Joint Standing Committee on the

National Disability Insurance Scheme:

April 2026

About Allied Health Professions Australia and the allied health sector

Allied Health Professions Australia (AHPA) is the recognised national peak association for Australia’s allied health professions. AHPA’s membership consists of 30 full member organisations, each representing a particular allied health profession. AHPA collectively represents over 195,000 allied health professionals and AHPA works on behalf of the Australian allied health sector.

AHPA’s Disability Working Group (the Working Group) comprises policy and clinician representatives drawn from the range of AHPA’s members that provide services to people with disability including through the National Disability Insurance Scheme (NDIS). The Working Group is therefore informed by the views and experiences of both individual allied health professions and the broader allied health sector.

AHPA and its member associations are committed to ensuring that all Australians can access safe, evidence-based services to assist them to realise their potential for physical, social, emotional and intellectual development.

Initial remarks

AHPA thanks the Joint Standing Committee on the National Disability Insurance Scheme (NDIS) for the opportunity to provide feedback in support of its inquiry into the integrity of the Scheme, the effectiveness of current compliance initiatives, and opportunities for broader reforms. AHPA notes that many of our member organisations have provided detailed responses to this inquiry, including profession specific details and examples.

In responding to this inquiry, AHPA notes our concern about the portrayal of therapy supports by some stakeholders and media and what appears to be a perception among some Parliamentarians that there are issues in how therapy support providers operate that require significant intervention. It is our view that this is not the case and that there is significant disparity between dialogue about issues of integrity relating to therapy supports and the volume of actual issues that have been identified. Public figures, including those in government, have made unsubstantiated claims about overservicing or overcharging without evidence that service volumes are inappropriate for the individual needs of the participant or an understanding of how allied health service delivery costs may differ across funding Schemes. Many of the significant areas of concern, such as the costs associated with reporting and assessment, relate more to NDIS processes than necessarily inappropriate work by individual providers.

We are aware of very few findings made against therapy providers, particularly where those therapy providers are registered or certified allied health professionals rather than those fraudulently purporting to offer those services. Registered in this context refers to allied health professionals that fall within the National Registration and Accreditation Scheme (NRAS), while certified refers to participation in the self-regulation programs run by allied health profession peak bodies where the level of risk presented by the profession is often too low to warrant inclusion in the NRAS. Public dialogue about therapy supports also fails to align with the experience of

participants in the scheme who regularly continue to highlight the importance of capacity building and maintenance focused therapy supports.

At the same time, there continue to be too many examples of providers delivering services without the allied health professional workforce required to deliver those. We note by way of example that the review of art and music therapy found that the NDIS was paying a much larger number of providers to deliver music therapy services than met the definition of a qualified and accredited music therapist.i While we understand the NDIA is undertaking work to address this issue, it is not clear whether there are still claims being made by those without the requisite qualifications.

We also note that registration with the NDIS (referred to in this document as NDIS registration to contrast with registration under the NRAS) does not currently appear to address this issue. The continued sale of so-called ‘cleanskin’ NDIS-registered businesses to purchasers that have not undertaken registration, and the limited requirements associated with the workforce delivering services as part of NDIS registration both undermine this as a means of limiting delivery of therapy services by practitioners who do not meet NDIS requirements.

Despite our view that there are no substantial integrity issues impacting the work of the majority of the therapy supports provider market, AHPA notes that we strongly support the importance of robust mechanisms to identify and deal with providers that defraud the system and create risks for participants. AHPA and our member associations welcome opportunities to work with government to strengthen safeguards and acknowledge the importance of penalties to maintain the integrity of the scheme. AHPA has undertaken significant work with government in relation to regulation, particularly through the NRAS Complexity Review, with a focus not only on Ahpra- registered professions, but also on the role of self-regulation, the National Code of Conduct, health complaints entities (HCEs) and how best to realise opportunities to strengthen regulatory coordination as a means of safeguarding all users of health services.

AHPA further notes our concern that governments and the National Disability Insurance Agency (NDIA) have yet to meaningfully engage with the allied health sector to support quality improvement. AHPA members have offered on numerous occasions to work with the NDIA to understand the key areas of non-compliance or concern (where these don’t meet the threshold of fraud or serious non-compliance), so that these issues can in turn be addressed through professional education lead by allied health peak bodies. The sector has also called for dedicated work to identify and communicate high quality practice. The engagement of the sector in the development of the Best Practice Framework for Early Childhood Intervention provides clear evidence of the level of interest in supporting quality practice. Closer collaboration between the NDIA teams that identify issues related to practice, and the peak bodies that can drive quality improvements and professional education must be prioritised.

