Inquiry into the National Disability Insurance Scheme
Written questions on notice arising from public hearing of 15 May 2026
Executive Summary
Professionals Australia welcomes the opportunity to provide responses to the Joint Committee of Public Accounts and Audit regarding workforce sustainability within the National Disability Insurance Scheme (NDIS).
Professionals Australia represents allied health professionals, interpreters and other highly skilled professionals delivering services across the disability sector. Our members work directly with participants in homes, schools, workplaces, hospitals, clinics and community settings throughout Australia. They are responsible for supporting communication, mobility, independence, participation, health, safety and quality of life for people with disability.
The evidence available to Professionals Australia demonstrates that workforce sustainability has become one of the most significant challenges facing the NDIS.
Current workforce pressures are not simply a labour market issue. They are already affecting participant access to services, continuity of care, early intervention, participant choice and control, and the long-term sustainability of the Scheme itself (Independent Review into the National Disability Insurance Scheme, 2023).
Professionals Australia members consistently report increasing difficulty attracting and retaining experienced practitioners within the NDIS. These challenges are driven by a combination of factors, including pricing arrangements that do not adequately reflect the full cost of service delivery, growing administrative burden, increasing compliance requirements, workforce shortages, reduced travel funding, insufficient support for professional development and supervision, and growing complexity of participant needs (Professionals Australia, 2026; Allied Health Professions Australia [AHPA], 2024).
The evidence suggests that current pricing arrangements are discouraging experienced professionals from entering, remaining in or expanding their participation within the Scheme. While public discussion often focuses on hourly price limits, the central issue is the growing gap between the actual cost of delivering safe, high-quality services and the funding available to support those services (National Disability Insurance Agency [NDIA], 2025; AHPA, 2024). Many practitioners report undertaking significant amounts of unpaid labour to meet participant needs, including report writing, multidisciplinary coordination, participant communication, travel, compliance and administrative work (Professionals Australia, 2026).
Professionals Australia is particularly concerned that current policy settings are increasingly dependent on professional goodwill rather than sustainable business models. Practitioners report spending increasing amounts of time proving the need for services rather than delivering services. This
contributes to burnout, workforce attrition and reduced service availability for participants (Professionals Australia, 2026; Independent Review into the National Disability Insurance Scheme, 2023).
The impacts are particularly severe for sole practitioners, small providers, regional providers and professionals supporting participants with complex needs. These providers frequently lack the capacity to absorb rising costs, increasing compliance requirements and unfunded work. As a result, some providers are reducing service areas, limiting participant intake, closing books to new referrals or reconsidering their ongoing participation in the Scheme (Professionals Australia, 2026).
The consequences are being felt most acutely by participants. Professionals Australia has received evidence of increasing waiting times, reduced access to specialist services, reduced continuity of care, delays to early intervention and growing barriers to accessing culturally responsive supports. Participants living in regional and remote communities, First Nations participants, culturally and linguistically diverse participants, and participants with complex support needs are disproportionately affected by workforce shortages and provider exits (Australian Institute of Health and Welfare [AIHW], 2024; Coalition of Peaks, 2023; Deloitte Access Economics, 2025).
Professionals Australia is particularly concerned about evidence suggesting that workforce constraints are contributing to emerging market failure in some parts of the Scheme. The Independent Review into the NDIS recognised that participant choice and control cannot be achieved in the absence of functioning service markets (Independent Review into the National Disability Insurance Scheme, 2023). However, participants cannot exercise meaningful choice where providers are unavailable, waiting lists are extensive or specialised services no longer exist. Choice without availability is not genuine choice.
The evidence available to Professionals Australia suggests that workforce constraints are no longer a future risk. They are a current reality affecting participant access and outcomes across the Scheme.
Professionals Australia submits that workforce sustainability should be viewed as a participant rights issue. Every participant outcome ultimately depends on the availability of a skilled workforce. When workforce capacity declines, participant outcomes decline with it (United Nations, 2006; Independent Review into the National Disability Insurance Scheme, 2023).
Professionals Australia therefore recommends three priority reforms.
First, the establishment of an independent workforce and pricing authority responsible for workforce planning, market monitoring, workforce data collection and evidence-based pricing recommendations. Workforce sustainability should be treated as a core performance measure of the NDIS, with pricing decisions informed by workforce impacts, provider viability and participant access (Productivity Commission, 2017; Independent Review into the National Disability Insurance Scheme, 2023).
Second, the development of a long-term National NDIS Workforce Strategy focused on workforce attraction, retention, professional development, supervision, leadership pathways, workforce
wellbeing and reduction of administrative burden. Workforce sustainability cannot be achieved through recruitment alone. It requires retaining experienced professionals and creating sustainable career pathways across the disability sector (Jobs and Skills Australia, 2025; AHPA, 2024).
Third, the establishment of a national Equity, Inclusion and Access Framework focused on improving workforce diversity, cultural capability and service accessibility for First Nations communities, culturally and linguistically diverse communities, regional and remote communities, and participants with complex support needs. Workforce sustainability should be measured not only by workforce numbers but also by workforce accessibility, cultural responsiveness and participant outcomes (Coalition of Peaks, 2023; FECCA, 2024).
Across all three reforms, Professionals Australia emphasises the need to reduce unnecessary administrative burden and compliance duplication. Members consistently report that increasing amounts of professional time are being diverted towards reporting requirements, evidence requests and administrative processes. Every hour spent navigating unnecessary bureaucracy is an hour unavailable for participant care. Reducing duplication represents one of the most immediate and cost- effective opportunities to improve workforce capacity and participant access (Professionals Australia, 2026; Independent Review into the National Disability Insurance Scheme, 2023).
Professionals Australia further submits that workforce sustainability, participant outcomes and Scheme sustainability are fundamentally interconnected. A sustainable NDIS requires sustainable workers, sustainable providers and sustainable participants simultaneously. The workforce should not be viewed as a cost centre. It is the mechanism through which participant outcomes are delivered. Investment in workforce sustainability is therefore not simply an investment in workers. It is an investment in participant wellbeing, participant rights, market sustainability and the long-term success of the NDIS itself.
The evidence presented in this submission demonstrates that action is required now. Delayed action risks further provider exits, increasing workforce shortages, longer waiting lists, reduced participant choice and control, and worsening outcomes for the people the NDIS was designed to support (Independent Review into the National Disability Insurance Scheme, 2023; Productivity Commission, 2017).
Question 1: Are price caps discouraging experienced professionals from participating in the scheme?
Professionals Australia’s view is that current NDIS pricing arrangements, including price caps, are discouraging experienced allied health professionals and other highly skilled practitioners from entering, remaining in, or expanding their participation within the National Disability Insurance Scheme (NDIS).
While public discussion frequently focuses on headline hourly rates, this approach does not accurately reflect the true cost of delivering safe, effective and participant-centred services. The NDIS pricing framework assumes a level of productivity that many practitioners report is increasingly difficult to achieve, particularly when working with participants who have complex needs, communication
barriers, behavioural support requirements, significant disability-related support needs, or who live in regional, remote and thin markets (Independent Review into the National Disability Insurance Scheme, 2023; NDIS Review Expert Advisory Group, 2023).
Professionals Australia represents a broad range of allied health professionals and interpreters working across the disability sector, including speech pathologists, occupational therapists, physiotherapists, psychologists, social workers, dietitians, podiatrists, behaviour support practitioners and interpreters. Across these professions, members consistently report that current pricing settings are failing to cover the actual costs of service delivery.
The issue is not simply the level of the hourly rate itself. Rather, it is the growing gap between the costs associated with delivering professional services and the funding available to support those services. Over recent years, providers have been required to absorb substantial increases in wages, superannuation, insurance premiums, professional registration costs, accreditation requirements, software expenses, information technology systems, rent, utilities and compliance obligations. At the same time, many NDIS price limits have either remained static or failed to keep pace with inflation, wage growth and broader labour market pressures (National Disability Insurance Agency [NDIA], 2024; Australian Bureau of Statistics [ABS], 2025).
