24 April 2026
Ms Libby Coker MP Chair Joint Standing Committee on the National Disability Insurance Scheme Inquiry into the Integrity of the National Disability Insurance Scheme Parliament House Canberra ACT 2600
Submitted via email - NDIS.Joint@aph.gov.au
Dear Chair,
Kismet Healthcare Submission to the Joint Standing Committee on the National Disability Insurance Scheme
Inquiry into the Integrity of the National Disability Insurance Scheme
On behalf of Kismet, I am pleased to provide this submission to the Committee.
Launched in February 2023, Kismet is a trusted digital community platform and HealthTech. Kismet is a provider of NDIS plan management services via our portfolio companies.
Kismet’s experience spans:
- Over 150,000 NDIS participants and providers in our ecosystem.
- Processing more than 200,000 NDIS invoices per month.
- Community engagement - Kismet runs over 130 disability engagement events every year, including the Australian Disability Services Awards (ADSA). Details on upcoming events can be found here.
- Data initiatives and sector research, including the Kismet Care Index, our partnership with e61 Institute on NDIS research, our work with Mandala Partners on Care Sector Innovation, and our Care Innovation Symposium at Australian Parliament House.
- Recent media coverage in the Australian Financial Review on NDIS invoicing practices and fraud risk mapping (March 2026).
The NDIS is critical social infrastructure. However, it faces a significant integrity challenge that risks eroding public confidence and undermining the scheme’s long-term sustainability.
Kismet welcomes this inquiry.
Kismet notes that on 22 April 2026, Minister Butler announced significant NDIS reforms at the National Press Club, including the introduction of a commissioning framework for plan managers.
The commissioning model is consistent with what Kismet has advocated for over the past 18 months. This submission offers the Committee detailed recommendations on how the commissioning framework and broader integrity architecture should be designed.
As an at-scale plan manager processing hundreds of thousands of invoices monthly, we have direct visibility into claiming patterns, provider behaviours, and system weaknesses that enable non-compliance. This submission draws on that operational experience to offer the Committee practical recommendations.
SUBMISSION
- The nature and extent of non-compliance, including fraud and sharp practices
Non-compliance exists on a spectrum. From deliberate criminal fraud (fabricated claims, identity theft, organised extraction schemes) to a large volume of “grey zone” claiming that reflects confusion, poor documentation, or exploitation of ambiguous rules rather than deliberate dishonesty.
Kismet’s invoice processing data reveals several persistent patterns of concern:
- Invoice quality and traceability. A material proportion of invoices contain incomplete or vague service descriptions, making it difficult to assess whether a claimed support was reasonable, necessary, and plan aligned. Handwritten or non-standard invoices compound this, as they resist automated validation and create record-keeping gaps.
- Provider verification gaps. Plan managers lack adequate real-time tools to verify provider identity, registration status, or that an invoice’s ABN matches an active, legitimate entity.
- Claims fragmentation and pricing anomalies. Kismet observes patterns where services are fragmented across multiple small claims, potentially to avoid detection thresholds or where pricing sits consistently at the maximum price guide rate regardless of service type, location, or market conditions. This phenomenon was backed up by research Kismet collaborated on with the e61 Institute.
- Disconnect between plan detail and invoice detail. There is a fundamental gap between the detail in a participant’s plan and the detail on an invoice. Invoices typically reference only an item code, obscuring what was delivered. Without visibility into what a plan specifically funds, plan managers cannot determine whether a claimed support aligns with funded goals. This problem is magnified by significant inconsistency in plans themselves: some contain highly specific descriptions and hours, while others contain generic copy-and-paste language bearing little relationship to the individual. The absence of a single, standardised source of truth about what is funded in each plan is a root cause of integrity failure. Put simply: the scheme asks plan managers to verify that claims are consistent with a participant’s plan, but does not give plan managers reliable, complete, or structured access to that plan. Until this foundational gap is closed, no amount of downstream fraud detection or post-payment audit will be sufficient.
- Unintentional misuse driven by poor information. A significant volume of non- compliant claiming is not deliberate but reflects participants acting on incorrect advice. For example, a provider recommending unfunded equipment, or encouraging supports outside plan scope. Participants frequently contact plan managers with genuine confusion about what their plan covers. As a result, plan managers need access to real- time, complete and standardised plans. This “unintentional misuse” results in NDIA rejections or clawbacks, creating participant distress and system-wide administrative cost.
