Joint Committee of Public Accounts and Audit
February 2026
About NACCHO
NACCHO is the national peak body representing 149 Aboriginal Community Controlled Health Organisations (ACCHOs). We also assist a number of other community-controlled organisations.
The first Aboriginal medical service was established at Redfern in 1971 as a response to the urgent need to provide decent, accessible health services for the largely medically uninsured Aboriginal population of Redfern. The mainstream was not working. So it was, that over fifty years ago, Aboriginal people took control and designed and delivered their own model of health care. Similar Aboriginal medical services quickly sprung up around the country. In 1974, a national representative body was formed to represent these Aboriginal medical services at the national level. This has grown into what NACCHO is today. All this predated Medibank in 1975.
NACCHO liaises with its membership, and the eight state/territory affiliates, governments, and other organisations on Aboriginal and Torres Strait Islander health and wellbeing policy and planning issues and advocacy relating to health service delivery, health information, research, public health, health financing and health programs.
ACCHOs range from large multi-functional services employing several medical practitioners and providing a wide range of services, to small services which rely on Aboriginal health practitioners and/or nurses to provide the bulk of primary health care services. Our 149 members provide services from about 550 clinics.
Our sector provides over 3.1 million episodes of care per year for over 410,000 people across Australia, which includes about one million episodes of care in very remote regions.
ACCHOs contribute to improving Aboriginal and Torres Strait Islander health and wellbeing through the provision of comprehensive primary health care, and by integrating and coordinating care and services. Many provide home and site visits; medical, public health and health promotion services; allied health; nursing services; assistance with making appointments and transport; help accessing childcare or dealing with the justice system; drug and alcohol services; and help with income support. Our services build ongoing relationships to give continuity of care so that chronic conditions are managed, and preventative health care is targeted. Through local engagement and a proven service delivery model, our clients ‘stick’. Clearly, the cultural safety in which we provide our services is a key factor of our success.
ACCHOs are also closing the employment gap. Collectively, we employ about 7,000 staff – 54 per cent of whom are Aboriginal or Torres Strait Islanders – which makes us the third largest employer of Aboriginal or Torres Strait people in the country.
Enquiries about this submission should be directed to:
NACCHO Level 5, 2 Constitution Avenue Canberra City ACT 2601 Telephone: 02 6246 9300 Email: policy@naccho.org.au Website: naccho.org.au
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Recommendations
- NACCHO recommends any interventions to address inquiry into the administration of the National Disability Insurance Scheme align with the National Agreement and its four Priority Reform Areas.
- NACCHO recommends ensuring fraud prevention and compliance processes do not create unmanageable administrative burden on ACCHOs.
- NACCHO recommends expanding and strengthening ADLO and RCC services as the culturally appropriate mechanism for supporting and monitoring culturally safe service delivery.
- NACCHO recommends NDIS safeguarding frameworks are strengthened to explicitly protect the cultural rights of Aboriginal and Torres Strait Islander people including the preservation of culture, cultural practices, and
redactedways of healing and being and that these frameworks are developed in partnership with the Aboriginal and Torres Strait Islanderredactedsector.redactedcommunity-ledredactedcommunity-controlled - NACCHO recommends culturally informed compliance frameworks
redactedwith ACCHOs and Aboriginal and Torres Strait Islander disability advocates, in line with DRC Recommendation 9.10.redactedco-designed - NACCHO recommends working in partnership with NACCHO and ACCHOs to create clearer communication and targeted engagement with participants to improve the visibility and accessibility of the NDIS Quality and Safeguards Commission.
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Acknowledgements
NACCHO welcomes the opportunity to provide a submission to the inquiry into the administration of the National Disability Insurance Scheme (NDIS). NACCHO supports the submissions to this consultation made by NACCHO Members and Affiliates.
National Agreement on Closing the Gap
Advocating for and securing the National Agreement on Closing the Gap was an historically significant act of Aboriginal and Torres Strait Islander self-determination. The National Agreement is evidence of a new era of engagement by and with Aboriginal and Torres Strait Islander people. It commits Australia to a new direction and is a pledge from all governments to fundamentally change the way they work with Aboriginal and Torres Strait Islander communities and organisations – to support self-determination and build the capacity of the community-control sector.