The NDIS created enormous workforce demand, some of which has been met by early career professionals. The Scheme has also been subject to constant change, leaving providers with significant administrative burdens that can impact their ability to focus on quality improvement. Rather than punishing participants and the vast majority of providers that are seeking to work effectively in support of people with disability by cutting back services or arbitrarily limiting

access, a focus on more effectively stewarding and promoting high quality practice with the sector should be seen as a crucial opportunity to improve the efficacy of the NDIS.

Responses to the Terms of Reference

1. The nature and extent of non-compliance, including fraud and sharp practices, in the National Disability Insurance Scheme

AHPA notes our view and understanding that serious non-compliance and fraud is not a substantial issue where therapy support providers are registered or certified allied health professionals. It is our understanding that the protections in place under the Health Practitioner Regulation National Law (the National Law) and through the National Code of Conduct, supported by the work of self-regulating allied health professions, provide sufficient safeguards for consumers. We also recognise and support the strengthened measures the Australian government and NDIA have put in place to better define evidence-based therapy supports, appropriate providers of those supports, and some work to identify good practice in early childhood. This, when combined with the work of dedicated teams focused on identifying fraud where it is occurring, should be sufficient to address issues relating to serious non-compliance.

However, AHPA also recognises that a view persists among some commentators and stakeholders that therapy providers are providing higher volumes of service to participants than needed, or charging higher rates to an NDIS participant than may be charged to a different client or a person who does not yet receive NDIS funding, and that this represents ‘sharp practice’. Typically, commentators reference a volume of services with no reference to the individual needs of the participant, or that different types of therapy supports may have a different focus and associated volume of services.

For example, AHPA notes that therapy supports may include both capacity building supports aimed at supporting functional or developmental gains, and therapy supports focused on maintaining function. While the first is more likely to be delivered as a program of supports over a defined period with key outcome goals, the latter may be a support that is needed at various levels of intensity over very long periods of time. For example, some types of physical disability can cause significant deterioration in function over relatively short periods of time due to muscle tightness, cramping and pain that arises directly from the participant’s disability. Maintenance focused therapy interventions are needed to address those issues and allow the participant to retain function. In the absence of that intervention, the participant may no longer be able to participate in education, employment and daily living activities.

The volume of supports a participant needs to achieve functional outcomes can also be heavily impacted by the capacity of formal and informal supports. For example, where the participant independently or in conjunction with a family member, caregiver, or disability support worker has the capacity to engage in capacity building activities outside of formal sessions with a therapy provider, fewer interventions may be needed.

However, where this is not the case, more formal therapy supports may be needed to achieve outcomes. A therapy provider may also work on multiple outcome areas over a period of time, particularly where these may build towards a more substantial overall goal outcome.

AHPA notes that there are opportunities to better translate best practice guidance about the appropriate volume of supports to provide to participants that could address inadvertent overservicing because of a lack of alignment with contemporary practice. This is something that should be addressed through the development of guidance in conjunction with peak bodies and investment in education and resources for professionals rather than as a compliance issue.

NDIS hourly rates for therapy supports, and perceived differences in rates charged by providers to clients based on whether they are NDIS participants, have been the focus of some discussion. Some commentators and government representatives have expressed views that differences in rates reflect sharp practices and taking advantage of NDIS participants. AHPA strongly disagrees and suggests instead that there is a lack of understanding of allied health practice, the complex mix of funding sources many users of allied health services rely on, and the significant gaps that exist in relation to funding of allied health services that can lead providers to effectively have to work at lower rates than what would be sustainable for a bulk of services. Furthermore, there are significant differences in the costs of delivering services under various schemes, such as differences in administration requirements and processes.

If we take as an example the funding of pain-focused services to a person in NSW with a neurodevelopmental disorder, across a mix of funding sources, those differences quickly become clear. Maintenance focused therapy services that address pain and related issues may be funded by the NDIS and would allow the provider to charge up to the current cap of $183.99/$193.99 (depending on profession.) However, the participant may also have to rely on the Medicare Chronic Conditions program, as the NDIS often does not sufficiently fund chronic pain and muscular issues with functional impacts as a result of their disability. The Medicare Chronic Conditions program rebate is based on five annual 20-minute services capped at $61.80. Many providers still choose to support participants despite the rebate and session duration. Finally, a provider may deliver a service to someone with similar (complex) support needs but eligible for funding under the NSW SIRA worker’s compensation scheme rather than the NDIS. Within this scheme the provider would be eligible for a rebate of $19.60 per five minutes capped at one hour per service. We note that in addition to differences in the hourly rates of each of these schemes, each also has varying levels of administration and reporting required and potential differences in the funding of those.

