NDIA Accountability Project

Submission 44 — Australian Physiotherapy Association — Integrity of the National Disability Insurance Scheme

‹ PrevPage 1 of 41 · Source p. 1Next ›

Joint Standing Committee on the National

Disability Insurance Scheme

Via email to ndis.joint@aph.gov.au

Submission by the Australian Physiotherapy Association

April 2026

Authorised by:

Rob LoPresti Chief Executive Officer Australian Physiotherapy Association Level 1, 1175 Toorak Rd Camberwell VIC 3124 Phone: redacted Fax: redacted www.australian.physio

Acknowledgement of

Traditional Owners

The APA acknowledges the Traditional Custodians of Country throughout Australia and their

connections to land, sea and community. We pay our respect to their Elders past and present and extend that respect to all Aboriginal and Torres Strait Islander Peoples today.

About the Australian Physiotherapy Association

The Australian Physiotherapy Association’s (APA) vision is that all Australians will have access to quality physiotherapy, when and where required, to optimise health and wellbeing, and that the community recognises the benefit of choosing physiotherapy. The APA is the peak body representing the interests of Australian physiotherapists and their patients. It is a national organisation with state and territory branches and specialty subgroups.

The APA represents more than 35,000 members. The APA corporate structure is one of a company limited by guarantee and is governed by a Board of Directors elected by representatives of all stakeholder groups within the Association. Of the potential nine Directors, seven must be financial members of the APA, and up to two may be external, non-physiotherapist Directors.

We are committed to professional excellence and career success for our members, which translates into better patient outcomes and improved health conditions for all Australians. Through our National Groups we offer advanced training and collegial support from physiotherapists working in similar areas and are committed to embedding cultural safety within the organisation, policy and education programs.

Page | 3

Table of Contents

Executive summary 5

Introduction 6

Terms of Reference 7 TOR 3: The effectiveness and adequacy of successive government policies to improve scheme integrity 7 TOR 4: Any legislative or other reforms required to strengthen scheme integrity 8

References 9

Page | 4

Executive summary

The Australian Physiotherapy Association (APA) welcomes the opportunity to contribute to the Joint Standing Committee inquiry into the Integrity of the National Disability Insurance Scheme.

The APA contends that pricing integrity is not peripheral to scheme integrity; it is a practical determinant of it.

For physiotherapy, the integrity question is not confined to fraud detection after the event. It begins much earlier, in the system settings that govern whether legitimate providers can remain in the market and whether participants can access timely and safe supports.

The scheme’s under-pricing and poorly designed travel settings are not merely commercial concerns. They shape whether physiotherapy can be delivered safely, in the right setting, by the right professional, with enough time for documentation, multidisciplinary coordination, and regulatory compliance.

The National Disability Insurance Agency (NDIA’s) own therapy guidance states that therapy supports must be effective, beneficial, and evidence-based. Those are integrity safeguards. But they depend on a pricing framework that makes compliant practice viable.

When prices are set using methods that systematically understate the true cost of delivering regulated, evidence-based practice, the scheme amplifies integrity risk by creating market fragility, reducing access to reputable providers, and increasing barriers to appropriate supports.

This submission focuses on terms of reference three and four, outlining how pricing integrity is an enabling condition for scheme integrity. Evidence provided by the APA, including an independent review of the NDIA’s 2024-25 Annual Pricing Review by the Nous Group’, demonstrates that the current physiotherapy pricing methodology understates prevailing market costs due to non-like-for-like comparator data, invalid modelling assumptions (including session-duration), and insufficient recognition of NDIS service delivery complexity.

The APA asserts that the committee should treat reforms to pricing methodology and transparency as integrity reforms, alongside enforcement-focused measures and recent legislative reforms.

The APA recommends urgent correction of the physiotherapy price limit; adoption of a transparent bottom-up costing model; funding travel as a standalone plan item; and monitoring metrics focused on both non-compliance risk and participant access.

Introduction

The APA supports strengthening NDIS integrity machinery. However, enforcement-focused integrity policy will overlook a significant risk: fair and transparent pricing with the scheme.

The 2024–25 NDIS Annual Pricing Review (APR) reduced the national physiotherapy limit from $193.99 to $183.99 per hour, removed higher jurisdictional loadings in Western Australia, South Australia, the Northern Territory, and Tasmania, and reduced claimable travel labour to 50 per cent of the applicable therapy rate.

