Inquiry into the
Administration of the
National Disability
Insurance Scheme
Submission by
THE ASSOCIATION OF PROFESSIONALS AUSTRALIA
APRIL 2026
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Executive Summary
Professionals Australia represents allied health professionals and related practitioners across Australia, including Occupational Therapists, Speech Pathologists, Physiotherapists, Psychologists, Social Workers, Exercise Physiologists, Dietitians, Behaviour Support Practitioners, Music and Creative Therapists, Equine Therapists, Disability Support Coordinators, and Interpreters, including AUSLAN Interpreters.
These professionals deliver therapeutic, behavioural, developmental, psychosocial, and capacity building supports funded through the NDIS. Often to participants with complex needs, communication barriers, trauma histories, or limited access to mainstream services (National Disability Insurance Agency, 2023; Australian Institute of Health and Welfare, 2022).
Our members work predominantly as sole traders, small and medium practice owners, not-for-profit providers, and clinicians embedded within community-based services. They interact daily with NDIA planners, payment systems, compliance mechanisms, and safeguarding frameworks, and experience firsthand the practical consequences of administrative and regulatory decisions made under the Scheme.
Across these disciplines, there is a shared and growing concern that the NDIS has increasingly relied on:
- policy development driven by a narrow set of peak bodies or targeted disability organisations;
- generic assessment tools not validated for funding allocation;
- automated or algorithmic decision‑making processes lacking transparency; and
while failing to meaningfully engage the wider allied health workforce that provides the majority of functional capacity and support‑needs evidence (NDIS Review 2023; ANAO 2023; OTSi 2026).
This has weakened upstream safeguards, increased participant vulnerability, and contributed to inconsistent and unsafe planning decisions. The proposed Support Needs Assessment (SNA) and reliance on the I‑CAN tool risks further entrenching these systemic weaknesses by reducing the role of clinical judgement and replacing individualised assessment with generic scoring systems (HIQA 2024; Reed 2006; OTSi 2026).
A sustainable, safe, and equitable NDIS requires reforms that prioritise clinical evidence, transparency, and meaningful engagement with the multidisciplinary allied health workforce.
This submission advances a central proposition: that integrity failures in the NDIS are predominantly systemic, not individual, and cannot be resolved through compliance expansion alone. Current reform directions risk conflating fraud control with safeguarding, resulting in blunt regulatory responses that may increase participant risk, reduce access, and further destabilise the allied health workforce.
Critically, consultation informing recent integrity reforms appears to have been limited to a narrow subset of peak bodies and/or targeted providers and may not be representative of the breadth of allied health providers, particularly sole traders, small practices, and discipline-specific workforces. This has resulted in policy settings that appear operationally disconnected from real-world service delivery and safeguarding practices.
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Executive Summary
Allied health professionals are central to the NDIS’s design and operation. The Scheme relies on allied health evidence to:
- determine eligibility,
- assess functional capacity,
- identify disability‑related support needs,
- detect foreseeable risks,
- inform reasonable and necessary decision‑making, and
- support participants to build capacity and live safely (WFOT 2022; WHO 2001).
Despite this reliance, the NDIA has historically:
- failed to engage widely with allied health professions in policy development,
- relied on a narrow set of peak bodies or targeted disability organisations to shape reforms,
- implemented administrative tools that do not reflect clinical practice,
- overlooked the expertise of the broader allied health workforce, and
- introduced reforms without adequate consultation, targeted piloting mechanisms, or evaluation (NDIS Review 2023; OTSi 2026).
Response to Terms of Reference
(a) Nature and extent of non‑compliance, including fraud and sharp practices
Allied health professionals consistently observe that non‑compliance is more often enabled by systemic weaknesses in planning, assessment, and oversight (ANAO 2023; OTSi 2026).
- Plans that do not reflect functional capacity create structural vulnerabilities
When planners fail to incorporate allied health evidence particularly regarding cognitive impairment, executive functioning, communication needs, or decision‑making capacity participants may be allocated funding they cannot safely manage. This creates opportunities for:
- predatory providers
- coercive service arrangements
- financial exploitation
- inappropriate service use
- unmanaged risk
(NDIS Review 2023; OTSi 2026).
