NDIA Accountability Project

Administration of the National Disability Insurance Scheme

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Administration of the National Disability

Insurance Scheme

CPSU Submission January 2026

Committee Secretary Joint Committee of Public Accounts and Audit PO Box 6021 Parliament House Canberra ACT 2600

Administration of the NDIS

The Community and Public Sector Union (CPSU), as the union representing employees in the National Disability Insurance Agency (NDIA) and the National Disability Insurance Scheme Quality and Safeguards Commission (NDISQSC), welcomes the opportunity to make a submission. Herein, the CPSU highlights the ideas and solutions of CPSU members on how the administration and financial sustainability of the National Disability Insurance Scheme (NDIS) can be improved. Our submission focuses on:

  • Fraud reduction,
  • Plan management,
  • Long term sustainability practice,
  • New framework planning, and
  • Measurement of relevant data.

Fraud Reduction

CPSU members have stated that fraud is worsened by branches and divisions often operating in isolation, which creates communication silos. 1 This is true of communication between the NDIA and the NDISQSC as well as internally within those respective agencies. Alignment of communication across branches and with relevant

1 The NDIA faces comparable communication and information sharing issues to those identified at the NDIS Quality and Safeguards Commission in the following report: Australian National Audit Office. (2025). Effectiveness of the NDIS Quality and Safeguards Commission’s Regulatory Functions (Auditor-General Report No. 2 2025–26). https://www.anao.gov.au/work/performance-audit/effectiveness-the-ndis- quality-and-safeguards-commissions-regulatory-functions-2025

stakeholders is essential. In some cases, even teams within the same branch or division fail to share information effectively. This is particularly evident at the NDIA in the Scheme Integrity Response Team and the Participant Safeguarding Response Branch. Missed opportunities to share critical information have led to outcomes such as approval of payments to dishonest or fraudulent providers – issues that could have been prevented through better collaboration. The CPSU recommends establishing or enhancing structured communication channels and tracking processes between agencies, branches and within teams to ensure timely information sharing. This will improve decision-making and reduce risks associated with fraud and integrity breaches.

Plan Management

CPSU members have also raised concerns about the role of external plan managers.2 These roles were established to help participants at the stand up of the scheme when the market of providers was significantly more fragmented. However, CPSU believes there are good reasons to review the operation of this role which now significantly complicates NDIA’s capacity to track what supports are being funded. Some members believe that the training and education of plan managers should be improved. Others recommend imposing greater and more frequent penalties for payment of supports that are not NDIS supports. Furthermore, other member believed bringing plan management activities into the NDIA itself would be the best way forward. Given these concerns, the CPSU recommends reviewing the operation, training, and penalisation of plan managers.

Long Term Sustainability Practice

The CPSU recommends the NDIA ensure long-term sustainability practice is integrated into everyday work practices. The NDIA historically has adopted an inconsistent approach to sustainability that regularly switches focus. For example, the NDIA will focus for some months on policing participant plan budgets (typically through review of completed plans and by establishing separate review teams). However, once the immediate objective is achieved (e.g. lowering the growth of the scheme participant payments) the NDIA frequently defaults to attempts to restore relationship with the participants, typically through relaxing restrictions around funding. A move away from knee-jerk reactions towards a long-term sustainability practice inbuilt into regular work controls will ensure continuity and that these restrictions are received by the public at a lower impact.

2 For an introduction to this role, see: National Disability Insurance Scheme. (2020). Guide to plan management. https://www.ndis.gov.au/media/2693/download

CPSU members have additionally recommended the NDIA adopt a policy of broad capacity building review for a participant after an agreed number of years to determine the efficacy of funding provided and how it has been utilised to achieve participant therapy and plan goals. This should focus on the use of allied health therapies, with Agency planners conducting a review of information provided over a longitudinal period to determine if the level of therapy support is having tangible outcomes.