A key concern raised by Professionals Australia members is that NDIS pricing arrangements are built upon assumptions regarding practitioner productivity that do not reflect the realities of contemporary allied health practice. A clinician’s work extends far beyond direct participant contact. Safe and effective disability support requires report writing, multidisciplinary consultation, family engagement, risk assessment, case coordination, professional supervision, professional development, record keeping and compliance activities. Many of these activities are either inadequately funded or not funded at all.
Professionals Australia has received evidence from providers across multiple disciplines indicating that achieving billable utilisation rates above 60 per cent is often unrealistic when working with participants who have complex needs. Practitioners consistently report that a significant proportion of their workday is devoted to essential but non-billable activities. This issue is particularly pronounced for occupational therapists, speech pathologists and behaviour support practitioners, whose work frequently involves substantial assessment, documentation and coordination requirements (Allied Health Professions Australia [AHPA], 2024a; Independent Review into the National Disability Insurance Scheme, 2023).
The result is that many experienced practitioners are effectively subsidising the Scheme through unpaid labour. This finding is consistent with broader concerns raised by the Independent Review into the NDIS regarding market stewardship, workforce sustainability and the growing administrative burden placed upon providers (Independent Review into the National Disability Insurance Scheme, 2023).
These challenges are particularly acute for sole practitioners and small businesses, which comprise a significant proportion of the allied health workforce delivering NDIS supports. Unlike large corporate
providers, small providers often have limited capacity to absorb financial losses or cross-subsidise disability services from other revenue streams. Research has consistently demonstrated that small, allied health businesses face greater exposure to funding fluctuations, workforce shortages and administrative burdens than larger organisations (AHPA, 2024a; Productivity Commission, 2017).
Professionals Australia has received evidence from allied health practitioners across Australia that many services are now being delivered at extremely low margins, with some providers reporting that NDIS work is no longer financially sustainable. One occupational therapy provider advised Professionals Australia that, after accounting for administration, supervision, travel, clinical documentation, professional development and compliance obligations, their business was operating at approximately two per cent profit despite maintaining a full caseload. Other practitioners have advised that they have ceased accepting new NDIS referrals, reduced staffing levels or limited the number of participants with complex needs they can support because the funding available no longer reflects the true cost of service delivery (Professionals Australia, 2026).
The recent removal and restriction of travel funding has further intensified these concerns. Professionals Australia has received extensive evidence from allied health practitioners regarding the impact of travel funding changes introduced in 2025. Many allied health professionals provide services in participants’ homes, schools, workplaces and community settings because these environments often represent best-practice clinical care. Community-based intervention is particularly important for participants with complex disabilities, communication difficulties, psychosocial disabilities and significant functional impairments (NDIS Review Expert Advisory Group, 2023).
Following the reduction and removal of travel-related funding arrangements, members reported that many providers were reassessing whether they could continue servicing certain participants or geographic locations. Occupational therapists reported that lengthy travel times to regional communities had become financially unsustainable. Speech pathologists reported being forced to limit the geographic areas they serviced, while physiotherapists described reducing home visit availability because travel costs could no longer be recovered. Many sole practitioners advised that they faced an impossible choice: absorb the travel costs themselves, reduce service availability, or cease providing services to some participants entirely. The consequences of these decisions fall most heavily on participants with the highest support needs and those living in regional, remote and thin markets where provider choice is already limited (Professionals Australia, 2026; Independent Review into the National Disability Insurance Scheme, 2023).
These pressures are contributing to workforce attrition.
Experienced clinicians are often the most mobile section of the workforce. They possess skills that are highly transferable across health, aged care, workers compensation, education and private practice settings. As a result, when NDIS work becomes financially unsustainable or administratively burdensome, experienced practitioners are often the first to leave. Workforce shortages already exist across many allied health professions, meaning experienced practitioners can frequently secure
alternative employment with better remuneration, lower administrative burdens and more sustainable working conditions (Jobs and Skills Australia, 2024; AHPA, 2024a).
Professionals Australia members have reported increasing numbers of clinicians reducing their NDIS caseloads, restricting the number of NDIS participants they accept, closing waiting lists, moving into private fee-paying practice, returning to hospital settings, or leaving disability services altogether. Similar concerns have been raised by professional associations across multiple allied health disciplines, which have warned that current funding arrangements risk undermining workforce retention and participant access to services (AHPA, 2024a).
This trend is particularly concerning because experienced practitioners are often those providing support to participants with the most complex needs. Participants requiring specialist communication support, complex behavioural interventions, multidisciplinary care coordination, assistive technology prescription, complex home modifications or intensive therapy programs frequently rely on highly experienced clinicians. When those clinicians leave the sector, participants face longer waiting periods, reduced provider choice and greater difficulty accessing appropriate expertise (Independent Review into the National Disability Insurance Scheme, 2023; Productivity Commission, 2017).
The findings of the Independent Review into the National Disability Insurance Scheme reinforce the concerns raised by Professionals Australia members. The Review identified workforce shortages, workforce instability and service market failures as significant risks to participant outcomes and the long-term sustainability of the Scheme. The Review recognised that participants cannot exercise genuine choice and control where services are unavailable, waiting lists are extensive, or workforce shortages limit access to appropriately qualified professionals (Independent Review into the National Disability Insurance Scheme, 2023).
Professionals Australia submits that pricing arrangements cannot be considered separately from workforce outcomes. A pricing framework that contributes to workforce exits ultimately undermines the Scheme’s stated objectives by reducing participant access to services and limiting provider choice.
Current pricing arrangements also have significant gender implications. The allied health workforce is overwhelmingly female. Professions such as speech pathology, occupational therapy, social work, dietetics and physiotherapy are predominantly staffed by women. Many practitioners work in small businesses, sole-trader arrangements or community-based service models that are particularly sensitive to changes in pricing and funding settings (AHPA, 2024b).
When pricing arrangements fail to reflect the true cost of service delivery, the financial burden is disproportionately borne by women workers through lower earnings, unpaid labour, longer working hours and increased workforce attrition. Professionals Australia members frequently report undertaking substantial amounts of unpaid work to ensure participants receive appropriate care. This includes completing reports after hours, communicating with families outside paid time, responding to NDIA requests, coordinating multidisciplinary care and managing administrative requirements. These expectations contribute to burnout, workforce dissatisfaction and increasing numbers of experienced clinicians leaving disability practice (AHPA, 2024b; Professionals Australia, 2026).
The gendered nature of the allied health workforce means that policies which suppress remuneration or fail to fund the full cost of professional practice have broader implications for women’s workforce participation, career progression and economic security (Workplace Gender Equality Agency, 2024).
Professionals Australia’s work with interpreters has revealed similar pressures. Deloitte Access Economics identified an ageing workforce, significant retention challenges and concerns regarding workforce sustainability within the translating and interpreting sector. The report found that approximately 43 per cent of practising interpreters are approaching retirement age and highlighted low remuneration, insecure work and inadequate recognition of professional expertise as major barriers to attracting and retaining experienced workers (Deloitte Access Economics, 2025).
The parallels between the interpreting workforce and the allied health workforce are striking. In both cases, governments rely heavily on highly skilled professionals to deliver essential services. In both cases, funding arrangements have failed to keep pace with the true costs of service delivery. In both cases, workforce shortages are beginning to affect participant access and service quality (Deloitte Access Economics, 2025; AHPA, 2024a).
Professionals Australia has also heard evidence from practitioners that current pricing arrangements are contributing to increasing levels of burnout and moral distress. Many allied health professionals report spending substantial amounts of unpaid time completing reports, communicating with families, coordinating care, responding to NDIA requests, managing compliance requirements and undertaking mandatory professional development. Practitioners describe feeling caught between the needs of participants and the financial realities of operating within the NDIS funding framework.
Several members have reported that they are increasingly forced to choose between providing the level of care they believe participants require and maintaining the financial viability of their practice. One member summarised the situation as follows:
“The people we support need more time, more planning and more coordination, but the system increasingly rewards volume rather than quality. Experienced clinicians can only absorb those costs for so long before they leave.”
Professionals Australia submits that these examples are not isolated incidents. Rather, they reflect broader workforce pressures being experienced across the disability sector (Professionals Australia, 2026).
