Building Scheme Integrity Through Workforce Sustainability, Clinical Evidence and Good Administration

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

Building Scheme Integrity Through Workforce Sustainability, Clinical Evidence and Good

Administration

Executive Summary

Professionals Australia welcomes the opportunity to provide this supplementary response to Questions on Notice arising from the Joint Committee of Public Accounts and Audit Inquiry into the Administration of the National Disability Insurance Scheme. This response should be read alongside Professionals Australia’s previous submissions and evidence provided during the Committee hearing.

Professionals Australia supports a sustainable, accountable and effective National Disability Insurance Scheme. We support measures that improve participant safety, strengthen public confidence, reduce fraud and ensure public funds are spent appropriately. However, we are increasingly concerned that current reform discussions are often framed as though integrity, financial sustainability, workforce sustainability and participant outcomes are separate policy objectives.

They are not.

Professionals Australia submits that long-term Scheme sustainability depends upon maintaining a stable and skilled workforce, making evidence-based decisions, supporting participants to achieve functional outcomes, and ensuring administrative systems operate fairly, transparently and efficiently. Integrity should not be understood solely as detecting fraud or reducing expenditure.

Integrity also requires decision-makers to have access to high-quality evidence, participants to have confidence in planning and review processes, providers to understand compliance obligations, and the workforce to remain capable of delivering supports across Australia. The Committee should recognise that allied health professionals, psychologists, social workers, interpreters and other professional practitioners are not simply service providers operating within the Scheme. They form part of the Scheme’s integrity infrastructure.

Every day, these professionals assess functional capacity, identify safeguarding concerns, monitor outcomes, recommend supports, detect emerging risks and provide the evidence upon which reasonable and necessary decisions are made. Without this workforce, the Scheme loses a critical source of expertise, oversight and accountability. Current policy settings are creating increasing pressure on that workforce.

Professionals Australia members consistently report growing administrative burden, increasing compliance requirements, repeated requests for evidence, audit costs, uncertainty regarding interpretation of pricing rules and growing concern regarding provider viability.

These concerns exist against a backdrop of prolonged pricing stagnation. Many allied health disciplines have now experienced approximately seven years without meaningful price growth

despite substantial increases in wages, insurance, supervision requirements, compliance obligations and operational costs. Recent pricing decisions have reduced rates for some professions even further.

The result is a growing risk of workforce attrition, provider withdrawal and market failure, particularly in regional, rural and thin market settings. This is not simply a workforce issue. It is a participant access issue, a safeguarding issue and ultimately an integrity issue.

Where providers leave the Scheme, participants frequently lose access to preventative and capacity- building supports that help maintain independence and avoid deterioration. The consequences are often experienced elsewhere through increased demand on public hospitals, mental health services, child protection systems, housing services and informal carers. Reducing expenditure within the NDIS does not necessarily reduce the overall cost of disability support. In many cases, costs are simply shifted elsewhere.

Professionals Australia is particularly concerned about reforms that prioritise short-term expenditure reduction without adequately considering long-term impacts on participants, families, the workforce and other government systems. The evidence is clear that timely access to allied health and therapeutic supports improves functional outcomes, promotes independence, supports education and employment participation, reduces crisis presentations and lowers long-term support requirements. Conversely, delaying, reducing or removing access to supports frequently increases future demand for more intensive and expensive interventions. The Committee should also consider the impact of administrative decision-making on Scheme sustainability. Poor administrative processes create substantial costs.

When evidence requirements are unclear, clinicians produce increasingly lengthy reports in an attempt to avoid rejection. When decisions are not adequately explained, participants seek review. When planners do not have sufficient time or support to properly consider clinical evidence, decisions are more likely to be challenged. These costs are significant.

The Committee will be aware that the Agency has spent substantial sums defending decisions through review and tribunal processes. During the 2024-25 financial year alone, approximately $60.7 million was spent on external legal services associated with Administrative Review Tribunal matters. Improving decision-making quality at the outset represents one of the strongest integrity measures available to the Scheme.

Professionals Australia is also concerned by proposals that increase reliance on standardised assessment tools without sufficient safeguards for clinical judgement, treating practitioner evidence and participant-specific circumstances. Standardised tools may assist consistency, but they cannot replace professional expertise.

Disability is inherently individual. Functional capacity is influenced by environmental factors, psychosocial circumstances, trauma history, cultural context, fluctuating symptoms, communication needs and a range of other factors that cannot be fully captured through standardised instruments alone. Consistency is important. However, consistency should be achieved through better decision-

making, improved training, clearer evidence standards and meaningful consideration of professional evidence. A consistently inaccurate decision is not fairness. It is simply a consistently inaccurate decision.

Professionals Australia further submits that procedural fairness must remain central to any reform agenda. Participants and clinicians must be able to understand how decisions are made, why evidence has been accepted or rejected, and what information is required where evidence is considered insufficient. Trust in the Scheme depends upon transparency. Where participants repeatedly experience decisions that appear disconnected from available evidence, confidence in the Scheme deteriorates. This submission therefore argues that the strongest path to long-term sustainability is not through increasingly restrictive compliance frameworks or administrative shortcuts.

Rather, sustainability will be achieved through investment in workforce capacity, proportionate regulation, evidence-based decision-making, clear administrative processes, participant-centred planning and genuine engagement with the professionals who implement the Scheme every day. Poor administration is not neutral. Poor administration creates cost, risk and harm. Getting decisions right at the beginning remains one of the most effective integrity measures available to the National Disability Insurance Scheme.

Professionals Australia would welcome the opportunity to provide further evidence or clarification to assist the Committee in its deliberations.

Question 1

Short-Term Versus Long-Term Impacts

(a) Impact of current compliance and cost containment approaches on long-term provider,

participant compliance and NDIS financial sustainability

Professionals Australia submits that current compliance and cost containment approaches are increasingly undermining the long-term sustainability of the National Disability Insurance Scheme. While accountability for public expenditure is essential, integrity measures that focus predominantly on short-term expenditure reduction risk creating significantly greater long-term costs for governments, participants, families and the broader community (Productivity Commission, 2019; NDIS Review, 2023; WHO, 2022).

The Committee should recognise that sustainability cannot be measured solely through annual reductions in Scheme expenditure. A reduction in expenditure is not necessarily a reduction in need. In many cases, expenditure reductions simply shift costs elsewhere or delay expenditure until needs become more acute, complex and expensive to address (Productivity Commission, 2011; OECD, 2021).

The NDIS was established to improve independence, participation, social inclusion and economic participation for people with disability (National Disability Insurance Scheme Act 2013 (Cth)).

Financial sustainability should therefore be assessed against these objectives rather than solely against annual expenditure targets.

Professionals Australia is concerned that current policy settings increasingly prioritise immediate budget containment over long-term functional outcomes, workforce sustainability and preventative intervention. This approach risks creating a false economy whereby apparent short-term savings generate substantially greater future liabilities. The NDIS was established to improve independence, participation, social inclusion and economic participation for people with disability. Financial sustainability should therefore be assessed against these objectives, rather than solely against annual expenditure targets.

Integrity and sustainability are not separate objectives; public discussions frequently treat integrity and sustainability as distinct policy goals. Professionals Australia submits that they are fundamentally interconnected. A sustainable Scheme must have integrity.

An integrity framework must be sustainable. The NDIS depends upon a highly skilled professional workforce to:

• assess functional capacity;
• identify safeguarding concerns;
• recommend evidence-based supports;
• monitor outcomes;
• identify emerging risks;
• prevent deterioration;
• support participant independence.

These professionals are not external to the integrity framework. They are part of it. Allied health professionals play a critical role in identifying risk, assessing functional capacity, supporting evidence- based decision making and preventing avoidable deterioration, all of which contribute to effective stewardship of public resources (Professionals Australia, 2026b; AHPA, 2026). Every occupational therapist conducting a home safety assessment, every speech pathologist preventing aspiration risk, every psychologist supporting emotional regulation, and every physiotherapist preventing functional decline contributes directly to Scheme integrity. They help ensure public funding is directed towards supports that are effective, necessary and evidence based. Any reform that undermines the workforce responsible for these functions ultimately undermines Scheme integrity itself.

The False Economy of Rationed Care

One of the most significant risks facing the Scheme is the assumption that reducing support expenditure automatically improves sustainability. This assumption is not supported by evidence from disability, health, mental health or social policy systems. Extensive international evidence demonstrates that early intervention, rehabilitation and community-based supports improve long- term participation outcomes and reduce future expenditure associated with crisis intervention, institutionalisation and health system utilisation (Productivity Commission, 2011; OECD, 2021; WHO,

2022). Reducing access to therapeutic intervention does not eliminate need. It frequently increases future need.

For example:

• reducing speech pathology may delay communication development and increase lifelong support dependence;
• reducing psychology services may increase crisis presentations and mental health admissions;
• reducing occupational therapy may increase falls, injuries and carer burden;
• reducing physiotherapy may accelerate functional decline and increase reliance on higher-cost supports;
• reducing behavioural supports may increase restrictive practices, crisis interventions and safeguarding risks.

These outcomes often cost substantially more than the supports that could have prevented them. The Committee should therefore distinguish between reducing expenditure and reducing costs because they are not necessarily the same thing. A cheaper plan today may create a more expensive participant tomorrow. Cost Shifting Does Not Equal Savings.

Professionals Australia is concerned that some current reforms may be reducing NDIS expenditure while increasing costs elsewhere across government. The NDIS does not operate in isolation.

Participants also interact with:

• public hospitals;
• mental health services;
• education systems;
• child protection systems;
• housing services;
• justice systems;
• primary healthcare services.

When participants lose access to supports, the consequences frequently emerge elsewhere.

Example: Dysphagia and Hospitalisation

Speech pathology interventions addressing dysphagia are well established as preventative measures that reduce aspiration risk, hospitalisation and associated health costs (Speech Pathology Australia, 2024; WHO, 2022). A participant with a significant swallowing disorder may require regular speech pathology support to maintain safe eating and drinking. If service access is reduced because providers withdraw from the Scheme or participants cannot access funding, the risk of aspiration pneumonia increases significantly. A single hospital admission for aspiration pneumonia may cost many times more than ongoing preventative speech pathology intervention.

