NDIA Accountability Project

Improving NDIS governance through plan management

‹ PrevPage 1 of 7 · Source p. 1Next ›

30 January 2026

Mr Josh Burns MP Chair - Joint Committee of Public Accounts and Audit Parliament House Canberra ACT 2600 Submitted via email - jcpaa@aph.gov.au

Kismet Healthcare Response to Joint Committee of Public Accounts and Audit

Inquiry into the Administration of the National Disability Insurance Scheme

On behalf of Kismet, I am delighted to provide Kismet’s submission to the Committee.

Launched in February 2023, Kismet is a trusted digital community platform and HealthTech. Kismet is a provider of NDIS plan management services via our portfolio companies.

Kismet approaches this consultation from the perspective of both a care services marketplace and a NDIS plan manager.

Kismet’s experience spans:

The NDIS is a critical piece of social infrastructure of which all Australians should be proud. However, the scheme is at a crucial juncture and needs significant governance and innovation reform to ensure the NDIS continues to sustainably meet the needs of participants.

We think it’s important for organisations like Kismet to be actively involved in making the NDIS fair and sustainable.

Kismet will host a further Care Innovation event at Parliament House on 31 March 2026, and we would be pleased to extend an invitation to Committee members to attend and engage directly with participants, providers and stakeholders.

redacted

Regards,

redacted

Mark Woodland CEO and Co-founder, Kismet Healthcare

KISMET SUBMISSION

1. Executive Summary

The NDIS is one of Australia’s most significant social reforms. However, the scheme is under increasing pressure — from cost growth, service gaps, administrative complexity, inconsistent planning, as well as fraud and non-compliant claiming.

Kismet submits that improved scheme administration must focus on three connected priorities:

  • Outcomes and participant value: The NDIS needs to become more focused on the goals and outcomes of participants and their families and carers.
  • Governance and integrity: strengthening controls and monitoring to protect public funds and participant safety.
  • Sustainability and provider viability: ensuring pricing and administration supports a stable, quality provider market.

A central theme of this submission is that plan managers should be asked to do more as a practical, scalable lever to enhance scheme governance while also improving participant experience. Plan managers should function as a real-time integrity and financial governance layer — improving visibility, strengthening payment controls, reducing financial abuse and waste, and helping participants purchase supports more effectively. This should be able to be achieved through existing funding arrangements.

2. Financial Sustainability & Provider Viability

The Scheme’s financial sustainability depends not only on participant growth and Pricing decisions, but also on the effectiveness of the operating model that sits underneath the NDIS. In Kismet’s experience, structural weaknesses in payment administration and verification create integrity risks and unnecessary costs, including:

  • Uneven or inconsistent control environments across participant funding pathways.
  • Limited pre-payment verification, including for supports delivered by non- registered providers.
  • High levels of manual administration, which increase provider overheads and reduce service availability.

Our view is that sustainability and provider viability cannot be treated as separate issues. The e61 Institute’s work highlights that while price caps can help contain costs, blunt pricing settings can also:

  • Distort provider incentives.
  • Discourage innovation and investment in quality.
  • Contribute to market thinning, particularly where supports are high-complexity, labour-intensive, or regionally delivered.

Mandala’s findings reinforce that a material sustainability dividend exists in lifting productivity and integrity through targeted digitisation, particularly in the NDIS funding and administration layer. This includes reforms such as:

  • Standardised digital invoicing and automated invoice validation.
  • Better real-time assurance and compliance checks.
  • Reduced administrative burden for providers, enabling worker time to be redirected back into participant-facing support.

Kismet therefore recommends that Scheme sustainability be treated as both a fiscal and service-delivery issue, combining smart governance and stronger integrity controls with productivity-enhancing digital infrastructure that reduces waste while supporting functional markets and participant outcomes.

One targeted cost-control measure the Government should consider is allowing participants to return unused funds within a defined funding period without penalising future funding periods, thereby rewarding participants for plan spending discipline.

3. Better Leveraging Plan Management for Governance, Integrity and

Sustainability

Kismet believes that plan management is an under-utilised NDIS governance and innovation tool.

Properly enabled, plan managers can operate as a practical integrity and value layer across the Scheme — strengthening financial controls without diminishing participant choice.

Plan managers sit at a unique intersection of Scheme activity, with visibility across:

  • Participant choice and purchasing behaviour.
  • Provider invoicing and claiming practices.
  • Financial data, trends and anomalies.
  • Practical outcomes evidence (what supports are purchased, how often, and to what effect).