The evidence available to Professionals Australia demonstrates that current price caps and associated Pricing arrangements are contributing to workforce attrition across allied health and related professions. The impacts are being felt most acutely by experienced practitioners, sole practitioners, regional providers and those supporting participants with complex needs.
The Committee should recognise that workforce sustainability is not a separate issue from participant outcomes. The quality, accessibility and continuity of NDIS supports are directly dependent on the ability of the Scheme to attract and retain experienced professionals. Pricing arrangements that fail to reflect the true cost of delivering disability services may reduce short-term expenditure, but they do
so at the expense of workforce capacity, participant choice and the long-term sustainability of the Scheme itself (Independent Review into the National Disability Insurance Scheme, 2023; Productivity Commission, 2017).
Question 2: Do you have a house view on how pricing should work within the NDIS?
Professionals Australia’s view is that NDIS pricing should be set through an independent, transparent and evidence-based pricing framework that reflects the full cost of delivering safe, high-quality, participant-centred services. Pricing should not be treated solely as a budget control mechanism. It is also a workforce policy, a market stewardship tool and a key determinant of participant access, choice, quality and continuity of care.
The NDIS relies on skilled professionals to deliver complex supports to participants across a wide range of settings, including homes, schools, workplaces, clinics, hospitals, community settings, regional areas and remote communities. The pricing system must therefore be designed around the actual work required to deliver those services safely and effectively. This includes direct participant contact, but also the substantial professional work that sits around direct service delivery, including report writing, clinical reasoning, risk assessment, multidisciplinary communication, family engagement, professional supervision, professional development, compliance, travel, record keeping and care coordination.
Professionals Australia does not support a pricing model that assumes the cheapest possible hourly rate represents value for money. In disability services, poor pricing can drive experienced practitioners out of the Scheme, reduce access to services, increase waiting lists, undermine quality and shift unpaid labour onto workers, most of whom are women. A pricing model that suppresses the cost of professional services may appear to reduce expenditure in the short term, but it creates longer-term costs through workforce attrition, thin markets, poorer participant outcomes, reduced early intervention and greater pressure on health, education, justice and family systems (Independent Review into the National Disability Insurance Scheme, 2023; Productivity Commission, 2017).
Professionals Australia’s house view is that NDIS pricing should be based on independence, transparency, full-cost recovery, workforce sustainability and participant outcomes. These principles should operate together. A pricing system that is transparent but not independent will not build provider or participant confidence. A pricing system that considers participant outcomes but ignores workforce sustainability will fail in practice. A pricing system that focuses only on fiscal restraint will undermine the very services the Scheme exists to provide.
The current approach to pricing does not adequately reflect the real cost of service delivery for many allied health professionals and other skilled practitioners. The NDIA has stated that the Annual Pricing Review is intended to ensure price limits remain suitable, responsive and supportive of safe and effective supports and sustainable provider markets (National Disability Insurance Agency [NDIA], 2025a). However, the evidence received by Professionals Australia from members indicates that many providers do not experience the current pricing framework as responsive, transparent or sustainable. This is particularly the case for small allied health businesses, sole practitioners, regional providers and professionals supporting participants with complex needs.
Professionals Australia supports the establishment of an independent pricing authority or independent Pricing mechanism for the NDIS. The current arrangement, where the NDIA is both the Scheme administrator and the body responsible for setting price limits, creates an inherent tension between Scheme cost control and market sustainability. Pricing decisions should be made by an independent body with access to detailed labour market data, provider cost data, participant access data, service quality data and workforce supply data. This body should be required to consult with participants, providers, workers, unions, professional associations, peak bodies and independent experts before making pricing recommendations.
The need for independent and active market stewardship has been recognised repeatedly. The Productivity Commission identified thin markets as a persistent risk within the NDIS and warned that provider markets would not always develop without intervention (Productivity Commission, 2017). The Independent Review into the NDIS similarly found that market settings, workforce shortages and uneven access to supports were undermining participant choice and control, particularly in regional and remote areas and for participants with complex needs (Independent Review into the National Disability Insurance Scheme, 2023). These findings are directly relevant to pricing. A pricing framework that does not support a viable workforce and provider market cannot deliver genuine choice and control.
Professionals Australia submits that NDIS pricing should be based on the full cost of delivering services, not only the face-to-face clinical hour. The current model too often treats direct participant contact as the only legitimate work, even though safe and effective disability support requires substantial non- face-to-face professional labour. For allied health professionals, this includes assessments, clinical notes, reports, assistive technology applications, home modification documentation, communication with families and carers, liaison with schools and employers, multidisciplinary coordination, supervision, quality assurance and compliance. For interpreters, it includes preparation, travel, briefing, debriefing, professional development and the emotional labour associated with traumatic, complex or high-risk assignments.
The failure to properly fund this work is one of the central flaws in the current pricing model. Professionals Australia members have consistently reported that they are performing significant unpaid labour in order to meet participant need and maintain professional standards. Occupational therapists have reported completing extensive reports after hours. Speech pathologists have reported undertaking unpaid communication with families, schools and support coordinators. Physiotherapists have reported reducing home visits because travel costs cannot be recovered. Interpreters have reported being expected to manage complex and traumatic assignments without funded preparation, supervision or debriefing. These are not optional extras. They are part of safe, ethical and effective professional practice (Professionals Australia, 2026; Deloitte Access Economics, 2025).
One occupational therapy provider advised Professionals Australia that, after accounting for administration, supervision, travel, clinical documentation, professional development and compliance obligations, their business was operating at approximately two per cent profit despite maintaining a full caseload. Other allied health professionals have reported that they have stopped accepting new
NDIS referrals, reduced services to participants with complex needs, or shifted their work into private fee-paying practice because NDIS pricing no longer covers the true cost of service delivery. These examples demonstrate that price limits are not an abstract policy issue. They directly affect whether participants can access experienced professionals.
Pricing should also recognise that not all services are equivalent. Supporting a participant with complex communication needs, significant behavioural support needs, psychosocial disability, complex assistive technology requirements or multiple intersecting disabilities often requires substantially more preparation, coordination, documentation and clinical judgement than a lower-complexity intervention. The pricing framework should therefore include loadings or differentiated pricing for complexity, risk, rurality, travel intensity and thin markets.
Professionals Australia is concerned that pricing discussions are often framed primarily through the lens of Scheme expenditure. While fiscal sustainability is important, expenditure alone is an incomplete measure of success. The purpose of the NDIS is not to minimise spending. The purpose of the NDIS is to improve outcomes for people with disability through access to high-quality supports that maximise independence, participation and quality of life.
Pricing decisions should therefore be evaluated against a broader set of measures, including participant access, waiting times, continuity of care, workforce retention, provider viability, regional service availability and participant outcomes. A reduction in expenditure cannot automatically be assumed to represent a positive outcome if it is accompanied by reduced service availability, longer waiting lists, provider exits or poorer participant outcomes. Equally, an increase in expenditure may represent good value for money if it improves participant outcomes, prevents crisis intervention, reduces future support needs or increases workforce participation.
Professionals Australia submits that future pricing reviews should explicitly assess the likely impact of proposed pricing changes on participant outcomes, workforce sustainability and service availability before implementation.
Professionals Australia is particularly concerned about the impact of pricing decisions on early intervention services. The evidence supporting early intervention is well established. Timely access to occupational therapy, speech pathology, physiotherapy, psychology and other allied health services can improve functional capacity, increase independence, support educational participation and reduce future support needs (Productivity Commission, 2017; Independent Review into the National Disability Insurance Scheme, 2023).
However, early intervention services are often highly dependent on small providers, multidisciplinary collaboration and significant non-face-to-face work. When pricing arrangements fail to adequately fund these activities, provider viability is undermined and participant access is reduced. Professionals Australia members have reported increasing difficulty maintaining early intervention services under current pricing arrangements, particularly where substantial coordination with families, schools, childcare providers and other professionals is required.
The long-term consequences of inadequate pricing may therefore extend beyond workforce shortages. Reduced access to early intervention can result in increased support needs, poorer outcomes and higher long-term costs for the NDIS and other government systems. In this respect, pricing decisions should be viewed as investments in participant outcomes rather than simply as expenditure controls.
