SUBMISSION TO THE JOINT COMMITTEE OF PUBLIC ACCOUNTS AND AUDIT
Introduction
This submission is provided in response to the Joint Committee of Public Accounts and Audit inquiry into the administration of the National Disability Insurance Scheme (NDIS), with particular reference to the management of financial sustainability risks, claimant and provider compliance with claim requirements, and the monitoring and reporting of NDIA performance.
Support Coordination is a critical component of the NDIS ecosystem. It enables participants—particularly those with complex needs, psychosocial disability, limited informal supports, or living in rural and regional areas—to understand, implement, and maximise the benefit of their plans. Without effective Support Coordination, many participants experience poorer outcomes, increased service disengagement, and greater reliance on crisis-based supports.
It is also a frontline mechanism for participant safeguards and compliance—support coordinators regularly identify service gaps, invoice irregularities, provider quality concerns, and risks to participants.
Despite its central role in participant outcomes and Scheme efficiency, Support Coordination pricing has remained effectively unchanged for approximately five years. This stagnation has occurred in the context of significant increases in operational, staffing, compliance, and service delivery costs. The failure to index Support Coordination rates in line with economic conditions is creating a serious provider sustainability risk, which in turn represents a financial and operational risk for the NDIA and the Scheme.
The Problem: Support Coordination Rates Have Not Kept Pace with Costs
Over the past consecutive five years, Support Coordination (Level 2 & 3) providers have faced steadily rising costs, including:
- Wage growth and workforce shortages across the disability sector
- Increased superannuation and employment on-costs
- Higher insurance premiums
- Significant increases in rent, utilities, and technology costs
- Expanded compliance and audit requirements
- Increased administrative burden linked to fraud prevention and reporting
The absence of meaningful indexation has eroded the viability of Support Coordination providers. Many services are now operating at or below cost, with limited capacity to reinvest in workforce development, service quality, or business continuity.
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This creates a structural contradiction: the NDIA expects high levels of compliance, quality assurance, and participant safeguards, while maintaining rates that do not adequately fund the delivery of these requirements.
Provider Sustainability is Directly Linked to Scheme Sustainability
The NDIS cannot function effectively without a stable, skilled, and sustainable provider market. Support Coordination plays a unique role in ensuring:
- participant choice and control
- appropriate utilisation of funded supports
- prevention of overspending or underutilisation
- connection to mainstream and community services
- reduction in service gaps and crisis escalation
If Support Coordination providers become financially unviable, the Scheme faces serious downstream impacts:
- fewer providers, reducing participant choice
- increased plan mismanagement and plan failure
- greater reliance on NDIA intervention
- increased risk of participant disengagement
- escalation into high-cost crisis supports
- higher administrative burden for the Agency
The sustainability of Support Coordination is therefore not merely a provider issue—it is a Scheme integrity and financial sustainability issue.
Rural and Regional Impacts: Market Fragility and Service Withdrawal
The risk is particularly acute in rural and regional Australia, where provider markets are already thin. In many communities, only one or two Support Coordination agencies operate. If those providers close due to unsustainable pricing:
- participants may have no local service access
- NDIA will face increased pressure to deliver or source alternative coordination mechanisms
- participants may experience delays, disengagement, or poorer outcomes
- inequity between metropolitan and regional participants will deepen
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Market failure in these areas would directly undermine the NDIS principle of equitable access and consistent national delivery.
Support Coordination agencies are often the backbone of regional disability service networks, and their withdrawal would create significant disruption for both participants and the NDIA.
Impact on Compliance and Scheme Integrity
The inquiry also highlights claimant and provider compliance with claim requirements and the NDIA’s monitoring of performance. Support Coordination providers are increasingly required to meet complex documentation, reporting, and audit standards. These compliance expectations require:
- qualified and experienced staff
- robust operational systems
- time-intensive case noting and oversight
- continuous training and governance
However, without adequate pricing, providers cannot sustainably fund the workforce and systems needed to maintain these safeguards.
This increases the risk of:
- workforce turnover
- reduced service quality
- inconsistent documentation
- provider exit from the market
- participants being left unsupported or vulnerable to exploitation
Appropriate pricing is therefore essential to support compliance, integrity, and Scheme assurance.
This inquiry specifically references compliance with claim requirements and NDIA monitoring and reporting. Support Coordination plays a practical role in that:
- Coordinators often scrutinise service agreements, help participants understand invoices, flag anomalies, and guide participants toward supports that meet “reasonable and necessary” intent.
- Coordinators support participants to navigate provider boundaries, reduce duplication, and prevent overlapping claims.
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- Coordinators assist with reporting to the NDIA as required within the pricing arrangements for Support Coordination.
Undervaluing this function increases compliance risk, because Support Coordinators are forced to reduce non-billable but necessary work (quality assurance, documentation, participant education, and inter-provider coordination) or exit altogether—leaving participants unsupported and more exposed to poor market behaviour.
With particular reference to rural and regional Australia, Support Coordination is commonly delivered with higher travel burdens, smaller caseloads (to maintain service quality), and greater time investment per participant due to limited service availability and longer coordination pathways. If a Support Coordination provider closes, participants may face:
- No substitute provider within a reasonable distance
- Longer waitlists and higher risk of participant deterioration
- Increased NDIA escalation and crisis presentations
This is the opposite of what an efficient, sustainable scheme should incentivise. A price limit that fails to reflect real input costs has the practical effect of withdrawing market capacity from the places that can least afford to lose it.
Recommendation: Immediate Indexation and Pricing Review
In earlier Parliamentary inquiries (e.g. Market Readiness), Committees noted that the NDIA’s price setting is a core market steward function and can influence the development or stagnation of markets. It also highlighted that price caps interact directly with thin market outcomes if they do not adequately support provider viability.
To support NDIA performance, participant outcomes, and provider sustainability, the following actions are recommended:
- Immediate indexation of Support Coordination rates Rates should reflect actual increases in wages, CPI, and operating costs since the last meaningful adjustment.
- A comprehensive pricing review specific to Support Coordination Recognising its distinct role, complexity, and administrative burden compared to other funded supports.
- Loading or targeted pricing measures for rural and regional delivery To prevent service withdrawal in areas with limited provider availability.
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- Recognition of Support Coordination as a Scheme sustainability mechanism Investment in Support Coordination reduces downstream NDIA costs through better plan implementation and reduced crisis escalation.
Support Coordination is not an optional or peripheral service—it is fundamental to participant outcomes, market stability, and Scheme financial sustainability.
The failure to increase Support Coordination rates over the past five years, despite substantial rises in operational and workforce costs, represents a significant risk to provider viability. Without urgent pricing reform, the NDIA faces the prospect of provider collapse, particularly in rural and regional areas, resulting in service disruption, increased Agency burden, and poorer participant outcomes.
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