Example: Psychosocial Disability

Loss of community-based psychosocial supports has been associated with increased mental health presentations, crisis interventions and housing instability (Productivity Commission, 2024; WHO, 2022). A participant with complex psychosocial disability may rely upon psychology, occupational therapy and psychosocial supports to maintain stability in the community.

Loss of these supports can result in:

• acute mental health presentations;
• psychiatric admissions;
• housing instability;
• homelessness;
• justice system involvement.

These costs are not eliminated. They are transferred. This phenomenon of cost shifting has been repeatedly identified in disability policy literature, where expenditure reductions within one system create increased demand on health, housing, justice and social support systems (Productivity Commission, 2019; NDIS Review, 2023).

Example: Early Childhood Intervention

Research consistently demonstrates that early intervention delivered during key developmental periods improves communication, educational engagement, independence and workforce participation outcomes across the life course (Productivity Commission, 2011; WHO, 2022). A child who cannot access early intervention during critical developmental periods may experience lifelong impacts across:

• education;
• employment;
• independence;
• social participation.

Delaying intervention frequently increases future support needs rather than reducing them.

Workforce Sustainability Is a Financial Sustainability Issue

Professionals Australia submits that workforce sustainability is one of the most overlooked determinants of long-term NDIS sustainability. The Scheme cannot function without a workforce capable of delivering supports. Workforce sustainability has been identified by multiple inquiries, peak bodies and government reviews as a critical determinant of long-term Scheme sustainability (Independent Advisory Council to the NDIS, 2022; AHPA, 2026; NDIS Review, 2023).

Current pressures include:

• prolonged pricing stagnation;

• workforce shortages;
• increasing compliance obligations;
• administrative burden;
• audit costs;
• registration requirements;
• payment uncertainty;
• workforce burnout.

Many providers report operating at or near financial viability thresholds. A significant number are limiting NDIS caseloads, reducing geographic coverage or considering leaving the Scheme entirely. Recent workforce surveys conducted by Professionals Australia found that 97.6 per cent of respondents reported negative impacts on their mental health associated with NDIS reforms and uncertainty, while approximately 75 per cent indicated they were considering leaving the sector within the next two to five years (Professionals Australia, 2026).

Where providers withdraw:

• participant choice declines;
• waitlists increase;
• continuity of care is disrupted;
• preventative supports become less accessible;
• participant outcomes deteriorate.

These outcomes increase future costs. They do not reduce them.

The Hidden Cost of Administrative Burden

Current administrative arrangements also create substantial hidden costs. Administrative burden has been repeatedly identified as a contributor to workforce dissatisfaction, reduced productivity and provider withdrawal across the disability sector (OECD, 2021; Independent Advisory Council to the NDIS, 2022). Clinicians increasingly spend significant time undertaking activities that are essential to safe service delivery but frequently unfunded.

These include:

• report writing;
• reassessment requests;
• responding to NDIA requests for information;
• multidisciplinary meetings;
• safeguarding documentation;
• audit preparation;
• compliance activities;
• review processes.

These tasks are important. However, they represent labour that could otherwise be directed towards participant support. The cumulative effect is reduced service capacity across the Scheme. This effectively transfers administrative costs from the Agency to providers without reducing the underlying workload required to safely deliver services (Professionals Australia, 2026). When highly trained clinicians spend increasing amounts of time on administration, participants receive fewer services and workforce productivity declines.

The Cost of Distrust

Many current administrative processes appear to be based upon an assumption that professional evidence requires extensive verification before it can be trusted. This approach is particularly concerning given that many allied health practitioners are already subject to professional registration, accreditation, insurance requirements, ethical obligations and disciplinary processes outside the NDIS framework (AHPRA, 2025; Professionals Australia, 2026).

This has created a cycle of:

• repeated reports;
• repeated reassessments;
• repeated evidence requests;
• repeated reviews.

The result is significant expenditure on administrative activity that does not necessarily improve participant outcomes. Clinicians frequently report writing increasingly lengthy reports because previous reports have been rejected without clear explanation. Participants report paying for multiple assessments to establish needs that have already been well documented. This is not an efficient use of participant funding or public resources.

Administrative Review Tribunal and Legal Costs

The Committee should note that the NDIA spent approximately $60.7 million on external legal services associated with Administrative Review Tribunal matters during the 2024-25 financial year (NDIS Joint Standing Committee, 2025). While review mechanisms are an essential component of procedural fairness, expenditure of this magnitude raises legitimate questions regarding the quality of primary decision-making and whether earlier resolution mechanisms could reduce administrative expenditure while improving participant outcomes.

Poor decision-making at the outset generates significant downstream expenditure. Where participants receive inadequate plans or decisions that fail to properly consider available evidence, disputes frequently escalate through:

• internal review;
• external review;
• Administrative Review Tribunal proceedings;
• legal representation.

The Committee should note that the NDIA has spent tens of millions of dollars defending decisions through review processes. These costs represent resources that could otherwise be directed towards participant supports. The existence of large volumes of review activity should prompt examination of decision quality rather than simply participant behaviour. A system that repeatedly produces decisions requiring correction is generating avoidable administrative expenditure.

Foundational Supports and System Readiness

Professionals Australia is particularly concerned about reforms that assume alternative supports exist before those supports are operational. Where participants are transitioned away from NDIS supports on the basis that foundational supports will become available, governments must ensure those services are:

• funded;
• staffed;
• operational;
• geographically accessible;
• culturally safe;
• capable of meeting demand.

Failure to do so risks creating service gaps that leave participants without support. This does not improve sustainability. It simply transfers risk to participants and families. This concern has been repeatedly raised by disability organisations and allied health peak bodies, particularly in relation to proposals to reduce participant numbers before foundational supports have been fully funded, staffed and implemented (AHPA, 2026; NDIS Review, 2023).

The Committee should recommend that significant transitions only occur once replacement systems are demonstrably operational.

Impact on Families and Informal Carers

The Productivity Commission has consistently recognised the significant economic contribution of informal carers and the risks associated with transferring support responsibilities from formal systems to unpaid family members (Productivity Commission, 2011). Current cost containment measures also risk increasing pressure on families and informal carers.

When formal supports are reduced, the burden frequently shifts to:

• parents;
• siblings;
• partners;
• friends;
• ageing carers.

This transfer of responsibility is often invisible within budget papers but very real for families.

The consequences can include:

• carer burnout;
• workforce withdrawal;
• reduced household income;
• mental health deterioration;
• family breakdown.

These impacts create both economic and social costs. They should be considered when evaluating sustainability.

Impact on Women’s Workforce Participation

The disability support system has a significant gender dimension. Women comprise the majority of the disability support workforce, the allied health workforce and informal caring arrangements across Australia (Australian Bureau of Statistics, 2022; Workplace Gender Equality Agency, 2024). Reductions in formal supports frequently increase unpaid caring responsibilities, creating adverse impacts on workforce participation, career progression, superannuation accumulation and economic security for women (Productivity Commission, 2024; OECD, 2021).

Women comprise the majority of:

• disability support workers;
• allied health professionals;
• carers;
• parents providing informal support.

Where supports are reduced:

• women are more likely to leave paid employment;
• women are more likely to reduce working hours;
• women are more likely to assume additional caring responsibilities.

This has implications for:

• workforce participation;
• economic productivity;
• retirement savings;
• gender equity.

These broader economic impacts should form part of any sustainability assessment.

Sustainability Requires Prevention

Preventative approaches are consistently identified in international disability and health policy literature as more cost-effective than crisis-driven interventions (WHO, 2022; OECD, 2021;

Productivity Commission, 2019). The most financially sustainable disability systems are those that prevent deterioration rather than simply respond to crisis.

Preventative intervention:

• improves independence;
• supports participation;
• reduces future support needs;
• reduces hospitalisations;
• supports employment;
• supports education;
• reduces carer burden.

These outcomes create savings across multiple systems. A sustainability framework that focuses only on immediate expenditure risks overlooking these benefits.

Recommendations

Professionals Australia recommends that:

1. Workforce sustainability be recognised as a core integrity and sustainability measure.
2. Integrity reforms be evaluated against long-term participant outcomes rather than short- term expenditure reduction alone.
3. Government adopt a whole-of-government approach to evaluating disability expenditure and cost shifting.
4. Workforce Impact Statements accompany significant reforms affecting pricing, planning, registration or compliance.
5. Administrative burden on clinicians be reduced through clearer evidence requirements and targeted resubmission pathways.
6. Governments ensure foundational supports are fully operational before relying upon them to replace NDIS-funded services.
7. Sustainability assessments include consideration of impacts on carers, workforce participation and economic productivity.
8. Greater attention be given to preventative and capacity-building supports as long-term cost reduction measures.

Conclusion

Professionals Australia submits that the long-term sustainability of the NDIS depends not on how effectively the Scheme reduces expenditure in a single budget cycle, but on how effectively it supports participants to maintain independence, participation and wellbeing over time. Policies that reduce access to evidence-based supports may appear to generate savings in the short term. However, many simply shift costs elsewhere, increase future liabilities and undermine the workforce responsible for delivering outcomes.

True sustainability requires investment in prevention, workforce capacity, good administration and evidence-based decision-making. The most sustainable Scheme is not the Scheme that spends the least. It is the Scheme that spends wisely, prevents deterioration, supports participation and reduces future demand for high-cost interventions. That approach strengthens both Scheme integrity and long-term financial sustainability.

Question 2

Pricing Settings and Financial Sustainability

(a) Detail on how pricing caps, workforce instability and service withdrawal are impacting financial sustainability of the NDIS

Professionals Australia submits that current pricing settings represent one of the most significant risks to the long-term sustainability of the National Disability Insurance Scheme. Multiple reviews and inquiries have identified workforce sustainability, provider viability and thin market failure as significant risks to the future operation of the Scheme (Productivity Commission, 2019; Independent Advisory Council to the NDIS, 2022; NDIS Review, 2023).

While pricing caps are intended to provide expenditure certainty and protect public funds, the current approach increasingly fails to reflect the actual cost of delivering safe, evidence-based and professionally accountable disability services.

The Committee should recognise that pricing policy is not merely a financial mechanism. Pricing settings directly influence workforce participation, provider viability, market stability, participant access and long-term Scheme expenditure.

A pricing framework that is disconnected from the realities of service delivery ultimately undermines both participant outcomes and Scheme sustainability. International evidence consistently demonstrates that disability support systems achieve better long-term outcomes when pricing arrangements support workforce retention, continuity of care and early intervention rather than simply focusing on expenditure restraint (OECD, 2021; WHO, 2022).

