January 2026
About Allied Health Professions Australia and the allied health sector
Allied Health Professions Australia (AHPA) is the recognised national peak association for Australia’s allied health professions. AHPA’s membership consists of 30 full member organisations, each representing a particular allied health profession. AHPA collectively represents over 195,000 allied health professionals and AHPA works on behalf of the Australian allied health sector.
AHPA’s Disability Working Group (the Working Group) comprises policy and clinician representatives drawn from the range of AHPA’s members that provide services to people with disability including through the National Disability Insurance Scheme (NDIS). The Working Group is therefore informed by the views and experiences of both individual allied health professions and the broader allied health sector.
AHPA and its member associations are committed to ensuring that all Australians can access safe, evidence-based services to assist them to realise their potential for physical, social, emotional and intellectual development.
Recommendations
Recommendation 1.
Increase the lead times for reform work to support improved consultation and communication, improve the timeliness of communication about changes, and commit to involving peaks in supporting understanding and implementation of changes for their NDIS provider members. Where needed, this should involve investing in co-development of resources and guidance.
Recommendation 2.
Establish one or more independent advisory bodies to monitor the impact of NDIS policy and Pricing changes on allied health service sustainability, and inform future pricing and policy settings, consistent with NDIS Review recommendations. This should include both overall representation from AHPA and large NDIS provider peaks, but also individual allied health professions that deliver therapy supports.
Recommendation 3.
Ensure changes to provider registration requirements and reforms to therapy provider registration are proportionate and take into account the existing regulatory requirements for allied health professionals.
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Response
AHPA thanks the Joint Committee of Public Accounts and Audit for the opportunity to provide a response to the Inquiry into the administration of the NDIS. AHPA values the NDIS and the lifechanging support it can offer to people with disability. Unfortunately, the Scheme isn’t always delivered as intended or as the Australian community would expect. The Committee has an opportunity with this Inquiry to ensure the sustainability, quality and integrity of the administration of the Scheme. To achieve this, improvements and coordination of Scheme implementation are needed across the National Disability Insurance Agency (NDIA), the NDIS Quality and Safeguards Commission (NDIS Commission) and the Department of Health, Disability and Ageing (DHDA). As highlighted in several of the Auditor-General reports improvements in governance, accountability and operational processes are required. Better management of the scheme and risks is needed to safeguard participants from the possibility of harm and protect participant outcomes.
Allied health professionals provide a range of services and supports within the NDIS such as comprehensive assessments, prescription and access to assistive technology and capacity building therapy supports. The current administration of the NDIS often impacts significantly on the delivery of services and supports by allied health professionals. Consistently we hear from the diverse allied health provider workforce of the challenges that exist with the current delivery and oversight of the scheme. These challenges relate directly to this Inquiry’s focus on examining the NDIA’s delivery of the NDIS, the NDIS Commission’s regulatory performance and the DHDA policy work. The range of administrative challenges, experienced by allied health professionals, impacts on providers engagement within the scheme and their sustainability to work within the NDIS. These challenges consequently also impact on participant access, outcomes and experience with the scheme.
Administration decisions impact significantly on the delivery of safe, evidence-based services.
The allied health sector consists of university qualified, regulated professionals, who are trained to provide individualised, evidence-informed services. As providers of NDIS services and more broadly as allied health professionals, they are bound by requirements to deliver safe, quality services. The delivery of allied health services is significantly impacted by administrative decisions outside of the providers direct control, such as decisions around funding and plans. These planning decisions can have substantial impacts on risks of harm and can undermine the delivery of safe, quality allied health services and supports.
Cuts to plan funds, reductions or exclusions of supports within plans, use of stated supports and implementation of funding periods, all impact on the ability to deliver quality supports and can have considerable negative consequences for participants. These issues are all regularly reported by allied health professionals.
