The Chair Joint Committee of Public Accounts and Audit Parliament House Canberra ACT 2600

                                                        Dr Judith Gould, PhD
                                                                  Director
                                                 Solid Foundations Allied Health
                                                     40 Mannum Road
                                                       Murray Bridge SA 5253
                                                       `redacted: s22`

                                                     28 January 2026

Dear Chair and Committee Members,

Re: Submission to the Joint Committee of Public Accounts and Audit - Inquiry into the Administration of the National Disability Insurance Scheme

On behalf of Solid Foundations Allied Health, I am pleased to provide this submission to the Joint Committee of Public Accounts and Audit’s Inquiry into the Administration of the National Disability Insurance Scheme (NDIS). Our organisation is a registered, audited allied health provider delivering services to children, young people, and adults across regional, rural, and very remote South Australia, including First Nations communities.

Through our experience on the ground, we have observed both the transformative potential of the NDIS and the significant challenges arising from gaps in oversight, compliance, and regulatory frameworks. This submission highlights systemic weaknesses that allow unethical or ineffective practices to occur, the resulting risks to participants, and the pressures faced by ethical providers striving to deliver high-quality, culturally safe, and evidence-based services.

Our submission includes detailed observations and recommendations aimed at strengthening governance, ensuring accountability, and improving participant outcomes. We emphasise the importance of measuring the quality and impact of services, not just compliance documentation, and call for transparent, measurable standards for both providers and the authorities responsible for regulating the Scheme.

We would be pleased to provide further evidence, de-identified case studies, and insights from lived service delivery to support the Committee’s work. Our aim is to assist the Committee in identifying reforms that safeguard participants, promote equity, and ensure the long-term sustainability and integrity of the NDIS.

I acknowledge that I live and work on the traditional lands of the Ngarrindjeri people and I thank all First Peoples for their teachings.

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Thank you for the opportunity to contribute to this important inquiry. We trust that our submission will provide

constructive insights and practical recommendations to strengthen the administration of the Scheme and protect its intended beneficiaries.

Yours sincerely,

Dr Judith Gould, PhD Director Solid Foundations Allied Health

Submission to the Joint Committee of Public Accounts and Audit

Submitted by: Dr Judith Gould

Date: January 2026

I acknowledge that I live and work on the traditional lands of the Ngarrindjeri and Far West peoples and I thank all First Peoples for their teachings.

Executive Summary

The author of this submission is the Director of a small, private practice allied health business that is a registered, audited, and compliant NDIS allied health provider with extensive experience delivering services to participants in rural, very remote and First Nations communities. Our business has voluntarily opted into registration and rigorous compliance scrutiny because we believe transparency, accountability, and adherence to evidence-based practice are essential to protecting participants and safeguarding Commonwealth funds.

This submission highlights systemic weaknesses in NDIS administration that allow unethical and opportunistic practices to occur, particularly where oversight and registration are limited. These gaps have a direct impact on participant outcomes, equitable access, and value for money, and they disproportionately affect First Nations participants and those in very remote regions, where services are already stretched and where continuity of care is essential.

Key issues identified include:

• Concentration of market power in a small number of large providers, resulting in restricted choice and control for participants.
• Pressure applied towards allied health providers by Support Coordinators to deliver non-evidence-based reports or recommendations, with retaliatory exclusion when ethical standards are upheld.
• Gaps in regulatory oversight, allowing providers to access funding without sufficient compliance monitoring.
• Service inequities for First Nations participants, including culturally unsafe or disconnected services, fly- in/fly-out in a day models, and inconsistent access to specialised allied health supports.
• Risks to continuity, culturally safe therapists, and evidence-based intervention in very remote communities.

Our business urges the Committee to strengthen oversight arrangements so that every Commonwealth dollar delivers genuine benefit, particularly for First Nations participants and those in regional and very remote communities. This includes ensuring mandatory registration, proportionate monitoring and auditing of providers, and regulatory structures that prioritise equity, culturally safe practice, and continuity of care.

We can provide de-identified case studies and evidence from on-the-ground service delivery to demonstrate effective, ethical allied health supports in regional, very remote and culturally diverse contexts, and to illustrate how systemic gaps currently undermine participant outcomes and public trust.