An independent review of the NDIA’s 2024–25 Annual Pricing Review by the Nous Group1 identified a clear misalignment between the NDIA’s physiotherapy price limit and actual market conditions. The assumption of a 45-minute session length, despite a 30-minute market norm, artificially suppresses hourly rates and distorts the NDIA’s understanding of the cost of delivering physiotherapy supports. The 2025–26 price limit of $183.99 per hour sits well below independent market evidence, which places the 75th percentile between $215 and $259 per hour. Private health insurance data shows a 70th percentile equivalent of $236.50 per hour. This gap is significant. It affects provider viability, workforce retention and participant access to essential supports.

That matters for integrity because mispricing can itself produce non-compliance risk. When price limits do not reflect the real cost of compliant delivery, providers must withdraw or curtail services or face pressure to shorten sessions, reduce supervision, cross-subsidise, avoid best practice outreach, or limit work with complex participants.

The travel changes are a particularly clear example undermining scheme integrity and equitable service delivery. The 2024–25 APR’s abrupt reduction in travel reimbursement created significant barriers to service delivery. These changes were introduced with insufficient consultation and minimal notice, forcing physiotherapy providers to adapt quickly to cuts while grappling with rising costs, all after a six-year price freeze followed by a five per cent cut.

This rapid shift placed undue stress on an already strained workforce. Delivering therapy in natural settings, such as participants’ homes or communities, is critical to achieving meaningful outcomes, particularly for those who struggle with mobility or are unable to travel due to their disability or other barriers.

In the Northern Territory, where access to services is already limited, these cuts have had devastating effects. For example, NDIS participants living in Groote Eylandt, which has the highest known prevalence of Machado-Joseph Disease per capita globally, until recently relied on fortnightly outreach visits. Machado- Joseph Disease causes progressive loss of mobility, speech, and independence, and without regular, on- country physiotherapy, these individuals now face worsening health outcomes. The necessary outreach across Groote Eylandt and five Homelands has ceased due to the unsustainable economics of travel under the new pricing structure.

A recent survey of APA members providing NDIS services nationally revealed that close to 50 per cent had reduced or ceased travel outreach services in the past six months because of the new pricing limits. Without urgent action to restore fair travel compensation, these cuts will continue to undermine the accessibility, quality, and equity of services under the NDIS.

There is no evidence that the NDIA is actively monitoring the impact of these changes on access, nor any evidence of meaningful engagement with the sector to gather feedback. The NDIS Annual Pricing Review 2025-26 consultation on pricing explicitly excluded feedback from providers on travel pricing. This lack of consultation and oversight risks further deterioration of service delivery in the communities that need it most.

Pricing is an integrity control. Poor pricing limits can create higher participant risk if it pushes supports out of homes, schools, and community settings where they are most effective even more so where it pushes high-quality evidence-based support providers out of the Scheme.

Page | 6

Terms of Reference

TOR 3: The effectiveness and adequacy of successive government policies to

improve scheme integrity

The NDIS was never designed to be cost neutral. It was built to generate returns, both human and economic. The scheme now supports more than 270,000 workers in more than 20 professions, and modelling from the False Economy report estimates its economic contribution at over $52 billion in 2020–21, with a multiplier effect of 2.25. 2,3

Physiotherapists, as frontline providers, see disconnect between policy intent and participant experience. Policy responses have focused on projected expenditure growth and participant volumes, while ignoring actual cost drivers. The result is a reform agenda shaped by optics rather than evidence.

Scheme uptake beyond initial projections has produced blunt cost-containment measures that restrict access instead of addressing inefficiencies in pricing architecture, planning design and service delivery. To restore integrity, the pricing framework must be structurally reframed.

Travel should be funded as a standalone item. Plans must reflect the true breakdown of provider recommendations. And reform must be grounded in actual expenditure data.

Government has a clear responsibility to ensure that people with disability have access to services that are well governed, safe, and delivered to best-practice standards. High-quality support is a rights-based obligation at the core of the NDIS.

Pricing decisions that prioritise cost containment over clinical integrity risk undermining safety, workforce capability, long-term integrity and sustainability.

The APA supports strengthened prevention and enforcement initiatives. However, for therapy supports (including physiotherapy), core integrity risks are not fully addressed unless pricing methodology and transparency are treated as integrity controls.