This Government’s first Closing the Gap Implementation Plan commits to achieving Closing the Gap targets through implementation of the Priority Reforms. This represents a shift away from focussing on the Targets, towards the structural changes that the Priority Reforms require, and which are more likely to achieve meaningful outcomes for our people in the long term.
The reforms and targets outlined in the National Agreement seek to overcome the inequality experienced by Aboriginal and Torres Strait Islander people and achieve life outcomes equal to all Australians. Governments at all levels have committed to the implementation of the National Agreement’s four Priority Reform Areas, which offer a roadmap to meaningfully impact structural drivers of poor health and social outcomes for Aboriginal and Torres Strait Islander people:
Priority Reform Area 1 – Formal partnerships and shared decision-making This Priority Reform commits to building and strengthening structures that empower Aboriginal and Torres Strait Islander people to share decision-making authority with governments, and to accelerate policy making that centres Aboriginal and Torres Strait Islander voices.
Priority Reform Area 2 – Building the community-controlled sector Recognising that community-controlled services achieve better outcomes, employ more Aboriginal and Torres Strait Islander people and are often preferred over mainstream services, this Priority Reform commits to building Aboriginal and Torres Strait Islander community-controlled sectors to deliver services to support Closing the Gap.
Priority Reform Area 3 – Transformation of mainstream institutions This Priority Reform commits to systemic and structural transformation of government organisations to identify and eliminate racism, embed and practice cultural safety, deliver services in partnership with Aboriginal and Torres Strait Islander people, support truth telling about agencies’ history with Aboriginal and Torres Strait Islander people, and engage fully and transparently with Aboriginal and Torres Strait Islander people when programs are being changed.
Priority Reform Area 4 – Sharing data and information to support decision making This Priority Reform commits to shared access to regional data and information to inform local decision making and support achievement of the first three Priority Reforms. This Priority Reform supports principles of Indigenous Data Sovereignty.
Despite some progress, the need for fundamental systemic reform remains evident. In its first review of the National Agreement on Closing the Gap, the Productivity Commission found that governments are not adequately delivering on their commitments. Despite support for the Priority Reforms and some good practice, progress has been slow, uncoordinated, and piecemeal.
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The Commission noted that to enable better outcomes, governments need to relinquish some control, share decision making and acknowledge that Aboriginal and Torres Strait Islander people know what is best for their communities. Aboriginal Community Controlled Organisations must be treated as critical partners rather than passive funding recipients, and trusted to design, deliver and measure government services in ways that are culturally safe and meaningful for their communities.
‘Too many government agencies are implementing versions of shared decision-making that involve consulting with Aboriginal and Torres Strait Islander people on a pre-determined solution, rather than collaborating on the problem and co-designing a solution’1
NACCHO recommends any interventions to address inquiry into the administration of the National Disability Insurance Scheme align with the National Agreement and its four Priority Reform Areas.
Introduction
NACCHO welcomes the opportunity to contribute to the inquiry into the administration of the National Disability Insurance Scheme (NDIS). We are committed to supporting Aboriginal Community Controlled Health Organisations (ACCHOs) to improve outcomes for Aboriginal and Torres Strait Islander people across all areas of care.
Through our coordination of the NDIS Ready (2020–2022) and Care and Support Ready (2022–2023) programs, NACCHO facilitated an increase in ACCHO/ACCO service providers in the NDIS market. Since the conclusion of these programs, provider numbers have declined, reflecting systemic misalignment between the NDIS’s financial and regulatory compliance processes and the ACCHO model of care.2 It is the aspiration of NACCHO and the NDIA’s First Nation Strategy 2025-20303 to expand the NDIA’s culturally thin markets of Aboriginal and Torres Strait Islander participant servicing through the community-controlled sector. To do this, Priority Reform 3 of the National Agreement dictates that structural transformation is required to improve this misalignment.
