownership:
- increases total handling time per matter
- leads to inconsistent outcomes
- reduces administrative efficiency
From a cost perspective, this is an inefficient workflow design rather than an operational necessity.
3.6 Limited Access to Specialist Decision-Makers
There is no clear, accessible pathway for providers to:
- contact a complex planner where complexity is evident
- resolve provider invoicing or payment issues through a dedicated function
Instead, matters are transferred between teams without clear ownership, prolonging resolution and increasing administrative cost per issue.
4. Compliance and Regulatory Implications
Where participants experience communication barriers, administrative misunderstandings are sometimes escalated into compliance or safeguarding pathways.
This can occur when:
- communication difficulty is mistaken for disengagement
- administrative delays are misinterpreted as non-compliance
Such escalations increase regulatory workload without corresponding risk reduction, representing inefficient use of compliance resources.
5. Performance Measurement Gaps
Current NDIA performance reporting does not adequately capture:
- rework driven by communication access failures
- repeated plan corrections or reviews linked to administrative misunderstanding
- duplicated handling arising from fragmented systems
As a result, significant administrative cost drivers remain invisible in performance metrics and sustainability modelling.
6. Recommendations
Communication eXtra recommends that the Committee consider the following actions:
- Recognise communication access as a core administrative efficiency factor in NDIA operational guidance.
- Improve integration between identity, endorsement and compliance systems to reduce duplication.
- Strengthen document management systems to ensure existing consent and authority records are easily accessible.
- Introduce clearer case ownership models to reduce repeated handling and improve continuity.
- Enhance NDIA performance reporting to capture administrative rework linked to communication barriers.
7. Conclusion
The administrative issues outlined in this submission are systemic and measurable. They increase NDIA workload, raise provider compliance risk, and generate avoidable administrative cost without improving participant outcomes.
Addressing communication access and administrative design inefficiencies would improve NDIA performance, strengthen financial sustainability, and support a more efficient and equitable Scheme.
Communication eXtra appreciates the opportunity to contribute to this inquiry and would welcome further engagement should the Committee seek additional evidence or clarification.
End of submission