The Australasian Association PO Box 518, Glenelg S.A. 5045 and Register of Practicing P (08) 7228 6855 Nutritionists E admin@aarpn.com www.aarpn.com 23/04/2026
Submission by The Australasian Association and Register of Practicing Nutritionists (AARPN) to the Joint Standing Committee on the National Disability Insurance Scheme
23 April 2026
1
About AARPN
AARPN (The Australasian Association and Register of Practicing Nutritionists) is the professional association and register for the Certified Practicing Nutritionist (CPN) profession. AARPN is a full member of Allied Health Professions Australia and a full member of the National Alliance of Self Regulating Health Professions (NASRHP). Certified Practicing Nutritionists are university-qualified clinically trained primary care nutrition professionals who provide evidence-informed therapeutic nutrition supports and capacity-building interventions where disability factors affect eating, drinking, meal planning, and nutrition self-management.
Initial remarks
AARPN thanks the Department of Health, Disability and Ageing for the opportunity to respond to the consultation Integrity of the National Disability Insurance Scheme.
AARPN’s overall view is that Government is building important foundations for NDIS integrity, but the next reform phase must go beyond tightening claims controls and expanding provider registration alone. The Scheme now needs a more mature integrity architecture, being one that links provider identity, provider regulation, workforce governance, and participant-facing transparency.
AARPN’s observation is that the Scheme’s integrity problems are not only about fraudulent claiming or isolated bad actors. They are also the product of an under-specified provider architecture. Government has improved the baseline, but the framework is still not sufficiently coherent, visible or risk-proportionate to safeguard participants consistently across the market. A stronger system would not regulate everyone identically; it would regulate according to risk, while making sure that anyone who materially delivers or controls disability supports is identifiable, accountable, and subject to safeguards that match the seriousness of the role.
In AARPN’s view, one of the central issues is that provider architecture, workforce architecture, and participant safeguards are too often treated as separate matters when, in practice, they are closely connected. Integrity is stronger where the system can clearly answer five questions: who is providing the support, what kind of role they occupy, what governance applies to them, what safeguards attach to that role, and who is accountable if something goes wrong. Where those questions are unclear, integrity is weakened even before any specific misconduct occurs.
AARPN therefore considers that the next phase of reform should be guided by clarity, proportionality, visibility, and accountability. The objective should not be to regulate more for its own sake, nor to impose the same regulatory burden across all parts of the market - rather, it should be to regulate the right actors in the right way and at the right intensity, while ensuring that participants can understand who is operating in the market and what protections do, and do not, apply.
Recommendations
- Reframe the provider definition so accountability follows practical control: The NDIS provider concept should clearly capture entities that materially deliver, arrange, control, match, supervise, or profit from NDIS-funded supports, including relevant brokerage, platform, labour-intermediary, and subcontracting models.
- Adopt a graduated integrity model built on light-touch enrolment and risk-proportionate regulation: The Scheme should use broad enrolment for market visibility, while reserving stronger registration and compliance requirements for higher-risk provider cohorts rather than applying a blanket model to all providers.
- Target full registration and independent audit to genuinely higher-risk settings: Full registration and audit should be applied where risk is elevated, such as high participant dependency, unsupervised or intimate supports, complex support environments, or delivery models where accountability is diffused, and should not be imposed universally where the safeguarding benefit is not proportionate to the cost burden.
- Recognise existing external professional regulation as an integrity asset: Where providers are already governed through AHPRA or a credible independent self-regulating professional association with robust entry,
2
credentialing, insurance, CPD, complaints, conduct, and disciplinary mechanisms, the NDIS should leverage that governance and credentialing rather than duplicate it unnecessarily. 5. Establish a clearer workforce architecture with defined role categories and stronger direct-contact safeguards: Integrity reform should more clearly distinguish between professionally governed practitioners, support workers, allied health assistants or support workers under delegation, intermediary roles, and platform-mediated workers, and ensure safeguards attach to the reality of the role being performed, not merely the provider label. 6. Treat participant-facing transparency and support worker governance as core integrity measures: Participants should be able to see, in plain language, what governance and safeguards apply to a provider or worker, and Government should examine whether support workers require a more formal external credentialing and governance structure over time, given their central participant-facing role.
Terms of Reference
The effectiveness and adequacy of successive government policies to improve scheme integrity, safeguard participants, and tackle non-compliance
AARPN’s position is that successive policy measures have been partly effective, but not yet fully adequate. The system is stronger where it has clear lines of accountability, visible provider status, enforceable conduct obligations, and defined regulatory entry points. It is weaker where service delivery is fragmented, where market actors materially shape participant risk without being clearly regulated as providers, or where participants are expected to understand complex differences in service provider governance that are not made sufficiently visible to them.
In AARPN’s view, the present framework still reflects a structural imbalance. Parts of the market are more heavily governed, while other parts remain comparatively lightly specified despite involving direct participant contact, repeated service delivery, or practical control over supports. That imbalance creates avoidable integrity risk. It also places too much responsibility on participants and families to work out who is accountable, what safeguards apply, and whether the person or entity delivering a support is operating within a credible professional governance framework.
AARPN considers that one of the central weaknesses in the present system is that provider architecture, workforce architecture, and participant safeguards are still treated too separately. In practice, these issues are interdependent. Integrity is stronger when the Scheme can clearly answer five questions: who is providing the support, what category of role they occupy, what governance applies to them, what safeguards attach to that role, and who is responsible if something goes wrong. Where those questions cannot be answered clearly, integrity is weakened even before any specific misconduct occurs.
