Submission to the Joint Committee of Public Accounts and Audit Inquiry into the Administration of the National Disability Insurance Scheme (NDIS)
Submission date: 25 January 2026
Submitted by: Gaynor Lowndes, CEO, HomeCare Australia
1. Purpose of this submission
This submission addresses two issues that directly impact participant safety, scheme integrity, and financial sustainability:
- the regulation of unregistered providers; and
- the effectiveness and sustainability of current payment arrangements where many claims are processed via plan managers.
2. Background
HomeCare Australia has been an NDIS provider since the trial site commenced in Newcastle in 2013. In the early years, participant claims were managed by the NDIA and the claiming process was relatively straightforward.
Following the establishment of the NDIS Quality and Safeguards Commission, providers were required to become registered and to undergo periodic audits (typically every 18 months) to remain registered and able to claim directly.
Registration audits can be expensive and administratively burdensome. At the same time, a significant proportion of participants have moved from NDIA-managed funding to plan-managed arrangements, reducing the practical benefits of being a registered provider while the compliance costs remain.
3. Issue 1: Unregistered providers and participant safeguards
Australia now has a very large number of unregistered providers operating in the NDIS. In our experience, the current settings create uneven safeguards for participants. We have observed situations—some serious—where participants receiving supports from unregistered providers have been exposed to higher risk. This is particularly concerning in higher-risk settings such as Supported Independent Living (SIL), where providers may have limited capability, weak governance, or insufficient understanding of participant-centred care and duty of care obligations.
We have also observed unregistered providers delivering community access supports in ways that would not meet the policies, procedures, and training expectations required of registered providers. The gap in regulation increases the risk of poor-quality supports, reportable incidents not being managed appropriately, and fraudulent or incorrect claiming for services that were not delivered or were not delivered as claimed.
4. Recommendation 1
Require all NDIS providers to be registered, regardless of the specific supports they deliver, with regulatory requirements proportionate to risk. A tiered model could preserve flexibility for low-risk supports while still ensuring baseline safeguards, traceability, and compliance across the entire provider market.
5. Issue 2: Payment arrangements and plan manager impacts
In practice, the increasing reliance on plan managers has introduced payment delay risk for providers. Plan managers regularly cause cash flow pressure in our organisation, even when invoices are submitted promptly after services are delivered. In some cases, payments are received monthly despite weekly invoicing. This creates downstream risk for participants because providers may be forced to consider pausing services—an outcome that is particularly harmful for vulnerable participants.
In addition, plan-managed arrangements can reduce real-time budget oversight. Participants may run out of funds prior to their plan review/renewal date. When more participants were NDIA-managed and providers claimed directly, there was stronger visibility of budgets and a clearer shared responsibility to avoid preventable funding exhaustion. At minimum, plan managers should have clearer obligations to monitor budgets and proactively warn participants (and relevant providers, where consent permits) when funds are at risk of running out.
6. Recommendation 2
Review the sustainability and effectiveness of plan-managed claiming arrangements, including:
- service standards for payment timeframes; and
- stronger accountability for plan managers regarding budget monitoring and proactive notifications.
The Scheme should also explore modernised claim processing solutions that reduce administrative overhead. For example, digital automation and advanced analytics could be used to support claim validation and fraud detection at lower cost, while improving payment timeliness for compliant providers.
7. Closing
HomeCare Australia supports reforms that strengthen integrity and safeguarding while protecting participant choice and ensuring the NDIS remains financially sustainable. In our view, a consistent baseline regulatory framework for all providers, combined with improved payment arrangements and accountability, would materially reduce risk and improve outcomes.