- Participant vulnerability and sharp practices. Some non-compliance targets participants directly, through aggressive sign-up tactics, inducements, or services not in their interest. Kismet observes providers locking participants into lengthy agreements (e.g., 12-month exclusive arrangements with a single allied health provider) that may not represent value for money. Plan managers have visibility into these agreements but lack clear regulatory authority, standards, or escalation pathways to intervene.
- Scale of undetected non-compliance. The Auditor-General’s finding (ANAO Report No. 48, 2024–25) that the NDIA was reviewing only 0.4% of claims by dollar value while detecting high levels of non-compliance in the claims it did examine suggests the true extent of the problem is materially understated.
- The impacts of non-compliance on NDIS participants and their families
We see the following harms in the current system:
- Direct harm. Exploitative providers deliver poor-quality services, expose participants to unsafe practices, or exhaust plan budgets on supports that do not advance goals. Participants with cognitive or psychosocial disabilities are disproportionately vulnerable. Families face anxiety when they cannot verify services are being delivered as claimed.
- Systemic harm. Every dollar lost to fraud is a dollar unavailable for legitimate supports. When integrity failures drive cost growth, the political response is to tighten controls in ways that increase burden on compliant participants and providers.
- Erosion of public confidence. Sustained media coverage of NDIS fraud risks undermining public support for the scheme. The NDIS depends on a social contract that Australians will fund a generous, participant-directed scheme. Integrity failures erode that compact and undermine what should be a national asset.
- The effectiveness of government policies to improve scheme integrity
Kismet acknowledges significant steps taken by the Government, particularly the NDIS Amendment (Integrity and Safeguarding) Act 2026 and the NDIA Fraud Fusion Taskforce. The Minister’s 22 April 2026 announcement of a commissioning framework for plan managers is a further welcome step, signalling the Government’s recognition that plan managers must meet enforceable quality standards if they are to serve as an effective integrity layer within the scheme.
Plan managers are an under-utilised integrity layer As outlined in our January 2026 submission to the Joint Committee of Public Accounts and Audit, plan managers sit at a unique intersection with visibility across participant purchasing, provider invoicing, and financial anomalies. Yet we currently lack:
- Clear regulatory authority to act on integrity concerns.
- Consistent data access to perform meaningful pre-payment validation.
- Standardised escalation pathways for suspected fraud or safeguarding concerns.
- A formal relationship with the NDIS Commission for fraud-related intelligence sharing.
Technology infrastructure is lagging The NDIS payment system does not yet:
- Require standardised digital invoicing.
- Support real-time provider verification at the point of claim.
- Provide adequate API-based data access to intermediaries such as plan managers.
These are basic digital infrastructure requirements that exist in other government payment systems, including through the ATO’s Peppol e-invoicing standards but have not been applied
to the NDIS. This is why Kismet has developed its own Peppol compliant digital invoice that is now live.
Kismet would also encourage the Government to prioritise investment in core back-end digital infrastructure such as APIs, data standards, and interoperability frameworks. While allowing the private market to develop the participant-facing and provider-facing tools that sit on top of that infrastructure. This approach would accelerate innovation while ensuring the Government retains control of the foundational data layer on which scheme integrity depends.
Registration reforms are necessary but incomplete The increased registration requirements from 1 July 2026 are welcome.
However, registration alone does not prevent non-compliance it must be coupled with real time monitoring that leverages data from across the payment chain.
- Legislative or other reforms required to strengthen scheme integrity
Kismet recommends the Committee consider the following reforms:
4.1 Mandate standardised digital invoicing across the NDIS All NDIS claims should be submitted electronically in a standardised format. In research commissioned by Kismet, Mandala Partners estimates the NDIS invoicing automation opportunity at $630 million annually. Standardised digital invoicing enables:
- Pre-payment validation: checking claims against plan budgets, price guides, and provider registration in real time.
- Anomaly detection at scale.
- Improved audit trails and traceability.
- Reduced administrative burden for providers and plan managers alike.
The Government should adopt Peppol or equivalent e-invoicing standards for NDIS claims, consistent with the ATO’s broader digital invoicing agenda.
4.2 Strengthen plan management’s integrity role Plan managers should be formally recognised as an integrity and assurance layer within the NDIS governance architecture. The commissioning framework announced by Minister Butler on 22 April 2026 provides the vehicle for this recognition. Kismet urges the Committee to recommend that the commissioning model include robust quality standards. This should include:
- Clear minimum standards for invoice verification: covering completeness, price reasonableness, plan alignment, provider qualification checks against line items, and elevated scrutiny for reimbursement claims (which carry higher fraud risk).