The central question is not whether providers can survive in the short term. The question is whether the Scheme can retain the skilled workforce required to deliver supports over the coming decade.

Professionals Australia is increasingly concerned that current pricing arrangements are contributing to workforce attrition, provider withdrawal and reduced service availability, particularly in regional, remote and thin market settings.

These developments do not strengthen Scheme sustainability. They weaken it.

The Myth of the Published Hourly Rate

Public discussions regarding provider viability often rely upon the assumption that published NDIS hourly rates reflect provider earnings. This assumption is fundamentally flawed.

The published hourly rate is not equivalent to take-home income, profit or sustainable revenue.

Rather, it must cover the full cost of delivering a professional service. This distinction is frequently overlooked in public discussions regarding NDIS pricing. Published hourly rates represent gross business revenue, not clinician earnings, and must fund all aspects of service delivery, governance and regulatory compliance (AHPA, 2026; OECD, 2021)

For allied health professionals and other regulated practitioners, this includes:

• salaries and wages;
• superannuation;
• workers compensation;
• professional indemnity insurance;
• public liability insurance;
• registration and accreditation fees;
• continuing professional development;
• supervision requirements;
• clinical governance;
• cybersecurity requirements;
• privacy compliance;
• software and practice management systems;
• rent and utilities;
• administration;
• bookkeeping and accounting;
• travel;
• report writing;
• multidisciplinary collaboration;
• safeguarding activities;
• compliance requirements.

These costs continue regardless of whether a clinician is delivering a billable service. Accordingly, the published hourly rate significantly overstates actual provider earnings. The Independent Advisory Council to the NDIS has previously recognised that provider sustainability depends not only on direct service delivery costs but also on the broader operating environment, including workforce, compliance and administrative obligations (Independent Advisory Council to the NDIS, 2022).

The Committee should exercise caution when comparing NDIS pricing rates to hourly wages or individual incomes. They are not comparable.

Non-Billable Labour and Hidden Costs

One of the most significant challenges facing the workforce is the growing volume of non-billable work required to safely deliver services.

Many activities essential to participant outcomes cannot be directly billed. Professionals Australia members consistently report that significant portions of their working week are devoted to activities necessary for participant safety, continuity of care and regulatory compliance, yet these activities are frequently unfunded or only partially funded (Professionals Australia, 2026a; Professionals Australia, 2026c).

These include:

• reviewing clinical records;
• documenting progress notes;
• preparing reports;
• attending multidisciplinary meetings;
• communicating with families;
• consulting with schools;
• consulting with support coordinators;
• responding to NDIA requests;
• safeguarding documentation;
• quality assurance processes;
• professional supervision.

These activities are not optional. They are integral to ethical and effective practice. However, many participants do not receive funding sufficient to cover these activities. Historically, many clinicians absorbed these costs as unpaid labour. This has effectively transferred administrative and compliance costs from government to providers, a practice that becomes increasingly unsustainable as compliance expectations continue to expand (OECD, 2021; Professionals Australia, 2026c).

This model is no longer sustainable.

Members consistently report that increasing administrative complexity is consuming growing amounts of professional time. Consequently, providers are increasingly forced to choose between:

• reducing service quality;
• reducing participant contact time;
• absorbing unpaid labour; or
• exiting the Scheme altogether.

None of these outcomes support long-term sustainability.

The Seven-Year Pricing Freeze

Professionals Australia remains deeply concerned about the prolonged stagnation of allied health pricing. Several allied health disciplines have experienced approximately seven years without meaningful price increases despite substantial increases in operating costs. Allied health therapy rates were frozen from 2019 onward, while recent Annual Pricing Reviews have reduced rates for some disciplines, including physiotherapy, dietetics and podiatry (NDIA, 2025; AHPA, 2026).

During this same period providers have experienced increases in:

• wages;
• superannuation contributions;
• insurance costs;
• rent;
• fuel;
• technology expenses;
• registration costs;
• compliance requirements;
• professional development obligations.

Recent pricing decisions have further reduced rates for some professions. This has created a situation in which providers are expected to deliver increasingly complex services while receiving remuneration that has not kept pace with inflation or operational realities.

If NDIS pricing had maintained parity with cumulative inflation over this period, rates would be substantially higher than current pricing limits. This divergence between pricing and operating costs has been repeatedly raised by providers, peak bodies and workforce organisations as a significant threat to workforce sustainability (AHPA, 2026; OECD, 2021).

By comparison, other publicly funded systems have recognised the need to adjust provider remuneration to maintain service viability. For example, the Department of Veterans’ Affairs has implemented substantial pricing increases for a range of allied health and psychological services. The absence of equivalent adjustments within the NDIS risks creating workforce migration away from disability services and towards more sustainable sectors (AHPA, 2026).

The practical effect is an ongoing reduction in real provider income. This is not sustainable indefinitely.

Travel and Community-Based Service Delivery

Professionals Australia is particularly concerned about the impact of travel-related pricing changes on participant access.

For many allied health professions, travel is an essential component of evidence-based practice. Peak professional bodies including Speech Pathology Australia, Occupational Therapy Australia and the World Federation of Occupational Therapists have consistently emphasised the importance of

delivering supports within participants’ natural environments to maximise functional outcomes and support participation (WFOT, 2022; Speech Pathology Australia, 2024).

Best-practice disability support frequently requires service delivery in natural environments, including:

• homes;
• schools;
• childcare settings;
• workplaces;
• community settings;
• supported accommodation environments.

These environments provide critical information about functional capacity, environmental barriers and support requirements. An occupational therapist conducting a home modification assessment cannot safely perform that assessment without attending the participant’s home. A speech pathologist implementing an augmentative communication device may need to work directly with teachers and support staff in a classroom. A physiotherapist may need to assess mobility within the participant’s actual living environment. Travel is therefore often intrinsic to service delivery.

Where travel becomes financially unviable, providers are forced to:

• reduce outreach;
• limit geographic coverage;
• restrict participant intake;
• withdraw from regional services.

These outcomes disproportionately affect participants living outside metropolitan centres. Participants living in regional, rural and remote communities are particularly vulnerable to these changes because they often have limited alternative providers available (Independent Advisory Council to the NDIS, 2022).

Regional and Thin Market Economics

The economic realities of regional practice differ substantially from metropolitan service delivery.

Regional providers frequently face:

• greater travel requirements;
• lower participant density;
• reduced economies of scale;
• increased recruitment challenges;
• workforce shortages;

• higher operating costs.

The NDIS Independent Advisory Council has repeatedly identified thin market failure as a significant risk in regional, remote and specialist service settings (Independent Advisory Council to the NDIS, 2022).

Many pricing assumptions appear to be based upon metropolitan service models. These assumptions often fail to reflect the realities of servicing regional, remote and thin market communities. Where pricing arrangements fail to account for these realities, service withdrawal becomes increasingly likely. Participants in regional areas frequently have limited alternative options. Provider withdrawal therefore has a disproportionate impact on access. This creates a cycle whereby workforce shortages further reduce provider viability, making recruitment and retention increasingly difficult.

Workforce Attrition and Provider Withdrawal

Professionals Australia is increasingly concerned by reports of workforce exit across multiple professional groups. Recent workforce survey findings from Professionals Australia indicate that 97.6 per cent of respondents reported negative impacts on their mental health associated with NDIS reform processes and uncertainty, while approximately 75 per cent indicated they were considering leaving the sector within the next two to five years (Professionals Australia, 2026a).

Members frequently describe feeling trapped between:

• professional obligations;
• participant needs;
• administrative expectations;
• financial realities.

Many clinicians entered disability practice because they are committed to improving participant outcomes. However, commitment alone cannot compensate indefinitely for unsustainable operating conditions. Workforce attrition is not simply a workforce issue. The NDIS Review identified workforce sustainability as a critical factor in maintaining participant access and Scheme effectiveness over time (NDIS Review, 2023).

This is a sustainability issue.

When experienced clinicians leave:

• participants lose established therapeutic relationships;
• waiting lists increase;
• workforce shortages worsen;
• recruitment costs rise;
• continuity of care is disrupted.

These impacts frequently generate additional costs elsewhere within the Scheme.

Market Failure and Service Scarcity

Restrictive pricing settings can create market failure. Market failure occurs when providers are unable to sustainably deliver services despite ongoing participant demand. This risk has been repeatedly identified in relation to disability supports delivered in regional, remote and specialised practice areas (Productivity Commission, 2019; Independent Advisory Council to the NDIS, 2022).

This is particularly evident when providers:

• stop accepting NDIS participants;
• cap NDIS caseloads;
• withdraw from regional communities;
• cease delivering complex services;
• close practices altogether.

The resulting scarcity has significant consequences.

Participants may experience:

• delayed intervention;
• reduced service frequency;
• interrupted care;
• inability to access specialist supports.

The assumption that another provider will simply replace the departing provider is often incorrect. In many communities there is no replacement provider available.

Cost Shifting to Health Systems

The Committee should be cautious about interpreting reduced disability expenditure as genuine savings. Where participants lose access to preventative supports, costs frequently emerge elsewhere.

Example: Swallowing Disorders

A participant with dysphagia may require ongoing speech pathology support to maintain safe eating and drinking. If access to services is disrupted due to workforce shortages or provider withdrawal, the participant may experience aspiration pneumonia requiring hospitalisation. The cost of a hospital admission frequently exceeds the cost of ongoing preventative intervention. Dysphagia management is widely recognised as a preventative intervention that reduces aspiration risk, respiratory complications and avoidable hospitalisation (Speech Pathology Australia, 2024; WHO, 2022).

Example: Falls Prevention

A participant unable to access physiotherapy or occupational therapy may experience preventable falls. Falls can result in:

• fractures;

• emergency department presentations;
• surgery;
• rehabilitation;
• long-term support increases.

Again, these costs substantially exceed the cost of preventative intervention. Falls prevention interventions delivered by physiotherapists and occupational therapists have consistently demonstrated positive health and economic outcomes by reducing avoidable injuries and hospital presentations (WHO, 2022; Productivity Commission, 2019).

Example: Psychosocial Disability

Participants with psychosocial disability frequently rely upon ongoing therapeutic supports to maintain stability.

