23 April 2026
Dr Jane Thomson Committee Secretary Joint Standing Committee on the National Disability Insurance Scheme PO Box 6100 Parliament House Canberra ACT 2600
By email: NDIS.joint@aph.gov.au
Dear Dr Thomson
RE: Inquiry into the Integrity of the National Disability Insurance Scheme
Thank you for correspondence of 26 March 2026 inviting Aruma’s submission to the Inquiry into the Integrity of the National Disability Insurance Scheme (the Inquiry).
Responding to your invitation:
- Aruma’s submission is enclosed as Annexure 1;
- Aruma consents to the publication by the Committee of our submission; and
- I am available to appear before the Committee if required, and extend an additional invitation for Committee members to meet informally with the National Disability Insurance Agency (‘NDIA’) participant members of Aruma’s Human Rights Advisory Committee about their ‘lived experience’ views on the Inquiry.
Aruma’s Position in brief
In mature human service systems, integrity comes from governance that prevents harm, not just enforcement that follows it. Australia’s hospitals, health professions and aged care regulators have structured continuous practice improvement roles with service providers they regulate that can be replicated within the NDIS.
Summary of Aruma’s position
Aruma supports efforts to strengthen the integrity of the NDIS and safeguard participants, provided reform is grounded in proportionality and system maturity. Integrity is not secured by enforcement alone. In complex human services systems, participant safety is most effectively protected when regulatory expectations focus
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on whether providers have the governance, capability and workforce systems needed to prevent harm before it occurs. Integrity measures should therefore be applied in stages, within a graduated framework that distinguishes between remediable system failures and conduct that is reckless, exploitative or persistent.
For integrity reforms to succeed, stronger regulatory expectations must be aligned with the practical realities of service delivery. This includes participant plan adequacy, sustainable pricing, and intentional workforce skills uplift. This is particularly so for not‑for‑profit providers delivering complex and high‑risk supports. Expecting mature‑market governance and compliance standards without addressing resourcing and workforce constraints risks destabilising safe services and reducing capacity where participants need it most. Aruma’s position is that the NDIS will be most durable, safe and trusted when integrity settings promote learning, early risk identification and accountability, alongside firm action where serious misconduct occurs.
Thank you for inviting Aruma to make a submission on the Inquiry. Aruma looks forward to assisting the Committee’s deliberations.
Yours sincerely
redacted
Dr Martin Laverty Chief Executive
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Annexure 1 — Submission to the Joint Standing Committee on the National Disability Insurance Scheme
Inquiry into the Integrity of the NDIS
- Scope and basis of this submission
Aruma welcomes the opportunity to make a submission to the Joint Standing Committee’s inquiry into the integrity of the National Disability Insurance Scheme (NDIS).
This submission is confined to Terms of Reference 3 and 4:
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The effectiveness and adequacy of successive government policies to improve Scheme integrity, safeguard participants, and tackle non- compliance; and
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Any legislative or other reforms required to strengthen Scheme integrity.
This submission draws on Aruma’s experience delivering complex, regulated supports at scale, and addresses Scheme integrity from the perspective of regulatory design, risk management and system maturity.
- Integrity as a function of system design (TOR 3)
From Aruma’s experience, integrity in complex human services schemes is primarily a function of system design, capability, and regulatory maturity rather than enforcement activity alone.
In mature regulatory environments such as public hospitals and aged care, regulators protect the public by embedding strong clinical and organisational governance, including clear accountability structures, incident management and open disclosure, workforce supervision, and continuous quality improvement. These mechanisms operate as preventative integrity controls.
Where integrity frameworks rely predominantly on retrospective enforcement within an immature or under-resourced market, they risk discouraging early disclosure, incentivising defensive practice, and reducing provider capacity in complex or thin markets. Each of these outcomes can undermine participant safety.
From a risk and governance perspective, early identification of issues, transparent reporting and timely remediation are more effective integrity mechanisms than penalties applied after harm has occurred.
