Psychology Supports and Accountability in the National Disability Insurance Scheme

Submission to the

29 January, 2026

Dear Joint Committee of Public Accounts and Audit (JCPAA),

The Australian Association of Psychologists Inc. (AAPi) is the peak body representing psychologists across Australia, including a substantial membership delivering therapeutic, behavioural, and assessment services to NDIS participants. Our members work at the coalface with autistic people, people with intellectual disability, people with psychosocial disability, physical disabilities, sensory disabilities, cognitive impairment, neurological conditions, and complex co-morbidities. We welcome the opportunity to contribute to the JCPAA’s inquiry into the administration of the NDIS.

Executive Summary

AAPi’s central concern is that the current administration of the Scheme is failing to adequately provide timely, evidence-based psychology supports to people with disability, with serious knock-on impacts for participant safety and wellbeing. These failures are exacerbated by unsatisfactory accountability and transparency from the National Disability Insurance Agency (NDIA), even as the Agency’s decisions materially affect participants’ risk of harm. Recent legislative reforms intended to “get the NDIS back on track” are not translating into improved participant outcomes, and in some areas, notably psychosocial disability access and continuity of psychological support for disabled Australians, the situation has deteriorated.

We ask the Committee to recommend urgent, targeted actions (detailed at the end of this submission) to:

1. Restore reliable access to psychology supports;
2. Strengthen independent accountability for NDIA decision-making; and
3. Stabilise the psychosocial support system inside and outside the NDIS.

Addressing the Terms of Reference

1) NDIA delivery of the NDIS, with reference to performance monitoring, risk, and compliance

Access to psychology supports is faltering. Even before the 2024 legislative amendments commenced, approval rates for psychosocial disability—the cohort for whom regular, structured psychological supports are most clearly indicated collapsed from ~66% to ~25% over five years, despite no formal change to eligibility criteria. This steep decline is unique to psychosocial disability and is not mirrored across other disability groups, pointing to systemic administrative barriers rather than reduced need. The human impact is severe: people denied access face worsening symptoms, crisis presentations, greater use of acute services and a suicide rate in Australia that has continued to increase at alarming levels.

Participants’ mental health distress remains high. The latest Australia’s Disability Strategy Outcomes Framework shows no improvement in high/very high psychological distress among adults with disability since baseline (32% to 31%), underscoring persistent unmet mental health need in the disability population. This is consistent with what AAPi members observe: participants experience greater instability in plans, more “stated supports,” shorter funding periods, and gaps between plans, all of which disrupt therapy and increase distress.

NDIA performance reporting and accountability are insufficient. In both 2023– 24 and 2024–25, the Auditor-General issued qualified conclusions over NDIA annual performance statements, citing material omissions in performance information— including on fraud/non-compliance and the effectiveness of early intervention supports, a core function related to improving participant outcomes. This calls into question whether the Agency’s reporting allows Parliament and the public to assess whether participants are safer and better supported.

Board governance needs strengthening. The ANAO’s 2025 performance audit found the NDIA Board “largely effective” yet identified gaps in conflict-of-interest management, risk oversight, and strategic reporting on financial sustainability initiatives. For a demand-driven scheme where administrative settings directly shape clinical risk, these governance gaps have real consequences for participants.

Market stewardship is lagging. Provider viability remains under pressure with 81% of providers surveyed reported they cannot continue at current NDIS prices, risking further loss of quality psychology providers from the market—especially outside metropolitan areas (NDS 2025). This compounds access barriers for participants and undermines continuity of care.

The NDIA’s current administrative posture and performance monitoring are not reliably translating into access to psychology supports or measurable mental health improvements. Weaknesses in performance reporting and governance obscure program effects on participant risk and outcomes.

2) The regulatory performance of the NDIS Quality and Safeguards Commission (NDIS Commission)

AAPi recognises improvements in the NDIS Commission’s operational metrics (e.g., faster registration decisions and increased behaviour support practitioner approvals). However, regulatory outputs do not in itself guarantee participant safety if NDIA planning and funding decisions precipitate therapy gaps or drive participants toward unsupported “wait states.” The Commission’s Q2 2024–25 report shows increased compliance activity, but there remains a need for joined-up oversight where NDIA plan decisions that foreseeably create risk (e.g., sudden withdrawal of behaviour support funding) are escalated for preventative safeguarding. When issues are reported to the Commission by our members (usually in times of extreme concern for the safety or

wellbeing of participants), responses and investigations appear to be absent altogether, calling into question the utility of making Commission reports.