Loss of these supports may contribute to:

• crisis presentations;
• psychiatric admissions;
• homelessness;
• justice system involvement.

These outcomes create substantial costs for governments and communities. Community-based psychosocial supports are widely recognised as reducing crisis service utilisation, acute admissions and homelessness risk (Productivity Commission, 2024; WHO, 2022)

Productivity and Economic Participation

The sustainability of the NDIS should also be considered within the broader context of economic participation.

One of the founding objectives of the NDIS was to improve economic and social participation for people with disability (NDIS Act 2013; Productivity Commission, 2011). Effective allied health interventions support:

• workforce participation;
• educational participation;
• community engagement;
• independence.

Where participants lose access to supports, their ability to participate economically may be reduced. Similarly, family members often reduce employment participation when disability supports become unavailable. This is particularly relevant for women, who continue to undertake a disproportionate share of unpaid caring responsibilities. Research consistently demonstrates that reductions in formal disability supports increase unpaid caring responsibilities, disproportionately affecting women’s

workforce participation, earnings and retirement savings (OECD, 2021; WGEA, 2024; Productivity Commission, 2024).

A sustainability framework focused solely on Scheme expenditure risks overlooking these broader economic impacts.

International Evidence

International evidence consistently demonstrates that early intervention, rehabilitation and community-based supports produce positive economic returns over time. The United Nations Convention on the Rights of Persons with Disabilities recognises access to rehabilitation, rehabilitation and community participation as fundamental rights and emphasises the importance of supports that maximise independence and inclusion (United Nations, 2006, Articles 19 and 26). Consistent with these obligations, international disability policy increasingly recognises that long- term sustainability is achieved through investment in participation, prevention and community-based supports rather than crisis-driven intervention models (WHO, 2022; OECD, 2021).

The OECD (2021), World Health Organization (2022) and Productivity Commission (2011, 2019) have all emphasised the importance of disability support systems that maximise participation and functional capacity. These outcomes are not achieved through expenditure restraint alone. They require investment in workforce capacity and evidence-based interventions.

Recommendations

Professionals Australia recommends that:

1. NDIS pricing arrangements be independently reviewed against actual service delivery costs.
2. Workforce sustainability be recognised as a core component of Scheme sustainability.
3. Pricing models explicitly recognise non-face-to-face work required for safe and effective service delivery.
4. Travel arrangements be reviewed to ensure continued viability of regional, remote and community-based services.
5. Workforce Impact Statements accompany future pricing reforms.
6. Additional pricing considerations be developed for regional, remote and thin market settings.
7. Government undertake regular monitoring of provider withdrawal and workforce attrition.
8. Market stewardship measures include participant access indicators, not simply provider registration numbers.
9. Pricing decisions be assessed against likely impacts on participant outcomes, workforce retention and long-term government expenditure.

Conclusion

Professionals Australia submits that pricing policy cannot be separated from workforce sustainability, participant access and long-term Scheme performance.

Current pricing settings are increasingly contributing to workforce instability and provider withdrawal at a time when participant needs remain significant and workforce shortages continue to grow.

The Committee should recognise that the most financially sustainable Scheme is not necessarily the Scheme with the lowest annual expenditure.

Rather, it is the Scheme that retains a skilled workforce, supports early intervention, prevents deterioration and maximises participant independence.

A pricing framework that undermines provider viability may reduce expenditure temporarily, but it risks creating substantially greater costs in the future.

True sustainability requires investment in the workforce that delivers outcomes.

Without that workforce, the objectives of the NDIS cannot be achieved.

Question 3

Transparency Over Compliance Requirements

(a) To what extent are these issues occurring?

Professionals Australia submits that uncertainty regarding compliance requirements has become a significant and systemic issue throughout the National Disability Insurance Scheme.

The issue extends well beyond isolated examples of confusion or administrative inconsistency. Frontline professionals, participants and providers increasingly report difficulty understanding what is required to remain compliant, what evidence is necessary to support funding decisions, how Pricing rules should be interpreted, and how compliance decisions are made.

This uncertainty creates costs throughout the Scheme. It creates costs for participants, providers, planners, delegates, reviewers and government. Importantly, compliance uncertainty does not strengthen Scheme integrity. It undermines it.

A compliance framework functions most effectively when expectations are clear, consistently applied and proportionate to risk. Where requirements are ambiguous, inconsistently interpreted or subject to retrospective reinterpretation, providers become less confident, participants become less certain and disputes become more likely (OECD, 2021; ANAO, 2025).

Professionals Australia submits that the current environment is characterised by increasing compliance complexity without corresponding improvements in clarity, consistency or transparency.

Compliance Uncertainty Is a Systemic Issue

Members consistently report uncertainty regarding:

• travel claiming;
• non-face-to-face supports;
• report-writing expectations;
• evidence requirements;
• documentation standards;
• audit expectations;
• registration obligations;
• record-keeping requirements;
• support categorisation;
• plan interpretation.

Importantly, most providers are not seeking to avoid compliance. They are actively attempting to comply. The problem is that many providers struggle to determine exactly what compliance requires.

This distinction is critical.

A system cannot reasonably expect compliance where rules are unclear, inconsistent or subject to changing interpretation. The Australian National Audit Office has repeatedly highlighted the importance of transparent compliance systems, clear guidance and proportionate risk-based approaches to regulatory oversight (ANAO, 2025).

Professionals Australia submits that many current compliance challenges stem not from provider unwillingness but from administrative complexity and inconsistent interpretation.

Inconsistent Interpretation of Rules

One of the most frequently reported concerns is inconsistency in the interpretation of NDIS rules.

Providers regularly report situations where:

• a claiming practice considered acceptable by one delegate is questioned by another;
• documentation accepted during one audit is rejected during another;
• providers receive conflicting advice regarding the same issue;
• regional offices apply different interpretations of pricing arrangements;
• participants receive different advice depending upon which planner or Local Area Coordinator they speak with.

This inconsistency creates significant uncertainty. Participants and providers should not be required to navigate multiple interpretations of the same rule. Compliance systems function most effectively when expectations are predictable and transparent.

Professionals Australia is particularly concerned that providers are increasingly making decisions based on perceived audit risk rather than participant need. This creates a compliance culture driven by uncertainty rather than confidence.

Travel Claims as a Case Study in Compliance Uncertainty

Travel provides a useful example of how compliance uncertainty manifests in practice. For many allied health professions, travel is an essential component of evidence-based practice.

International professional standards recognise that participants frequently achieve better outcomes when services are delivered in natural environments such as homes, schools and community settings (WFOT, 2022; WHO, 2022).

However, members consistently report uncertainty regarding:

• when travel can be claimed;
• how travel should be documented;
• whether travel will withstand audit scrutiny;
• how travel rules apply across different support categories;
• whether regional travel is treated differently.

Many providers report that travel claims considered compliant in one circumstance are subsequently questioned in another. This uncertainty creates financial risk for providers and contributes to reluctance to provide services in regional and remote communities. The result is reduced access for participants. The issue is not merely administrative. It directly affects service availability.

Administrative Trauma and Workforce Impact

Professionals Australia is increasingly concerned about the psychological impact of compliance uncertainty on the workforce. Members frequently describe the compliance environment as stressful, unpredictable and adversarial.

Many report spending significant time worrying about:

• audits;
• payment holds;
• retrospective reviews;
• evidence requirements;
• interpretation changes;
• administrative disputes.

This burden has become sufficiently widespread that many clinicians now describe experiencing “administrative trauma” associated with the Scheme. Recent Professionals Australia workforce survey findings indicate that approximately 97.6 per cent of respondents reported negative impacts on their mental health associated with NDIS reforms, administrative uncertainty and compliance concerns (Professionals Australia, 2026a).

This statistic should be understood as a workforce sustainability issue. A compliance system that creates widespread workforce distress ultimately undermines participant access and Scheme performance.

Retrospective Scrutiny and Provider Confidence

Professionals Australia supports appropriate compliance monitoring. However, compliance systems should focus on preventing errors before they occur rather than retrospectively penalising providers who acted in good faith based on available guidance. Providers report increasing concern regarding retrospective reinterpretation of rules.

Where guidance is unclear, providers may believe they are acting appropriately only to discover later that a different interpretation has been applied. This creates significant financial uncertainty. A provider cannot confidently operate within a system where compliance expectations appear to change after services have already been delivered. Regulatory best practice generally emphasises prospective guidance, education and risk-based intervention rather than retrospective enforcement where rules are ambiguous (OECD, 2021).

The Hidden Cost of Compliance Complexity

Compliance complexity creates costs that are often invisible within Scheme expenditure reporting.

Every hour spent:

• preparing audit documentation;
• seeking clarification;
• responding to reviews;
• rewriting reports;
• documenting routine activities in excessive detail;

is an hour that cannot be spent supporting participants. These costs are real. They are simply shifted from government administration to frontline providers. Professionals Australia submits that current compliance settings increasingly require clinicians to undertake substantial volumes of administrative labour that contribute little to participant outcomes. This is particularly concerning given widespread workforce shortages and growing demand for services.

Compliance Burden on Sole Traders and Small Practices

The impact of compliance requirements is not evenly distributed across the provider market.

Large organisations often possess:

• dedicated compliance staff;
• legal teams;
• governance units;
• administrative support functions.

Sole traders and small practices do not. The same compliance requirement may therefore impose dramatically different burdens depending upon provider size. For a sole practitioner, preparing for an audit may require sacrificing billable clinical time.

For a large provider, the task may be absorbed by existing administrative staff. A compliance framework that does not recognise these differences risks disproportionately disadvantaging small providers and contributing to market consolidation.

This is particularly concerning given the important role played by sole traders and small practices in regional and thin market settings (Independent Advisory Council to the NDIS, 2022).

Evidence Requirements and Administrative Escalation

Professionals Australia members consistently report uncertainty regarding evidentiary expectations.

Clinicians frequently describe situations where:

• reports are rejected without clear explanation;
• additional evidence is requested after substantial documentation has already been provided;
• participants are required to obtain multiple assessments addressing similar issues;
• recommendations are questioned without identifying specific deficiencies.

The predictable response is defensive reporting. Clinicians increasingly produce longer reports because shorter reports are perceived as more likely to be rejected. This contributes to escalating costs for participants and providers. The Committee should recognise that lengthy reports are often a symptom of administrative uncertainty rather than clinical preference. If evidence requirements were clearer, reports could become shorter, more targeted and more efficient.