- Generic tools and automated systems create loopholes
Tools such as WHODAS‑2 and I‑CAN were not designed to holistically determine funding levels (HIQA 2024; Reed 2006).
- Lack of upstream safeguards increases downstream compliance burden
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OTSi (2026) emphasises that upstream safeguards particularly allied health evidence is under-utilised, enabling the Scheme to rely on less effective downstream compliance mechanisms.
- Blanket provider registration will not equal safeguarding
Blanket registration of providers, while often presented as a safeguard, does not in itself constitute an effective or meaningful protective mechanism within the NDIS.
Strengthening Scheme integrity therefore requires investment in upstream safeguards such as accurate functional assessment, risk identification, and evidence‑based planning rather than relying on registration as a proxy for safety. Registration may be necessary, but it is not sufficient. Genuine safeguarding depends on the quality of decision‑making and the integration of multidisciplinary allied health evidence into all stages of the assessment and planning process.
(b) Impacts of non‑compliance on participants and families
- Increased exposure to harm
Participants with cognitive impairment, psychosocial disability, or communication barriers are particularly vulnerable when allied health evidence is ignored. This can lead to:
- unsafe living arrangements,
- unmanaged health risks,
- financial exploitation,
- deterioration in mental and physical health (NDIS Review 2023; OTSi 2026).
- Distorted funding and unmet needs
Under‑funding leads to unmet needs, carer burnout, and increased reliance on crisis services.
Over‑funding leads to predatory provider behaviour and rapid budget depletion and withdrawal of therapeutic supports (ANAO 2023).
- Administrative trauma
Participants and families experience significant stress navigating reviews, appeals, and inconsistent decisions (NDIS Joint Standing Committee 2025; OTSi 2026).
Effectiveness and adequacy of successive Government policies
- Over‑focus on downstream compliance
Government integrity measures have prioritised fraud detection and provider regulation, while neglecting the quality of planning and assessment (Every Australian Counts 2024).
- Insufficient investment in evidence‑based planning
The NDIS Review (2023) identified that poor assessment of functional capacity is a major driver of participant harm and Scheme cost escalation.
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OTSi (2026) similarly argues that reforms have “not sufficiently recognised or operationalised preventative safeguarding.”
- Failure to engage the broader allied health workforce
Policy development has relied heavily on peak bodies and targeted disability organisations, excluding the clinicians who provide the majority of disability functional evidence (Villamanta 2025; OTSi 2026).
- Policy Instability
The frequent changes to pricing, travel components, eligibility interpretation, and compliance settings:
- Increased inadvertent non-compliance
- Undermined provider confidence
- Reduced workforce retention
- Restricted and/or impacted participant therapeutic supports
- Risks in New Framework Planning
The shift toward impairment‑based funding, algorithmic decision‑making, and generic assessment tools risks undermining the Scheme’s founding principles (Every Australian Counts 2024; OTSi 2026).
Critical Issue: The Support Needs Assessment (SNA) and the I‑CAN Tool
The proposed SNA and reliance on the I‑CAN tool represent a significant departure from the NDIS’s functional, individualised approach.
- The I‑CAN tool does not appear to capture the complexity of disability, particularly for people with:
- psychosocial disability,
- autism,
- neurological conditions,
- chronic illness,
- sensory processing differences,
- fluctuating conditions
(HIQA 2024; OTSi 2026).
- Generic tools cannot replace clinical judgement
Allied health assessments involve nuanced clinical reasoning, functional observation, and risk identification elements which are absent from I‑CAN (WFOT 2022; Reed 2006).
- An over‑reliance on I‑CAN will increase risk
Participants may receive inappropriate supports, insufficient oversight, or misaligned funding (NDIS Review 2023; OTSi 2026).
- Generic tools undermine Scheme integrity
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They produce inconsistent funding, unreliable support packages, and increased appeals (ANAO 2023; OTSi 2026).
Potential for discipline‑specific failures of the I‑CAN Tool
(References: HIQA 2024; Reed 2006; SCIE 2022; OTSi 2026)
- Occupational Therapy: fails to capture executive functioning, environmental barriers, and safety risks.