For example, the allied health sector has observed significant challenges with the implementation of Section 33 (funding periods) on participants’ access to services and supports. Often funding is arbitrarily split equally across the periods, which fails to provide adequate flexibility for factors such as fluctuations in conditions and instances where there may be higher upfront needs or costs. This means participants cannot access the services and supports they need, when they are
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needed. We’ve heard countless examples from clinicians including ones where funding for prostheses or assistive technology products or repair has been split across periods; meaning participants cannot access these supports until multiple funding periods have elapsed.
These decisions on funding periods can prevent participants from accessing supports at times when they may be most needed.
Allied health providers are reporting the frequent application of and confusion around stated supports on plans, which restricts or prevents access to types of therapy supports. The use of stated supports can impact on flexibility and limit choice and control for participants.
AHPA continues to have strong concerns that many of these decisions, such as planning decisions about eligible supports, stated supports and funding periods are made by a workforce that is not always clinically trained. This workforce may not understand the quality and safety impact of their decisions and are themselves not subject to oversight by the Commission. Furthermore, many allied health providers report that the information provided in their assessments and reports is not being considered or actioned within planning decisions. Instead, advice is being ignored or overridden and decisions about clinical care are being made by a workforce that does not necessarily have clinical reasoning, expertise or the clinical oversight to be making such decisions.
Proposed changes under the new framework planning approach being introduced by the NDIA, including the introduction of Support Needs Assessments, will likely exacerbate these issues as these appear to further reduce the role of clinically trained allied health assessors and limit opportunities for expert clinical input to be weighted in support needs assessments. Allied health expertise and advice must be adequately recognised and protected both within the current (old) and new framework planning for the NDIS as an important mechanism to ensure that highly trained and regulated health workforces are guiding decision-making. There must also be adequate provisions and safeguards in place to enable timely reviews of decisions. Clinical oversight is essential to mitigate risks within the delivery of the Scheme.
The scheme is in a constant state of change, often with limited lead time for implementation, impacting delivery of services and participants access to supports.
The disability ecosystem is experiencing a substantial period of rapid and extensive reform. This reform is being driven across the NDIA, DHDA and NDIS Commission. There is a need for this reform to be coordinated, with adequate implementation time and support to ensure the workforce is prepared and participants do not experience disruptions to service delivery. With multiple areas of reform taking place concurrently and with very short implementation timeframes, there is significant pressure placed on providers to understand and implement changes. The lack of clarity from the Department, NDIS Commission and NDIA about the direction and timing of all the reform changes, creates significant concern and uncertainty amongst the sector. For example, early childhood providers have faced the uncertainty of how foundational supports will be implemented and still have no means of knowing whether they will be eligible to provide future supports, whether they will be able to do so as private providers or will need to seek employment, and which children will still be eligible for NDIS services. With only a few months to go until Thriving Kids is expected to commence, and feedback from many stakeholders highlighting that supports are unlikely to be ready, there must be assurances that transitions will be managed effectively. We call for the release of detailed timelines and implementation plans for the rollout of future reform changes.
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Without sufficient guidance on the future direction of reforms, it is increasingly difficult for providers to plan and prepare the workforce for the changes. The impact of this is that providers will potentially make decisions to limit investment in workforce development (i.e., hiring early career professionals and teaching them to deliver high quality supports), implementing innovative approaches based on new tools and techniques, or even investing in improving their own systems. To support providers to implement changes and maintain high quality services throughout this next phase of reform, much greater focus is needed on coordination across the multiple areas of reform, with clear directions and sequencing of changes. Providers also need assurance that there will be adequate time to enable systems and the workforce to be ready to implement changes. The role of allied health peak bodies in supporting these transitions needs to be considered as does the resourcing needed to deliver that. We note the level of investment by the Australian government in supporting the safe and effective implementation of primary care health reforms through the funding of peak bodies and Primary Health Networks as an example of an effective approach.
