JOINT COMMITTEE OF PUBLIC ACCOUNTS AND AUDIT

Submission from: Scope (Aust) Ltd Level 2, 109 Burwood Rd Hawthorn, VIC, 3122

Contact: Liz Cairns Chief Strategy and Impact Officer

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Introduction

On 27 November 2025, the Joint Committee of Public Accounts and Audit resolved to conduct an inquiry into the administration of the National Disability Insurance Scheme (NDIS).

This submission from Scope (Aust) Ltd (“Scope”) responds to those aspects of the inquiry related to the Department of Health, Disability and Ageing’s policy advice to the government; provider compliance with NDIS claim requirements; and the regulatory performance of the NDIS Quality and Safeguards Commission.

About Scope

Scope is one of the largest not-for-profit organisations in Australia. Our origins stretch back to 1948, when a group of parents who wanted better lives and opportunities for their children with disability established the Spastic Children’s Society of Victoria. The values these families championed are demonstrable and enduring, ensuring people are always at the heart of everything we do.

Scope’s purpose is to create meaningful opportunities for people with disability to belong and thrive.

Today Scope supports more than 5,600 people with complex intellectual, physical, and multiple disabilities across metropolitan and regional Victoria and New South Wales. Our services include home and living supports delivered at 340 specialist disability accommodation sites. We also provide therapy, social connection, employment and school leaver transition programs, communication access supports, and we offer tailored disability inclusion programs to corporate and community organisations.

Scope remains committed to amplifying the voices of people with disability. We always assume clients have the capacity to make decisions and exercise choice regardless of their disability. Our strategic business decisions and operational practices are also increasingly informed by the voice of the client. We have established a Client Participation Framework and Client Advisory Panel, and lived experience is represented in our governance and in our staffing. The voice of the client is fully embedded in our induction process for all staff.

Our practice is informed by evidence, and we remain committed to further enhancing our service delivery through research and investing in quality and safeguarding, including the adoption of open disclosure principles and practice.

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Policy advice delivered by the Department of Health, Disability and Ageing

Operational changes and fragmented responsibilities

Following the 2025 Federal Election, the newly re-elected Labor government issued a Machinery of Government administrative order on May 13, 2025. This order included the transfer of Disability and Carers functions from the Department of Social Services (DSS) to the new Department of Health, Disability and Ageing (DHDA).

The transition of responsibility for disability policy from DSS to DHDA raised significant concern in the disability sector that this move would reframe disability policy within a “health” context rather than focusing on social inclusion and human rights. There is limited disability content available on the DHDA website, and it is notable that the website address remains health.gov.au. Disability advocates argue that the linkage of “health” with “disability” may shift public perceptions back toward the long-prevalent medical model of disability, with disability being considered a deficit that people need to overcome. This would be counter to Australia’s Disability Strategy 2021-2031, which is clear about disability issues being social and rights-based, and would limit the government’s ability to deliver coordinated, person‑centred policy. Scope maintains these concerns have not yet been adequately addressed.

While the NDIS and general disability policy moved to the new department, DSS retained responsibility for disability employment programs, income support (including the Disability Support Pension), and housing. This fragmentation has the potential to undermine efforts to build a “unified disability ecosystem” as recommended by the NDIS Review.

The challenge of this transition period was exacerbated by the formal transfer of functions from DSS to DHDA taking several months to complete. Rather than strengthening policy coherence, the transition introduced operational instability across agencies, which created uncertainty for providers and participants and had a detrimental impact on their relationships with departmental staff. Additionally, this transition occurred during a “workforce crisis” in both the disability and aged care sectors. The cumulative effect is a sector struggling to adapt to simultaneous structural, regulatory, and operational pressures without adequate support or clarity.

For NDIS participants aging past 65, navigating the transition to the aged care system exposes significant gaps in access, policy, funding, and service models, often resulting in a substantial reduction in support quality and intensity. While the NDIS offers uncapped, needs-based, and individualised funding, the aged care sector relies on capped, means-tested packages that often provide far fewer resources for people with complex support needs. This also entails a shift from a disability-focused

choice and control

Implement a structured transition strategy

• With dedicated resourcing, sector training, and co-design mechanisms to avoid continual delays in future reforms.

• Publish the evidence base behind the support needs assessment model (including I CAN v6), undertake public pilots, and report annually on outcomes and budget impacts.

• Ensure implementation planning includes the needs and preferences of the Scheme’s most vulnerable participants.

Provider compliance with NDIS claims requirements

Scope has identified several issues and risks arising from current system controls intended to prevent non-compliance. Significant information gaps have created confusion, operational challenges, financial pressure, and risks to participant safety and service quality.

Since the rollout of PACE in October 2023, providers have experienced a significant loss of visibility over funding for portal-managed clients. Prior to this change, providers were already facing ongoing challenges in obtaining accurate funding information for plan-managed participants. However, they were at least able to exercise a level of budget control for agency-managed funding through service bookings on the MyPlace portal, which enabled effective service planning and financial management.