The observations outlined below are drawn from our direct service delivery experience and professional interactions within the NDIS, particularly in rural, remote, and First Nations contexts.

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1. INTRODUCTION

Our business is a registered allied health provider delivering evidence-based services to people with disability under the National Disability Insurance Scheme (NDIS). We strongly support the intent of the Scheme and its foundational principles of choice, control, and improved outcomes for participants.

We are increasingly concerned that systemic weaknesses in the administration and regulation of the NDIS have enabled unethical, exploitative, and, in some cases, fraudulent and dangerous behaviour by a subset of providers and associated entities. These practices undermine participant safety, rapidly deplete individual plans, distort service markets, and erode public trust in the Scheme. We also consider the NDIA can provide additional support to providers to improve the experiences to participants through improved education and support to schools and learning environments. We hold the view that improved continuity and capability within NDIA staffing, including access to informed advice for allied health providers, would support best- practice service delivery, reduce system strain, and better safeguard participants - especially those navigating the Scheme for the first time. We also consider there needs not just a committee focus on the financial spend of the NDIA but a review of the quality of services being provided and the ability to assess value for money of services being delivered by providers.

We submit this evidence as a provider that has consistently chosen transparency and accountability, where doing so was optional, and therefore has firsthand insight into how the absence of equivalent scrutiny enables systemic misuse of NDIS funding.

This submission is intended to assist the Committee in assessing whether current NDIS administrative and regulatory arrangements provide adequate financial oversight, accountability, and value for money. In doing so, it highlights systemic weaknesses in NDIS administration that directly affect financial stewardship, regulatory effectiveness, and the protection of Commonwealth funds.

2. VOLUNTARY REGISTRATION, AUDITS AND COMPLIANCE

2.1 Voluntary Registration Benefits

We wish to make clear that we are, and have always been, a registered NDIS provider, despite operating in service categories where registration has not been mandatory.

We have voluntarily opted into registration because we believe rigorous oversight, independent auditing, and regulatory accountability are not only essential to protecting NDIS participants and the integrity of the Scheme but are essential to improving our ongoing business operations and service delivery. This decision has required us to submit to:

• Regular independent third-party audits.
• Ongoing compliance with the NDIS Practice Standards.
• Financial scrutiny, robust record-keeping, and evidence-based service delivery requirements.
• Continuous quality improvement processes, complaints management, and incident reporting obligations.

These requirements involve significant financial cost, administrative burden, and operational scrutiny. Ethical providers accept these obligations as a necessary safeguard for participants and public funds - not as an inconvenience to be avoided.

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By contrast, the current system allows some organisations to structure their operations to avoid registration, auditing, and meaningful oversight while still drawing substantial funding from participant plans. This creates an uneven playing field, disadvantages compliant providers, and significantly increases risk to participants.

2.2 Audit Administration

An issue we have observed after undergoing six past audits is the lack of consistency in Auditor interpretation of NDIS Practice Standards. Auditors appear to have authority in the interpretation of Practice Standards which may conflict with previous auditor requirements, subsequently imposing significant administrative burdens on business to then rectify perceived non-conformances. When seeking clarification directly from the NDIS, businesses are met with an inability, or lack of willingness to provide clear interpretations of Practice Standard requirements, and are instead referred back to the Auditors judgement. Hence, it is our opinion that the knowledge and understanding of the NDIS guidelines are not well understood by the NDIS’s own workforce, nor do they have an appreciation of the cost and administrative impact of their advice and decision making.

3. ACCOUNTABILITY FOR USE OF COMMONWEALTH FUNDS

We hold the firm view that any individual or organisation accessing Commonwealth funds through the NDIS must be subject to mandatory registration, audit, and regulatory oversight. That said, however, these should be commensurate to the size and type of service delivery of each business.

The NDIS represents one of the largest public expenditures in Australia. Where public money is involved, voluntary accountability is insufficient. Registration is not merely administrative; it is a safeguard ensuring minimum standards of care, financial probity, and participant safety.

Allowing unregistered providers to access NDIS funding has created a regulatory vacuum. It is within this gap that unethical and opportunistic actors have entered the Scheme, extracting significant funds while avoiding scrutiny. These actors have spoilt the system for participants, families, ethical providers, and taxpayers alike. We strongly contend that if an organisation has its hands in the Commonwealth purse, it must also accept Commonwealth-level accountability.