Under-pricing and restrictive travel settings reduce access to high quality support, particularly outreach- based supports delivered in homes and community settings. When access collapses, participants are more vulnerable to inducements and other sharp practices. Sustainable, meaningful access to appropriate supports protects against scams and abuse.

Case study – Shelley

  A criminal perpetrating a romance scam spent months grooming Shelley, a 65-year-old
   NDIS participant. The scammer pretended to be a celebrity and said they would move
     to Australia to be with Shelley. Over several months Shelley sent more than $9,000 in
       gift cards, leaving them unable to afford expenses to cover basic needs.

     Shelley’s physiotherapist and disability carer noticed the warning signs and reported
      their concerns to Scamwatch. This case highlights the crucial role of NDIS providers in
    recognising red flags and the need for stronger referral processes to protect victims.

               -     NDIS report: ACCC observations on consumer issues in the NDIS (February 2026) 4

The APA submits that the effectiveness of integrity policy should be assessed not only by enforcement outputs but by whether policy settings maintain a stable, high-quality market that facilitates participants’ choice, control and agency in therapy supports.

Page | 7

TOR 4: Any legislative or other reforms required to strengthen scheme integrity

The APR has faced criticism for lacking transparency and being shaped by internal agency priorities rather than independent oversight. While the Independent Pricing Committee has produced strategic advice aimed at guiding reform, many of its key recommendations have not been adopted. Nor have those from other independent bodies, such as the Independent Health and Aged Care Pricing Authority (IHACPA), whose Pricing data strategy remains unpublished and unaddressed. Instead, recent decisions reflect a shift toward tighter agency control, raising concerns about the integrity and independence of the pricing process.

Last year’s physiotherapy pricing changes are formally presented by the NDIA as “fairer” pricing and value- for-money policy, but independent evidence affirms that the cost and pricing foundations are methodologically unreliable for disability physiotherapy and risk embedding structural under-pricing.

The Nous Group review concludes that the NDIA’s 2024–25 Annual Pricing Review methodology underestimated prevailing market rates for physiotherapy due to regression-based session-duration assumptions (around 45 minutes) that diverge from typical private-market sessions (about 30 minutes) used to convert session fees into hourly benchmarks, limited and inappropriate comparator data (MBS, scraped website listings, and a single private insurer dataset), and insufficient accounting for the operational complexity of delivering therapy supports in the NDIS.

Under-pricing can push providers toward volume-maximising behaviour, cross-subsidisation, service withdrawal and substitution of staffing models that do not match participant risk (for example, replacing physiotherapists with less qualified roles). These are not merely sustainability issues; they are integrity pressures because they increase the likelihood of avoidable non-compliance and participant exposure to unethical conduct.

The APA welcomes the passage of reforms to strengthen safeguarding and integrity, including new offences and expanded regulatory tools. To strengthen integrity for therapy supports, non-legislative reforms are also required:

The NDIA should urgently review and correct the physiotherapy pricing decision made in the 2024– 25 Annual Pricing Review. The attached evidence indicates that the current price limit is not based on a sufficiently reliable methodology and does not reflect the actual cost of physiotherapy delivery under the NDIS.

Travel should be funded as a standalone line item in participant plans. Travel is integral to community- based and natural-environment physiotherapy, particularly for children, participants with mobility limitations, and participants in thin markets. A separate travel line item would reduce ambiguity in claiming and better align pricing policy with quality and practice standards.

The NDIA should review the impact of July 2025 changes to therapy travel settings and publish monitoring data on access, outreach, and equity impacts, especially in thin markets.

“Last week I met a participant who has had her therapy reduced within her plan. I asked, ‘What’s been the downside of the reduction of your physiotherapy?’ She said, ’I can no longer walk’.” - Dr Martin Laverty:

      -  From the Community Affairs Legislation Committee hearing on the National Disability Insurance
                 Scheme Amendment (Integrity and Safeguarding) Bill 2025 (February 2026) 5

Page | 8

References

1.  Nous Group 2025, Review of the 2024–25 APR with respect to physiotherapy, report prepared for
    the Australian Physiotherapy Association, 21 October. (Attachment 1)

2.  Australian Government Productivity Commission. (2011). Disability care and support: Inquiry report
    (Report No. 54). Productivity Commission. https://www.pc.gov.au/inquiries-and-
    research/disabilitysupport/report/

