NDIS delivery, financial sustainability, and regulatory performance | External submission

Committee Secretary Joint Committee of Public Accounts and Audit PO Box 6021 Parliament House Canberra ACT 2600 E-mail: jcpaa@aph.gov.au

Uniting Church in Australia, Synod of Victoria and Tasmania, Submission to the inquiry into the Administration of the National Disability Insurance Scheme (NDIS) 30 January 2026

The Uniting Church in Australia, Synod of Victoria and Tasmania, welcomes the opportunity to contribute to the Committee’s inquiry into the administration of the National Disability Insurance Scheme (NDIS). The Scheme is central to Australia’s commitment to supporting people with disability, and its effective administration is critical to ensuring dignity, independence, and inclusion for participants.

The Uniting Church in Australia, both at a national level and through the Synod of Victoria and Tasmania, has expressed it support for the inclusion and support of people with disability to reach their full potential and live flourishing lives. The relevant resolutions of the National Assembly and Synod meetings are provided in the Appendix.

The Uniting Church has members who are NDIS participants and their carers. The submission provides anecdotal feedback from participants and carers.

UnitingCare and Uniting agencies are also disability service providers on the NDIS. The following submission did not obtain input from these providers.

This submission addresses the Committee’s terms of reference, with particular regard to:

The NDIA’s delivery of the Scheme, including financial sustainability and compliance.
The monitoring, measurement, and reporting of NDIA performance.
The regulatory performance of the NDIS Quality and Safeguards Commission.

Recommendations

We urge the Committee to make the following recommendations to the Commonwealth Government:

The NDIA provide stronger financial and non-financial incentives for providers to service regional and remote areas, as well as aligning workforce incentives for disability, aged care and health.
Financial sustainability measures must prioritise efficiency, fraud prevention and safeguards. Transparency in reporting for both the NDIA and NDIS Quality and Safeguards Commission is essential to maintain participant and provider confidence.
The NDIA should strengthen its processes and administrative capability by improving performance measurement frameworks, enhancing internal reporting, and building stronger capability in risk management and operational oversight.
Periodic reviews should assess if the NDIA is making consistent decisions for participants with similar needs and make recommendations to systems to improve such consistency.
NDIA delegates should fully document plan decisions to ensure that Local Area Coordinators who need to work with participants understand plan funding decisions.
NDIA delegates should be transparent if a plan is not being fully funded due to NDIS budget constraints, and not upset participants and their carers with other reasons if they are not the cause of not being able to meet all legitimate funding requests.
The NDIA should not make offers of services to participants they have not requested, to offset not meeting the funding requests that the participant or their carers have requested.
The NDIA should seek to keep private sector plan managers and support coordinators to a minimum.
The Commonwealth Government should establish government-employed support coordinators to minimise costs for support coordination and provide a higher-quality service. Such positions already exist in some specialist schools, where government-employed transition staff at the school assist students and their parents in identifying appropriate disability support services when a student is leaving the school. Our anecdotal experience is that the system works well.
The NDIA should strengthen the quarterly report data on participant and family outcomes by incorporating quality-of-life indicators, more detailed participant experience measures, reviews, appeals and provider engagement, and clearer reporting on unmet need and service gaps. These improvements would ensure that performance monitoring reflects what truly matters to people with disability.

To ensure timely and effective protection for participants, the NDIS Quality and Safeguards Commission should implement immediate risk mitigation measures, develop a clear and properly resourced workforce plan, and accelerate improvements to its intelligence, triage, and oversight functions.
That the Commonwealth Government implement the recommendations of the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability to establish a national disability worker registration scheme, a national code of conduct, and strengthened screening arrangements of disability service providers.
That the Auditor-General conduct a follow-up review to assess progress against previous recommendations, identify ongoing systemic risks, and ensure that the Scheme’s governance and regulatory settings are aligned with the National Disability Insurance Scheme Act 2013.

NDIA Delivery and Financial Sustainability

The NDIA faces the dual challenge of ensuring the Scheme remains financially sustainable while meeting the diverse needs of current and future participants. One of the main concerns of participants and their families is that many services are being cut off from essential support due to the new NDIS support lists and a lack of transparency in budget-setting and plan variation decisions.

