Committee Secretary Joint Committee of Public Accounts and Audit PO Box 6021 Parliament House Canberra ACT 2600 jcpaa@aph.gov.au 30 January 2026
To the Joint Committee of Public Accounts and Audit,
Queenslanders with Disability Network (QDN) is a state-wide, not-for-profit organisation led by and for people with diverse disability and we are focused on advancing disability rights, inclusion and systemic advocacy in Queensland. QDN is the Executive Peak Body for people with disability in Queensland, providing overarching leadership and coordination across disability peak and representative organisations funded by Queensland Government. QDN operates a state-wide network of over 3,000 members and supporters all over Queensland. Guided by our motto “nothing about us without us.”
QDN welcomes the opportunity to provide feedback on the Administration of the NDIS Inquiry. As QDN is an organisation by and for people with disability, this submission will primarily focus on the terms of reference that directly relates to NDIS participants – namely the performance of the NDIS Quality and Safeguard Commission and claimant compliance with NDIS claim requirements.
1. Performance of the NDIS Quality and Safeguard Commission
QDN acknowledges the important role that the NDIS Quality and Safeguard Commission plays in protecting people with disability from violence, abuse, neglect and exploitation.
Although the NDIS Quality and Safeguards Commission is the lead agency responsible for handling NDIS participant complaints, many people with disability are not aware of its functions and responsibilities.
When consulting with our members, they stated that they did not know what the Commission does, or how it can support them. In addition, many of our members believe that the Commission was created specifically to support service providers.
QDN members identified that the Commission’s external communication was bureaucratic and confusing:
“The name ‘NDIS Quality and Safeguards Commission’ is even confusing. Looking at that you wouldn’t know that they are here to protect us [people with disability]. Going to their website doesn’t instantly make that any clearer. It takes you so long to work out how to make a complaint and even then, you don’t really know what they’ll do with it.”
In order for people with disabilities to understand what the Commission does or how it may be able to assist them, QDN recommends that there is more education and focus for participants about the role of the Commission as well as what they do when a complaint is received and that all materials be made available in Plain English, Easy Read and AUSLAN versions.
For participants who are self-managed or plan-managed and need to apply for a worker screening check, it is important that this system is accessible. This includes ensuring that the process is screen-reader friendly and alternative processes exist for people who have intellectual disabilities or poor computer literacy, such as a hotline or paper application and mail alerts if a worker’s status changes.
Additionally, QDN members have reported that the Commission does not clearly communicate their processes for handling or investigating complaints. This includes explaining how their complaint will be investigated, following up to advise on where their complaint is up to and the outcomes and findings when an investigation is finalised. Informing people with disability of the outcome of their complaint is key to building trust in the oversight system.
QDN members also reported that there is inconsistency at times depending on jurisdiction in how the Commission responds to complaints. People with disability feel it is important that a nationally consistent approach is taken:
“A national approach to how the NDIS Commission staff conduct themselves, handle complaints and clear processes for both, as well as mandatory contact with the person lodging the complaint at its resolution to discuss reasons for the decision, are necessary for a functional service.”
To help resolve these issues, QDN members have suggested increasing the Commission’s investigative powers and ability to issue penalties which have more impact for service providers who are found to have breached their responsibilities under NDIS policies and legislation as one mechanism for shifting compliance and driving behaviour change:
“The NDIS Commission needs more power to fine providers and do so on a broader scale to reduce cases of abuse against people with disability, which are extremely common.”
2. Claimant compliance with NDIS claim requirements
QDN members report that understanding the NDIS claim requirements, specifically in relation to what is considered ‘reasonable and necessary, remains a significant challenge. They also state that confusion around what can and cannot be funded under the NDIS also extends to their plan managers, support coordinators, and providers, with many people reporting they were told conflicting information.
A consistent message from our members is that they try their best to do the right thing and meet all the NDIS claim requirements, but they often find it difficult to have their questions answered. For example, while the NDIS support rules were intended to clarify what is and isn’t considered a disability-related support, their interpretation has been described as complex and confusing:
“I feel like the support rules aren’t easy to understand because I think they’ve used complex language, included detailed and layered information and relied on subjective judgements about what’s reasonable, necessary or value for money.”
Furthermore, QDN members have shared that the efforts by the Scheme to provide further information such as through the NDIS ‘Frequently Asked Questions’ about legislation’ section have inadvertently added to their confusion.
People with disability described that they often need to cross-reference multiple sources of information to understand what can be funded under their NDIS plan and how to submit a new claim which are not always presented in accessible or Easy Read formats.
QDN members have also reported inconsistent decisions being delivered by planners which is leading to inequity and increased pressure on mainstream services like hospitals and housing.
Items that have been inconsistently funded, and cause confusion about whether they meet claim requirements of ‘reasonable and necessary’ are:
- Disposable gloves: These may be considered standard household items, yet they are essential for immunocompromised individuals.
- Air conditioners: Previously funded for participants with temperature regulation needs, now often deemed ineligible as standard appliances.
- Recreational activities for children: Supports such as sports programs may have therapeutic or developmental value but are frequently excluded without clear justification.
- Assistive Technology: Sensory items like weighted blankets may require proof of therapeutic benefit, creating confusion about eligibility. Low-cost equipment such as bed poles may be classified as high-risk, needing professional input despite their simplicity. Communication tools like apps are often funded, but not the devices required to run them, leading to misunderstandings.
- Vehicle modifications: The criteria for what constitutes a “fully accessible” vehicle are inconsistently applied, leading to confusion and delays.
- Pharmaceuticals and wound care: These items are sometimes rejected despite being directly related to a participant’s disability and essential for their wellbeing.
Recommendations
To improve the performance of the NDIS Quality and Safeguards Commission, and effectively protect people with disability, QDN recommends:
- Increase awareness of the role and responsibilities of the NDIS Quality and Safeguard Commission: Increase engagement with people with disability and their families, including more accessible communication.
- Accessible worker screening checks: Ensure that the process is screen- reader friendly and alternative processes exist for people who have intellectual disabilities or poor computer literacy.
- Simplified and more transparent compliant process: Streamlined and clearer complaints processes with a focus on tangible outcomes for people with disability.
- Performance framework: A transparent performance framework, requiring greater monitoring and public reporting.
To improve NDIS participant claims against the NDIS claim requirements, QDN recommends:
- Simplify and clarify language: Ensure that rules and support lists are written in Plain English and Easy Read formats that are genuinely accessible to people with intellectual disability and those with limited digital literacy.
- Improve consistency in interpretation: Provide clearer guidance and training to planners, support coordinators, and providers to reduce inconsistent decision-making.
- Co-design communication tools: co-design future updates to the rules or support lists with people with disability to ensure they are relevant, understandable, and practical. This includes testing materials with diverse user groups before release.
QDN thanks the Committee for the opportunity to contribute to this inquiry and the opportunity to improve the NDIS for people with disability.
Yours sincerely
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Michelle Moss Chief Executive Officer QDN