AARPN also observes that the current settings do not yet distinguish clearly enough between different forms of service delivery. It matters, for participant safeguarding and market integrity, whether a support is being delivered by a professionally governed practitioner, by a support worker, by an assistant operating under delegation, by a platform-mediated workforce, or through a subcontracting chain. These are not merely administrative distinctions. They affect competence expectations, supervision requirements, complaints handling, incident visibility, and the participant’s ability to understand what kind of support they are receiving from whom.
The present framework is therefore not best characterised as lacking safeguards altogether - rather, it is insufficiently coherent. Some safeguards are broad but shallow, while others are stronger but confined to specific parts of the market. The result is a system that has improved the baseline for integrity but still does not align regulatory intensity closely enough with actual participant risk.
3
AARPN further considers that integrity related policy has tended to focus more heavily on corrective and compliance- oriented responses than on market intelligibility. Participant safeguarding is not achieved only by detecting wrongdoing after the fact - it also depends on whether the Scheme is structured in a way that lets participants understand ‘who-is-who’ in the market, what protections do and do not apply, and where role boundaries sit. A system that is difficult to interpret is itself an integrity problem.
Any legislative or other reforms required to strengthen scheme integrity
AARPN respectfully submits that future reform should be directed toward a clearer and more risk-proportionate integrity model.
First, the Scheme needs a clearer and more functional provider architecture. The concept of a NDIS provider should be framed around entities that materially deliver, arrange, control, match, supervise, or profit from NDIS-funded disability supports. Integrity is weakened when entities that shape participant risk can sit at the edge of the framework without clear accountability, particularly in brokerage, platform, labour-intermediary, or subcontracted delivery models. Future reform should therefore ensure that accountability follows practical control, not only direct service description.
Second, AARPN supports a graduated regulatory model in which visibility across the market is more varied than blanket full registration. A light-touch enrolment layer is, in AARPN’s view, the right foundation for a more coherent system. It would allow the Scheme to know who is operating in the market, while reserving stronger regulatory requirements for higher-risk cohorts. Respectfully, this is preferable to an approach that attempts to subject all providers to the same form of regulation regardless of role, delivery context, or existing level of professional governance.
Third, registration and independent audit should be applied proportionately, not universally. AARPN questions the cost/benefit of model that would treat all providers as presenting the same level or type of risk. Respectfully, we would put forward that full registration and independent audit should be targeted to those service types, delivery settings, and business models that warrant them. This includes circumstances involving high participant dependency, unsupervised or intimate supports, complex support environments, or delivery models in which accountability can be diffused. By contrast, a blanket audit model risks imposing unnecessary cost on lower-risk or already-governed providers without a commensurate safeguarding benefit.
Fourth, future reform should explicitly recognise existing external professional regulation as an integrity asset. Where a provider is already subject to robust professional governance through AHPRA or through a credible independent self-regulating professional association with defined entry standards, credentialing requirements, insurance requirements, continuing professional development, complaints pathways, conduct standards, and disciplinary processes, the NDIS should leverage that governance rather than duplicate it unnecessarily. A lighter-touch enrolment model for such providers would preserve visibility and accountability while avoiding avoidable duplication, cost burden, and provider attrition from the market.
Fifth, the Scheme needs a clearer workforce architecture. AARPN considers that integrity reform should distinguish more clearly between professionally governed practitioners, support workers, allied health assistants or support workers operating under delegation, intermediary or coordination roles, and platform-mediated workers. Without clearer role categories, the system is more vulnerable to blurred scopes, role substitution, weak accountability, and participant misunderstanding about the nature of the support being delivered.
Sixth, future reform should strengthen direct-contact safeguards in parts of the market that are currently governed more lightly. AARPN’s position is that participant risk is shaped not only by provider status, but also by the practical nature of worker contact, the level of supervision, and the vulnerability of the participant cohort. Reform should therefore focus on whether safeguards attach to the reality of the role being performed, rather than relying too heavily on formal provider classification alone.
4
Seventh, participant-facing transparency should be treated as a core integrity measure. Participants should be able to understand, in plain language, whether a provider is enrolled, registered, professionally governed, worker-screened, operating through subcontractors, or subject to specific incident and complaints obligations. Integrity is weakened where participants are left to infer these matters for themselves.
Finally, AARPN submits that Government should examine whether support worker governance requires a more formal external structure over time. AARPN sees merit in exploring an independent credentialing and governance model for support workers, such as the creation of a peak body association for NDIS support workers to self-regulate that workforce. AARPN’s point regarding support workers, is that long-term integrity is unlikely to be fully achieved if large participant-facing workforces remain governed only at a minimal baseline level.
AARPN’s overall observation is that the next phase of integrity reform should be built on clarity, proportionality, visibility, and accountability. The key issue is not whether the Scheme should regulate more, in the abstract – it is whether it regulates the right actors, in the right way, at the right intensity. A stronger system would make more of the market visible through enrolment, target stronger regulation to areas of genuine risk, recognise credible external professional governance where it already exists, and make role boundaries and provider status much clearer to participants. In AARPN’s view, that is the direction in which integrity reform should now move. The objective should be a system that is not only better at responding to non-compliance, but better at preventing confusion, diffused accountability, and avoidable safeguarding failures in the first place.
redacted
Natasha Radcliffe, AARPN Chair & CEO CPN (AARPN) 23/04/2026
5