Anecdotally, participants on the autism spectrum and their carers have reported that the funding level of their requests is not being met or is being significantly reduced, even when supported by medical and functional assessments. These reductions appear to result from budget constraints on the NDIS, but NDIA delegates who engage with participants or carers often suggest that participants do not need the support. For example, if funding is reduced to fewer days of support than requested, a participant’s carers may be told that the NDIA rejects the assessment of medical and disability experts and that they should instead see how going with fewer days of support works out. Further anecdotal reports indicate that the Local Area Coordinator for the participant and the carers often do not understand the decisions made to reject requested supports, with the participant’s files not explaining the reasons for the delegate’s decisions.

In addition, if participants and their carers are unhappy with decisions, they may be offered funding for disability supports they did not request, such as occupational therapy or speech therapy. Such offers can create frustration for participants and their carers, who are denied support for services medical and allied health professionals have advised would be beneficial, while being offered services they did not request.

Media reports indicate that a reduction in funded support from the NDIS is becoming increasingly common for participants.¹ Some participants reported that they have been compelled to move into group homes due to cuts in funding for their plans.

Villamanta Disability Rights Legal Services alleged back in August 2025 that the NDIA was increasingly abusing its powers, “More matters are being met with intransigent conduct by the NDIA at the Tribunal, resulting in an increase in other funded advocacy services seeking our assistance for support of their work”.²

Anecdotally, providers, participants, and carers report inconsistent decisions, where participants with very similar circumstances receive very different levels of service funding despite making very similar requests.

Anecdotal evidence also suggests that NDIS plans using plan managers can incur unnecessary costs for the NDIS, with plan managers able to charge significant fees for basic tasks, such as submitting invoices for payment. Concern has been raised that plan managers charging “trail fees” and support co-ordinators can earn as much as junior doctors.³ Such charges reduce funding for direct services provided to people with disability. Media reported that an NDIS provider stated that plan managers can charge participants between $230 and $350 as a setup fee, followed by a “trail fee” of between $104 and $157 per month for the life of the participant’s plan.⁴

The recent State of the Disability Sector Report 2025, released by National Disability Services (NDS), found the sector under significant financial and operational strain, with nearly half of responding providers reporting financial losses. The survey obtained responses from 290 providers. Of these, over half were companies, 38% were incorporated associations, 5% were sole traders, 3% were trusts, and 1% were partnerships. Of the respondents, 91% were NDIS registered. The survey found that 81% of responding providers were unable to sustain services at current NDIS prices, and 77% delivered unfunded services, at an average cost of almost $500,000 per provider. The number of providers entering administration, scaling back or closing their NDIS services has increased. The report found 81% of respondents feel the NDIA is not working well with providers, 92% of providers cited policy uncertainty, and 82% of supported employment providers reported a worsening financial outlook.⁵

Service disruptions can leave participants without the essential supports they depend on, creating risks to their well-being and stability. To prevent these gaps, NDIS plans

¹ Julie Cross, “We’re dying from a thousand NDIS cuts”, The Herald Sun, 13 August 2025 ² Rick Morton, “NDIA accused of ‘repeated non-compliance’ as it prepares for autism reforms”, The Saturday Paper, 30 August 2025. ³ Natasha Robinson, “NDIS ‘gravy train for middlemen’”, The Australian, 21 March 2025. ⁴ Ibid. ⁵ National Disability Services. State of the Disability Sector Report, November 2025. NDS State of the Disability Sector Report, accessed 13 January 2026.

should include measures that anticipate and respond to disruption, such as flexible funding or contingency options, so participants are not left without critical services when providers reduce or withdraw support.

The financial pressures facing service providers directly affect participant outcomes, the quality of supports delivered, and the ability of people with disability to exercise genuine choice and control. Addressing these pressures is essential to improving the Scheme’s overall effectiveness and stability.