The introduction of PACE has removed this remaining visibility entirely. Providers now lack insight into funding availability across both plan-managed and agency-managed supports. This has created serious challenges for service planning, budget control, and financial forecasting, undermining certainty and stability in service delivery. Ultimately, this loss of transparency introduces risks to participants, as providers may be forced to continue delivering unfunded supports to meet contractual obligations and compliance requirements. The corollary is that this places substantial pressure on providers’ financial viability while still requiring the delivery of high quality, compliant services.

To compensate for the lack of funding visibility, providers are now wholly reliant on support coordinators or participants’ families to obtain critical information such as remaining budgets or plan details. In practice, this information is often delayed or incomplete, due to the complexity of navigating constant changes within the NDIS system. Scope is aware that support coordinators and families are struggling to keep pace with reforms, making timely and accurate communication increasingly difficult.

These systemic changes appear to have overwhelmed the NDIA itself. It is now common for provider enquiries to take weeks to receive a response, with payment disputes remaining unresolved for extended periods. Current lead times between the submission of a change of circumstances and the approval of a new plan can extend up to nine months, or four months in the best-case scenario. These delays pose significant health and safety risks for participants, alongside serious financial risks for providers.

Unlike commercial sectors where services can be paused in the event of nonpayment, disability service providers, particularly those operating in Supported Independent Living (SIL) environments, have no such option. Prolonged National Disability Insurance Agency (NDIA) response times, combined with strict compliance obligations, have forced providers to fund supports out of pocket with little to no recourse when payments are delayed or denied. This is further compounding the already well-documented financial sustainability challenges.

Even where participants are adequately funded and providers can obtain timely plan information, additional pressures remain due to NDIS Pricing Arrangements and Price Limits. These regulatory

Constraints Can Compromise Service Quality

A notable example is the lack of adequate provision for unplanned absences in SIL settings, such as hospitalisation or holidays. While a provider cannot reduce shared support rosters when one resident is absent, the absent participant is subject only to a seven-day cancellation period. This does not adequately offset the ongoing staffing and operational costs borne by providers.

Further complexity arises from the annual release of updated Pricing Arrangements and Price Limits each June, effective from 1 July. The limited time provided for implementation often underestimates the operational adjustments required. Providers are expected to comply within a narrow timeframe, which adds considerable stress and increases the risk of confusion, administrative errors, and service disruption for both participants and providers.

Recommendations

• Improve data sharing and establish a clearer, risk-proportionate regulatory framework that reflects the full diversity of provider types and risk profiles.
• Introduce a funding model that addresses the gaps between plan funding and participants’ required support levels, recognises the need for differential pricing for complexity, and ensures the financial sustainability for ‘providers of last resort’.
• Work with the sector to systematically trial and introduce an outcomes approach to funding that considers participant complexity, achievement of outcomes, experience and quality.

The graphic below depicts areas of concern to Scope:

Conclusion

The disability sector is undergoing rapid and overlapping reforms that are advancing faster than government and providers can realistically manage. Misalignment between policy development and operational delivery has created uncertainty and exposed both providers and participants to significant risks arising from gaps in governance and system design. Providers are also navigating substantial compliance demands without the policy settings, pricing structures, workforce support, or information systems required to deliver sustainable, high-quality services.

These pressures fall disproportionately on a small group of registered providers, often those acting as providers of last resort, while broader systemic risks remain insufficiently addressed. At the same time, the lack of timely, accurate, and complete information severely limits providers’ ability to plan, forecast, and manage budgets. This contributes to service instability and further erodes trust between participants, providers, and government. Strengthened market stewardship and coordinated action across all levels of government are urgently needed to stabilise the sector, safeguard participant outcomes, and establish the foundations for successful long-term reform.

Recommendations

• Develop a whole-of-government disability framework that brings together disability policy, NDIS design, disability employment, housing, and income support to ensure coherence.

• Review the policy and funding gap between the NDIS and aged care including an assessment of whether the aged care system is equipped to support people with complex and lifelong disabilities.

• Adopt a staged communication and consultation process for legislative changes to reduce uncertainty among providers and participants.

• Publish a comprehensive, updated reform roadmap to provide certainty for participants, providers, and the broader disability ecosystem.

• Implement a structured transition strategy with dedicated resourcing, sector training, and co- design mechanisms to avoid continual delays in future reforms.

• Publish the evidence base behind the support needs assessment model (including I CAN v6), undertake public pilots, and report annually on outcomes and budget impacts.

• Ensure implementation planning includes the needs and preferences of the Scheme’s most vulnerable participants.

• Establish an independent pricing mechanism, proportionate and universal regulation, and targeted interim measures (such as temporary loadings) to maintain provider viability during the transition to longer term reforms.

• Restore the visibility of real-time funding information through PACE and any future IT systems to improve provider insights and address planning, forecasting and service continuity risks.

• Set enforceable timeframes to resolve plan changes and disputes, with a rapid response capacity for high-risk cases that increase participant risk and erode provider viability.

• Improve data sharing and establish a clearer, risk-proportionate regulatory framework that

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reflects the full diversity of provider types and risk profiles.

Introduce a funding model that addresses the gaps between plan funding and participants’ required support levels, recognises the need for differential pricing for complexity, and ensures the financial sustainability for ‘providers of last resort’.

Work with the sector to systematically trial and introduce an outcomes approach to funding that considers participant complexity, achievement of outcomes, experience and quality.

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