4. OBSERVED PATTERNS OF MISUSE AND HARM

Based on our experience within the sector, recurring patterns of concern include:

• Inflated or inappropriate billing
• Services that provide minimal or no therapeutic benefit
• Revenue-driven service models
• Fragmented or duplicated supports
• Rapid depletion of participant plans without concern for continuity of supports

These practices disproportionately affect participants with cognitive, communication, or psychosocial disabilities, who may be less able to identify or challenge inappropriate claims. These practices also disproportionately impact participants whose nominated carer/s may be especially vulnerable to exploitation due to a range of factors beyond their control. First Nations peoples being forced to accept supports provided by culturally unsafe providers (including support co-ordination, support worker and allied health supports) due to thin markets are especially at risk from unethical providers.

Additional issues observed in very remote service markets include:

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• In very remote regions, market power is frequently concentrated in a small number of support coordination and support worker providers. In very remote communities, only a single provider may exist. This concentration can result in participants’ access to services being effectively controlled by intermediaries, rather than reflecting genuine choice and control, including where services are not delivered in culturally safe or anti-racist ways.

• We have observed instances where support coordinators have sought to influence or pressure allied health providers to produce reports or recommendations that are not clinically accurate, for the purpose of securing increased funding, rather than reflecting evidence-based need.

• Where providers have declined to participate in such practices and have maintained professional and ethical standards - including limiting reports to factual assessment findings and evidence-based recommendations - retaliatory behaviour has occurred, including:

  o Removal of multiple participants from allied health services without clinical justification

  o Systematic exclusion of ethical providers from referral pathways

  o Failure to offer participants a genuine choice of providers, contrary to the NDIS Act.

• In these situations, participants were either:

  o Redirected to providers perceived as more compliant with questionable practices, or

  o Left without services altogether, despite available, qualified providers willing to deliver supports.

• In these instances, participants regularly fail to complain about their provided support coordination due to the fear of the non-provision of services, and sometimes, do not feel empowered to complain.

• These practices are particularly damaging in very remote First Nations communities, where:

  o Allied health services are already scarce

  o Continuity of care is critical

  o Disruptions disproportionately affect children with developmental disorders where the regular provision of one on one, specialised allied health therapies is a necessary requirement

  o Cultural safety and trust are undermined when services are arbitrarily withdrawn.

• The absence of effective oversight of support coordination practices allows gatekeeping behaviour to go unchecked, enabling some providers to effectively hold participants and their funding to ransom by controlling access to allied health supports.

• Current regulatory arrangements do not adequately monitor:

  o Conflicts of interest in referral pathways

  o Retaliatory or exclusionary practices by support coordinators and large organisation business owners

  o Whether participants are genuinely offered informed choice among available providers.

• In very remote settings, these failures compound existing inequities, further disadvantaging First Nations participants and undermining the intent of the Scheme to provide equitable access to supports regardless of geography.

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These practices represent a failure of administrative safeguards and regulatory oversight, with direct implications for participant outcomes, value for money, and the integrity of the NDIS in very remote regions, where First Nations peoples are disproportionately represented and already experience significant barriers to equitable access to allied health supports.

NDIS Complaints

An observation when undergoing audits is the level of evidence and administrative requirements of clearly identifying to participants their options to submit complaints. While we agree with this requirement, there appears to be an inappropriate level of focus on this attribute rather than the delivery of quality services. Quality audits demonstrate that required processes exist on paper, but they do not confirm the quality or appropriateness of services delivered to participants.

Conversely, complaints made to the NDIS regarding potential breaches of the NDIS Code of Conduct by other providers often receive no apparent response or feedback, limiting transparency and confidence in the complaints process. Complaints we have previously made to the NDIS of which we have not seen any response have included:

• Perceived inappropriate billing practices, including the depletion of therapy budgets through falsified billing for autism diagnostic assessments. Families have also used therapy funding for high-cost, non- evidence-based bulk chiropractic appointments, reducing funds available for evidence-based supports. The use of NDIS funding for chiropractic services should be specifically investigated. De-identified case examples can be provided with parental permission.
• Perceived collusion between providers and the provision of non-evidence based services.
• Misuse of funds to improve homes that were not directly attributable to the participants needs.