The disability community needs assurances, backed by genuine evidence of an NDIA policy shift, that people with disability will not lose access to supports while new, suitable supports are being established. Despite assurances that changes are not yet occurring, allied health providers report that participants are losing access to the NDIS or are experiencing significant cuts to supports, despite other areas of the disability support ecosystem, such as foundational supports not being ready. Continuity of service provision must be protected during these reforms to ensure we do not endanger participants. Reforms must be supported by simple and timely review processes that enable providers, participants and families to flag potential issues and risks as they arise.
AHPA recognises that the government has set an ambitious timeframe for reform. When combined with internal NDIA and Commission processes, this pace leads to very short lead times for the provider sector to understand and implement changes. Improving change management processes and better involving sector peaks in supporting their NDIS provider members to prepare for and make changes must be an urgent priority for government. Historically we have seen short timeframes for the workforce to implement changes and limited collaboration with sector peaks to support workforce transitions. For example, last year’s Annual Pricing Review was released in June with implementation expected from 1 July. Allied health providers experienced significant changes in last year’s annual pricing review, particularly regarding travel price limits. With any change in policy or pricing, there are multiple implications for providers, such as updating service agreements and operational systems. Short lead times put immense pressure on the workforce to implement changes quickly on top of their everyday work. It also significantly increases the risk of providers inadvertently failing to align to current policy. For policy changes to date, we highlight that there have been many missed opportunities to work closely with sector peaks to support communication to providers and workforce transition. This must change; better collaboration with peaks offers potential to better support the extensive reform underway.
Market stewardship requires a re-shaping of the role of the NDIA, NDIS Commission and Department.
A range of reviews have argued that there is a clear need to improve the role of the NDIA, DHDA and NDIS Commission in stewarding the NDIS market and ensuring that a quality, effective and sustainable system is protected now and into the future. AHPA notes particular concerns about
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the sustainability of allied health services and supports within the scheme and an overall lack of focus on engaging and supporting the therapy sector through a time of major therapy policy and Pricing change.
National Disability Services (NDS) 2025 State of the Disability Sector report highlighted substantial issues with the scheme and its impacts on providers. It highlighted that many providers are operating at a loss and for many their ongoing engagement in the scheme is at risk.1 Several of AHPA’s member organisations have surveyed their professionals and heard similar sentiments and concerns about sustainability as a provider of NDIS services. Most therapy supports within the NDIS in last year’s pricing review had price limits reduced or continued to be frozen. Therapy support price limits have largely been frozen for years during a period where there have been extensive increases in costs experienced by providers. While the NDIA has argued strongly that its price limits are supported by pricing data, many reports have challenged this.2,3 AHPA notes that a range of providers have given feedback that the uncertainty arising from pricing policy changes means that they are currently unwilling to invest in maintaining and building the quality of their services, growing future workforces, and investing in infrastructure. This in turn impacts on quality and potential continuity of supports for participants. There is no evidence that the broader impact of pricing changes on workforce development, distribution of services, and access to in- community services is being actively monitored and addressed.
AHPA notes that the NDIA’s 3-year workplan outlines specific work to investigate and understand therapy pricing. This includes work through a Quality Supports Program therapy pilot and other therapy pricing focused review activities. Whilst this review is welcome, there are clear signs that the review will have major gaps, the most significant of which is the decision to invite a narrow selection of large provider organisations to participate in the pilot. AHPA has heard from some large NDIS therapy providers that have been advised that they are ineligible to participate despite supporting many participants. We’re also concerned that no comparable work will be undertaken at this time to understand small providers, despite clear differences in their service and staffing models. This is of major concern to the sector as the workplan clearly identifies the intention by the NDIA to implement changes based on the findings and activities within the therapy pilot. AHPA is calling for further work to be undertaken to address important knowledge gaps about the costs and structures of other provider types, including smaller providers.