2.1 Sustainable Pricing

Current pricing doesn’t account for the complexity of the services being delivered in some cases. In other cases, providers delivering basic services with minimal overhead will charge the maximum rate possible, up to the cost of NDIS funding, resulting in lower levels of support for participants.

Stephen Anthony, who chaired the panel that conducted the NDIS pricing review, pointed out that the NDIS’s design was flawed because it assumed participants would participate in a private-sector market for disability services. The reality is that the:⁶

supply of services would largely collapse without direct or indirect public funding. Price sensitivity is almost non-existent, and participants have limited ability or incentive to shop around. Proximity, trust and reliability routinely trump price. Many participants struggle to navigate the system at all, and any underspend on one service category cannot be redirected to another.

Mr Anthony pointed out that the single regulated price cap means:⁷

Bulk providers of services and low-cost sole traders capture almost all the revenue, crowding out high-quality, multi-faceted providers that incur higher costs to deliver higher-value services. The scheme is at risk of systematically under-funding and driving these high-quality providers out of business. At the same time, resources are being drawn into low-value bulk activity funded by the NDIS and drawn away from other public programs and the market activity. This is resulting in skills shortages and higher wage escalation. Innovation and client focus are stifled.

The result is endemic cherry-picking; the easiest, cheapest services are overpaid relative to participant benefit, while complex, high-value services are underfunded and are now at risk of disappearing.

⁶ Stephen Anthony, “I helped review the NDIS and I know how to fix it”, The Australian Financial Review, 30 November 2025. ⁷ Ibid.

My committee’s strong advice was to abandon the illusion of a single efficient price per category, and instead we proposed a differentiated price framework that reflects genuine differences in value to scheme participants, not just costs.

Properly calibrated, such a framework would constrain overpayments to low-value areas and redirect resources towards the services participants value most. Over time, it would rebalance the market towards quality and innovation rather than volume and corner-cutting.

Mr Anthony pointed out that “In the absence of normal market self-correction, active market stewardship by the agency is indispensable.”⁸

Such a reform would help address current overspending on some NDIS services, reducing conflict between the NDIA and participants by providing more funding for legitimate needs. However, a more complex pricing structure would also require the NDIA to have the necessary skills and staff to prevent unethical providers from claiming they provide a higher-quality service than they actually do to access the higher-level payment.

The NDIA has released a three-year pricing workplan to provide clarity to the disability community, providers, and the broader sector on the pricing approach through 2025-2028. In the first year of the plan, the Modified Monash Model has been implemented. The model classifies locations as metropolitan, rural, remote or very remote. However, further action is needed to address the challenges faced by participants in regional, rural and remote areas. The challenges will continue without appropriate workforce funding and community-led initiatives. Ongoing financial pressures make it difficult for providers to operate in these locations, which can fewer available services, longer waitlists and reduced choice for participants. The impact is likely to be most significant in remote or very remote areas, where reduced funding for travel time makes in-home or community-based supports financially unsustainable for many providers. The snapshot of the report, “A fresh approach to NDIS pricing: Exploring opportunities for pricing reform” done by Independent Health and Aged Care Pricing Authority (IHACPA) had extensive public consultation and confirmed the challenges for service delivery in remote and very remote areas and for people with complex disabilities, the impact of pricing quality, safeguards and predictability for long term planning.

Despite reforms and ongoing improvements to the NDIS, broader structural changes are needed to ensure the NDIS’s efficiency and safeguard participants.

⁸ Ibid.

Monitoring, Measurement, and Reporting of NDIA Performance

Although the NDIA Board includes disability representation, recent findings from the Australian National Audit Office highlighted that the agency still requires much stronger oversight of performance, risk management, and operational accountability. These gaps affect the consistency and transparency of decisions, contribute to delays, and undermine confidence in the scheme’s ability to deliver fair and timely outcomes. Strengthening the NDIA’s monitoring and reporting systems is essential to ensuring the Agency can accurately track performance, identify emerging risks, and respond quickly to issues that affect participants’ access to supports.