Choice and control are foundational principles of the NDIS. However, participant choice can only exist where participants have genuine access to multiple qualified providers.
The Independent Review into the NDIS identified workforce shortages, thin markets and provider availability as significant barriers to participant choice and control (Independent Review into the National Disability Insurance Scheme, 2023). Professionals Australia members consistently report that many participants already face lengthy waiting lists, limited provider availability and significant difficulties accessing experienced practitioners. These challenges are particularly acute in regional, rural and remote communities.
Pricing arrangements that contribute to provider exits; workforce shortages or reduced service availability undermine the practical exercise of choice and control. A participant cannot meaningfully choose between providers where there is only one provider available. Nor can a participant exercise genuine control over their supports where services are unavailable or waiting lists extend for many months. Professionals Australia submits that participant choice and control should be treated as key indicators of whether pricing arrangements are functioning effectively.
Professionals Australia is concerned that current pricing arrangements may unintentionally favour larger corporate providers over smaller community-based services, sole practitioners and multidisciplinary local practices. Large organisations are often better positioned to absorb pricing pressures through economies of scale, centralised administration and diversified revenue streams. Smaller providers generally have fewer opportunities to cross-subsidise services and are therefore more vulnerable to funding constraints.
Many allied health practitioners have advised Professionals Australia that they are experiencing increasing difficulty maintaining viable practices under current pricing settings. This is particularly true where providers deliver outreach services, work with participants with complex needs or operate in regional communities.
Small providers frequently play a critical role within local disability ecosystems. They often offer continuity of care, trusted relationships, flexibility and specialised expertise that may not be available through larger organisations. Participants repeatedly report valuing these services because they provide personalised support and long-term therapeutic relationships.
Professionals Australia submits that pricing arrangements should support a diverse provider market rather than inadvertently encouraging market consolidation. A healthy NDIS market requires large providers, small providers, sole practitioners, multidisciplinary teams, community-based organisations and innovative service models.
Professionals Australia submits that NDIS pricing should also be assessed through a gender equality lens. The disability workforce is highly feminised. Women comprise the overwhelming majority of the many professions that deliver NDIS-funded supports, including speech pathology, occupational therapy, social work, dietetics, early childhood intervention and large sections of the disability support workforce (Workplace Gender Equality Agency [WGEA], 2024; Allied Health Professions Australia [AHPA], 2024). Pricing decisions therefore have direct implications for women’s economic participation, earnings, workforce retention and career progression.
Current pricing settings rely heavily upon forms of labour that are frequently invisible, undervalued or unpaid. Professionals Australia members consistently report undertaking substantial amounts of administrative work, participant communication, report writing, coordination, supervision and compliance activity outside funded hours. Many describe completing this work after hours, on weekends or during unpaid time because they believe it is necessary to meet participant needs and maintain professional standards.
This dynamic mirrors historical patterns of undervaluation in female-dominated professions. When Pricing assumptions fail to recognise the full scope of professional work, the result is often that women workers absorb the shortfall through unpaid labour, reduced earnings or increased workload.
Professionals Australia has heard from members who have reduced their working hours, withdrawn from regional service delivery, stopped accepting complex participants or considered leaving the NDIS entirely because current pricing arrangements are incompatible with sustainable practice.
For this reason, Professionals Australia submits that future NDIS pricing reviews should include a formal gender impact assessment. Pricing decisions should be evaluated not only against budgetary outcomes but also against their likely impacts on women’s workforce participation, retention, earnings and career progression.
A recurring theme in evidence received by Professionals Australia is that many services continue to operate because practitioners are personally committed to participants rather than because the business model is sustainable. Members regularly report undertaking unpaid administrative work, unpaid coordination, unpaid report writing and unpaid participant communication in order to maintain service quality. While this commitment reflects the professionalism of the workforce, it should not form the foundation of public policy.
A sustainable funding framework should not depend upon practitioners working unpaid hours, accepting declining profitability or sacrificing their own wellbeing to compensate for structural funding deficiencies. The current reliance on professional goodwill masks underlying sustainability problems. It can delay provider exits in the short term, but it often contributes to burnout, workforce dissatisfaction and eventual attrition.
Professionals Australia submits that pricing should reflect the actual work required to deliver services rather than assuming practitioners will continue to absorb unfunded labour indefinitely.
Professionals Australia is concerned that workforce costs are sometimes framed primarily as a financial burden on the Scheme. This framing misunderstands how the NDIS operates. The workforce is not a cost centre separate from participant outcomes. The workforce is the mechanism through which participant outcomes are delivered. Every improvement in communication, mobility, independence, employment participation, education participation, social inclusion or functional capacity ultimately occurs because a skilled worker has supported that outcome. Every successful early intervention program, assistive technology prescription, behavioural support plan, therapy intervention or interpreting service relies upon the expertise of trained professionals.
Reducing investment in the workforce may reduce expenditure in the short term, but it also reduces the system’s capacity to deliver outcomes. Professionals Australia submits that workforce sustainability should therefore be treated as a core performance measure for the NDIS rather than a secondary consideration.
Professionals Australia does not accept that Scheme sustainability can be achieved by focusing exclusively on government expenditure. True sustainability requires three elements to exist simultaneously. Providers must be able to operate viable businesses. Workers must be able to sustain long-term professional careers without excessive burnout, unpaid labour or financial insecurity. Participants must be able to access timely, high-quality supports that improve their outcomes and quality of life. If any one of these elements fails, the broader system becomes unstable.
A provider market characterised by business closures is not sustainable. A workforce characterised by burnout and attrition is not sustainable. A participant population facing long waiting lists and reduced access to services is not sustainable.
Professionals Australia accepts that the NDIS must be financially sustainable and that pricing should include safeguards against overcharging, poor quality services and inappropriate claiming. However, Scheme sustainability cannot be achieved by suppressing the cost of labour or transferring costs onto workers, participants and families.
The current debate around NDIS expenditure often frames workforce costs as a financial pressure on the Scheme. Professionals Australia submits that the workforce should instead be viewed as a strategic asset. Every successful NDIS outcome depends upon the availability of skilled professionals capable of delivering safe, effective and person-centred supports. A pricing framework that fails to retain those professionals will inevitably undermine participant outcomes, increase unmet need and create additional costs elsewhere in the health, education, justice and social services systems.
Professionals Australia is also concerned that inadequate pricing may accelerate the consolidation and corporatisation of disability services. Large providers are often better positioned to absorb funding pressures through economies of scale, while small providers, sole practitioners and community-based organisations may struggle to remain viable. Participants consistently report valuing smaller providers because of their flexibility, continuity of care, local knowledge and personalised support. A pricing framework that unintentionally drives smaller providers from the market risks reducing participant choice and weakening local service ecosystems.
The impact is particularly pronounced in regional, rural and remote communities. In many locations, participant choice already exists only in theory. Participants may have access to a single provider, limited outreach services or lengthy waiting lists. In these contexts, pricing decisions can determine whether services remain available at all.
Professionals Australia further notes that the long-term consequences of inadequate pricing are unlikely to be borne solely by the NDIS. When participants cannot access timely allied health intervention, the resulting impacts are often felt across health, education, housing, child protection, justice and mental health systems. Delayed therapy, reduced access to communication supports, insufficient behavioural intervention and limited community participation can all create additional costs that ultimately fall elsewhere within government systems. The central question should not be whether prices can be reduced. The central question should be whether pricing arrangements are sufficient to ensure participants can access skilled, experienced professionals when and where they need them.
Professionals Australia’s preferred approach is therefore a regulated pricing framework based on independent price setting, transparent methodology, annual indexation, proper recognition of non- face-to-face work, adequate travel funding, complexity loadings, workforce planning, market stewardship and gender impact assessment. Price caps may continue to play a role in protecting participants and the Scheme from excessive charging, but they must be set at levels that support sustainable professional practice and participant access.
