National Disability Services (NDS) Joint Committee on Public Accounts and Audit Responses to Questions on Notice Public hearing: 15 May 2026
Overview
These responses build on NDS’s submission and evidence to the Committee. They reflect consistent feedback from providers on how NDIS administration is operating in practice, particularly across market stewardship, regulatory administration and reform implementation.
Our evidence to the Committee emphasised that the key issue is not policy intent, but implementation, specifically the absence of clear accountability, coordinated decision-making and early intervention across the system.
These responses are provided on behalf of National Disability Services following the Committee’s public hearing of 15 May 2026 and respond to questions received on notice.
Questions on Notice
1. Clarity of roles
Question: You recommend that clear joint accountability for NDIS administration outcomes, including for market stewardship, regulatory administration and reform implementation. Your submission notes ‘Fragmented roles, unclear decision pathways and weak coordination have limited the system’s ability to act on known risks…’
(a) Can you elaborate on and provide examples, from your experience, on the lack of role clarity?
NDS continues to observe fragmented roles, unclear decision pathways and weak coordination across the Department, NDIA and the NDIS Commission.
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In practice this results in:
- Limited clarity about who is responsible for identifying and acting on emerging market risks.
- Delays in escalation where participants are at risk of losing supports.
- Reactive responses once disruption has already occurred.
A common example is partial provider exit. Providers may withdraw from specific service types, cohorts or regions without formally exiting the Scheme. This often occurs without early identification, clear accountability or coordinated response, reducing service availability and continuity before the system intervenes.
NDS’s recommendation is for a clear, jointly owned accountability framework, including defined roles, escalation pathways and responsibility for continuity of supports. This would support providers and participants to know who is responsible for intervening and what they should expect from these entities.
2. Market stewardship and financial sustainability
Question: Your submission notes that ‘Strong market stewardship is also central to Scheme integrity and long-term budget sustainability; without it, risks are not identified early, costs are shifted downstream and administrative responses become reactive rather than preventative’.
(a) Can you provide further detail on the link between market stewardship and financial sustainability?
Market stewardship is directly linked to financial sustainability because it determines whether risks are managed early or allowed to become more costly problems.
Where stewardship is effective, emerging risks, such as workforce instability, declining service capacity or provider withdrawal, are identified early and addressed through targeted intervention.
Conversely, where stewardship is weak, these risks are not addressed until they result in disruption to participant supports.
This leads to:
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Emergency placements and short-term arrangements.
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Increased reliance on higher-cost supports.
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- Loss of provider capability and reduced market efficiency.
- Disruption of supports that are working well for participants and overall poorer outcomes.
These downstream responses are more expensive and reduce overall value for money. Strengthening early warning and time-bound intervention is therefore critical to both Scheme integrity and cost control.
3. Pricing settings and financial sustainability
Question: Your submission mentions that ‘Without pricing mechanisms that can be adjusted to stabilise supply, support continuity or recognise quality and complexity, administrative responses are largely reactive and occur only after service disruption has already taken place. This increases reliance on crisis responses, emergency placements and short-term interventions, driving higher downstream costs and poorer outcomes for participants.’
(a) Can you comment in more detail the link between adjustable pricing mechanisms and the financial sustainability of the NDIS?
Pricing is a primary tool of market stewardship and a key driver of financial sustainability.
If pricing does not reflect service complexity, workforce costs and regulatory obligations, providers will reduce service scope or exit higher-risk areas of the market.
This results in:
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Reduced access to appropriate supports, particularly for people with complex needs.
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Greater reliance on crisis-driven responses.
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Higher overall system costs.
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Increased financial pressure on quality providers who have the clinical and practice capability and infrastructure to support people with more complex support needs.
Adjustable pricing mechanisms allow the system to respond to emerging market stress by stabilising supply and supporting continuity. Without this, responses occur only after disruption, when costs are already higher.
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Where quality providers with the experience and capability to support participants with the highest support needs exit the market, rebuilding this capacity takes time and is costly.
In a contracting Scheme, pricing also acts as a key behavioural signal. If it is not aligned with quality and risk, it will drive demand toward lower-cost providers rather than those best able to meet participant needs.
4. Transparency over compliance requirements
Question: Your submission expresses concerns over inconsistent interpretation and application of requirements, and weak transparency and feedback loops in relation to compliance and audit processes.
(a) In your experience, to what extent is a lack of transparency over compliance requirements reported?
NDS members consistently report that lack of transparency and consistency in compliance requirements is a widespread issue.
This includes:
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Variation in audit interpretation and outcomes.
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Limited visibility of regulatory expectations and areas of focus.
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Inconsistent feedback from auditors and regulators.
(b) From your perspective, what can be improved?
Improvements should focus on:
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Clear and accessible guidance on regulatory requirements.
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Greater transparency over audit priorities and expectations.
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Consistent interpretation and application across the system.
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Stronger feedback loops focused on continuous improvement.
Improving transparency will reduce unnecessary compliance burden while strengthening safeguarding outcomes and system effectiveness.
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Conclusion
NDS’s evidence to the Committee is that financial sustainability, integrity and participant outcomes are driven by how effectively the system is administered in practice.
Strengthening joint accountability, enabling early intervention, aligning pricing with risk, and improving transparency of regulation are all critical to ensuring continuity of supports and long-term sustainability of the NDIS.
NDS thanks the Committee for its consideration of these responses and would welcome the opportunity to engage further as the inquiry progresses.
Contact
Michael Perusco
Chief Executive Officer
National Disability Services
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