While in these instances the potential fraud would be comparatively low in value i.e. in the low thousands, it results in a reduced level of service for participants, reduced level of trust in the NDIS and reduced levels of participant control. If such practices remain unchecked across the NDIS, the cumulative impact of waste and fraud will continue to be significant.

5. FIRST NATIONS PARTICIPANTS, CULTURAL SAFETY AND REMOTE SERVICE DELIVERY

Our business has extensive experience providing allied health assessment and therapy services with First Nations children and families in rural and very remote communities, including through regular outreach supported by NDIS funding.

5.1 Culturally Safe and Evidence-Based Supports

We strongly support the principle that NDIS supports for First Nations participants must be culturally safe, community-led, and provided in place and on Country. Cultural expertise is essential and irreplaceable. Non- Indigenous allied health therapists can develop the skills and knowledge required to provide culturally safe supports. Culturally safe allied health therapists are able to provide the supports First nations peoples need in place, on Country as long they are working alongside and in true collaboration with First Nations peoples.

Both cultural expertise and specialised allied health intervention are necessary and complementary. We can provide de-identified case studies demonstrating improved outcomes for First Nations children receiving regular, targeted allied health therapy within culturally safe frameworks.

5.2 Place-Based, On Country Models

Our experience strongly supports the position that:

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• Allied health supports should be provided in place and on Country, by qualified and registered culturally safe professionals.
• Fly-in, fly-out models involving brief (often only one day), disconnected visits are not appropriate for effective allied health therapy.

Effective allied health intervention requires continuity, trust, and sustained relationship-building, none of which can be achieved through episodic or fly-in, fly-out service delivery models. These models are structurally incapable of delivering long-term participant outcomes, a limitation that is well understood within the sector. These businesses also generally experience a high degree of allied health staff turnover due to the unsustainable work hours, billable numbers and lack of clinical supervision and provision of resources required to do their work to the level required when supporting people with disabilities. For participants who have additional layers of complexity such as living with trauma or cultural diversity, including First Nations peoples, high staff turnover further impacts the continuity and quality of care for people living in rural to very remote areas.

Fly-in, fly-out allied health services are typically delivered for a finite period, often ceasing once participant funding is exhausted through the application of maximum allowable travel and service charges rather than being structured to support continuity of care. This approach promotes short-term, block-based intervention rather than longitudinal therapy delivered with the intention of returning year after year until outcomes are achieved, progress can be meaningfully measured, and participants can be clinically discharged where appropriate, or supported to establish the foundational skills required for lifelong participation and wellbeing.

Allied health professionals require access to a broad range of specialised assessment tools and therapy resources to deliver targeted, evidence-based supports. The volume and specificity of these resources cannot be accommodated within short-duration fly-in, fly-out services, particularly those conducted within a single day. As a result, these models rely on generic, ‘one-size-fits-all’ approaches that are inconsistent with best practice and represent an inefficient use of NDIS funding in rural and very remote settings.

5.3 Role of ACCHOs and ACCOs

Culturally safe allied health services including those provided by non-Indigenous clinicians can be delivered appropriately when ACCHOs and ACCOs are central to governance and oversight.

Effective models include:

• Delivery through or in formal partnership with ACCHOs/ACCOs
• Community approval of allied health professionals
• Community-defined standards of cultural safety
• Localised, ongoing cultural learning.

5.4 Workforce Lessons

Evaluations of rural and remote allied health workforce initiatives including programs designed to support allied health assistant roles have highlighted challenges in recruitment, training, supervision, and sustainability in these complex contexts. These findings reinforce the need for properly funded, well-supervised, specialised allied health services delivered in collaboration with communities, rather than relying on assistant-only or short-term service models that cannot adequately meet community needs, especially within First Nations communities (refer SARRAH BRAWAH Report dated August 2025).