Regulatory Performance of the NDIS Commission

Auditor-General Report No. 2 (2025–26) examined the Commission’s regulatory functions and provided ten recommendations that were accepted fully or in principle by the Commission.

The NDIS Quality and Safeguards Commission’s submission for this consultation confirms that fragmented intelligence systems, inconsistent risk-based decision-making, and limited visibility of provider behaviour across the market constrain the Commission’s ability to safeguard participants. The Commission has provided a plan to address them. These issues directly affect the Commission’s capacity to identify systemic risks, respond to current and emerging harms, and ensure that providers meet their obligations under the National Disability Insurance Scheme Act 2013.

We agree with all the ANAO’s recommendations. However, the proposed timelines and reliance on future system upgrades raise concerns that improvements will not occur fast enough to protect participants, despite the ANAO identifying serious regulatory weaknesses. The actions by the NDIS Quality and Safeguards Commission don’t include interim measures. The absence of interim measures is a significant gap, as risks remain inadequately managed during the transition period and participants and providers may still experience harm or regulatory inconsistency.

The rising volume and complexity of complaints and investigations continue to place significant pressure on the NDIS Quality and Safeguards Commission, making it difficult for the agency to reduce existing backlogs or consistently meet its own timeline benchmarks. The Commission has committed to strengthening workforce capability, but not to increasing staffing levels.

Although the ANAO noted that the NDIS Quality and Safeguards Commission continues to have limited visibility over unregistered providers, the Disability Royal Commission recommended establishing a national registration scheme, a national code of conduct, and stronger screening and oversight. These reforms should form part of a broader effort to strengthen quality and safety across the sector.

Conclusion

The administration of the NDIS has increasingly drifted from its founding principles. Rather than empowering people with disability, the system has become adversarial and bureaucratic, leaving participants fearful of losing essential supports, placing families under significant strain, and some good quality disability service providers facing growing financial pressure.⁹

The systemic weaknesses also create conditions that allow fraud and misuse of funds, further undermining trust in the Scheme. Strengthening transparency and requiring regular public reporting on regulatory performance, complaints, investigations, and enforcement outcomes will be critical to restoring confidence and ensuring accountability.

Dr Mark Zirnsak Senior Social Justice Advocate Uniting Church in Australia Synod of Victoria and Tasmania Centre for Theology and Ministry 29 College Crescent Parkville Victoria 3052 redacted

Elga Rodriguez (She/Her) Disability Inclusion Advocate Uniting Church in Australia Synod of Victoria and Tasmania Centre for Theology and Ministry 29 College Crescent Parkville, VIC 3052 redacted

⁹ Natasha Robinson, “NDIS ‘gravy train for middlemen’”, The Australian, 21 March 2025.

Appendix: Resolutions of Uniting Church bodies relevant to people with disability

Resolution of the Uniting Church in Australia National Assembly meeting

The 2018 meeting of hundreds of Uniting Church representatives from across Australia adopted the following resolution:

The Assembly resolved:

18.18.01 to adopt the following ‘Statement of Access and Welcome’ as a starting point for further conversation and action regarding justice and equality for people with disability as it provides a basis for the Assembly and Synods to develop their particular response to this matter. In accordance with the Uniting Church Basis of Union, the Church is a fellowship of reconciliation, “a body within which the diverse gifts of its members are used for the building up of the whole, an instrument through which Christ may work, and bear witness to himself” (Paragraph 3). In light of this, the Uniting Church affirms that:

(a) Christ is most fully present when all people in the Body are unconditionally accepted as people of worth. All people are created in the image of God, including people with disability;

(b) along with all members, the faith, gifts, hopes and dreams of people with disability are to be valued and honoured; and

(c) God is a God of justice and peace who seeks reconciliation amongst all people.

In seeking to be a community of reconciliation, the Uniting Church acknowledges that, for many people with disability, its life and faith have not always borne witness to this vision. The Uniting Church seeks:

(a) to embody a community life that, in its theology and practice, is accessible to all people;

(b) to ensure that within its own life, people with disability are treated justly and have their hopes and rights realised; and

(c) to advocate for justice and equality for people with disability in the wider community.