Ultimately, the success of the NDIS depends upon the people who deliver it. A pricing system that relies upon unpaid labour, workforce shortages, business closures and professional goodwill is neither equitable nor sustainable. A sustainable NDIS requires sustainable businesses, sustainable workers and sustainable participants simultaneously. Pricing arrangements must recognise the full value, skill and complexity of the work being performed because workforce sustainability and participant outcomes are fundamentally inseparable.
Question 3: What are your top three recommended reforms to improve workforce sustainability
within the NDIS?
Professionals Australia submits that workforce sustainability is one of the most significant challenges facing the National Disability Insurance Scheme (NDIS). The success of the NDIS depends upon the availability of a skilled, stable and adequately supported workforce capable of delivering high-quality services to participants across Australia. Workforce sustainability is not a secondary issue. It is fundamental to participant outcomes, market stability, participant choice and control, and the long- term sustainability of the Scheme itself.
The Independent Review into the NDIS identified workforce shortages, market failures and service availability as key risks to the future effectiveness of the Scheme (Independent Review into the National Disability Insurance Scheme, 2023). Similarly, workforce shortages have been identified across numerous allied health professions, disability support occupations and interpreting services,
creating growing challenges for participants seeking timely access to supports (Jobs and Skills Australia, 2025).
Professionals Australia recommends three priority reforms.
Reform 1: Establish an Independent Workforce and Pricing Authority for the NDIS
Professionals Australia recommends the establishment of an independent workforce and pricing authority responsible for workforce planning, market monitoring and evidence-based pricing recommendations. Current arrangements place responsibility for both Scheme administration and Pricing decisions within the NDIA. While the NDIA performs an important role, the current framework creates an inherent tension between short-term expenditure management and long-term workforce sustainability.
Workforce sustainability requires independent oversight of workforce supply, workforce demand, provider viability, regional workforce shortages, participant access and market performance (Independent Review into the National Disability Insurance Scheme, 2023; Productivity Commission, 2017). Workforce sustainability should therefore be treated as a key performance measure of the NDIS rather than an indirect outcome (Independent Review into the National Disability Insurance Scheme, 2023).
The authority should collect and publish workforce data including vacancy rates, waiting times, workforce turnover, workforce demographics, provider exits, participant access measures and regional workforce availability. It should undertake regular modelling of future workforce demand across allied health professions, disability support occupations, interpreting services and specialist disability supports.
A major concern raised by Professionals Australia members is that workforce impacts are often treated as a consequence of policy decisions rather than a core consideration in policy development. The workforce should be recognised as a strategic asset of the Scheme. Every participant outcome relies upon the availability of appropriately qualified professionals. Workforce sustainability should therefore be treated as a key performance measure of the NDIS rather than an indirect outcome.
The authority should assess the impacts of pricing decisions on workforce attraction, retention and provider viability before implementation. It should also monitor the impact of pricing decisions on participant access, waiting times, regional service availability and provider market sustainability.
Professionals Australia further submits that the authority should be responsible for monitoring the administrative impacts of policy and pricing decisions. Workforce sustainability is affected not only by remuneration and workforce supply, but also by the administrative burden placed upon providers and practitioners. Members consistently report spending increasing amounts of time responding to funding reviews, preparing duplicate reports, navigating compliance requirements and supplying evidence that has already been provided through previous processes.
The authority should therefore assess the workforce implications of administrative burden and regulatory duplication. This would ensure that workforce capacity is not unintentionally reduced through policy settings that divert professional time away from participant care.
Professionals Australia is concerned that there remains no comprehensive public dataset capable of accurately tracking workforce exits, provider closures, waiting times, workforce turnover and unmet participant demand across the Scheme. Effective workforce planning depends upon reliable workforce intelligence. The Committee should recommend regular public reporting on workforce sustainability indicators, including workforce supply, vacancy rates, waiting times, provider viability, regional access, workforce diversity and participant outcomes. Without robust workforce data, governments risk responding to workforce shortages only after they have become entrenched. Better workforce intelligence would support earlier intervention, more effective workforce planning and more informed policy development (Jobs and Skills Australia, 2025).
Importantly, workforce planning must include consideration of gender equity. The disability workforce is overwhelmingly female, particularly within allied health professions, disability support services, community services and interpreting services (WGEA, 2024; Allied Health Professions Australia [AHPA], 2024)). Policies that suppress remuneration, increase unpaid labour or fail to account for non-billable work disproportionately affect women workers. Workforce planning should therefore incorporate gender impact assessments and workforce participation analysis to ensure pricing and workforce policies support retention, career progression and long-term workforce participation.
Reform 2: Develop and Fund a National NDIS Workforce Strategy
Professionals Australia recommends the development of a long-term National NDIS Workforce Strategy focused on workforce attraction, retention, professional development and career progression. While significant attention has been given to participant growth and Scheme expenditure, comparatively less attention has been paid to the workforce required to deliver services. A sustainable NDIS requires a workforce strategy comparable in ambition to those developed for aged care, nursing and medical workforces (Health Workforce Australia, 2014; Independent Review into the National Disability Insurance Scheme, 2023). The strategy should address workforce shortages across allied health professions, disability support occupations, behaviour support services, interpreting services and emerging specialist areas. Workforce sustainability cannot be achieved through recruitment alone.
The evidence received by Professionals Australia demonstrates that retention is becoming an increasingly significant challenge. Many practitioners report leaving the NDIS because of burnout, excessive administrative burden, inadequate remuneration, insufficient supervision, growing compliance requirements and increasing complexity of participant needs (Professionals Australia, 2026). A workforce strategy should therefore focus on retaining experienced workers rather than relying solely upon new entrants. The strategy should include funded supervision programs, graduate pathways, mentoring frameworks, leadership development opportunities and continuing professional development.
Professionals Australia has repeatedly heard from members that supervision, mentoring and peer support are among the most important factors influencing workforce retention, particularly for early- career practitioners and practitioners working in regional and remote communities.
Professionals Australia is also concerned that workforce sustainability discussions often focus on workforce numbers while overlooking workforce wellbeing. Many NDIS professionals work with participants experiencing significant trauma, family violence, abuse, neglect, mental ill-health, complex psychosocial needs and highly distressing life circumstances. Allied health professionals, behaviour support practitioners, disability support workers and interpreters are regularly exposed to traumatic content as part of their work (Professionals Australia, 2026; AHPA, 2024).
Professionals Australia’s evidence from interpreters has highlighted situations where practitioners have been exposed to highly traumatic matters, including sexual assault investigations, family violence matters and child protection issues, often without access to structured debriefing or professional support.
Workforce sustainability is not simply about attracting workers into the Scheme. It is also about ensuring workers can remain in the Scheme without experiencing burnout, compassion fatigue or psychological injury (National Mental Health Commission, 2023).
Investment in supervision, reflective practice, mentoring, trauma-informed workplaces and wellbeing supports should therefore be recognised as core workforce infrastructure rather than discretionary expenditure (National Mental Health Commission, 2023; Deloitte Access Economics, 2025).
The strategy should also support multidisciplinary and collaborative models of care. Many participants require coordinated support from multiple professions, yet current funding arrangements often discourage collaboration because non-face-to-face work is inadequately funded. A sustainable workforce requires service models that support professional collaboration rather than professional isolation.
The strategy should further recognise the growing pressures facing sole practitioners and small businesses, which comprise a significant proportion of the NDIS workforce. Many providers report that increasing compliance requirements and administrative workloads are becoming barriers to remaining in the Scheme. Professionals Australia submits that workforce retention cannot be addressed without reducing administrative burden.
Members repeatedly report that burnout is driven not only by workload and remuneration concerns, but also by excessive paperwork, repetitive reporting requirements, funding review processes and growing compliance obligations. Many practitioners describe spending increasing amounts of time justifying supports rather than delivering supports.
Occupational therapists, speech pathologists and physiotherapists have reported devoting substantial clinical time to preparing reports, gathering evidence and responding to requests for information associated with funding decisions. In many cases, practitioners report providing the same information multiple times through different processes.
Professionals Australia has heard repeatedly from allied health practitioners that increasing amounts of clinical time are being diverted away from participant care and towards evidentiary requirements associated with NDIS planning, reassessments, reviews and funding decisions. Members report spending hours preparing reports and supporting documentation to justify supports that are already well-established, clinically recommended or previously approved. This time is often unpaid, poorly remunerated or funded through resources that would otherwise be directed to participant services. The result is that highly skilled clinicians are increasingly spending time proving the need for services rather than delivering them (Professionals Australia, 2026).