3.  False Economy: The economic benefits of the NDIS and the consequences of government
    costcutting - Per Capita. (2021). Per Capita. https://percapita.org.au/our work/false-economy-

theeconomic-benefits-of-the-ndis-and-the-consequences-of-government-cost-cutting/

4.  Australian Competition and Consumer Commission (2026). NDIS report: ACCC observations on
   consumer issues in the NDIS, Australian Competition and Consumer Commission.
    https://www.accc.gov.au/about-us/publications/ndis-report-accc-observations-on-consumer-issues-
     in-the-ndis

5.  Senate Community Affairs Legislation Committee (2026). Public hearing on the National Disability
   Insurance Scheme Amendment (Integrity and Safeguarding) Bill 2025, 24 February, Parliament of
     Australia, Canberra.
    https://parlinfo.aph.gov.au/parlInfo/download/committees/commsen/29382/toc pdf/Community%20
   Affairs%20Legislation%20Committee 2026 02 24.pdf;fileType=application/pdf#search=%22comm
   ittees/commsen/29382/0000%22

Review of the 2024-25 APR

with respect to physiotherapy

Australian Physiotherapy Association

21 October 2025

Nous Group acknowledges Aboriginal and Torres Strait Islander peoples as the First Australians and the Traditional Custodians of Country throughout Australia. We pay our respect to Elders past and present, who maintain their culture, Country and spiritual connection to the land, sea and community.

This artwork was developed by Marcus Lee Design to reflect Nous Group’s Reconciliation Action Plan and our aspirations for respectful and productive engagement with Aboriginal and Torres Strait Islander peoples and communities

Disclaimer:

Nous Group (Nous) has prepared this report for the benefit of Australian Physiotherapy Association (the Client).

The report should not be used or relied upon for any purpose other than as an expression of the conclusions and recommendations of Nous to the Client as to the matters within the scope of the report. Nous and its officers and employees expressly disclaim any liability to any person other than the Client who relies or purports to rely on the report for any other purpose.

Nous has prepared the report with care and diligence. The conclusions and recommendations given by Nous in the report are given in good faith and in the reasonable belief that they are correct and not misleading. The report has been prepared by Nous based on information provided by the Client and by other persons. Nous has relied on that information and has not independently verified or audited that information.

© Nous Group

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | i |

Contents

Executive summary 1 Background and Context 1 Purpose of this report 2 Key findings 2 Recommendations and next steps 6

1 Background and context 7

2 Methodology review 12 2.1 The use of regression modelling to estimate session duration resulted in hourly rates that are misaligned to prevailing market prices. 12 2.2 The data sources relied upon for the APR are too limited to generate robust and reliable NDIS price limits. 20 2.3 The pricing method does not reflect the complexity involved in delivering disability supports 21

3 Alternative methodologies 24 3.1 Short term approach 24 3.2 Longer term approach 25

4 Recommendations 27

Appendix A Private health insurance claims data 28

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | ii |

Executive summary

Background and Context

The NDIS is essential to the lives of many Australians The National Disability Insurance Scheme (NDIS) represents the most ambitious social reform since Medicare, having now supported over 700,000 participants to access essential services, pursue life goals and participate in everyday life. The Scheme has matured into a critical enabler of inclusion with tens of thousands of providers operating across the country. It functions as a national infrastructure that delivers long-term social and economic benefits.

Physiotherapy is an integral component of the NDIS Physiotherapy is a cornerstone support within the NDIS, playing a vital role in enabling participants to achieve meaningful engagement across all domains of life—social, economic, and community. It is not merely a therapeutic intervention but a foundational enabler of independence, mobility, and functional capacity. Through tailored, evidence-based approaches, physiotherapy empowers individuals to participate in education, employment, recreation, and relationships - thereby fulfilling the core objectives of the NDIS.

Physiotherapy establishes the baseline of functional capacity that makes participation possible for many NDIS participants. It supports participants with complex needs to engage, build skills and better realise the opportunities in other funded supports. Without it, function is limited, independence is compromised, and other funded supports lose effectiveness. Physiotherapy enables participants to move, engage, and build capacity. It is the foundation that allows the NDIS to deliver on its promise.

NDIS price limit for physiotherapy was reduced this financial year after a 5-year price freeze

The National Disability Insurance Agency’s (NDIA) 2024-25 Annual Pricing Review (APR) was released in June 2025 and introduced a:

  • Cut in hourly rate: $10 (5.2%) reduction in the national price limit for physiotherapy, from $193.99 to $183.99 per hour. This followed a five-year NDIS price freeze for physiotherapy1.