- Standardised escalation pathways for suspected fraud or safeguarding concerns to the NDIS Commission.
- A formal information-sharing framework between plan managers and the NDIA/Commission.
- At-scale plan managers should have a direct relationship manager at the NDIS Commission for fraud-related intelligence sharing.
4.3 Enable real-time provider verification Plan managers and the NDIA should have real-time tools to verify provider identity, registration status, ABN validity, and compliance history at point of claim. This should include:
- Integration with the Document Verification Service (DVS) and Confirmation of Payee (CoP) infrastructure being developed through the New Payments Platform.
- Verification extending beyond the provider entity to the individual worker delivering the support — particularly for high-risk categories such as community participation, where services are delivered one-on-one over extended periods.
- Invoices for high-risk supports should include a worker identifier, relevant qualifications, and hours worked and location of service delivery.
Worker-level verification creates a secondary compliance layer, enabling cross-referencing with employment and taxation records and making it significantly harder for fraudulent providers to fabricate service delivery.
4.4 Invest in pre-payment assurance, not just post-payment audit The NDIS should shift toward a prevention-oriented integrity model. The NDIA’s payment integrity function has grown substantially, but its primary intervention point remains after claims are submitted. The more effective approach is to prevent non- compliant claims from being submitted at all. This requires:
- Automated pre-payment validation rules, risk-based transaction monitoring, and cross- provider trend analysis by drawing on data held by plan managers and other intermediaries.
- For high-risk categories (reimbursement claims, community participation supports), pre-submission eligibility checks confirming the support is plan-funded, the provider appropriately qualified, and the claim within pricing and volume parameters.
- A real-time “pre-checker” tool for plan managers and participants — confirming whether a proposed support is within scope before a claim is raised. This would dramatically reduce non-compliant claims reaching the payment system and the burden on the NDIA’s payment integrity teams.
4.5 Mandate full plan access and standardise plan documentation This is the most important reform the Committee should recommend.
Plan managers cannot fulfil an integrity role without access to the full detail of plans they manage. Currently, data access is fragmented, and non-PACE plans are often available only as unstructured PDFs. Plan managers are routinely asked to verify claims against plans they have not seen in full.
Kismet recommends the Government legislate to require the NDIA to provide plan managers with full, API-based access to participant plan data including: plan inclusions, funding periods, budget balances, stated goals, and descriptions of funded supports (assistive technology, consumables, capacity-building). The ideal state is a structured API enabling automated compliance checks at point of claim.
Equally important is standardising plan documents themselves. Kismet’s operational experience reveals significant inconsistency in plan quality. Some plans contain detailed descriptions with specified hours and clear goal linkages. Others rely on generic, copy-and- paste language that bears little relationship to the individual participant. In some cases, plans are simply inaccurate. Kismet has observed plans for older adults that include references to
early childhood supports, while others offer no meaningful guidance on what community participation or capacity-building funding is intended to achieve. This inconsistency makes it impossible for plan managers, participants, or providers to reliably determine what is and is not funded.
The Committee should recommend that the NDIA adopt standardised plan templates requiring planners to specify, for each funding category, the types of supports funded, the expected volume or hours, and the participant goals they are intended to address.
Standardised plans would serve as the single source of truth for the scheme, enabling plan managers to verify claims against clear parameters, empowering participants to understand and exercise genuine control over their funding, and providing the data foundation on which all other integrity measures depend. Without this reform, investments in digital invoicing, pre- payment assurance, and provider verification will be limited in their effectiveness, because the plan itself - the document against which all claims should be assessed - remains ambiguous and inaccessible.
4.6 Publish scheme integrity metrics The NDIA should publish regular, disaggregated reporting on:
- Fraud detection rates and recovery outcomes.
- Claims anomaly levels.
- Provider compliance trends.
- Market integrity indicators.
Transparency will build public confidence and allow the sector to benchmark its own performance.
- Conclusion
Kismet supports the Committee’s focus on integrity.
These reforms are not about restricting participant choice. They are about building digital infrastructure and governance settings that allow the scheme to operate with confidence.
Kismet welcomes the opportunity to provide further evidence to the Committee, including:
- Demonstrations of our digital invoicing and provider verification capabilities.
- Aggregated claims data and trend analysis.
- Case studies illustrating practical integrity challenges faced by plan managers.
We would also welcome the opportunity to appear before the Committee at a public hearing.
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Regards, Mark Woodland CEO and Co-founder, Kismet Healthcare