NACCHO will not be responding to the first three Auditor-General reports, as they focus largely on NDIS financial reporting and internal controls, which fall outside NACCHO’s core policy priorities. Instead, NACCHO will direct its response to the three reports that have clear and direct implications for NDIS service delivery through ACCHOs and for Aboriginal and Torres Strait Islander communities. Specifically, regarding the effectiveness of the National Disability Insurance Agency (NDIA) Board, the NDIA’s management of claimant compliance with NDIS claim requirements, and the effectiveness of the NDIS Quality and Safeguards Commission’s regulatory functions.
The Auditor General reports examining governance, compliance, and regulatory oversight across the NDIS highlight several systemic weaknesses that continue to disproportionately affect Aboriginal and Torres Strait Islander communities. These issues directly intersect with access, cultural safety, provider accountability, and the overall quality of NDIS supports. ACCHOs and Aboriginal and Torres Strait Islander participants require a system that is culturally responsive, risk sensitive, transparent, and accountable.
1 Productivity Commission, Review of the National Agreement on Closing the Gap, Study Report, Canberra, 7 Feb 2024 https://www.pc.gov.au/inquiries/completed/closing-the-gap-review/report. 2 National Aboriginal Community Controlled Health Organisation (2021). Core Services and Outcomes Framework. [online] Available at: https://www.naccho.org.au/wp-content/uploads/2024/10/Core-Services-Outcomes-Framework-full-document.pdf. 3 National Disability Insurance Agency. (2025). NDIS First Nations Strategy 2025–2030 (PDF). National Disability Insurance Scheme. https://www.ndis.gov.au/strategies/first-nations-strategy#first-nations-strategy-2025-2030
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Board of the National Disability Insurance Agency
We welcome the recent efforts to strengthen the effectiveness of the NDIA Board, specifically through the inclusion of Aboriginal and Torres Strait Islander representative. The presence of Aboriginal and Torres Strait Islander membership on the Board supports better alignment with the National Agreement and the needs, perspectives, and lived experiences of Aboriginal and Torres Strait Islander communities.
We support further embedding Aboriginal and Torres Strait Islander perspectives into decision making structures. Continued investment in culturally competent leadership will help the Board drive more responsive, equitable, and community-aligned outcomes across the Scheme.
Compliance and exploitation
Impacts on Aboriginal and Torres Strait Islander communities
Auditor-General *Report No. 48 (2024–25)*4 examined how the NDIA verifies NDIS claims and found an increasing emphasis on fraud prevention and stricter compliance checks. While these measures are important for protecting the integrity of the Scheme, they depend on extensive paperwork, reliable digital access, and quick turnaround times. These are requirements NACCHO has consistently highlighted as difficult for many Aboriginal and Torres Strait Islander communities to meet, particularly in rural and remote areas.
It cannot be assumed that all NDIS providers have the same access to reliable telecommunications and digital services, especially in rural and remote areas. There are ongoing systemic barriers to internet access for Aboriginal and Torres Strait Islander communities in remote areas nationally, with 41% of Aboriginal and Torres Strait Islander people considered –digitally excluded– [corrected from source OCR ‘“digitally excluded”,’], which means they have limited access, affordability or ability to effectively use the internet and digital technologies.5 In remote communities and homelands, rates of digital exclusion are even higher.6 Some of our ACCHOs do not have adequate infrastructure support or reliable connectivity to be able to provide the growing range of digital health and related services.
For ACCHOs, this results in increased administrative workload, more time spent on documentation, and added pressure on already stretched staff, ultimately diverting resources away from direct client support. ACCHOs already manage highly complex environments to ensure client safety as primary health care providers. Various ACCHOs provide services across healthcare, aged care and disability – all with differing accreditation requirements. There is no funding to support the increased regulatory burden which will result in increased financial burden. This will be particularly impactful on smaller providers. We have previously highlighted that ACCHOs require long-term, stable funding to manage these demands, but such supports are not yet adequately in place.