  • Cap on travel rates: a cap on provider travel claims for therapy supports set at 50% of the claimable hourly rate.

  • Removal of regional pricing: removed State and Territory Special Pricing Arrangements for Western Australia, South Australia, Northern Territory, and Tasmania.

Many in the physiotherapy sector are concerned the reduced rate will reduce access to care Recent survey data from Australian Physiotherapy Association (APA) members and sector consultations indicate that many physiotherapy practices see the NDIS hourly rates as unsustainable. Sector survey and consultation data shows that 30% of providers report they do not

1 The hourly rate for physiotherapy in the NDIS has not increased since the specific physiotherapy rate was introduced in 2019-20

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | 1 |

Purpose of this report

The purpose of this report is to present the findings of an independent review of the pricing methodology used in the NDIA’s 2024-25 Annual Pricing Review.

The Australian Physiotherapy Association (the APA) engaged Nous Group (Nous) to complete an independent review the NDIA’s 2024-25 Annual Pricing Review (APR) to better understand the NDIA’s methodology for setting the new hourly rates and to identify opportunities to strengthen the methodology to ensure that reference market rates for Physiotherapy can be restored in the short term and reflected in future APRs. Although, detailed consideration of the rationale and impact of NDIA changes to travel rates and regional pricing were out of scope for the review, the implications of these changes on the viability and sustainability of physiotherapy support under the NDIS is noted. The report is intended for the use of the APA and its members.

To ensure the independence of this review, this report is focused on examining the APR methodology and identifying opportunities for its improvement to ensure that the true reference market rate for Physiotherapy is reflected in ongoing price determinations. Accordingly, this report:

-e avoids commentary where there is no evidence base

-e specifies where evidence is drawn from stakeholder input.

Current NDIS pricing limits for physiotherapy

Current NDS pricing limits for physiotherapy are misaligned with current market conditions and service delivery realities for people living with disability.

The review (covering around 25 per cent of the national market) shows a 70th percentile session fee equivalent to $236.50 per hour. This is significantly higher than the 75 percentile hourly fee of $150.50 estimated by the APR method. The APR method assigns a session duration for private market and MBS fees using a regression formula based on web-based information. Session duration is then used to convert session fees into hourly rates. We conclude that the APR method yields session times (around 45 minutes) that are misaligned with current service delivery realities (around 30 minutes), resulting in the underestimation of hourly rates. This misalignment has significant implications for NDIS service costing and resource planning.

Second, the data sources relied upon for the APR are too limited to generate robust and reliable NDIS price limits.

The APR relies on MBS fee data, publicly available website data, and a single PHI dataset. The MBS data reflects GP-led chronic disease care, which is not comparable to disability supports. The private health insurance dataset, drawn from a single undisclosed insurer, which may not be representative, is unclear on the inclusion of preferred provider programs and excludes indicators of care complexity and service profile. Public website listings while helpful for linking fees to session duration can obscure price variations linked to funding arrangements, including MBS and NDIS. These limitations reduce the reliability of the pricing outputs and their value to inform evidence-based policy.

Lastly, the pricing method does not reflect the complexity involved in delivering disability supports. The NDIA’s approach, which sets therapy price limits by referencing private market rates and MBS pricing, does not adequately account for the complexity of operating in the NDIS system. NDIS providers operate under a set of different conditions that impact service delivery and financial sustainability. The system complexity reduces the time available for funded therapeutic engagement and significantly lowers productivity.

Comparative evidence consistently indicates APR undervaluation of physiotherapy support, with the actual 75th percentile market rate lying between $215 and $259 per hour

The NDIA national price limit for physiotherapy in 2025-26 is $183.99 per hour. This represents a $10 per hour (5.2%) reduction on the price limit in the previous year. The APR relied on insights from the introduction of limited private health insurance and MBS data and related analysis in the 2024-25 review to justify a decrease in the national price limit for physiotherapy.

Our review found that these insights are broadly inconsistent with those from other available evidence, including data sources and analysis used by the NDIA in the past and presented in the 2024-25 APR report (see Table 1).