Plan managers’ effectiveness is constrained by fragmented regulatory settings, inconsistent system integration, and limited formal pathways for plan managers to support compliance and safeguarding.

Kismet recommends the NDIA and NDIS Quality and Safeguards Commission strengthen the plan management role through targeted reforms to:

  • Clarify expectations and baseline standards for plan management integrity controls;
    • Minimum invoice verification requirements (completeness, alignment to plan category, basic reasonableness checks).
    • Stronger documentation standards to improve traceability, auditability and evidence consistency.
  • Clear escalation pathways for irregular billing patterns and high-risk invoices.
  • A scalable monitoring layer that improves fiscal oversight without restricting participant choice.
  • Enable stronger information-sharing and system interoperability between plan managers and the NDIA / Commission.
  • Formally incorporate plan managers into assurance and early-intervention processes.

Plan management can help prevent fraud, misuse and “grey-zone” claiming, but requires clearer regulatory authority and stronger agency interfaces. Reforms should enable:

  • A pre-payment assurance layer for non-compliant invoices.
  • Safe and consistent pathways to escalate safeguarding and exploitation concerns to the NDIS Commission.
  • Stronger controls to deter invoice manipulation, claims fragmentation and vague service descriptions.
  • Finally, as an at-scale plan manager it would be helpful to have a direct relationship manager at the NDIS Commission to liaise with on fraud related issues – both specific investigations and broad macro or policy related fraud issues. We think this can be done without affecting the Commission’s role as a plan management regulator.
    • Kismet commends the work of the NDIA’s Fraud Fusion Taskforce for the way in which they positively engage with the sector to reduce fraud.

4. Accountability, Registration & Safeguards

Registration settings need to strike an appropriate balance between safety and access, but current gaps create inconsistent standards and participant risk.

Kismet recommends:

  • Phased strengthening of provider registration requirements (particularly in high- risk support categories).
  • Improved resourcing for the NDIS Quality and Safeguards Commission.
  • Targeted compliance activity informed by real transaction-level intelligence (including plan management data trends).

NDIA governance should transition from reactive audits toward a more modern, systematic, risk-based approach, drawing on:

  • Digital invoice trails.
  • Transaction anomaly detection.
  • Cross-provider trend analysis.
  • Participant safeguarding flags.

5. Scheme Performance Monitoring and Reporting

Public confidence depends on transparent performance reporting and rich accessible datasets for analysis - this is part of the reason we established our own Kismet Care Index to help policymakers and stakeholders better understand the NDIS through data.

Kismet recommends:

  • Clearer reporting on participant outcomes (not just numbers of plans processed).
  • Disaggregated reporting by region and cohort (revealing where the scheme is failing to deliver equity of access).
  • Publication of scheme integrity metrics such as:
    • Fraud rates and recovery outcomes
    • Claims anomalies
    • Provider compliance trends
    • Market thinness indicators
  • The establishment of a data panel managed by the Department of Health, Department of Health, Disability and Ageing that includes both public and private sector NDIS stakeholders that:
    • Establishes data standards for the entire Australian care sector.
    • Monitors NDIS effectiveness against both quantitative and qualitative standards.

6. Participant-Centric Navigation and Planning

Administrative reform should strengthen participant experience rather than restrict it. One of the constant pieces of criticism we hear from participants and their families / carers is that NDIS plans do not have a large enough focus on goals and outcomes. Some participants we speak with would gladly trade overall plan value for greater flexibility and a larger focus on outcome.

Kismet recommends:

  • Maintaining human oversight and transparency in planning decisions, particularly for complex cases.
  • Improving participant access to explanations, review pathways and navigation supports.
  • Co-designing planning reforms to ensure decisions remain understandable and fair.

7. Conclusion

Kismet supports the Committee’s focus on sustainability, integrity and performance. In our view, the discussion of NDIS reform cannot simply be focused on cost — it requires better administration, stronger governance, and smarter integrity tools that preserve participant choice.

Kismet welcomes the opportunity to provide further evidence to the Committee, including case studies, aggregated trends and provider-market insights.

We would welcome the opportunity to meet with the Committee to discuss any aspect of our feedback in more depth, particularly;

  • How technology can support the effective implementation of the proposed obligations.
  • Supporting relevant data initiatives.
  • Extending invitations to our upcoming community events so members of the committee can engage directly with participants and providers.