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5.5 Racism and Structural Inequities and Barriers to Effective Service Delivery

We remain concerned by racist assumptions that influence how some NDIS supports are delivered to First Nations participants, including:

• Reliance on standardised assessment tools. Standardised assessments that are neither culturally appropriate nor linguistically relevant often set First Nations participants up to fail from the outset, as these tools may not reflect linguistic diversity, cultural knowledge, or local context, resulting in inaccurate conclusions about ability or need.
• Consequences for service access. The use of standardised, Standardised English tests have been shown to over misdiagnose communication disorders and Intellectual Disability Disorder for First Nations children by misinterpreting cultural and linguistic differences as deficits and disorders. These concerns also apply to the use of the I-CAN as a Special Needs Assessment with First Nations peoples. When standardised assessments are applied without cultural adaptation, First Nations participants may be incorrectly assessed as having lower needs or abilities, which can lead to reduced funding, inappropriate therapy plans, and inequitable access to specialised allied health supports further compounding disadvantage in very remote communities.
• Superficial assessments and limited professional input. These outcomes are often exacerbated by assessments conducted by providers who have minimal knowledge of the participant, limited direct observation, and no hands-on experience with the participant’s location (Country), relying instead on brief reports, single tests or at best, second-hand information from other professionals. For the Fly In and Fly Out in a day allied health therapies, it is typically not logistically possible for the allied health therapists to involve a child participant’s family, to collaborate with other allied health, nursing, medical or child protection supports and to collaborate with ACHHOs and ACCOs. Such a lack of holistic service provision is not best practice for any children and especially not for First Nations children.
• Workforce scarcity and continuity issues. In very remote locations, the shortage of qualified, culturally safe allied health providers means participants may receive inconsistent, episodic, or fly-in/fly-out in a day services, undermining the continuity and cultural safety of care.
• Equity implications for First Nations participants. The combination of inappropriate standardised tools, inadequate developmental assessments, and workforce shortages disproportionately affects First Nations children and families, reinforcing existing systemic barriers and limiting their ability to access the supports they need to thrive.

These practices result in lower service standards and poorer outcomes for First Nations participants.

5.6 Community Control of Coordination and Plan Management

Supporting First Nations community control over support coordination, support workers, allied health therapies and plan management enhances transparency, trust, and culturally safe decision-making, and reduces the risk of misaligned or inappropriate service delivery.

6. PROVIDER IMPROVEMENTS

The NDIA Corporate Plan 2025-26 outlines the Key Functions to achieve the NDIA purpose and the strategies to achieve their stated goals. We note the NDIA Strategic Risk 2 – Providers and markets as follows:

Our ability to inform, engage and enable providers to deliver evidence-based, accessible and innovative supports to people with disability.

We agree that availability and performance of providers represent a significant risk in the achievement of NDIA performance targets. This is also reflected in key activities 1 and 3 of the NDIA Corporate Plan. In rural

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and remote areas, the availability of allied health personnel is limited, resulting in long wait times, or non- provision of services due to fully booked allied health professionals. The non-availability of service providers limits participant’s choice and control which is a key attribute of Function 1 of the NDIA. As a provider, we have seen little to no evidence of the NDIA’s reach out to provide support and information to improve in this area. The NDIA could assist in this area through positive programs for new graduates in relocating to rural and remote areas.

We also consider the NDIA Corporate Plan fails to reflect the importance of providers especially given they are providers of services, in our context therapy services, that aim to improve the lives of participants. We recommend the NDIA develop programs or networks that allow therapists to improve in providing services to people with disabilities.

A further area or potential improvement could, as an example, be achieved through providing support in achieving agreements with state governments of consistent access to school and education centres to deliver therapy services. This is particularly important especially with high-needs and autistic participants in the delivery of services as it:

• Assists in reducing the burden on carers to meet appointments when their lives are usually busy and obtaining paid employment is not negotiable.
• Assists therapists observe the teaching practices being employed and enable the integration of therapy with teaching programs.
• Minimises the impact on clients in having additional disruptions in their day and maintains routines.

Overall, our opinion is that providers need commensurate support and respect and should not be considered as organisations that commit fraud and be imposed with additional administrative burdens to reduce the NDIA’s budget.

7. EXAMPLES AND CASE STUDIES

Our business can provide de-identified examples and case studies illustrating:

• Ethical and effective use of NDIS funding
• Positive participant outcomes through place-based, on Country allied health supports
• Risks associated with poorly governed or disconnected service models.

These can be provided to the Committee upon request.

8. RECOMMENDATIONS

We recommend that the Committee consider:

1. Mandatory registration or tiered oversight for all providers accessing NDIS funds without exception.

2. Localised First Nations organisations such as ACCHOs and ACCOs be adequately funded to provide the much needed oversight of and collaboration with NDIS providers. The onus remains on non-Indigenous NDIS providers to do what is needed to ensure that we provide anti-racist and culturally safe NDIS funded supports.