The Compliance Burden on Participants

Compliance complexity does not only affect providers. Participants and families frequently report confusion regarding:

• what supports can be purchased;
• what evidence is required;
• how funding categories operate;
• whether particular services can be claimed;
• how reviews work;
• what documentation must be retained.

This confusion creates barriers to effective use of plans. Professionals Australia is particularly concerned that participants with:

• low health literacy;
• cognitive disability;
• psychosocial disability;
• limited English proficiency;
• limited informal support;

may be disproportionately disadvantaged by complex administrative systems. Complexity itself can become an access barrier.

Compliance Uncertainty and Procedural Fairness

Transparency is a prerequisite for procedural fairness. Participants and providers cannot reasonably comply with expectations they do not understand. Similarly, they cannot meaningfully challenge decisions if they do not understand how those decisions were reached. Professionals Australia submits that transparency should be viewed as an integrity measure.

Transparent systems:

• improve compliance;
• reduce disputes;
• increase trust;
• reduce review activity;
• improve decision quality.

Conversely, opaque systems generate confusion, contestation and administrative cost.

(b) How Could Transparency Be Improved?

Nationally Consistent Interpretation Framework

The NDIA should establish a nationally binding interpretation framework for pricing, claiming and compliance requirements. Participants and providers should receive the same answer regardless of:

• geographic location;
• regional office;
• delegate;
• planner;
• auditor.

Consistency is essential to fairness.

Public Compliance Guidance Register

Professionals Australia recommends the creation of a publicly accessible register containing:

• pricing interpretations;
• compliance rulings;
• frequently asked questions;
• examples of compliant practice;
• audit guidance.

This would significantly reduce uncertainty and improve voluntary compliance.

Risk-Based Compliance

Compliance activity should be proportionate to risk. Highly regulated professionals already operate under:

• professional registration requirements;
• ethical obligations;
• insurance requirements;
• disciplinary frameworks;
• continuing professional development obligations.

Compliance systems should recognise existing safeguards rather than duplicating them. The ANAO has repeatedly emphasised the importance of risk-based compliance approaches that direct resources toward genuine areas of concern rather than applying blanket compliance expectations across all providers (ANAO, 2025).

Greater Use of Education

Compliance improves when providers understand expectations. The NDIA should expand:

• education initiatives;
• guidance materials;
• webinars;
• provider engagement forums;
• clarification mechanisms.

Providers should be supported to comply rather than primarily monitored for failure.

Targeted Correction Pathways

Where compliance issues arise, providers should have access to mechanisms that allow them to correct errors before punitive action is taken. Many compliance issues arise from misunderstanding rather than misconduct. Correction pathways improve compliance while maintaining provider engagement.

Transparency Around Audit Processes

Providers should clearly understand:

• what triggers an audit;
• what evidence is required;
• how findings are determined;
• how decisions can be reviewed.

Greater transparency would improve confidence and reduce anxiety associated with compliance processes.

Recommendations

Professionals Australia recommends that:

1. The NDIA establish a nationally binding compliance interpretation framework.
2. A publicly accessible compliance guidance register be created.
3. Compliance activities adopt a risk-based approach recognising existing professional regulation.
4. Greater emphasis be placed on education and early intervention rather than retrospective enforcement.
5. Audit processes be made more transparent and consistent.
6. Clear, support-specific evidence standards be developed in consultation with frontline professionals.
7. Compliance requirements be assessed for their impact on workforce sustainability and participant access.
8. Administrative burden be treated as a measurable policy outcome within future reforms.
9. Frontline allied health professionals be formally involved in the development of compliance frameworks.

Conclusion

Professionals Australia submits that compliance uncertainty has become a significant and systemic issue across the NDIS. The challenge is not a lack of willingness to comply. The challenge is a lack of clarity, consistency and transparency. A compliance system functions best when participants and providers understand what is expected of them.

Current arrangements too often generate confusion, defensive practice, workforce stress and administrative inefficiency. Improving transparency would strengthen Scheme integrity, improve provider confidence, reduce disputes and support better outcomes for participants. The Committee should recognise that transparency is not merely an administrative principle, it is one of the most effective compliance tools available to government.

Question 4

Standardised Information, Assessment Tools and Review Mechanisms

(a) Impact of centralised and standardised assessment approaches on participant outcomes, provider compliance and Scheme integrity

Professionals Australia supports efforts to improve consistency, transparency and fairness in NDIS decision-making. Participants with similar levels of functional impairment should not receive substantially different outcomes based on geography, planner experience, local practice variations or inconsistent interpretation of evidence.

However, Professionals Australia is concerned that increasing reliance on standardised assessment approaches may unintentionally undermine the individualised and evidence-based principles upon

which the NDIS was founded. Consistency is important. Accuracy is more important. A consistently inaccurate decision is not a fair decision. It is simply a consistently inaccurate decision.

The Committee should therefore ensure that standardised assessment tools support, rather than replace, professional judgement, treating practitioner evidence and participant-specific circumstances.

The NDIS was established to provide reasonable and necessary supports based on the individual circumstances, goals, functional capacity and support needs of each participant (NDIS Act 2013). Any assessment framework that reduces disability to a standardised score, classification or administrative category risks undermining this foundational principle.

Human Rights Framework

The Committee should consider assessment reform within Australia’s broader human rights obligations. Australia is a signatory to the United Nations Convention on the Rights of Persons with Disabilities (CRPD). Article 19 recognises the right of people with disability to live independently and participate fully in the community. Article 26 recognises the importance of habilitation and rehabilitation services that maximise independence, participation and inclusion (United Nations, 2006).

These obligations are reflected in the objectives of the NDIS Act, which emphasises:

• independence;
• social participation;
• economic participation;
• individual choice and control.

Assessment systems should therefore be designed not merely to control expenditure but to support these legislative and human rights objectives. Any assessment model that prioritises administrative efficiency at the expense of individual circumstances risks undermining the purpose of the Scheme itself.

Standardisation and Individualisation Are Not the Same Thing

The desire for consistency within the Scheme is understandable. The NDIS Review identified substantial variation in planning outcomes and participant experiences across different regions and planning teams (NDIS Review, 2023). However, consistency should not be confused with standardisation.

Disability is inherently individual. Two participants with the same diagnosis may have profoundly different support requirements depending upon:

• age;
• environment;
• communication needs;

• psychosocial factors;
• family supports;
• cultural context;
• trauma history;
• co-occurring conditions;
• education and employment circumstances.

A planning framework that prioritises standardisation at the expense of individualisation risks creating inequitable outcomes. The Productivity Commission recognised during the original design of the NDIS that individualised funding was a core mechanism for promoting participant choice, control and inclusion (Productivity Commission, 2011). Professionals Australia submits that reforms should preserve this principle.

Functional Capacity Cannot Be Reduced to a Single Score

Many disabilities cannot be accurately understood through a single assessment event or standardised instrument. Functional capacity is dynamic. It is influenced by:

• environment;
• fatigue;
• support availability;
• psychological state;
• communication barriers;
• pain;
• sensory processing;
• cumulative demands.

For example, a participant with autism may appear highly capable during a structured assessment but experience significant functional impairment in educational, employment or community environments due to sensory overload, executive functioning challenges or communication barriers. Similarly, participants with psychosocial disability may present well during short appointments while experiencing substantial functional impairment across longer periods.

Research consistently demonstrates that disability-related functioning is strongly influenced by environmental and contextual factors rather than diagnosis alone (World Health Organization, 2022). This complexity cannot always be captured through standardised assessment tools.

Hidden and Fluctuating Disability

Professionals Australia is particularly concerned about the impact of standardised assessment approaches on participants with hidden, episodic or fluctuating disabilities.

Examples include:

• psychosocial disability;

• chronic fatigue syndrome;
• Ehlers-Danlos syndrome;
• acquired brain injury;
• multiple sclerosis;
• functional neurological disorders;
• chronic pain conditions;
• post-viral syndromes.

These participants may experience significant variability in functioning over time. A short assessment may capture performance on a good day while failing to identify the cumulative impacts of fatigue, pain, symptom fluctuation or environmental stressors.

The World Health Organization’s International Classification of Functioning, Disability and Health (ICF) framework emphasises that disability arises through interactions between health conditions and environmental factors, rather than being determined solely by observable impairment (WHO, 2022). Professionals Australia submits that any assessment model adopted by the NDIA should reflect this understanding.

Importance of Natural Environment Assessment

Many functional impairments are only apparent within real-world environments. Professional bodies such as the World Federation of Occupational Therapists and Speech Pathology Australia recognise the importance of assessing participants within their actual living, learning and working environments (WFOT, 2022; Speech Pathology Australia, 2024). For example:

• home modification assessments require direct observation of the participant’s home;
• assistive technology assessments frequently require equipment trials in natural environments;
• communication supports must often be assessed in schools, workplaces or community settings;
• behavioural supports frequently depend upon environmental factors.

A standardised assessment conducted in an office environment may not adequately identify these issues. Assessment systems should therefore support rather than discourage real-world functional assessment. This becomes particularly important if travel funding is reduced or assessment processes become increasingly centralised.

Impact on Children and Early Intervention

Professionals Australia is particularly concerned about the impact of standardised assessment approaches on children. Child development is not linear. Developmental trajectories vary considerably between children, particularly where disability is present. Many developmental gains occur gradually over time and may not be fully captured through short assessment processes.

The Productivity Commission recognised early intervention as one of the core foundations of the original NDIS design because of its capacity to improve long-term participation outcomes and reduce future support needs (Productivity Commission, 2011).

Assessment systems should therefore be sufficiently flexible to recognise:

• developmental potential;
• family circumstances;
• educational participation;
• communication development;
• behavioural supports;
• safeguarding needs.

Overly rigid assessment frameworks risk underestimating support requirements during critical developmental periods.

Cultural Safety and Communication Barriers

Assessment systems must also account for cultural and linguistic diversity. Participants from culturally and linguistically diverse backgrounds may experience barriers relating to:

• language;
• health literacy;
• cultural expectations;
• access to interpreters;
• previous experiences with government systems.

Assessment tools developed within one cultural context may not always perform consistently across diverse populations. Where standardised assessments are used, culturally safe implementation and access to qualified interpreters are essential. Failure to account for these factors risks producing inaccurate assessments and inequitable outcomes.

