NDIA Accountability Project

Complex allied health service delivery and NDIS sustainability

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Committee Secretary Joint Committee of Public Accounts and Audit PO Box 6021 Parliament House Canberra ACT 2600

Dear Committee Secretary,

Please note that we were notified of this important inquiry after the stated submission deadline. We respectfully request that the Committee accept this submission out of time and take its contents into consideration, given the significant operational and sustainability issues affecting allied health providers and NDIS participants.

Re: Submission to the Inquiry into the Administration of the National Disability Insurance Scheme

I write on behalf of Coast Rehab, a regional allied health provider on the NSW Central Coast supporting approximately 250 people with complex neurological and physical disabilities each year. Our team consists of occupational therapists, physiotherapists and administrative staff delivering predominantly in-home services to participants with conditions such as ABI, TBI, cerebral palsy, MND, MS and spinal cord injury.

This submission addresses the Committee’s terms of reference in relation to:

  • NDIA management of financial sustainability risks;
  • claimant and provider compliance requirements;
  • monitoring and performance;
  • regulatory performance of the NDIS Quality and Safeguards Commission; and
  • policy advice impacting allied health service viability.

We do not raise individual participant matters, but rather systemic issues affecting service delivery, financial sustainability and participant outcomes.

1. Plan Structure and Funding Periods – Inefficient and Risk-Creating

The introduction and rigid enforcement of shorter funding periods has materially reduced efficiency in the delivery of complex allied health services.

Participants with high physical support needs frequently require coordinated assessment and prescription of multiple items of assistive technology (AT), for example: hospital bed, pressure-relieving mattress, wheelchair and hoist. Under current funding structures:

  • Funding may be allocated in small, segmented amounts across plan periods.
  • Allied health practitioners may have sufficient hours to assess and trial equipment, but insufficient hours to complete the comprehensive clinical justification required for NDIA approval.
  • Providers must either absorb the unfunded administrative and reporting time or leave the participant without an essential support request lodged.

This creates three systemic risks:

  1. Clinical Risk – Delays in essential equipment (e.g., pressure care supports) increase the risk of hospitalisation, skin breakdown and carer injury.
  2. Financial Inefficiency – Where funding runs out mid-process, providers must recommence elements of assessment in the next plan period, resulting in duplicated visits and higher total system cost.
  3. Provider Sustainability Risk – Ethical providers routinely absorb non-billable time to ensure participants are not disadvantaged. This is not sustainable in a low-margin environment.

The current approach does not reduce costs; it shifts them into inefficiency and provider financial strain.

2. Assistive Technology (AT) Assessment and Approval Processes

The AT pathway has become increasingly unpredictable and administratively burdensome.

a) Lack of Clinical Engagement

There is no accessible, clinically informed advisory pathway to discuss AT prescriptions. Applications are submitted into a process without opportunity for case discussion, clarification, or real-time review. This results in:

  • Long processing delays;
  • Inconsistent decision-making;
  • Requests for information that suggest limited clinical understanding of complex disability.

b) Inconsistent Interpretation of Privacy

We have experienced repeated instances where NDIA staff decline to discuss AT requests with the prescribing clinician, even where participant consent is documented. This significantly delays clarification and creates unnecessary administrative back-and-

forth.

c) Delays Delays in AT approval are common and can extend for months. For participants with degenerative or progressive conditions, this has material health consequences and increases downstream system costs. The absence of transparent performance metrics regarding AT decision timeframes and clinical review standards limits accountability.

  1. Planning Processes and Review Mechanisms

a) Plan Reviews Conducted Without Clinical Context We have observed planning processes conducted by phone, sometimes without the participant physically present, and without meaningful engagement with treating clinicians. Functional Capacity Assessments (FCAs) appear not to be systematically reviewed in full. Decisions frequently appear to be cost-driven rather than needs-driven.

b) Administrative Review Tribunal (ART) Burden A high proportion of review decisions are subsequently overturned at the ART. It is widely understood that approximately 70% of matters proceeding to review result in outcomes favouring participants. This raises critical concerns:

  • The system incurs significant legal and administrative cost.
  • Participants experience prolonged stress and service uncertainty.
  • Providers must invest additional unpaid time preparing documentation and supporting clients through review processes.

From a public audit perspective, this represents inefficient allocation of public funds and avoidable administrative burden.

  1. Pricing and Market Sustainability Allied Health Professional (AHP) pricing under the NDIS is below comparable market benchmarks, particularly for experienced clinicians delivering complex in-home services.

Recent and ongoing pricing uncertainty, including sudden reductions in travel and therapy pricing, has created sector instability and undermined business confidence.

For regional providers delivering high-complexity services:

  • Profit margins are minimal (often approximately 5% or less once full costs are accounted for).
  • Administrative overhead has increased significantly without commensurate funding.
  • Workforce attraction and retention are compromised.

The current pricing structure does not reflect:

  • High documentation requirements;
  • Travel time in regional areas;
  • Risk, compliance and reporting obligations;
  • Clinical complexity of participants.

Market fragility poses a direct risk to scheme sustainability if experienced providers exit the sector.

  1. Increased Compliance and Administrative Burden Administrative requirements have increased substantially, yet there is limited observable benefit to participants in terms of improved outcomes.

Providers must manage:

  • Detailed claim compliance requirements;
  • Frequent plan boundary constraints;
  • Increased reporting obligations;
  • Complex privacy interpretations;
  • Regulatory oversight from multiple bodies.

While accountability is essential, compliance processes must be proportionate and risk-based. Excess administrative burden diverts clinical time away from participants and contributes to workforce burnout.

  1. Regulatory Performance and Policy Settings We submit that there is insufficient alignment between:
  • NDIA operational decision-making;
  • NDIS Commission regulatory expectations; and
  • Policy settings developed by the Department of Health, Disability and Ageing.

Allied health providers are expected to meet high clinical governance and documentation standards, yet funding structures do not adequately support the time required to meet these obligations.

Policy reform aimed at financial sustainability must be balanced with service viability. Cost containment that destabilises the provider market will ultimately increase long- term expenditure.

Recommendations We respectfully recommend that the Committee consider:

  1. Reviewing the efficiency and clinical impact of short funding periods for complex participants.
  2. Establishing a clinically informed AT advisory pathway with defined processing benchmarks.
  3. Publishing transparent performance metrics for AT approvals and plan review decision timeframes.
  4. Evaluating ART overturn rates as a key performance indicator of planning quality.
  5. Commissioning an independent pricing review benchmarking AHP rates against comparable markets.
  6. Implementing proportionate, risk-based compliance frameworks that reduce unnecessary administrative burden.

Conclusion The NDIS remains a critical and transformative reform. However, the current administrative settings are generating inefficiencies, clinical risk and financial instability within the allied health market.

True financial sustainability cannot be achieved solely through price suppression and tighter plan boundaries. It requires:

  • Efficient clinical pathways,
  • Transparent performance measurement,
  • Fair and sustainable pricing, and
  • Alignment between policy, regulation and operational delivery.

We appreciate the opportunity to contribute to this inquiry and would welcome further engagement should the Committee seek clarification on any matters raised.

Yours sincerely,

Laura Stockwell (she/her) Practice Manager Availability: Monday, Tuesday, and Thursday 9:00am – 3:00pm

Address: 45/94 The Entrance Road Erina Post: PO Box 3380 Erina 2250 | E: admin@coastrehab.com.au NDIS Provider No: 4050031659 | ABN: 49 623 286 966

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