The Disability Royal Commission stressed the need for strengthened independent oversight and accessible complaint pathways. In our sector, complaints about plan cuts or the refusal of psychological supports often sit at the interface between administration and safeguarding; the current architecture leaves participants and clinicians unclear about where to escalate systemic risks created by NDIA decisions.

3) Department of Health, Disability and Ageing policy advice; alignment with broader mental health system

The Productivity Commission’s 2025 review of the National Mental Health and Suicide Prevention Agreement found the national mental health plan “not fit for purpose” and identified 500,000 Australians with moderate-to-severe mental illness who need psychosocial supports outside the NDIS—supports that remain underfunded and fragmented. As reforms roll out (including foundational supports), people with psychosocial disability are falling into gaps, and the NDIS is (again) functioning as the default safety-net without the policy levers to fund clinical care. This misalignment places pressure on NDIS plans to fund psychology that the mainstream system does not adequately provide, and when NDIA restricts such supports, risk is shifted to crisis services.

Specific Issues Raised by AAPi Members

1. Difficulty meeting NDIS access for psychosocial disability
   • Approval rates have plummeted from ~66% to ~25% since 2020–21, with reports of opaque changes, inconsistent assessor expectations, and prohibitive evidentiary costs. People who do gain access then face short plan cycles and frequent reviews that disrupt therapy.
2. Inadequate provision and continuity of psychology supports
   • AAPi has repeatedly raised barriers to funding of psychology supports focused on functional impact (not merely clinical “treatment”). While the NDIA has acknowledged the role of psychology and committed to improved guidance, on-the-ground experience remains patchy, with planners too often misclassifying or underfunding necessary supports.
3. Participant distress has increased with administrative instability
   • National data show persistently high psychological distress in adults with disability and no improvement from baseline. AAPi members report distress spikes aligned with shorter funding periods, “stated supports” re-emerging, delayed transitions to “foundational supports,” and plan gaps after the 2024 reform tranche commenced. These administrative drivers of distress require monitoring as key risk indicators.
4. Lack of NDIA accountability when decisions elevate risk
   • Repeated qualified conclusions on NDIA performance statements and ANAO findings about governance gaps illustrate a broader accountability

problem. When NDIA decisions remove psychology supports for people with complex needs (e.g., those with behaviours of concern), foreseeable risks (self-harm, aggression, carer burnout, placement breakdown) can result, yet there is no clear, timely mechanism to review such decisions through a safeguarding lens before harm occurs.

Implications of the 2024 Legislative Amendments

AAPi recognises the intent of the NDIS Amendment (Getting the NDIS Back on Track No.

1. Act 2024 to clarify supports, introduce new assessment processes, and manage scheme sustainability. However, transitional uncertainty (e.g., the shift to new “framework plans,” evolving rules on what is and isn’t an NDIS support) has produced variable interpretations and short-term disruptions in therapy funding. Without robust safeguards, changes risk further limiting evidence-based psychology supports under the guise of “mainstream responsibility,” even where clinical and functional needs are intertwined.

Recommendations

AAPi proposes practical steps aligned to the Committee’s remit.

A. Restore and protect access to psychology supports

1. Issue binding, public NDIA guidance on psychology supports that:
   • Distinguishes clinical treatment from functional, capacity-building psychology supports, affirming eligibility where supports demonstrably reduce disability-related functional impairment.
   • Requires continuity plans and bridging funding to prevent therapy gaps during plan transitions or reviews.
   • AAPi can provide case-series anonymised evidence, standardised clinical risk indicators for plan decisions, and co-design input to NDIA therapy guidelines.
2. Psychosocial Pathway and access safeguards:
   • Establish a dedicated psychosocial access pathway with specialist assessors, proportionate evidence standards, and cost caps for required assessments so cost is not a barrier to entry.
   • Accept evidence of diagnosed conditions from all Psychologists. Current rules and Lists restrict evidence provided by psychologists despite the legislated scope of practice of psychologists requiring all to be competent in the assessment and treatment of psychological disorders (and many other conditions).
   • Publish monthly access metrics disaggregated by primary disability, decision turnaround times, and reasons for refusal to track the post-2024 legislation impact on approvals.
3. Market stewardship for psychology

• Direct the NDIA to run a pricing and thin-markets review for psychology within six months, with targeted supplements for rural/remote service delivery and complex presentations, to arrest provider exit and waitlist blowouts.