18.18.02 to request the Standing Committee to develop disability access guidelines for use at all events and activities overseen by the Assembly and to encourage each Synod to develop similar disability access guidelines for use at Synod events and meetings;

18.18.03 to encourage each Synod to develop Disability Action Plans in accordance with the federal Disability Discrimination Act 1992, with the aim of eliminating access barriers pertaining to:

(i) Attitude/Theology and access and welcome;

(ii) Communication; and

(iii) Physical Environment.

18.18.04 to request the appropriate Standing Committee to arrange for the development of an appropriate liturgical response that acknowledges the historical exclusion experienced by many people with disability.

Resolutions of the meetings of the Synod of Victoria and Tasmania

The 1998 meeting of hundreds of representatives of the Synod from across Victoria passed the following resolution:

98.5.4.5 The Synod resolved:

In keeping with the spirit of resolutions made in the International Year of Disabled Persons, and in the light of the Disability Discrimination Act (DDA) (Cwth: 1992):

(a) To affirm its commitment to creating a Church that is for all people with disabilities (as defined in the DDA) and in all aspects of its life, free from discrimination.

(b) To appoint a Task Group to develop and implement an Action Plan under the DDA in compliance with Section 61 of that Act. The initial phase would be to undertake an audit of current practices within the life of the Church that may discriminate (including unintentionally) against people with a disability, including, but not limited to, physical or sensory barriers, informational or attitudinal barriers, and any other elements of proclamation, teaching, fellowship or service.

(c) That the Standing Committee be asked to appoint members of the Task Group.

(d) That the Task Group report to the 1999 Synod with its recommendations, including financial and staffing implications and a schedule of action.

The 2022 Synod meeting adopted the following resolution:

The Synod resolved:

To support the full implementation of the UN Convention on the Rights of Persons with Disabilities in Australia.

To call on the Victorian Government to:

a) Amend the Victorian Disability Act to

i) recognise the right of people with disabilities to spiritual expression, and this be referenced in all Victorian State Disability Action Plans;

ii) ensure that the Victorian Government will provide essential supports to people with disabilities where the National Disability Insurance Scheme fails to deliver such supports;

iii) establish a Victorian Commissioner for Disability Inclusion who:

(1) oversees compliance with the state disability plan and disability action plans;

(2) has a duty to support, advocate for, and promote the rights and well-being of people with disability across Victoria, like the functions of the

Commissioner for Children and Young People and the Victorian Commissioner for LGBTIQ+ Communities; and

(3) upholds the rights of all people with disability in Victoria, in line with the United Nations Convention on the Rights of Persons with Disabilities;

iv) require all organisations that receive funding from the Victorian Government above a reasonable threshold should be required to have a meaningful disability action plan;

v) ensure that any use of restrictive practices be a last resort in response to the risk of harm to the person with disability or others. The use of restrictive practices should also comply with the human rights principles contained within the UN Convention on the Rights of People with Disabilities and the Optional Protocol to the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment;

vi) create an offence to hinder, obstruct, intimidate or threaten a Community Visitor carrying out their functions; and

vii) allow designated people on the Community Visitors program to be able to visit all forms of accommodation that the National Disability Insurance Agency has introduced, accommodation provided by the Transport Accident Commission and all accommodation that is connected or managed by, or on behalf of, a disability service provider.

b) Develop Minimum Accessibility Standards for mainstream services with guidance to Victorian businesses on how to improve their inclusivity. The Standards should be backed by a complaint mechanism. An education program should be conducted in the Victorian community on accessibility;

c) Establish a central register of disability residential properties that Community Visitors are able to inspect;

d) Establish a Disability Deaths Registrar modelled on the State Coroner’s Victorian Suicide Register and accompanying review;

e) Ensure people with disabilities leaving prison are provided with appropriate transitional planning for post-release, including direct referrals to disability services, housing and other funded in-community supports.

To write to the Victorian Premier, the Minister for Disability, Ageing and Carers, the Leader of the Opposition and the Shadow Minister for Disability, Ageing and Carers to inform them of this resolution.