3. Supporting the building of a First Nations allied health, support co-ordination and support worker workforce.

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4. Cultural safety for providers should not be certified solely via online courses, which allow highly variable engagement and learning outcomes yet result in the same credential. Certification should instead require evidence of applied learning, reflective practice, and genuine engagement with First Nations and diverse communities.
5. Enhanced real-time financial monitoring.
6. Consistent enforcement for misuse.
7. Improved participant safeguards and transparency.
8. Align and monitor billing with actual service delivery to prevent misrepresentation of provider discipline, safeguard participant outcomes, and maintain funding integrity.
9. Policy recognition of compliant, ethical providers.
10. Collaboratively work with state and territory governments to make schools and educational facilities open to therapy services.
11. Provide additional proactive support and educational programs for therapy service providers.
12. Better oversight on support coordination to eliminate potential coercive controls and promote choice and control.

9. CONCLUSION

The NDIS is one of Australia’s most important national investments in the wellbeing and independence of people with disability. Its sustainability and integrity rely on robust governance, effective administration, and rigorous oversight. Our experience as an ethical, registered, and audited allied health provider demonstrates that gaps in registration, compliance, and regulatory oversight allow unethical practices to occur, disproportionately affecting participants everywhere but most especially in very remote communities and for First Nations peoples.

The consequences of these gaps are significant: participants may experience disrupted or inappropriate services, limited choice and control, and diminished access to culturally safe, evidence-based allied health supports. These impacts are particularly acute for First Nations participants, who already face systemic barriers, workforce shortages, and geographic isolation. When oversight fails, the most vulnerable participants bear the greatest cost.

We urge the Committee to strengthen oversight arrangements so that every Commonwealth dollar delivers genuine benefit, particularly for those in very remote communities. This includes ensuring that providers are properly registered, subject to proportionate compliance monitoring, and accountable for both the quality and integrity of services delivered. Oversight and regulatory frameworks must also be assessed against measurable indicators of service quality, not merely compliance documentation or policy artefacts, and there must be transparent benchmarks for outcomes that reflect lived, participant-centred service delivery. Funding structures and regulatory systems must prioritise equitable access, culturally safe service delivery, and continuity of care, so that participants -regardless of location - can exercise genuine choice and receive supports that meet their assessed needs.

We further submit that those who set the rules, frameworks, and compliance structures for the NDIS must themselves be held accountable, with transparent, measurable standards that can be monitored and reported publicly. This includes ensuring that oversight authorities demonstrate how regulatory decisions and support allocations genuinely improve participant outcomes, rather than solely achieving the

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appearance of compliance or producing well-documented processes that are not consistently implemented. Financial compliance and auditing must go beyond verifying documentation or plan expenditure and instead be linked to measurable participant outcomes. Every dollar spent should be demonstrably contributing to participant progress, independence, and wellbeing, rather than simply satisfying box-ticking or paper-based compliance requirements.

We submit that closing these systemic gaps is essential not only for participant outcomes but also for the long-term sustainability, integrity, and public trust of the NDIS. Ethical providers, particularly those who operate in very remote and culturally diverse settings, especially with First Nations communities, must be supported and enabled, while actors who exploit loopholes or circumvent oversight must be effectively regulated.

We urge the Committee to strengthen oversight arrangements so that every Commonwealth dollar delivers genuine benefit, particularly for First Nations participants and those in very remote communities.

We stand ready to provide further evidence, de-identified case studies, and insights from on-the-ground service delivery to support the Committee’s work in identifying solutions that protect participants, safeguard public funds, and promote equity across the NDIS.

Finally, we urge the Committee not to let this review become a mere demonstration of effort, but to seize this opportunity to implement meaningful, lasting reforms that support all size of business supporting the NDIA. The NDIS is too valuable to allow gaps in oversight, quality, and accountability to persist. This includes identifying providers who are exploiting loopholes, circumventing oversight, or delivering substandard services, and taking decisive action to regulate, restrict, or remove them from the Scheme. Protecting participants and ethical providers depends on holding these actors accountable and ensuring that every dollar of NDIS funding delivers real, measurable benefit.

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