B. Strengthen NDIA performance monitoring and accountability

4. Close the performance reporting gaps identified by ANAO
   • Mandate that NDIA performance statements include (i) fraud/non-compliance management outcomes and (ii) early intervention/therapy effectiveness indicators, with independent data assurance.
   • Require the NDIA to publish participant-level outcome trends (e.g., NDIS Outcomes Framework mental health items) by primary disability and region.
5. Create a “Clinical & Safeguarding Impact Statement” for plan changes
   • Before implementing material reductions to psychology or behaviour support, the NDIA must document risks, consult the participant’s clinician(s), and—where risks are identified—seek NDIS Commission input and/or apply bridging supports. This embeds preventative safeguarding into administrative decisions.
6. Independent review avenue for high-risk decisions
   • Pilot a fast-track merits review stream (within the Administrative Review Tribunal) for plan decisions that clinicians certify as likely to elevate harm risk if implemented, with interim orders preserving supports pending review.

C. Stabilise the psychosocial support system beyond the NDIS

7. Fund and roll out Foundational Psychosocial Supports at scale
   • In line with the Productivity Commission’s findings, urgently stand up and transparently fund non-NDIS psychosocial supports (navigation, coaching, group programs, step-up/step-down) to serve the 500,000 Australians with unmet need—thereby reducing inappropriate reliance on NDIS plans and preventing clinical deterioration.
8. Interface protocol between NDIS and mental health systems
   • Co-design and publish a national interface protocol clarifying when psychology supports are an NDIS responsibility versus mainstream mental health—prioritising continuity for participants and eliminating “referral ping-pong.” Require joint escalation for people at risk of harm.

Closing Comment

The NDIS has transformed lives. But today, too many participants cannot access or sustain the psychology supports that keep them safe, stable, and connected to

community. Administrative decisions that remove or delay therapy have foreseeable clinical consequences; the NDIA must be held to account for those consequences through transparent performance reporting, preventative safeguarding, and accessible review. AAPi urges the JCPAA to recommend immediate administrative directions to the NDIA that prevent therapy gaps and require a clinical risk review before reducing behaviour support or psychology in plans.

AAPi and our members stand ready to support the Parliament, the NDIA, and the NDIS Commission to deliver the reforms participants deserve.

Sincerely,

redacted: s47F - Personal privacy

Amanda Curran Chief Psychologist Australian Association of Psychologists Inc.

redacted: s22 - Irrelevant material

www.aapi.org.au

References

Australian Association of Psychologists Inc. (2025). AAPi–NDIA engagement note (April 2025). https://aapi.org.au

Australian Institute of Health and Welfare. (n.d.). Australia’s Disability Strategy Outcomes Framework: Mental health. https://aihw.gov.au

Australian National Audit Office. (2024). NDIA accountability and performance statements: Qualified conclusions (2023–24; 2024–25). https://finance.gov.au

Australian National Audit Office. (n.d.). NDIA board governance: Audit and sector analysis. https://anao.gov.au

Australian Psychosocial Alliance. (n.d.). Access denied: Psychosocial disability and the NDIS—Campaign resources and media releases. https://psychosocialalliance.org.au/campaign

National Disability Insurance Agency. (2024). NDIS Amendment (Getting the NDIS Back on Track No. 1) Act 2024: Explainers and news. https://legislation.gov.au

National Disability Insurance Agency. (n.d.). Outcomes reporting updates. https://ndis.gov.au

NDS – National Disability Services. (2025). State of the disability sector report 2025. https://www.nds.org.au

NDIS Quality and Safeguards Commission. (2025). Quarterly performance report: Q2 2024–25. https://ndiscommission.gov.au

Parliament of Australia. (2024). NDIS Amendment (Getting the NDIS Back on Track No.

1. Act 2024: Parliamentary Bills Digest. https://aph.gov.au

Productivity Commission. (n.d.). Psychosocial supports outside the NDIS: System interface and unmet need. Coverage and analysis via ABC News and The Conversation. https://abc.net.au ; https://theconversation.com

Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability. (2023). Final report: Oversight and safeguarding recommendations. https://disability.royalcommission.gov.au