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The findings of the Royal Commission into Aged Care Quality and Safety reinforce this perspective. The Royal Commission concluded that serious integrity failures arose primarily from weaknesses in governance, workforce capacity and system design - not from an absence of enforcement powers. In the aged care system, repeated compliance activity co‑existed with sustained harm, while integrity settings that imposed obligations disconnected from pricing, workforce availability and service realities discouraged early disclosure and delayed corrective action.
The Royal Commission highlighted that durable integrity in complex human services depends on preventative regulation, governance capability and early intervention, with enforcement appropriately targeted to cases of deliberate, reckless or exploitative conduct. Similar risks arise in the NDIS if integrity measures are not calibrated to system capacity, particularly in complex and thin markets.
- Embedding a “Just Care” approach to Scheme integrity
Aruma supports a “Just Care” approach to NDIS integrity, adapted from well- established “Just Culture” models applied in healthcare and other high-risk service systems.
The underlying principle is that harm most commonly arises from system weaknesses rather than malicious intent, and that regulatory settings should encourage early disclosure and correction of risk while reserving punitive responses for serious, reckless or exploitative conduct.
A Just Care approach does not dilute accountability. Instead, it enables regulators to distinguish between remediable system deficiencies and misconduct, to intervene earlier, and to promote learning and continuous improvement while maintaining firm consequences where warranted.
Just Care is embedded in the regulation and practices of Australia’s health care system. To illustrate, health care is overseen by three main regulators:
- Health practitioners are registered with, regulated by, and held accountable to the Australian Health Practitioner Regulation Agency (AHPRA).
- Health service quality and safety is overseen by the Australian Commission on Safety and Quality in Health Care (ACSQHC).
- Each state and territory operates a Health Care Complaints Commission or Health Care Ombudsman, reflecting that most public hospital services are state and territory responsibilities.
Complaints commissions and ombudsmen operate at strict arm’s length from clinicians and service providers. AHPRA and the ACSQHC, however, also work
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through structured partnerships with consumers, clinicians and service providers. For example:
- AHPRA operates National Boards for each regulated health profession, which set and enforce professional standards.
- The ACSQHC maintains the National Safety and Quality Health Service (NSQHS) Standards through structured and ongoing engagement with consumers, clinicians and providers.
This structured engagement builds shared ownership and accountability for quality standards across the provider sector, and supports the legitimacy of complaints commissions and ombudsmen when they enforce expectations.
There is an opportunity for the NDIS to draw on these models, by strengthening worker registration arrangements (drawing on AHPRA) and accelerating provider quality uplift through a standards-and-improvement approach similar to the NSQHS framework maintained by the ACSQHC.
- Recommendations to strengthen Scheme integrity (TOR 4)
Aruma recommends that the Committee consider whether Scheme integrity would be strengthened by the following directions:
4.1 Embedding clinical and organisational governance as core integrity safeguards, recognising governance maturity as a primary mechanism for preventing harm.
4.2 Applying proportionate, graduated regulatory responses that clearly distinguish between remediable system deficiencies addressed in good faith and conduct involving serious, reckless or exploitative behaviour.
4.3 Incentivising early disclosure and verified remediation, ensuring that regulatory practice does not unintentionally discourage providers from identifying and reporting emerging risks.
4.4 Aligning integrity expectations with system capacity, including pricing, workforce availability and participant plan adequacy, so that compliance obligations are realistically achievable.
4.5 Targeting enforcement responses to the locus of risk, rather than defaulting to organisation-wide sanctions where non-compliance is localised.
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- Conclusion
Scheme integrity will be most durable where regulatory settings promote system maturity, early risk management and learning, alongside firm action in cases of serious misconduct.
In Aruma’s view, embedding governance capability, proportionality and preventative regulation within integrity settings offers a sound pathway to improving participant safety while preserving the service capacity on which the NDIS depends.
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