Based on extensive discussions within the sector, it is our view that current NDIS price caps are lower than, or in some circumstances broadly align with private fee levels or those paid in other Schemes where rebates are not fundamentally flawed (as is the case with the Medicare Chronic Conditions program). Fee variation is common due to differences in how fees are set across funding Schemes and the fact that many allied health providers choose to maximise access to services rather than simply charging a flat rate. Each funding Scheme also has varying levels of administration associated with delivering services. Many providers report that delivering services

under the NDIS come with higher levels of administration and cost. This is further perpetuated for NDIS registered providers. Our submissions to the NDIA as part of annual pricing review consultationsii has highlighted substantial issues with existing NDIA price limits and called for price limits that reflect the true cost of quality NDIS therapy service delivery. Given this, we do not agree that there is a significant issue of overcharging NDIS participants in the scheme or that allied health providers in general are using sharp practices in relation to their fees.

2. The impacts of non-compliance on NDIS participants and their families

AHPA recognises the enormous potential impact of non-compliance on NDIS participants and their families. We expect that participants and disability advocates will provide more specific examples to the Committee, however we note that while it is often the most serious examples of fraud or non-compliance that receive focus, poor quality supports provided by inadequately trained workforces or by workforces that do not have formal allied health qualifications (but purport to do so and charge as therapy providers) can also result in missed opportunities for successful intervention leading to poorer long term outcomes and add inefficiency and waste to the system.

Serious issues of fraud and non-compliance, particularly where these impact the safety of participants and their families, must be the biggest priority for governments. However, we argue strongly that new work announced by the Minister to focus on enrolment of providers and additional payment controlsiii provide an important means of increasing the integrity of NDIS systems and ensuring that only qualified practitioners are delivering therapy supports.

3. The effectiveness and adequacy of successive government policies to improve Scheme integrity, safeguard participants, and tackle non-compliance

The establishment of the NDIS Quality and Safeguards Commission, and the introduction of associated changes to NDIS registration, was intended to create important safeguards for participants. It was also intended to create proportionate requirements for providers, in recognition of the difference between (for example) the risks associated with a gardening service that may involve no participant interaction, the delivery of personal supports such as showering and toileting supports by a disability support workforce with varying levels of training and no overarching registration or regulation scheme, and allied health professionals with robust existing regulatory requirements under the National Law, the National Code of Conduct, and the requirements of their certifying body.

That attempt can only be seen as a failure. The very high proportion of unregistered therapy providers reflects both participant comfort with therapy providers being unregistered, and the high costs and administrative burden associated with current registration requirements,

particularly the prohibitive cost of third-party audits for many allied health providers. Plans to reform NDIS registration provide an opportunity to build a new genuinely risk proportionate regulatory model that recognises the robust pre-existing regulation of allied health professionals and does not impose unnecessary additional registration requirements and costs with no evidence of improving safety or quality. The NDIS Provider and Worker Registration Taskforce acknowledged the need for future registration to recognise pre-existing regulatory requirements for allied health professionals.iv

Unlike most other NDIS workforces, allied health professionals are university qualified and operate within established regulatory infrastructures. Most professionals are either registered through Ahpra or participate in credentialing programs through their peak professional association for self-regulating professions and subject to the National Code of Conduct. This in turn provides mechanisms for investigating and dealing with complaints about inappropriate conduct, requiring providers to address quality issues, and providing the legislative basis for prohibition orders where serious misconduct is found. The clinical and practice standards that apply to both registered and self-regulating allied health professions are designed as a mechanism to protect consumers.

While new reforms provide an opportunity for improvement, current proposals define risk only by the type of service or support and associate registration requirements with that risk categorisation. This risks retaining the failures of the current NDIS registration approach which is not genuinely proportionate. While we acknowledge that allied health services have different risk profiles based on the sorts of services delivered, AHPA argues that risk is not only determined by the type of support but also by the qualifications, skills and regulatory oversight of the workforce delivering the support. While some types of supports or services represent a higher risk profile if delivered by unregulated workforces, allied health regulation requirements address these risks. A truly risk-proportionate regulatory model needs to consider the approach to registration based on the characteristics of the workforce’s delivering supports. The level of regulation that already applies to the allied health workforce, and the mechanisms for addressing quality and safety issues, are highly effective, positioning supports delivered by allied health professionals as low risk. As such, allied health provider registration should be limited to light touch requirements across all support/service types. Future registration models must also address the challenge of registration costs, particularly of third-party audits, which acts as a considerable barrier to registration at present. This is particularly so for allied health businesses that deliver only a small number of NDIS services.