Clinical Judgement Must Remain Central

Allied health professionals are specifically trained to assess complex interactions between impairment, environment, participation and support needs. Professional assessments involve:

• clinical reasoning;
• observation;
• functional analysis;
• risk assessment;
• multidisciplinary consultation;
• evidence synthesis.

These processes cannot be fully replicated by standardised tools. Assessment instruments may provide useful information. They do not replace professional judgement. Treating practitioners often possess information unavailable through a single assessment event.

They may have worked with a participant:

• weekly;
• monthly;
• over multiple years;
• across multiple environments;
• during periods of stability and crisis.

This longitudinal understanding provides important insight into functional capacity, risk, support effectiveness and changing circumstances. A clinician who has worked with a participant over several years may have a significantly more comprehensive understanding of support needs than an assessor conducting a single interview. Assessment frameworks should recognise the value of this evidence rather than treating all evidence sources as interchangeable.

The Committee should recognise that many allied health professionals already operate within highly regulated environments, including:

• AHPRA registration;
• professional accreditation frameworks;
• continuing professional development requirements;
• ethical obligations;
• professional indemnity arrangements;
• disciplinary processes.

These existing safeguards provide important quality controls that should not be disregarded when assessing evidence provided by qualified practitioners (AHPRA, 2025).

Fraud Prevention and Clinical Evidence Are Different Functions

Professionals Australia strongly supports measures aimed at preventing fraud, exploitation and inappropriate expenditure. However, the Committee should recognise that fraud prevention and evidence evaluation are different functions.

A system designed primarily around detecting fraud may inadvertently create barriers for legitimate participants and providers. Most allied health professionals operate within highly regulated professional frameworks. The overwhelming majority are not attempting to circumvent Scheme rules.

Assessment and evidence frameworks should therefore distinguish between:

• identifying fraud;
• evaluating support needs;

• determining reasonable and necessary supports.

Conflating these functions can create unnecessary administrative burden without improving integrity outcomes.

Risks Associated with I-CAN and Similar Assessment Tools

Professionals Australia acknowledges that tools such as the Instrument for the Classification and Assessment of Support Needs (I-CAN) may contribute useful information where appropriately used. However, concerns arise where assessment tools become:

• de facto funding calculators;
• substitutes for professional evidence;
• mechanisms for limiting participant budgets;
• barriers to review.

The validity of an assessment tool depends not only upon the instrument itself but also upon:

• how it is administered;
• who administers it;
• how results are interpreted;
• what decisions are subsequently made.

A clinically valid tool may become problematic if used outside its intended scope. For this reason, Professionals Australia strongly supports safeguards ensuring that assessment tools remain one source of evidence rather than the sole determinant of support decisions.

Assessment Tools Must Not Become Hidden Funding Caps

One of the most significant concerns raised by members is that standardised assessments may eventually operate as hidden funding caps. Where assessment scores become closely linked to budget allocations, there is a risk that individual circumstances become secondary to administrative classifications. Participants may receive funding based on averages rather than actual need, which would fundamentally alter the individualised nature of the Scheme.

The NDIS Review explicitly cautioned against reforms that reduce transparency regarding how planning decisions are made (NDIS Review, 2023). Participants must be able to understand how decisions affecting their lives have been reached.

Impact on Provider Compliance

Standardised assessment systems also influence provider behaviour. Where clinicians are uncertain about how evidence will be interpreted, they frequently respond by producing increasingly detailed reports.

Professionals Australia members consistently report that reports have become longer, more repetitive and more expensive because clinicians are attempting to anticipate administrative requirements.

This creates costs for:

• participants;
• providers;
• the NDIA.

Lengthy reports are often not the result of clinical preference. They are the result of uncertainty. If evidence standards were clearer, reports could become shorter, more targeted and more efficient.

The Cost of Report Burden

Current evidence pathways create significant administrative burden. Clinicians frequently report spending substantial time:

• rewriting reports;
• providing clarifications;
• responding to information requests;
• updating assessments;
• reproducing information already provided elsewhere.

This burden consumes clinical resources without necessarily improving participant outcomes. There is a growing risk that experienced clinicians may simply stop providing assessment reports altogether if the administrative burden continues to increase.

Members increasingly report that:

• report writing is becoming financially unsustainable;
• recommendations are frequently disregarded;
• evidence requests are repetitive;
• review outcomes are unpredictable.

If experienced clinicians withdraw from assessment activities, the Scheme risks losing access to critical expertise. This would weaken rather than strengthen decision-making quality.

The Independent Advisory Council has previously recognised that excessive administrative burden can undermine provider sustainability and participant access (Independent Advisory Council, 2022).

Permanent Disability Should Not Require Permanent Proof

Professionals Australia submits that participants should not be repeatedly required to prove permanent disability-related needs.

Where permanence has already been established, evidence requirements should focus on:

• current functional impact;
• changing circumstances;
• support effectiveness;
• emerging risks.

Participants should not be required to repeatedly establish the existence of conditions that are permanent, lifelong or degenerative. This approach would reduce costs for participants, providers and government while maintaining appropriate safeguards.

Procedural Fairness and Transparency

Procedural fairness is essential to Scheme integrity. Administrative law principles require decision- makers to genuinely consider relevant evidence and provide reasons that allow affected parties to understand the basis of decisions.

Participants should not be required to infer why evidence was rejected.

Where a treating clinician’s recommendation is not accepted, the decision-maker should clearly explain:

• what evidence was relied upon instead;
• why the recommendation was not accepted;
• what information would alter the decision.

Meaningful reasons improve transparency, support review rights and strengthen confidence in decision-making.

Participants must be able to understand:

• what evidence was considered;
• why decisions were made;
• why evidence was accepted or rejected;
• what additional information may be required.

Generic refusal letters do not support transparency. Meaningful written reasons improve trust, reduce disputes and support better decision-making. The Administrative Review Tribunal exists because participants require mechanisms to challenge decisions they believe are incorrect. Review rights should be viewed as an integrity safeguard rather than a system failure.

Cost of Poor Initial Decision-Making

Poor decision-making at the outset creates substantial downstream costs. These include:

• internal reviews;
• tribunal matters;
• additional assessments;
• legal expenses;

• administrative workload.

The Committee will be aware that the NDIA spent approximately $60.7 million on external legal services associated with Administrative Review Tribunal matters during the 2024-25 financial year.

While review mechanisms remain essential, expenditure at this scale highlights the importance of improving decision quality at the beginning of the process. Better decisions are often the most effective integrity measure available.

Confidence in Review Mechanisms

Health professionals require confidence that evidence provided within their professional scope will be:

• read;
• understood;
• considered;
• appropriately weighted.

Participants similarly require confidence that review mechanisms are accessible, fair and transparent. Where confidence in decision-making declines, participants are more likely to seek review. Conversely, transparent and evidence-based decision-making improves trust and reduces dispute activity.

Decision Quality as an Integrity Measure

Current discussions regarding Scheme integrity frequently focus on provider compliance, fraud detection and expenditure management. Professionals Australia submits that decision quality should be recognised as an integrity measure in its own right.

Indicators could include:

• review outcomes;
• participant satisfaction;
• timeliness;
• consistency;
• transparency of reasons;
• implementation success.

A Scheme that consistently produces decisions requiring correction is generating unnecessary administrative cost regardless of compliance activity elsewhere. Improving decision quality may therefore represent one of the most effective long-term integrity reforms available to government.

Recommendations

Professionals Australia recommends that the Australian Government, the National Disability Insurance Agency (NDIA) and the NDIS Quality and Safeguards Commission:

Assessment Frameworks

1. Ensure that standardised assessment tools remain supplementary sources of evidence and do not replace professional clinical judgement.

2. Prohibit the use of standardised assessment tools as de facto funding calculators, budget allocation mechanisms or hidden funding caps.

3. Require all assessment frameworks to support individualised decision-making consistent with the objects and principles of the NDIS Act 2013.

4. Subject any proposed assessment tool, including the Instrument for the Classification and Assessment of Support Needs (I-CAN), to independent evaluation regarding:

• validity;
• reliability;
• cultural safety;
• participant outcomes;
• workforce impacts;
• human rights implications.

5. Publish the evidence base, methodology, limitations and intended use of any assessment tool relied upon by the NDIA.

Clinical Judgement and Professional Evidence

6. Formally recognise treating practitioner evidence as a core component of reasonable and necessary decision-making.

7. Require decision-makers to explicitly consider and address evidence provided by qualified treating practitioners acting within scope of practice.

8. Require written justification where professional recommendations are not accepted.

9. Develop profession-specific evidence pathways in consultation with:

• occupational therapists;
• physiotherapists;
• speech pathologists;
• psychologists;
• social workers;
• behaviour support practitioners;
• other relevant allied health professionals.

10. Recognise longitudinal evidence provided by treating practitioners as a distinct and valuable source of information regarding participant functioning and support needs.

Hidden, Episodic and Fluctuating Disability

11. Ensure assessment frameworks explicitly account for hidden, episodic and fluctuating disabilities.

12. Require assessment processes to consider:

• cumulative fatigue;
• pain;
• psychosocial factors;
• environmental barriers;
• fluctuating presentation;
• sensory processing challenges;
• executive functioning challenges.

13. Ensure participants with psychosocial disability, autism, acquired brain injury, chronic illness and other fluctuating conditions are not disadvantaged by point-in-time assessment processes.

14. Develop specific guidance regarding assessment of disability-related masking and camouflaging behaviours, particularly among women and girls.

15. Ensure assessment frameworks distinguish between demonstrated performance and sustainable functional capacity.

Natural Environment Assessment

16. Recognise assessment conducted in natural environments as best practice for many support categories.

17. Ensure pricing and assessment arrangements support home, school, workplace and community-based assessments where clinically appropriate.

18. Require assessment frameworks to consider environmental barriers and contextual factors affecting participation and independence.

Children and Early Intervention

19. Ensure assessment processes for children recognise developmental trajectories and developmental potential rather than relying solely on current functioning.

20. Preserve access to early intervention supports where evidence demonstrates likely long-term benefits to participation, independence and reduced future support needs.

21. Require assessment frameworks affecting children to consider:

• family circumstances;
• educational participation;

• communication development;
• safeguarding risks;
• carer sustainability.