An effective scheme requires timely delivery of activities as well as consistent monitoring and management of issues. AHPA regularly hears feedback from clinicians about delays in access requests, development and approval of plans, assistive technology requests and approval of payments. When supports are reduced, removed or delayed, this can lead to poor and sometimes devastating outcomes for participants. For participants these issues may impact on service continuity, and they may not be able to access the supports or services they need in a timely manner, or at all. NDIS providers are, at times, choosing to provide unfunded supports to keep participants safe when plans are expired, inadequate and requests are delayed. Furthermore, for providers, rejections or delays in payment can impact on business viability. This can lead to decisions to exit the NDIS provider market. Unplanned service withdrawal can then further compound issues with access for participants. Effective delivery of the NDIS requires the NDIA to improve payment processes and reduce the length of delays in processing. The Commission also needs to effectively monitor and mitigate risks of unplanned service withdrawal, in line with Recommendation 7 from the ANAOs report, Effectiveness of the NDIS Quality and Safeguards Commission’s Regulatory Functions.
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AHPA argues that while the NDIA and Commission are improving their ability to gather and review scheme data, more must be done to actively monitor market conditions, the availability of allied health therapy services in all areas, the impact of pricing and policy changes on the allied health provider market and the accessibility of those services for participants. While the NDIA regularly provides reporting of aggregate data, such as number of providers, this does not paint a complete picture of the provider market, nor does it accurately reflect participant access to the supports they need. Data should be utilised to better identify and address issues with supply and demand.
As a final note, AHPA argues strongly that the NDIA, Department and Commission must not only improve their capacity to gather data to inform policy, and to monitor the impacts of policy changes on the therapy market, but also improve their ability to draw on independent expert advice to guide decision-making. Last year’s Annual Pricing Review reduced the price limits for therapy supports travel by 50%. This has the potential to impact considerably on the delivery of services within the community, reducing the accessibility of services as well as being inconsistent with best practice advice to deliver some services in natural settings. AHPA is yet to see evidence that the NDIA is actively monitoring the impacts on access and the risks of this change and there is no evidence of robust engagement with the provider sector to seek feedback. The current NDIA Annual Pricing Review consultation does not seek travel pricing feedback explicitly in the provider survey, though it does ask participant respondents to provide input within their version of the survey.
AHPA argues in the strongest possible terms that there is an urgent need for government to require the establishment of one or more independent advisory bodies for the NDIA, DHDA and NDIS Commission to monitor the impact of NDIS policy and pricing changes on allied health service sustainability and inform future pricing and policy setting.
A truly proportionate regulatory approach is required.
AHPA supports the role of regulation in protecting participants within the NDIS. We note the findings of the Auditor-General Report No. 2 2025-26: Effectiveness of the NDIS Quality and Safeguards Commission’s Regulatory Functions, which recognised that the NDIS Commission currently has very limited visibility over the provider market. We argue that a requirement for registration does not automatically increase visibility or quality and that more work is needed to understand how to improve data sharing and data gathering capability across the Scheme to support the Commission’s oversight role. We also argue that the having a small proportion of therapy support providers registered with the NDIS Commission represents a major failure in the design of registration requirements for therapy providers rather than any failure of overall regulation and safety of allied health providers.
The allied health workforce is highly regulated, due to the stringent requirements that apply to the health workforce. Most allied health professionals are either registered with Ahpra or certified by their professional association if they are a self-regulated allied health profession with additional regulatory oversight provided by the National Code of Conduct and the work of state and territory health complaints entities. This regulation protects all users of allied health services, including participants of the NDIS and there is no evidence AHPA is aware of that NDIS participants experience risks that are not addressed by existing regulation.
Conversely, allied health professionals cite the time, cost and administrative burden of registration as barriers to registering as a NDIS provider. The cost of third-party audit in particular
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is prohibitively expensive, varies significantly, and significantly impacts providers in regional and rural settings. Any new approach to regulation of therapy providers must take the current failures into account and revisit what risk proportionate registration for allied health means and what level of additional third-party audit, if any, is needed to ensure compliance. The application of this must take into account providers pre-existing regulations as allied health professionals. To effectively enable this, the Commission will need to have agreements in place with Ahpra and the professional associations to share relevant information.