Auditor-General *Report No. 2 (2025–26)*7 reviewed the NDIS Quality and Safeguards Commission’s regulatory approach to service quality and safety. Although strong regulation is necessary, the current rules do not always align with or support Aboriginal and Torres Strait Islander service models or cultural practices. As a result, ACCHOs can face regulatory requirements that do not match community-controlled ways of delivering care, making it more difficult for them to register or maintain registration as NDIS providers. This is
4 National Disability Insurance Agency’s Management of Claimant Compliance with National Disability Insurance Scheme Claim Requirements 5 Featherstone D, Ormond-Parker L, Thomas J, Parkinson, S, Hegarty K, Hawkins, L, Louie YM, Barton A, Johnson Y, Kennedy J, Bawden, S, Ganley L (2025) Mapping the Digital Gap: 2025 Outcomes Report, Melbourne: ARC Centre of Excellence for Automated Decision-Making and Society. https://doi.org/10.60836/1dhh-2e31. 6 Thomas, J., McCosker, A., Parkinson, S., Hegarty, K., Featherstone, D., Kennedy, J., Ormond-Parker, L., Morrison, K., Rea, H, & Ganley, L. Measuring Australia’s Digital Divide: 2025 Australian Digital Inclusion Index. Melbourne: ARC Centre of Excellence for Automated Decision-Making and Society, RMIT University, Swinburne University of Technology, and Telstra. 7 Effectiveness of the NDIS Quality and Safeguards Commission’s Regulatory Functions
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especially challenging in thin or remote markets, where limited-service availability already places additional administrative and financial strain on providers.
NACCHO recommends ensuring fraud prevention and compliance processes do not create unmanageable administrative burden on ACCHOs.
Systemic weaknesses enabling exploitation
Evidence from the audit reports points to persistent systemic weaknesses in the NDIA’s compliance and oversight processes, showing that current controls are not effective in detecting non-compliant, fraudulent or otherwise inappropriate claims early. As a result, Aboriginal and Torres Strait Islander participants remain vulnerable to financial exploitation and inappropriate service substitution.
In the Auditor-General Report No. 48 202, it was found that the NDIA’s claimant compliance management has been assessed as only partly effective, with major deficiencies in risk management, payment assurance testing and performance reporting. The audit also highlighted delays in implementing critical milestones designed to “crack down on fraud and non-compliant payments”.8 The extremely low proportion of claims subject to pre-payment review underscores a lack of preventative oversight, increasing the likelihood that fraudulent or exploitative providers can operate without early detection. NACCHO has heard from our members that often, when a complaint is made about a provider, there is no transparency for those making the complaint about investigations or outcomes. This undermines participant trust in the system.
For Aboriginal and Torres Strait Islander participants particularly those in remote and rural communities, these weaknesses are heightened by structural inequities such as limited digital connectivity, low access to advocacy, and fewer provider choices. Without effective protections, these participants face increased exposure to exploitation, including overcharging, service substitution, culturally unsafe practices, and coercive provider behaviour.
Community-controlled organisations play a critical role in mitigating these risks. Their service delivery models are grounded in deep understanding of family, cultural, and community contexts, enabling them to identify concerns early, ensure culturally safe support, and maintain stronger accountability mechanisms. These locally governed, community-embedded models of care strengthen compliance by ensuring that services are responsive, transparent, and aligned with participants’ needs. As a result, the robust governance and cultural safeguards within the community-controlled sector help prevent violence, abuse, neglect, and other forms of exploitation.
Moreover, to ensure Aboriginal and Torres Strait Islander people are protected and supported, there must be a strong focus on expanding, upskilling, and adequately funding the Aboriginal Disability Liaison Officer (ADLO) role and the Remote Community Connector (RCC) role. ADLOs deliver a critical safeguarding function within communities by providing culturally informed oversight of mainstream providers’ delivery of culturally safe services. Whilst a RCC helps link people in remote communities with services, programs, and support by acting as a trusted local point of connection. Strengthening the ADLO and RCC workforce would enhance the monitoring of support plans, service delivery, and complaints, and ensure that cultural needs and rights are upheld across the NDIS system.
NACCHO recommends expanding and strengthening ADLO and RCC services as the culturally appropriate mechanism for supporting and monitoring culturally safe service delivery.
8 National Disability Insurance Agency’s Management of Claimant Compliance with National Disability Insurance Scheme Claim Requirements
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Compliance mechanisms
Cultural Safety and Safeguarding
Regulatory requirements for disability services for Aboriginal and Torres Strait Islander people often fail to anticipate the unique barriers that exist for Aboriginal and Torres Strait Islander people.