Cultural Safety and Accessibility

22. Ensure all assessment frameworks are culturally safe and accessible.

23. Require access to qualified interpreters where needed.

24. Evaluate assessment tools for potential cultural, linguistic and gender bias prior to implementation.

25. Develop guidance to support equitable assessment outcomes for First Nations participants and culturally and linguistically diverse communities.

Evidence Requirements and Administrative Burden

26. Establish nationally consistent evidence standards for commonly requested supports.

27. Reduce duplication of evidence requirements where information has already been provided to the Agency.

28. Introduce targeted evidence requests that identify specific information gaps rather than requiring entirely new assessments.

29. Require the NDIA to demonstrate why existing evidence is insufficient before requesting additional reports.

30. Monitor and report on the administrative burden associated with evidence and reporting requirements.

31. Assess all proposed reforms for their impact on clinician time, workforce sustainability and participant costs.

Permanent and Lifelong Disability

32. Recognise permanent and lifelong disabilities once permanence has been established.

33. Limit future evidence requests to:

• changes in functional impact;
• changes in support needs;
• changes in circumstances;
• review of specific supports.

34. Eliminate unnecessary reassessment requirements for conditions that are permanent, degenerative or lifelong.

Procedural Fairness and Transparency

35. Require meaningful written reasons for all decisions involving:

• reductions in support;
• refusal of supports;
• rejection of professional recommendations;
• significant plan changes.

36. Require decision-makers to identify:

• evidence considered;
• evidence not accepted;
• reasons for rejection;
• information required to alter the decision.

37. Ensure all participants can readily understand how assessment outcomes influence planning decisions.

38. Publish clear guidance regarding the role of assessment tools within planning and review processes.

Review Mechanisms

39. Preserve independent review rights as a core integrity safeguard.

40. Ensure review pathways remain accessible, timely and affordable.

41. Establish specialist clinical review pathways for disputes involving complex functional assessment issues.

42. Require review processes to include appropriately qualified professionals where clinical judgement is central to the dispute.

43. Monitor review outcomes to identify recurring decision-making issues and opportunities for system improvement.

Decision Quality and Integrity

44. Recognise decision quality as a core integrity indicator alongside fraud prevention and compliance activity.

45. Develop performance measures assessing:

• decision accuracy;
• participant understanding;
• review outcomes;
• implementation success;

• participant confidence.

46. Conduct regular audits of planning and review decisions to assess consistency, transparency and evidence use.

47. Evaluate integrity reforms against participant outcomes, workforce sustainability and administrative efficiency rather than expenditure impacts alone.

Human Rights and Scheme Objectives

48. Ensure all assessment reforms are consistent with Australia’s obligations under the Convention on the Rights of Persons with Disabilities, including Articles 19 and 26.

49. Require assessment frameworks to support:

• independence;
• social participation;
• economic participation;
• community inclusion;
• participant choice and control.

50. Assess all significant planning and assessment reforms against their impact on human rights, participation outcomes and equality of access.

Workforce Consultation

51. Establish a permanent Allied Health and Professional Advisory Council to provide advice regarding assessment, planning and evidence reforms.

52. Require meaningful consultation with frontline professionals prior to implementing significant changes to assessment frameworks, evidence requirements or review processes.

53. Publish workforce impact assessments for major reforms affecting planning, assessment or evidence pathways.

Conclusion

Conclusion

Professionals Australia supports efforts to improve consistency, transparency and fairness within the National Disability Insurance Scheme. Participants should be able to expect that similar support needs will be assessed consistently, that decisions will be evidence-based and that planning processes will be transparent and understandable. However, consistency must not come at the expense of individualisation.

The Committee should recognise that disability is not a standardised experience. Functional capacity is shaped by a complex interaction of impairment, environment, support availability, psychosocial circumstances, cultural context, communication needs and personal circumstances. These factors

cannot always be fully captured through standardised tools, administrative templates or point-in- time assessments. Assessment reform should therefore be guided by the principle that standardisation can support decision-making but should never replace professional judgement, participant voice or individualised consideration.

The evidence provided to this inquiry demonstrates that many of the participants most likely to be disadvantaged by overly rigid assessment frameworks are also among the most vulnerable. This includes people living with psychosocial disability, autism, acquired brain injury, chronic illness, fluctuating conditions, communication disability and other forms of hidden disability that may not be immediately apparent during a short assessment process.

The Committee should be particularly cautious of approaches that equate observed performance with functional capacity. A participant’s ability to complete a task once, in a structured assessment environment, does not necessarily indicate their ability to perform that task safely, consistently, repeatedly and sustainably in everyday life. For this reason, treating practitioner evidence, natural environment assessment and longitudinal clinical knowledge remain essential components of accurate decision-making.

Professionals Australia also submits that assessment reform should be considered within the broader context of Scheme integrity. Integrity is not achieved solely through fraud detection, compliance activity or expenditure control.

Integrity also requires:

• high-quality decision-making;
• procedural fairness;
• transparency;
• participant trust;
• workforce confidence;
• meaningful review rights;
• evidence-based planning.

A system that consistently produces decisions requiring correction through review processes cannot be considered fully effective, regardless of the strength of its compliance framework. Similarly, a system that discourages participation by experienced clinicians through excessive administrative burden ultimately weakens the quality of decision-making available to participants.

The Committee should recognise that review mechanisms are not evidence of failure. They are a fundamental safeguard within a rights-based scheme. Participants must retain confidence that decisions can be challenged, evidence can be reconsidered and administrative errors can be corrected. Reducing access to review does not improve decision quality.

Improving decision quality improves decision quality.

Professionals Australia further submits that assessment reform should be consistent with the objectives of the NDIS Act and Australia’s obligations under the United Nations Convention on the Rights of Persons with Disabilities. Assessment frameworks should support independence, participation, inclusion, rehabilitation and self-determination rather than focusing solely on administrative efficiency or expenditure management.

Ultimately, the strongest assessment framework is not the one that produces the most uniform outcomes. It is the one that produces the most accurate outcomes. Accuracy requires professional judgement, transparency, participant engagement and procedural fairness. Most importantly, accuracy requires recognition that people with disability are individuals whose needs, circumstances and aspirations cannot always be reduced to a score, category or administrative classification.

Professionals Australia therefore encourages the Committee to support reforms that improve consistency while preserving individualisation, strengthen integrity while maintaining fairness, and enhance efficiency without compromising participant outcomes. Achieving that balance will strengthen confidence in the Scheme, improve decision-making quality and support the long-term sustainability of the National Disability Insurance Scheme.

Question 5

Market Stewardship and Workforce Retention in Areas of Scarcity

(a) What should the Committee consider and recommend regarding market stewardship and workforce retention in areas of scarcity?

Professionals Australia submits that workforce sustainability and market stewardship are among the most significant determinants of the long-term success of the National Disability Insurance Scheme.

While substantial policy attention has been directed towards participant numbers, expenditure growth and compliance activity, considerably less attention has been paid to the workforce required to implement the Scheme. The Committee should recognise that funding alone does not deliver outcomes. People deliver outcomes.

Every support funded through the NDIS ultimately depends upon the availability of a suitably qualified worker capable of delivering that support safely, effectively and sustainably. Consequently, workforce sustainability should be viewed not as a workforce issue alone but as a core integrity, access and sustainability issue. A participant cannot exercise choice and control if there is no provider available to choose.

The Workforce Is Infrastructure

Public discussions about infrastructure often focus on physical assets such as roads, hospitals and schools. Professionals Australia submits that the disability workforce should be viewed in a similar way. The workforce is infrastructure. Without therapists, psychologists, social workers, behaviour support practitioners, interpreters and disability professionals, the Scheme cannot achieve its

objectives regardless of available funding. The NDIS Review identified workforce availability as one of the most significant risks facing the future operation of the Scheme (NDIS Review, 2023).

Similarly, the Productivity Commission has repeatedly recognised that workforce capacity is fundamental to participant outcomes and long-term Scheme sustainability (Productivity Commission, 2011; Productivity Commission, 2019). Market stewardship must therefore extend beyond monitoring expenditure and provider registration numbers. It must include active stewardship of workforce supply, capability, wellbeing and retention.

Market Stewardship Is a Core NDIA Responsibility

The Committee should recognise that the NDIS operates as a market-based system. Unlike traditional government service models, participants cannot access supports unless providers are available to deliver them. This creates a unique responsibility for government.

The NDIA cannot simply fund supports and assume the market will respond appropriately. Market stewardship requires active intervention where market failure is emerging.

The NDIS Review specifically identified the need for stronger market stewardship functions and greater attention to workforce sustainability, thin markets and participant access (NDIS Review, 2023). Professionals Australia strongly supports this approach.

Market Stewardship Requires Intervention, Not Observation

Professionals Australia is concerned that market stewardship is sometimes interpreted as a passive monitoring function. Monitoring provider numbers and workforce trends is necessary but not sufficient. Effective stewardship requires active intervention where emerging risks are identified.

The Committee should recognise that the disability market does not operate as a conventional free market. Participants often have:

• limited purchasing power;
• limited provider choice;
• limited access to information;
• significant barriers to switching providers.

Similarly, providers operate within a heavily regulated environment characterised by price controls, compliance obligations and workforce shortages. Under these circumstances, government cannot reasonably assume that market forces alone will produce equitable outcomes.

The NDIS Review concluded that stronger stewardship functions are required precisely because participant needs are not always met through market mechanisms alone (NDIS Review, 2023). Where market failure is foreseeable, intervention should occur before participant access deteriorates.

Thin Markets and Service Scarcity

Thin markets already exist across significant parts of Australia.

They are particularly evident in:

• regional communities;
• remote communities;
• Aboriginal and Torres Strait Islander communities;
• psychosocial disability services;
• specialist allied health services;
• complex assistive technology services;
• interpreting and communication supports.

The Independent Advisory Council has repeatedly identified thin market failure as a significant risk to participant access (Independent Advisory Council, 2022). A participant may possess funding but still be unable to obtain services because no provider is available. From the participant’s perspective, funding without service availability is functionally equivalent to having no support at all.

Provider Numbers Do Not Measure Market Health

Professionals Australia is concerned that market health is often assessed using provider registration numbers. Registration data alone provides an incomplete picture. A provider may remain registered while:

• maintaining lengthy waiting lists;
• limiting NDIS intake;
• reducing geographic coverage;
• reducing service frequency;
• preparing to leave the Scheme.