- Psychology: fails to assess emotional regulation, trauma, and decision‑making capacity.
- Speech Pathology: fails to capture AAC needs, social communication deficits, and communication‑related safety risks.
- Physiotherapy: overlooks falls risk, mobility fluctuations, and fatigue patterns.
- Social Work: does not assess safeguarding risks, informal support breakdown, or housing instability.
- Exercise Physiology: does not assess endurance limitations or fatigue‑related functional decline.
Legislative and other reforms required to strengthen scheme integrity
- Legislate a Whole‑of‑Person Functional Approach
Legislation must require that functional impact not diagnosis is the primary basis for funding (WHO 2001; NDIS Review 2023; OTSi 2026).
This includes:
- recognition of fluctuating disability,
- environmental context,
- cognitive and communication needs,
- clinical evidence as the foundation of decision‑making.
- Regulate Algorithmic and Automated Decision‑Making
Legislation must require:
- transparency of algorithms,
- independent auditing,
- mandatory human oversight,
- participant rights to explanation and challenge,
- prohibition on using automated tools as the primary determinant of funding
(Every Australian Counts 2024; OTSi 2026).
- Fund Independent Advocacy and Strengthen Safeguarding Mechanisms
Independent advocacy is essential for safeguarding participants, particularly those with reduced decision‑making capacity.
Legislation must ensure:
- guaranteed funding for advocacy,
- early access to advocacy not only in crisis,
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- mandatory referral pathways,
- enhanced oversight for participants vulnerable to coercion or financial abuse
(Villamanta 2025; OTSi 2026).
Recommendations
Professionals Australia recommends that the Committee adopt reforms including:
- legislating a whole‑of‑person functional approach;
- mandating integration of allied health evidence;
- prohibiting reliance on I‑CAN or any single tool as the primary determinant of funding;
- regulating algorithmic decision‑making;
- restoring appeal rights;
- requiring NDIA engagement with the full allied health workforce;
- guaranteeing funding for independent advocacy;
- strengthening planner capability;
- implementing upstream safeguarding measures for people with a disability.
Submission summary
Scheme integrity depends on accurate, individualised, evidence‑based planning.
The proposed SNA and reliance on the I‑CAN tool risks undermining this by failing to capture the complexity of disability.
Successive governments have focused on downstream compliance while neglecting upstream safeguards for people with a disability.
Reforms must prioritise clinical evidence, transparency, and meaningful engagement with the multidisciplinary allied health workforce (OTSi 2026).
References
Australian National Audit Office (ANAO) 2023, Effectiveness of the National Disability Insurance Agency’s Management of Assistance with Daily Life Supports, ANAO, Canberra.
Every Australian Counts 2024, When Algorithms Decide: Lessons for the NDIS, Every Australian Counts Coalition, Canberra.
Health Information and Quality Authority (HIQA) 2024, Scoping Review to Inform Standards for Assessment of Need, HIQA, Dublin.
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National Disability Insurance Scheme (NDIS) Review 2023, Working Together to Deliver the NDIS, Department of Social Services, Canberra.
NDIS Joint Standing Committee 2025, Responses to Questions on Notice, Parliament of Australia.
Occupational Therapy Society for Hidden and Invisible Disabilities (OTSi) 2026, Submission to the Joint Standing Committee on the Integrity of the NDIS, OTSi, Australia.
Reed, G. 2006, ‘Operationalizing the International Classification of Functioning, Disability and Health in Clinical Settings’, Journal of Clinical Psychology, vol. 50, no. 2, pp. 122–130.
Social Care Institute for Excellence (SCIE) 2022, Integrated Care: Research and Practice on Multidisciplinary Teams, SCIE, London.
Villamanta Disability Rights Legal Service 2025, Submission to the Joint Standing Committee on the NDIS, Parliament of Australia.
World Federation of Occupational Therapists (WFOT) 2022, Scope of Occupational Therapy Practice, WFOT, Geneva.
World Health Organization (WHO) 2001, International Classification of Functioning, Disability and Health (ICF), WHO, Geneva.
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