AHPA argues that whilst current health worker focused regulation is highly effective in protecting all users of health services, we note that current regulatory functions appear inadequate to protect participants from risks of harm when there are issues in relation to the administrative functions of the NDIA. These issues many of which been highlighted earlier in our response include delays in approval for time sensitive supports, insufficient funding impacting safety, and lack of inclusion of needed supports in plans.
AHPA argues that if safety and quality is a genuine focus for government, the NDIA must be held accountable for the harms their actions can cause. Whilst providers must do all they can to reduce the risks of harm to participants, many risks are outside of their control. We hear regularly from providers who deliver care unfunded to try their best to support participants, particularly where plans are expired or insufficient. The NDS State of the Disability Sector report highlighted the scale of unfunded services often being provided by providers.1 Providers should not feel they need to address failures in planning processes, including where there are extensive delays or lengthy reviews in progress, and the Commission must protect participants from harm that can be caused by poor NDIA planning and administration.
Improving management of compliance and fraud is essential.
AHPA is supportive of safeguarding and integrity measures to prevent fraud and protect the scheme and its participants. The allied health sector has been subject to much public criticism for ‘rorting’ the system and we argue there is little basis for this assertion. Pricing data from the sector has demonstrated that there are a range of schemes with comparable rates and that many experienced, high-quality private providers charge the same or more than the rate that can be charged for the delivery of NDIS services under other funding arrangements. Ongoing failures to provide equitable access to allied health services under other schemes such as Medicare and Department of Veterans’ Affairs funding should not be equated with rorting.
The Auditor-General Report No. 48 2024-25: National Disability Insurance Agency’s Management of Claimant Compliance with National Disability Insurance Scheme Claim Requirements noted that some providers are claiming fraudulently and that the NDIA has work to do to improve the management of claimant compliance. AHPA supports increasing the capacity of the NDIA to monitor claiming, noting the importance of ensuring that providers are not penalised where claiming errors arise from poor communication of changes by the NDIS with short lead times for change.
We note that the NDIS as a scheme still struggles to ensure that only providers with the necessary skills and training to deliver supports do so. AHPA recommends that the NDIA improve its ability to ensure that only those professionals who have the appropriate qualifications and regulations deliver and subsequently claim for allied health therapy services. The Duckett review of art and music therapy noted that there were more professionals listed as delivering these services than
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the number certified through the relevant peak bodies,4 suggesting that some providers potentially lacked the training and regulation to deliver those services as therapy providers. The new Therapy Supports Operational Guideline makes it clear that only the professionals registered through Aphra or certified through the relevant professional association for self-regulating professionals can deliver the listed therapy supports.5 However, work is still needed to ensure that the NDIA can monitor and ensure compliance with these requirements.
References
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National Disability Services. State of the Disability Sector Report 2025. 2025. Available from: https://nds.org.au/images/State_of_the_Disability_Sector_Reports/NDS8221%20NDS% 20State%20of%20the%20Disability%20Sector%20Report%202025_FINAL.pdf
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Ability Roundtable. The Quality Quandary- what next for quality NDIS Registered Therapy providers. 2025. Available from: https://www.abilityroundtable.org/post/white-paper-the- quality-quandary-what-next-for-quality-ndis-registered-therapy-providers
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Nous Group. Report for the Australian Physiotherapy Association. Review of the 2024-25 APR with respect to physiotherapy. 2025. Available from: https://australian.physio/advocacy/NDIA-annual-pricing-review-report
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Duckett, S. Independent Review of the place of Art and Music Therapy within Australia’s National Disability Insurance Scheme. 2025. Available from: https://dataresearch.ndis.gov.au/research-and-evaluation/decision-making-access-and- planning/independent-review-art-and-music-supports
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National Disability Insurance Agency. Operational Guideline Therapy Supports. 2025. Available from: https://www.ndis.gov.au/understanding/supports-funded-ndis/therapy- supports
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