Beyond workforce impacts, this administrative burden has direct consequences for participants. Every hour spent producing duplicative reports or responding to repeated evidence requests is an hour unavailable for therapy, assessment, intervention, care coordination or early intervention. In practice, administrative inefficiency reduces the effective capacity of the workforce and contributes to longer waiting times and reduced service availability (Independent Review into the National Disability Insurance Scheme, 2023). This duplication reduces workforce productivity, contributes to burnout and limits the time available for participant care.
A National Workforce Strategy should therefore include a dedicated stream focused on reducing administrative burden, simplifying reporting requirements, improving information-sharing across the Scheme and eliminating unnecessary duplication. Reducing unnecessary administration represents one of the most immediate opportunities to increase workforce capacity without requiring additional workforce supply. Every hour returned to practitioners is an hour that can be spent supporting participants.
Reform 3: Establish an Equity, Inclusion and Access Framework for the NDIS Workforce
Professionals Australia recommends the establishment of a national framework focused on improving workforce access and equity for First Nations peoples, culturally and linguistically diverse communities, regional and remote communities and participants with complex support needs. Workforce shortages do not affect all participants equally.
Participants living in regional and remote communities frequently experience longer waiting times, fewer provider options and greater difficulty accessing specialised supports (Independent Review into the National Disability Insurance Scheme, 2023; Australian Institute of Health and Welfare [AIHW], 2024).
Similarly, First Nations participants continue to experience barriers to accessing culturally safe disability supports (AIHW, 2024; Coalition of Peaks, 2023), while participants from culturally and linguistically diverse communities often face significant challenges obtaining services in their preferred language or delivered in culturally appropriate ways (Deloitte Access Economics, 2025; Federation of Ethnic Communities’ Councils of Australia [FECCA], 2024).
Professionals Australia’s work with interpreters has highlighted the critical role language services play in ensuring equitable access to government services, healthcare, legal systems and disability supports.
The Deloitte Access Economics report, Translating and Interpreting Services: A Case for Change, identified an ageing workforce, significant retention challenges and growing concerns regarding workforce sustainability (Deloitte Access Economics, 2025). The report found that approximately 43 per cent of practising interpreters are approaching retirement age and highlighted concerns regarding remuneration, insecure work and workforce retention. Without targeted intervention, workforce shortages within the interpreting profession risk creating significant barriers for CALD participants attempting to access and navigate the NDIS.
Professionals Australia submits that workforce sustainability must include investment in culturally responsive workforce development. This should include targeted recruitment and retention initiatives for First Nations workers, bilingual practitioners, interpreters and professionals from diverse cultural backgrounds. The framework should support culturally safe supervision, culturally responsive professional development, community-led workforce initiatives and partnerships with First Nations and multicultural organisations.
Professionals Australia also recommends greater recognition and support for workers with lived experience of disability, First Nations workers, bilingual practitioners and community-based workforce models. These workers often play a critical role in building trust, improving engagement and supporting access to services for participants who may otherwise experience barriers to support (Coalition of Peaks, 2023; FECCA, 2024).
Participants from culturally and linguistically diverse communities frequently report better outcomes when services are delivered by workers who understand their language, culture and community context. Similarly, participants may benefit from services delivered by workers with lived experience of disability who bring unique perspectives and insights to their work.
Workforce sustainability should therefore be measured not only by workforce numbers but also by workforce diversity, cultural capability and the extent to which the workforce reflects the communities it serves (Closing the Gap Priority Reform Three, 2023).
Targeted investment in First Nations workforce development, bilingual workforce pathways, interpreting services and culturally responsive professional development should form part of any long- term workforce sustainability strategy. Importantly, workforce planning should recognise that participant choice and control cannot exist where culturally appropriate services are unavailable. For many participants, meaningful access to the NDIS depends upon the availability of workers who understand their language, culture, community and lived experience (FECCA, 2024; Coalition of Peaks, 2023).
Administrative complexity can also create equity barriers. First Nations participants, culturally and linguistically diverse participants, participants living in regional and remote communities, and participants with complex support needs often require additional coordination, advocacy and engagement to successfully navigate the Scheme. Practitioners working with these cohorts frequently report spending significant amounts of time supporting participants through administrative processes that are difficult to navigate.
Excessive administrative requirements therefore affect not only workforce sustainability but also participant access and equity. Time spent navigating bureaucracy is time unavailable for culturally responsive practice, relationship-building, community engagement and direct service delivery. Workforce sustainability reforms should therefore include a focus on reducing administrative barriers for both participants and practitioners, particularly where those barriers disproportionately affect vulnerable and underserved communities.
Workforce sustainability should be measured not only by workforce numbers but also by workforce diversity, accessibility and cultural capability.
Conclusion
Professionals Australia submits that workforce sustainability represents one of the most significant long-term challenges facing the NDIS.
A sustainable workforce cannot be achieved through recruitment initiatives alone. It requires coordinated workforce planning, evidence-based pricing, investment in retention, support for professional development, reduced administrative burden, stronger career pathways, improved workforce wellbeing and targeted action to address inequities experienced by First Nations peoples, culturally and linguistically diverse communities, regional and remote communities, and participants with complex support needs.
The Committee should recognise that workforce sustainability, participant outcomes and Scheme sustainability are fundamentally interconnected. Participants cannot exercise genuine choice and control where providers are unavailable. Early intervention cannot occur where waiting lists are excessive (Productivity Commission, 2017). Culturally safe services cannot be delivered where diverse workforces are absent. Regional access cannot be achieved where providers cannot afford to operate. Nor can workforce sustainability be achieved where practitioners spend increasing amounts of time navigating bureaucracy rather than supporting participants.
Professionals Australia further submits that reducing unnecessary administrative burden represents one of the most immediate and cost-effective opportunities to improve workforce sustainability. Every hour spent on duplicative reporting, repeated evidence requests and unnecessary compliance processes is an hour unavailable for participant care. Streamlining these processes would increase workforce capacity, improve productivity and enhance participant access without compromising accountability or safeguards.
Workforce sustainability should not be viewed solely as an industrial or labour market issue. It is fundamentally a participant rights issue. When an occupational therapist leaves the Scheme, participants lose access to assessments, home modifications and assistive technology support. When a speech pathologist leaves, participants may lose access to communication supports that underpin education, employment and community participation. When a physiotherapist leaves, participants may lose access to mobility and functional supports that enable independence. When an interpreter leaves, participants may lose the ability to effectively navigate disability, health, legal and government
systems. Workforce shortages therefore represent more than a service delivery challenge. They represent a direct threat to participant access, choice and control.
Ultimately, a sustainable NDIS requires sustainable workers, sustainable providers and sustainable participants simultaneously. The workforce is not a cost centre. It is the mechanism through which participant outcomes are delivered. Investing in workforce sustainability is therefore not simply an investment in workers. It is an investment in the future success of the NDIS itself and in the rights of people with disability to access the supports they need to participate fully in Australian society (United Nations Convention on the Rights of Persons with Disabilities, 2006).
Question 4: What evidence do you have of compromised outcomes linked to workforce constraints?
Professionals Australia submits that there is substantial evidence that workforce constraints are already compromising participant outcomes across the National Disability Insurance Scheme (NDIS).
Workforce shortages should not be viewed solely as a labour market issue. They are fundamentally a participant outcome issue. The quality, accessibility and continuity of NDIS supports are directly dependent on the availability of a skilled and sustainable workforce. When workforce capacity declines, participant outcomes decline with it.
The Independent Review into the NDIS identified workforce shortages, market failures and service availability as key risks to participant access, choice and control (Independent Review into the National Disability Insurance Scheme, 2023). Professionals Australia has received consistent evidence from allied health professionals, interpreters and other practitioners indicating that workforce constraints are already affecting the availability, timeliness and quality of supports delivered to participants.