New Framework Planning

The Australian Parliament made a series of changes to the NDIS Act in 2024. Changes to planning associated with this reform are scheduled to be implemented from July 2026. All participants in the NDIS will gradually move to new framework plans. As part of these changes support needs assessments will become more central and there will be clearer rules for what supports will and will not be funded by the NDIS.

CPSU members have mixed thoughts in relation to the new framework planning. They are aware of challenges to its implementation and the impact it may have on participants. However, overall, the CPSU believes new framework planning could be an overall positive for the NDIA and NDIS participants. It will place the focus of the scheme on the functional capacity (combined with contextual factors), as they relate to a person’s disability. This should lead to more consistent decisions. However, as one member puts it, “it is unclear that this will automatically result in an overall reduction in scheme costs.” There exists an underlying assumption that the current planning frameworks are inconsistent and overfund participants. What evidence the government relies upon is unknown, with the current publicly available information it is not possible to rule out that a more consistent decision-making process would not instead increase funding expenditure. Further information, namely the accompanying NDIS rules required to operate s33D legislation should be expediated by the government and considered by the JCPAA.

CPSU members also seek to emphasise the importance of ensuring that their jobs and conditions are maintained during any changes associated with new framework planning. In particular, the CPSU emphasises the commitment of the government to the Strategic Commissioning Framework. Under the SCF, core APS work must be done by APS employees. The CPSU seeks to ensure that APS jobs are maintained in line with this commitment.

Measuring Relevant Data

When assessing the success of the Scheme, economic activity and individuals’ integration into mainstream society should be given a greater emphasis. In June 2023, the participant employment rate was 23%. Of these, 24% worked in an Australian

Community and Public Sector Union

Disability Enterprise and 76% worked in open employment.3 However, often participants who are employed suffer from underemployment. The CPSU recommends the greater collection of data relating to underemployment of participants along with concrete measures to reduce underemployment. Relatedly, members have also raised concerns that some participants socialise primarily with other participants and carers when there are opportunities for them to be better integrated within broader society. The way in which activities are delivered as part of their plan could be altered to emphasise that broader integration where appropriate.

NDIS Quality and Safeguards Commission (NDISQSC)

The work of the NDISQSC is vital to ensuring that NDIS providers across the country are doing the right thing. It is responsible for preventing and exposing fraud, and for keeping people with disability safe as they access NDIS supports. CPSU members believe there is a strong need to secure resources at the NDISQSC to ensure the Commission can carry out its vital functions. These resources are in addition to the implementation of risk- based regulatory prioritisation model (RRPM) and the new data and regulatory transition (DART) system.

Furthermore, cultural issues have deeply impacted the NDISQSC as identified in the Broderick Report. These include bullying, harassment, psychosocial hazards, reports of being a toxic workplace and excessive workloads. Previous hiring freezes at the NDISQSC negatively impacted culture and staff retention and diminished the capacity of the Commission to regulate providers. For both regulatory and cultural reasons, the CPSU recommends ensuring the NDISQSC is well resourced and funded sufficiently.

CPSU Recommendations

Considering the above, the CPSU recommends the government:

  1. Establish or enhance structured communication channels and tracking processes between agencies, branches and within teams to ensure timely information sharing.
  2. Review the operation, training, and penalisation of plan managers.
  3. Embed long term sustainability measures into everyday work practices.
  4. Ensure the jobs of APS employees in the NDIA and NDISQSC are maintained in keeping with the Strategic Commissioning Framework.

3 National Disability Insurance Agency. (2024). Participant Employment Strategy 2024–2026. NDIS. https://www.ndis.gov.au/strategies/participant-employment-strategy, p24.

Community and Public Sector Union

    1. Greater collection of data on participant outcomes and restructuring of plans to emphasise better integration into mainstream society including by reducing underemployment.
    1. Increase staffing and resources for the NDISQSC to ensure that the disability

    regulator has the capacity to reduce fraud and properly protect participants in the scheme.