Market stewardship should therefore consider:

• participant wait times;
• workforce turnover;
• vacancy rates;
• provider viability;
• participant outcomes;
• service accessibility.

The critical question is not how many providers exist. The critical question is whether participants can access services when they need them.

Workforce Attrition Is Increasing

Professionals Australia members consistently report growing workforce pressures. These include:

• pricing stagnation;
• administrative burden;
• compliance complexity;

• report-writing requirements;
• workforce shortages;
• increasing participant complexity;
• professional burnout.

Recent Professionals Australia workforce survey findings indicate that 97.6 per cent of respondents reported negative impacts on their mental health associated with recent NDIS reforms and administrative uncertainty. Approximately 75 per cent reported considering leaving the sector within the next two to five years (Professionals Australia, 2026a). These findings should be viewed as a significant warning signal. The disability workforce cannot be assumed to be infinitely resilient.

Workforce Sustainability and Safeguarding

Workforce shortages are not only an access issue. They are also a safeguarding issue. Participants experiencing long waiting periods or service disruption may experience:

• deterioration in functional capacity;
• increased risk of hospitalisation;
• increased risk of social isolation;
• increased reliance on informal carers;
• increased vulnerability to abuse, neglect or exploitation.

The NDIS Quality and Safeguards Commission has repeatedly emphasised the importance of continuity, quality and provider capability in supporting participant safety. Where workforce shortages undermine continuity of care, participant safety may also be compromised. The Committee should therefore recognise workforce sustainability as a core safeguarding consideration.

Small Practices and Sole Traders Are Critical Market Infrastructure

Much public discussion focuses on large providers. However, a substantial proportion of NDIS professional services are delivered through:

• sole traders;
• small allied health practices;
• community-based providers;
• multidisciplinary clinics.

These providers are particularly important in:

• regional Australia;
• remote Australia;
• specialist service delivery;
• culturally specific service provision.

Small providers often deliver services that larger organisations are unable or unwilling to provide. However, they also possess fewer resources to absorb:

• pricing pressures;
• administrative burden;
• compliance costs;
• audit requirements.

A stewardship framework that fails to account for the unique contribution of small providers risks accelerating market concentration and reducing participant choice. The Productivity Commission has consistently recognised the importance of maintaining diversity within service markets to support participant outcomes and system resilience (Productivity Commission, 2011; Productivity Commission, 2019).

Workforce Ageing and Succession Risk

Many disability-related professions face an ageing workforce profile. This issue has been identified in allied health, psychology, social work and interpreting professions. Recent workforce analysis undertaken in the interpreting sector identified that approximately 43 per cent of practitioners are approaching retirement age (Deloitte Access Economics, 2025). Where experienced practitioners retire without sufficient workforce replacement, service availability may decline rapidly.

Market stewardship should therefore include:

• workforce pipeline development;
• graduate attraction;
• supervision capacity;
• mentoring programs;
• retention strategies.

Long-term workforce planning is significantly more effective than crisis recruitment.

Foundational Supports Cannot Exist Without Workers

Current reform discussions frequently assume that foundational supports will absorb demand previously met through the NDIS.

Professionals Australia submits that foundational supports will only succeed if an appropriately skilled workforce exists to deliver them.

A funding announcement does not create workforce capacity.

Workforce capacity requires:

• recruitment;
• training;
• supervision;
• retention;
• career pathways.

The Committee should therefore seek assurance that workforce planning for foundational supports is occurring alongside broader NDIS reform. Without workforce planning, service gaps are likely to emerge. These gaps will disproportionately affect children, regional communities and participants with lower support needs.

Regional and Remote Australia

Workforce shortages are particularly acute outside metropolitan areas.

Regional providers frequently face:

• recruitment difficulties;
• travel burdens;
• workforce isolation;
• reduced professional support;
• increased operating costs.

The same pricing arrangements that may be marginally sustainable in metropolitan settings can become unsustainable in regional environments. Where providers withdraw, participants often have no realistic alternatives. The Committee should recognise that market stewardship in regional Australia requires active intervention rather than reliance on market forces alone.

Aboriginal and Torres Strait Islander Communities

Workforce shortages have particularly significant implications for Aboriginal and Torres Strait Islander communities. Culturally safe disability support depends upon:

• trusted relationships;
• local knowledge;
• community engagement;
• culturally appropriate service delivery.

Where providers withdraw, these relationships may be lost entirely. Market stewardship should therefore include targeted investment in Aboriginal workforce development and culturally safe service delivery models.

The Caring Economy and Women’s Workforce Participation

The disability workforce is predominantly female. Women also undertake the majority of informal caring responsibilities. Consequently, workforce instability has gendered impacts.

Where formal supports become unavailable:

• women are more likely to reduce paid employment;
• women are more likely to increase unpaid caring responsibilities;
• women are more likely to experience reduced economic security.

The Workplace Gender Equality Agency and OECD have both identified disability support systems as important contributors to women’s workforce participation and economic equality (WGEA, 2024; OECD, 2021). Market stewardship should therefore consider these broader economic impacts.

Workforce Sustainability and National Productivity

The disability workforce contributes significantly to Australia’s economic productivity.

The workforce enables:

• participation in employment;
• participation in education;
• community engagement;
• reduced reliance on informal care.

When participants receive timely supports, family members are more likely to remain in paid employment. Conversely, where supports become unavailable, caring responsibilities frequently shift back to families. The Productivity Commission, OECD and Workplace Gender Equality Agency have all identified disability supports as an important contributor to workforce participation and broader economic productivity (Productivity Commission, 2024; OECD, 2021; WGEA, 2024). Market stewardship should therefore be viewed as an economic policy issue rather than solely a disability policy issue.

Cost Shifting and Workforce Failure

A workforce shortage does not eliminate need. It simply transfers consequences elsewhere. When participants cannot access supports, costs frequently emerge through:

• hospital admissions;
• mental health services;
• housing instability;
• child protection involvement;
• carer burnout;
• justice system interactions.

These outcomes are significantly more expensive than preventative intervention. The Committee should therefore evaluate workforce sustainability as a whole-of-government issue rather than solely an NDIS issue.

Workforce Planning Must Become Core Business

Professionals Australia submits that workforce planning should become a central function of market stewardship. Current workforce planning remains fragmented and reactive.

A comprehensive workforce strategy should include:

• workforce forecasting;

• vacancy monitoring;
• turnover monitoring;
• regional workforce modelling;
• profession-specific workforce analysis;
• participant demand projections.

Importantly, workforce planning should involve direct engagement with frontline professionals. The people delivering services often identify emerging workforce risks well before they become visible in administrative data.

Workforce Exit Has Participant Consequences

When experienced clinicians leave the sector:

• participant waitlists increase;
• continuity of care is disrupted;
• specialist expertise is lost;
• supervision capacity declines;
• recruitment costs increase.

Participants often lose relationships that have taken years to establish. This is particularly significant for:

• children;
• participants with communication disabilities;
• participants with psychosocial disability;
• participants with complex behavioural support needs.

These losses are difficult to replace.

Decision Quality and Workforce Sustainability

The Committee should also recognise the relationship between decision quality and workforce retention. Clinicians frequently report frustration when:

• evidence is disregarded;
• reports are repeatedly requested;
• recommendations are rejected without explanation;
• participants experience unnecessary review processes.

Poor administration contributes directly to workforce dissatisfaction. Improving decision-making quality is therefore likely to improve workforce retention.

Human Rights and Access to Services

Australia’s obligations under the Convention on the Rights of Persons with Disabilities include ensuring access to services that support independence, participation and inclusion. Article 19

recognises the right to live independently and participate in the community. Article 26 recognises the importance of rehabilitation and rehabilitation services that maximise independence and participation (United Nations, 2006). These rights cannot be realised if participants are unable to access appropriately qualified professionals. Consequently, workforce sustainability and market stewardship are also human rights issues.

A participant who cannot access services because no provider is available is effectively denied the practical benefit of Scheme funding.

Recommendations

Professionals Australia recommends that:

1. Workforce sustainability be recognised as a core market stewardship and integrity measure.

2. The NDIA develop and publish a national disability workforce strategy.

3. Workforce Impact Statements accompany significant reforms affecting pricing, planning, assessment or compliance.

4. Market stewardship frameworks include participant access measures rather than relying solely on provider numbers.

5. Government establish early warning indicators for workforce shortages and market failure.

6. Additional supports be developed for regional, remote and thin market providers.

7. Targeted investment occur in Aboriginal and Torres Strait Islander workforce development.

8. Workforce sustainability data be collected and publicly reported.

9. Frontline professionals be formally involved in market stewardship and workforce planning processes.

10. Pricing, planning and compliance reforms be assessed for their impact on workforce retention and participant access.

11. Establish a formal market stewardship framework with publicly reported indicators relating to:

    • participant access;
    • workforce supply;
    • wait times;
    • vacancy rates;
    • service withdrawal.

12. Develop a national disability workforce forecasting model covering:

    • allied health professions;
    • psychology;

• social work;
• behaviour support;
• interpreting and communication services.

13. Introduce targeted retention initiatives for professions experiencing workforce shortages.

14. Develop a dedicated strategy supporting sole traders and small providers.

15. Publish annual workforce sustainability reports.

16. Ensure workforce planning for foundational supports occurs prior to major participant transitions.

17. Recognise workforce sustainability as a safeguarding measure within NDIS policy and regulation.

18. Assess all major reforms against Australia’s obligations under the Convention on the Rights of Persons with Disabilities

Conclusion

The long-term sustainability of the NDIS depends upon the sustainability of the workforce that delivers it. Market stewardship cannot be reduced to monitoring provider numbers or controlling expenditure. It requires active management of workforce capacity, provider viability, participant access and service quality.

The Committee should recognise that participant funding, provider sustainability, workforce capacity and Scheme integrity are not separate policy challenges. They are different dimensions of the same challenge. A participant cannot access a service that does not exist. A provider cannot deliver services without a sustainable workforce. A workforce cannot be sustained without effective stewardship. Consequently, workforce sustainability should be viewed as a core measure of Scheme success.

Protecting and strengthening the workforce is not simply an operational consideration. It is one of the most important investments available to improve participant outcomes, safeguard public expenditure, support economic participation and ensure the long-term sustainability of the National Disability Insurance Scheme.

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