The evidence available to Professionals Australia demonstrates compromised outcomes across eight key areas: access to services, delayed intervention, participant safety, continuity of care, equity of access, participant choice and control, increased burden on families and carers, and reduced economic participation.
Reduced Access to Services
The most immediate impact of workforce constraints is reduced access to services. Professionals Australia members have reported increasing difficulty maintaining service availability due to workforce shortages, financial pressures, administrative burden and growing challenges in recruiting and retaining experienced practitioners.
Allied health practitioners have reported closing books to new referrals, reducing NDIS caseloads, limiting outreach services and restricting services to participants with complex needs because current funding and workforce conditions are becoming increasingly unsustainable (Professionals Australia, 2026).
Professionals Australia has received evidence from occupational therapists, speech pathologists and physiotherapists indicating that participants are experiencing longer waiting periods before receiving
assessments and interventions. In some communities, particularly regional and remote communities, participants may wait many months before accessing specialist allied health supports.
The recent reduction and removal of travel funding has exacerbated these challenges. Members have reported reassessing service areas, reducing outreach activities and limiting home visits because travel costs can no longer be recovered. In practical terms, this means some participants are no longer able to access services that were previously available. A participant cannot benefit from supports that are unavailable. Workforce constraints therefore translate directly into reduced participant access.
Delayed Intervention and Missed Opportunities
Workforce shortages are also delaying intervention and reducing opportunities for early support.
The evidence supporting early intervention is well established. Timely access to occupational therapy, speech pathology, physiotherapy, psychology and other allied health supports can improve functional capacity, communication, educational participation, independence and long-term outcomes (Productivity Commission, 2017; Independent Review into the National Disability Insurance Scheme, 2023). However, workforce shortages and provider capacity constraints are increasingly limiting access to early intervention services.
Professionals Australia members report growing waiting lists across multiple allied health disciplines. For children requiring developmental supports, a delay of several months may represent a significant lost opportunity during critical developmental periods. Similarly, participants requiring assistive technology, home modifications, communication supports or behavioural interventions may experience delays that affect their ability to participate in education, employment, community activities and daily life.
Professionals Australia has also heard concerns from practitioners working in early childhood intervention that workforce shortages and provider constraints are increasingly affecting access to timely supports for children with developmental delay and autism. Delayed intervention can result in missed developmental opportunities and increased support needs later in life.
Workforce shortages therefore have consequences that extend beyond delayed appointments. They can alter developmental trajectories, reduce functional gains and increase long-term support needs.
The Productivity Commission has previously noted that early intervention can improve outcomes and reduce future support requirements (Productivity Commission, 2017). Delays caused by workforce shortages therefore risk increasing costs and support needs over time.
Compromised Safety and Increased Participant Risk
Professionals Australia is concerned that workforce shortages are increasingly creating risks for participants with complex support needs.
Many participants rely on timely access to allied health professionals, behaviour support practitioners, interpreters and other specialists to maintain functional capacity, manage health conditions, support
communication and reduce risks associated with disability. When workforce shortages delay assessments, reviews or interventions, participants may experience deterioration in physical function, communication capacity, mental health, behavioural stability or community participation.
Professionals Australia members have reported concerns regarding delayed assistive technology assessments, delayed home modification recommendations, interruptions to therapy programs and reduced access to specialist services. For participants with complex needs, these delays may increase the likelihood of hospitalisation, falls, social isolation, behavioural escalation, carer breakdown or loss of independence.
Workforce sustainability should therefore be viewed not only as a service access issue but also as a participant safety issue.
Reduced Continuity of Care
Professionals Australia has also received evidence that workforce instability is affecting continuity of care.
Continuity of care is particularly important within disability services because effective support often relies upon long-term therapeutic relationships, deep understanding of participant circumstances and accumulated clinical knowledge. When experienced practitioners leave the Scheme, participants frequently lose access to professionals who understand their goals, communication styles, support needs, family circumstances and service history. Participants may be required to transition to new practitioners, repeat assessments, retell traumatic experiences or rebuild therapeutic relationships from the beginning.
Members report that high workforce turnover can result in interruptions to therapy programs, delays in service delivery and reduced confidence in support systems. These impacts are particularly significant for participants with complex communication needs, psychosocial disability, behavioural support needs or histories of trauma. The loss of continuity can undermine participant trust, engagement and outcomes.
Participants with Complex Needs Are Disproportionately Affected
Professionals Australia members consistently report that workforce shortages have the greatest impact on participants with complex support needs.
Participants requiring multidisciplinary intervention, intensive behavioural support, complex assistive technology, home modifications, communication supports or psychosocial disability services often require highly experienced practitioners and substantial coordination between service providers. These participants are also more likely to require non-face-to-face work, multidisciplinary collaboration and ongoing monitoring.
When workforce shortages occur, providers frequently report being forced to prioritise available capacity. Participants with complex needs may face longer waiting times, reduced provider choice and greater difficulty accessing practitioners with the necessary expertise. Professionals Australia is
concerned that current workforce pressures may unintentionally create inequitable outcomes whereby participants with the greatest support needs face the greatest barriers to accessing services.
Members have also reported increasing reluctance among providers to accept participants with highly complex support needs because of the significant amount of unfunded coordination, report writing, multidisciplinary communication and administrative work involved. Participants requiring complex assistive technology, behavioural supports, home modifications or multidisciplinary intervention are often those most affected by workforce shortages because they require highly experienced practitioners and intensive service coordination.
Reduced Access for First Nations Participants, CALD Participants and Regional Communities
Professionals Australia is particularly concerned about the impact of workforce constraints on vulnerable and underserved communities.
Workforce shortages are not experienced equally across the NDIS. Participants living in regional and remote communities often experience greater difficulty accessing services because workforce shortages are more severe and provider markets are thinner (Independent Review into the National Disability Insurance Scheme, 2023; Australian Institute of Health and Welfare [AIHW], 2024). In many communities, participant choice exists only in theory because there may be limited providers available or extensive waiting lists for specialist supports.
First Nations participants continue to experience barriers to accessing culturally safe disability services. Workforce shortages can further reduce access to workers who understand local communities, cultural contexts and culturally responsive approaches to care (Coalition of Peaks, 2023).
Similarly, culturally and linguistically diverse (CALD) participants often face significant challenges accessing services in their preferred language or delivered in culturally appropriate ways. Professionals Australia’s work with interpreters has highlighted growing concerns regarding workforce sustainability within the translating and interpreting sector. Deloitte Access Economics found that approximately 43 per cent of practising interpreters are approaching retirement age and identified significant concerns regarding workforce retention (Deloitte Access Economics, 2025). Workforce shortages among interpreters can create substantial barriers for CALD participants attempting to access disability supports, understand planning processes, communicate with providers and exercise informed choice. For these participants, workforce constraints may directly affect their ability to navigate and benefit from the Scheme.
Reduced Participant Choice and Control
Choice and control are foundational principles of the NDIS. However, meaningful choice and control require the availability of services. The Independent Review into the NDIS recognised that participants cannot exercise genuine choice where services are unavailable, provider markets are thin or workforce shortages limit access to supports (Independent Review into the National Disability Insurance Scheme, 2023).
Professionals Australia members consistently report situations where participants accept whichever provider is available rather than the provider best suited to their needs. This is particularly common in regional communities, for participants requiring specialist supports and for participants with complex needs. Choice without availability is not genuine choice. Workforce shortages therefore undermine one of the central objectives of the NDIS.
Increased Burden on Families and Carers
Professionals Australia has also received evidence that workforce constraints are increasing pressure on families and carers. When participants experience delays accessing services, lose access to providers or encounter gaps in support, families frequently absorb additional caring responsibilities. Parents may spend additional time coordinating services, advocating for supports, managing waiting lists and filling gaps in service provision. This burden is often disproportionately carried by women. Research consistently demonstrates that women continue to undertake the majority of unpaid caring responsibilities within Australian households (Workplace Gender Equality Agency, 2024).
Workforce shortages within the disability sector therefore have broader implications for workforce participation, economic security and gender equality. When formal supports become harder to access, unpaid care responsibilities frequently increase. In this way, workforce constraints shift costs from the Scheme onto families and carers.