Auditor-General Report No. 48 (2024–25) identifies major gaps in the NDIA’s ability to detect and prevent non-compliant or harmful provider behaviour such as delays in fraud-prevention measures and limited pre-payment checks. The Auditor-General Report No. 2 (2025–26) shows that current regulatory settings do not align well with community-controlled models or thin markets, adding pressure on ACCHOs and enabling mainstream providers to dominate Aboriginal and Torres Strait Islander disability markets. Provision of care by mainstream providers is often not culturally safe for Aboriginal and Torres Strait Islander participants which can lead to poorer outcomes and an increased risk of participant disengagement from the NDIS.
The NDIA’s First Nations Strategy 2025–30, co-designed with Aboriginal and Torres Strait Islander community members, recognises that “the rights of First Nations people with disability cannot be separated from First Nations concepts of holistic physical, cultural, social, emotional, and spiritual health and wellbeing.”9 This understanding extends beyond service delivery models to encompass ways of being, knowing, and doing, including culturally distinct understandings of disability that differ from Western, deficit-based definitions. Despite this recognition, the ongoing absence of culturally safe services identified by the Disability Royal Commission as a “time-sensitive national crisis” has left Aboriginal and Torres Strait Islander participants particularly vulnerable within the NDIS.10 In this context, Aboriginal and Torres Strait Islander disability markets are often dominated or exploited by mainstream providers who reportedly negate, suppress, or overlook the cultural rights and lived realities of Aboriginal and Torres Strait Islander people with disability.
These failures lead to ongoing inequity, a lack of personal and cultural safety, and further trauma, which in turn cause people to disengage from services. Evidence further indicates that inadequate safeguarding of cultural safety contributes to poorer health outcomes, lifelong harm, and, in some cases, preventable deaths within Aboriginal and Torres Strait Islander communities.11 These outcomes underscore that cultural safety is not an optional or supplementary consideration, but a fundamental safeguard.
Explicitly safeguarding cultural safety is therefore central to protecting the rights of Aboriginal and Torres Strait Islander people with disability to be free from harm, abuse, and neglect, and to uphold their right not only to life, but to a life of quality, dignity, and self-determination. Supporting Aboriginal and Torres Strait Islander ways of knowing, being, and doing – across physical, cultural, social, emotional, and spiritual domains – must be integral to safeguarding frameworks if these foundational rights are to be meaningfully realised in practice. The best way to ensure cultural safety is to increase the number of Aboriginal and Torres Strait Islander community-controlled providers – as recommended by the Disability Royal Commission - and ensure culturally appropriate mandatory training is delivered by the Aboriginal Community Controlled Registered Training Organisations (ACCRTO) sector to mainstream disability services.
NACCHO recommends NDIS safeguarding frameworks are strengthened to explicitly protect the cultural rights of Aboriginal and Torres Strait Islander people including the preservation of culture, cultural practices, and
redactedways of healing and being and that these frameworks are developed in partnership with the Aboriginal and Torres Strait Islanderredactedsector.redactedcommunity-ledredactedcommunity-controlled
9 NDIS (2025). First Nations Strategy | NDIS. [online] Ndis.gov.au. Available at: https://www.ndis.gov.au/strategies/first-nations-strategy. 10 Deloitte. (2023). Research report – Options to improve service availability and accessibility for First Nations people with disability. Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability. 11 Elvidge, E., & Haddock, R. (2025). Measuring what really matters for Aboriginal and Torres Strait Islander peoples – Racism and cultural safety in healthcare (Deeble Issues Brief No. 60). Australian Healthcare and Hospitals Association. https://ahha.asn.au/wp content/uploads/2024/09/Deeble-Issues-Brief-No.-60-Racism-and-cultural-safety-in-healthcare.pdf
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Building a culturally responsive compliance mechanism
Creating an effective NDIS system requires compliance settings that uphold integrity while not disadvantaging ACCHOs/ACCOs or the communities they serve. Building a culturally responsive compliance mechanism means shifting away from one-size-fits-all regulatory approaches and grounding oversight in a genuine understanding of community-controlled service models. This includes ensuring requirements are proportionate, flexible and culturally informed, while reducing unnecessary administrative burden. It also relies on long-term investment, co-design with ACCHOs, and compliance mechanisms that recognise community control and cultural safety as a core dimension of quality.