AHPA also notes that ongoing issues arising from differences in the training, skills, and interpretation of expert reports by the delegate workforce have led to enormous plan variation, with potentially significant impact on scheme integrity. Poor planning processes may result in overcommitment of funds but have also too often led to underfunding of important supports creating risks to the health and safety of participants. Work by the Australian government and NDIA to introduce new framework planning presents an opportunity to address some of these issues around consistency but could equally add new risks if the assessment process fails to sufficiently account for participant needs. Ensuring that there is ongoing consideration of allied

health and other expert reports, ensuring that the skills and training of the assessor workforce align with the needs of participants, particularly where a participant may have psychosocial, intellectual or other types of disability that may impact the assessment process, and the ability for assessors to override algorithmic decisions will be critical.

4. Any legislative or other reforms required to strengthen Scheme integrity

AHPA has welcomed recent changes to ensure that only registered or certified allied health professionals can deliver therapy supports. Further reforms associated with enrolment and payment system changes could help support the NDIA to monitor the integrity of those payment claims and ensuring that only allied health professionals with the appropriate regulation deliver therapy supports. NDIS registration changes more broadly would further support that and be a positive change if they are truly proportional. That will mean creating minimal administrative and regulatory burdens for allied health providers who are already subject to robust regulation, and ensure that large scale changes in registration requirements don’t create demand for expensive registration support and third-party audit services that act as a financial barrier for smaller and regional allied health services with smaller volumes of NDIS participants.

The most significant reform AHPA would like to see is a commitment to working much more closely with allied health peak bodies to monitor and guide the large-scale reforms that are currently being undertaken, particularly in relation to pricing, registration, and assessment. That closer collaboration should also include an explicit focus on improving the quality and standards across the therapy sector by working collaboratively to deliver education and resources for providers. Quality improvement shouldn’t be seen as addressing a deficiency in the workforce delivering services, particularly the large number of highly experienced professionals that have worked to support people with disability for many decades. Instead, it should be seen as a crucial component of an evolving and world first system that should at all times strive to be an international leader in what people with disability can achieve. The NDIA, in conjunction with allied heath peaks and providers should continually work to identify and share knowledge about best practice, about innovative approaches, and to build the knowledge and evidence base for capacity building supports.

AHPA notes that any existing and future reforms to strengthen scheme integrity must be balanced with the need to maintain service viability. In our response to the NDIS Amendment (Safeguarding and Integrity) Billv, we highlighted the importance of truly proportionate, risk-based measures to improve safeguarding and integrity. We must maintain service viability to protect the accessibility and availability of services for participants. Excessive compliance burden, can reduce provider participation with the scheme, ultimately reducing the available service for participants. With the volume of NDIS services likely to fall as a result of significant upcoming proposed reform for the NDIS, including reductions in NDIS participant numbers, shrinking budgets, and redirection to mainstream supports, the challenge to maintain viability as a provider is likely to grow. This in turn is likely to substantially increase risks in relation to thin markets and participants access to supports.

Concluding remarks

The allied health sector is committed to supporting a strong, effective, and sustainable NDIS. Managing fraud and non-compliance is a key means of ensuring the integrity of the scheme. However, a focus on improving overall quality and efficiency across the scheme must be equally important. In a still developing scheme, with major reforms to key elements such as assessment and planning, pricing, and eligibility currently being implemented, working constructively and collaboratively with providers and the peak bodies that represent them should be a key priority. That is best achieved by establishing more formal engagement structures with the sector, including through the establishment of a therapy supports national reference group.

AHPA welcomes the opportunity to work with government and the NDIA to ensure that people with disability have access to the quality supports they need to thrive.

i Duckett, S. Independent Review of the place of Art and Music Therapy within Australia’s National Disability Insurance Scheme. 2025. Available from: https://dataresearch.ndis.gov.au/research-and- evaluation/decision-making-access-and-planning/independent-review-art-and-music-supports

ii Allied Health Professions Australia. Submission: AHPA Response to 2025-26 NDIS Annual Pricing Review. 2026. Available from: https://www.ahpa.com.au/news-updates/submission-ahpa-response-to-2025-26-ndis-annual-pricing- review

iii Department of Health, Disability and Ageing. Securing the NDIS for future generations. 2026. Available from: https://www.health.gov.au/our-work/ndis-legislation-changes/amendments/securing-the-ndis-for- future-generations

iv Wade N, Borowick M, O’Halloran V, Fels A. NDIS Provider and Worker Registration Taskforce Advice. 2024. Available from: https://www.health.gov.au/resources/publications/ndis-provider-and-workerregistration- taskforce-advice?language=en

v Allied Health Professions Australia. Submission: NDIS Amendment (Integrity and Safeguarding) Bill 2025. 2026. Available from: https://www.ahpa.com.au/news-updates/submission-ndis-amendment-integrity- and-safeguarding-bill-2025