Reduced Workforce Participation and Economic Inclusion
Professionals Australia has received evidence that workforce shortages are also affecting the economic participation of people with disability and their families. Many participants rely on allied health services, communication supports, workplace supports and capacity-building interventions to participate in employment, education and community life. When access to these services is delayed or unavailable, participants may be less able to pursue employment opportunities, undertake study or engage in social and economic activities.
Workforce shortages can also affect carers’ workforce participation. Parents and carers frequently report reducing working hours, declining career opportunities or leaving employment entirely when formal supports are unavailable. These impacts are particularly significant for women, who continue to undertake the majority of unpaid caring responsibilities. Workforce shortages within the NDIS therefore have consequences not only for participants but also for broader labour force participation and economic productivity.
Administrative Burden and Reduced Workforce Capacity
Professionals Australia has received substantial evidence that increasing administrative burden is reducing effective workforce capacity. Members report spending growing amounts of time preparing reports, responding to evidence requests, participating in funding reviews and navigating compliance requirements.
Occupational therapists, speech pathologists and physiotherapists have described spending hours preparing documentation to justify supports that are already clinically established, previously approved or widely recognised as necessary. Practitioners consistently reported that they were spending increasing amounts of time proving the need for supports rather than meeting the need for supports. This administrative burden has direct implications for participant outcomes. Every hour spent preparing duplicative reports is an hour unavailable for therapy, assessment, intervention, care coordination or early intervention.
Workforce shortages are therefore being compounded by administrative inefficiencies that reduce the amount of time practitioners can spend delivering services. In practical terms, participants experience the consequences through reduced service availability, longer waiting times and fewer opportunities for intervention.
Costs Shifted to Other Systems
Professionals Australia is concerned that workforce constraints may ultimately increase costs elsewhere across government systems. When participants cannot access timely allied health services, interpreting services or disability supports, the consequences are often felt across healthcare, education, housing, child protection, mental health and justice systems.
Delayed intervention may result in greater support needs over time. Reduced access to communication supports may affect educational outcomes and employment participation. Limited access to behavioural supports may increase pressure on families, schools and community services. Workforce shortages therefore do not eliminate costs. They shift costs.
The long-term sustainability of the NDIS depends upon recognising that workforce investment is not simply expenditure. It is a mechanism for preventing future costs and improving participant outcomes.
Evidence from Professionals Australia Members and Stakeholders
The experiences reported by Professionals Australia members provide practical examples of the ways workforce constraints are already affecting participant outcomes.
Professionals Australia has received evidence from allied health providers indicating that current funding and workforce conditions are forcing difficult decisions regarding participant access. One occupational therapy provider advised that, despite maintaining a full caseload, their practice was operating at approximately two per cent profit after accounting for administration, supervision, travel, compliance obligations, professional development and clinical documentation. The provider advised that they were reassessing whether they could continue accepting new NDIS participants under current funding arrangements.
Professionals Australia has also received reports from speech pathologists, occupational therapists and physiotherapists who have reduced service areas or withdrawn outreach services following changes to travel funding arrangements. Practitioners reported that travel to regional communities, schools, homes and community settings was becoming increasingly difficult to sustain financially. These
changes have direct consequences for participants who require community-based services and for those living in regional, rural and remote areas where alternative providers may not exist.
Members have further reported increasing reluctance among providers to accept participants with highly complex support needs because of the significant amount of unfunded coordination, report writing, multidisciplinary communication and administrative work involved.
Professionals Australia’s work with interpreters has revealed similar concerns. Deloitte Access Economics found that approximately 43 per cent of practising interpreters are approaching retirement age and identified significant challenges in attracting and retaining experienced professionals (Deloitte Access Economics, 2025).
Professionals Australia has received reports from interpreters working in highly traumatic environments without adequate support structures. One interpreter reported being engaged to assist a victim during a sexual assault investigation involving highly distressing content. Following the assignment, the interpreter was advised to seek their own counselling support. Another interpreter reported repeated interruptions and dismissive treatment while facilitating communication within a hospital setting, creating risks for both the interpreter and the patient involved.
While these examples arise outside the NDIS itself, they illustrate broader workforce sustainability issues affecting sectors that are critical to equitable access for participants from culturally and linguistically diverse communities. These examples demonstrate that workforce constraints are not theoretical concerns. They are already influencing provider decisions, workforce participation and participant access to services.
Workforce Constraints and Emerging Market Failure
The Independent Review into the National Disability Insurance Scheme observed that participant choice and control cannot be realised in the absence of functioning service markets (Independent Review into the National Disability Insurance Scheme, 2023).
Professionals Australia submits that the evidence received from members suggests that workforce constraints are increasingly creating conditions consistent with emerging market failure in parts of the Scheme. Across multiple professions, members report reducing NDIS caseloads, limiting outreach services, restricting services to participants with complex needs, closing books to new referrals and reconsidering their ongoing participation in the Scheme. While individual decisions may appear isolated, collectively they indicate growing pressure on workforce supply and provider viability.
These pressures are particularly evident in regional, rural and remote communities, where workforce shortages are often more pronounced and participant choice is already limited. In some locations, the withdrawal of a single provider can substantially reduce service availability. Participants may face lengthy waiting periods, travel significant distances to access supports, or be left with no realistic provider options.
Professionals Australia has also received evidence that workforce pressures are affecting highly specialised areas of practice. Allied health professionals report increasing difficulty sustaining services requiring extensive non-face-to-face work, multidisciplinary coordination and complex clinical expertise. Interpreters report growing workforce shortages and concerns regarding workforce ageing and retention. These workforce pressures have direct implications for participant outcomes.
Participants who require specialised services, culturally responsive supports, interpreting services, behavioural supports, complex assistive technology assessments or multidisciplinary intervention are often those most affected when workforce capacity declines. The consequences are particularly significant for participants with complex needs, First Nations participants, culturally and linguistically diverse participants, and participants living in regional and remote communities.
Professionals Australia is concerned that current workforce trends may undermine one of the foundational principles of the NDIS. Choice and control depend upon the availability of qualified providers. Where participants are unable to access services within reasonable timeframes, where specialist expertise is unavailable, or where only a single provider remains available, participant choice becomes increasingly constrained. Choice without availability is not genuine choice.
The evidence available to Professionals Australia suggests that workforce constraints are no longer a future risk requiring monitoring. They are a current reality affecting participant access, continuity of care and service availability across parts of the Scheme. For this reason, workforce sustainability should be understood not only as a workforce issue, but also as a market stewardship issue. Maintaining a sustainable workforce is essential to maintaining functioning markets, and functioning markets are essential to achieving participant choice and control.
Conclusion
The evidence available to Professionals Australia demonstrates that workforce constraints are already affecting participant outcomes across the Scheme. Participants are waiting longer for services, losing access to experienced practitioners, experiencing reduced continuity of care and facing increasing barriers to choice and control. These impacts are not distributed equally. They are felt most acutely by participants in regional and remote communities, First Nations participants, culturally and linguistically diverse participants, participants with complex support needs and families already carrying significant caring responsibilities.
Workforce sustainability should not be viewed solely as a labour market issue. It is fundamentally a participant rights issue. When an occupational therapist leaves the Scheme, participants lose access to assessments, home modifications and assistive technology support. When a speech pathologist leaves, participants may lose access to communication supports that underpin education, employment and community participation. When an interpreter leaves, participants may lose the ability to effectively navigate disability, health, legal and government systems.
Workforce shortages therefore represent more than a service delivery challenge. They represent a direct threat to participant access, choice and control.
Every participant outcome ultimately depends upon the availability of a skilled workforce. When workforce capacity declines, participant outcomes decline with it.
The evidence available to Professionals Australia suggests that workforce constraints are no longer a future risk. They are a current reality affecting participants across the Scheme. Participants are already experiencing longer waiting times, reduced access to specialised supports, diminished continuity of care and fewer opportunities to exercise genuine choice and control. The Committee should therefore view workforce sustainability as an urgent participant outcome issue requiring immediate attention. Delayed action risks further provider exits, increasing market failure, longer waiting lists and worsening outcomes for participants who rely upon timely access to supports.
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