In this context, the Disability Royal Commission (DRC) Progress Report for Recommendation 9.10 noted that establishing a First Nations Disability Forum is essential for ensuring that compliance settings are shaped and continually informed by Aboriginal and Torres Strait Islander voices. The report also highlighted that no action has been taken since 2024.12 A dedicated forum will enable structured, ongoing engagement between Aboriginal and Torres Strait Islander communities, ACCHOs and government, ensuring that compliance approaches reflect lived experience, cultural knowledge and the unique service delivery environment across diverse communities.
A culturally informed approach is essential to prevent Aboriginal and Torres Strait Islander participants from being penalised due to structural barriers such as remote location, limited technological access, lower health literacy, and inconsistent access to support coordination or interpreters. To address these inequities, compliance frameworks should ensure communication materials are accessible, plain language and culturally appropriate. They should also offer targeted support to help Aboriginal and Torres Strait Islander participants and providers meet documentation and billing requirements, acknowledging that digital access and administrative capacity vary across communities. Equally important is avoiding punitive responses when non-compliance results from systemic disadvantage rather than deliberate misuse.
Together, these measures create compliance settings that support integrity while respecting cultural practice and community-controlled models of care. Embedding Recommendation 9.10 ensures that community-controlled governance structures can guide these reforms and strengthen accountability frameworks in ways that align with cultural values and community priorities. With sustained investment and genuine co-design, a culturally responsive compliance mechanism can strengthen accountability without undermining ACCHOs’ ability to provide culturally grounded, community-controlled services.
NACCHO recommends culturally informed compliance frameworks
redactedwith ACCHOs and Aboriginal and Torres Strait Islander disability advocates, in line with DRC Recommendation 9.10.redactedco-designed
Transparent provider quality
For ACCHOs, the low visibility and unclear public role of the NDIS Quality and Safeguards Commission is a significant concern. Although the Commission is responsible for regulating providers and safeguarding participant safety, many participants and community organisations are unsure what the Commission does or how to engage with it. This lack of visibility and accessibility places additional pressure on ACCHOs, who often become the first point of contact when participants experience unsafe or poor-quality services.
The recent Auditor-General findings reinforce why this is problematic. The Commission is only “partly effective” in its regulatory functions, with weaknesses in intelligence gathering, information sharing, and risk frameworks. These gaps mean cultural safety concerns raised by communities are not always captured or escalated, leaving ACCHOs to manage risks without strong regulatory backing.
12 Recommendation 9.10 – First Nations Disability Forum | Australian Government Department of Health, Disability and Ageing
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For ACCHOs, a more visible and accessible regulator is essential. The Commission must improve its cultural safety and engagement with communities to make it easier for participants to understand their rights and access complaint pathways. Greater visibility would help reduce the informal safeguarding burden carried by ACCHOs and ensure that culturally unsafe providers are identified and addressed sooner.
NACCHO recommends working in partnership with NACCHO and ACCHOs to create clearer communication and targeted engagement with participants to improve the visibility and accessibility of the NDIS Quality and Safeguards Commission.
Conclusion
The Auditor-General findings show that current NDIS governance, compliance and regulatory settings continue to disadvantage Aboriginal and Torres Strait Islander people and the ACCHOs that support them. Complex compliance requirements, culturally misaligned regulations, weak safeguards and an insufficiently visible regulator all contribute to inequitable outcomes and increased pressure on community-controlled services.
To ensure the NDIS delivers safe, culturally appropriate and effective supports, reforms must centre cultural safety, support community control and ensure fair regulatory practice. Strengthening culturally informed governance, compliance and safeguarding systems and improving the visibility and responsiveness of the NDIS Quality and Safeguards Commission will be essential to ensuring Aboriginal and Torres Strait Islander people can fully exercise choice, control and receive the quality of care they deserve.
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