Table 1: Comparative methods available to inform physiotherapy hourly fee benchmarks

APR methods/hourly fee estimate Non-APR methods/hourly fee estimate
Analysis of website listings $240 vetepeble hear te 3 $261
Comparison of other schemes $215 APA survey data* $259
MBS modelling (new) $159 APA reference PHI data® $237
PHI modelling (new)$151 Ability Roundtable costing®$220

In summary:

e The new APR modelling of MBS and PHI data resulted in hourly fee benchmarks in the range of $151 to $159.

e Other methods used by the APR previously and presented in the 2024-25 report resulted in hourly fee benchmarks in the range of $215 to $240.

e Other methods not used by the APR but reported elsewhere resulted in hourly fee benchmarks in the range of $220 to $261.

While both of new APR methods resulted in hourly fee benchmarks that are below (ranging from 18% to 22 %) the 2024-25 national price limit of $193.99, the other six methods reviewed for this report all resulted in hourly fee benchmarks above (ranging from 14% to 35%) the 2024-25 price limit.

In addition, the APR claimed that the most comparable schemes to the NDIS have hourly rates that fall between $140 and $190, yet its own data presented in the report shows a median rate closer to $200 and a 75th percentile rate around $215.

Looking ahead, short-term improvements could be achieved by validating existing data and related analytical methods through closer consultation with physiotherapy providers and data custodians (including MBS and PHI and those related to other schemes and website information). Longer- term, reforms to the pricing approach should integrate bottom-up costing with ongoing reference pricing. This would align NDIA’s approach with best practice models used by IHACPA in Australia, ACC in New Zealand, and the NHS in England.

3 Nous group report for APA on the identification of a sustainable hourly rate for the provision of physiotherapy services. 4 APA survey of physiotherapy practices on standard session durations and fees excluding the initial consultation.

Private health insurance data received by APA from a major insurer covering around 25 per cent of the national market. © Composite hourly cost estimate across four major allied health disciplines developed by the Ability Roundtable.

Changes to travel funding will likely have further implications for the availability and delivery of direct therapeutic supports.

The 2024-25 APR also introduced a change to travel funding whereby the maximum claimable rate for provider travel associated with therapy supports is halved, capped at 50% of the relevant hourly price limit per 10-minute increment. This is likely to affect ongoing service delivery models, particularly in relation to the NDIS Practice Standards, which encourage access to therapy supports in natural environments. This change extends the existing practice of funding enablers of service delivery from therapy budgets, which is likely to have further implications for the availability and delivery of direct therapeutic supports.

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | 5 |

Recommendations and next steps

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | 6 |

Background and context

The National Disability Insurance Scheme (NDIS) is a landmark reform in Australia’s social policy landscape, designed to empower people with disability to pursue their goals, participate fully in society, and exercise choice and control over their supports. Since its establishment in 2013, the NDIS has grown rapidly, now supporting over half a million participants and engaging tens of thousands of providers across Australia’.

Physiotherapy is a cornerstone support within the NDIS, playing a vital role in enabling participants to achieve meaningful engagement across all domains of life-social, economic, and community. It is not merely a therapeutic intervention but a foundational enabler of independence, mobility, and functional capacity. Through tailored, evidence - based approaches, physiotherapy empowers individuals to participate in education, employment, recreation, and relationships, thereby fulfilling the core objectives of the NDIS.

Physiotherapy establishes the baseline of functional capacity that makes participation possible for many NDIS participants. It supports participants with complex needs to engage, build skills and better realise the opportunities in other funded supports. Without it, function is limited, independence is compromised, and other funded supports lose effectiveness. Physiotherapy enables participants to move, engage, and build capacity. It is the foundation that allows the NDIS to deliver on its promise.

Importance of physiotherapy

Physiotherapists are among the few allied health professionals with diagnostic capabilities. Their clinical expertise allows them to assess, identify, and respond to a wide range of physical and functional impairments, often serving as the first point of contact in recognising emerging issues. This diagnostic capacity is especially critical in early intervention, particularly within paediatric populations, where timely identification of developmental delays, neuromuscular conditions, and motor impairments can profoundly influence a child’s long-term trajectory.

Early physiotherapy intervention supports optimal physical development, prevents secondary complications, and facilitates smoother transitions into educational and social environments. Across the lifespan, physiotherapists provide continuity of care that adapts to the evolving needs of participants—from infancy through to ageing—ensuring that interventions remain relevant, goal-directed, and impactful.

Beyond their direct therapeutic and diagnostic contributions, physiotherapy often functions as a junctional support—a critical connector between multiple services such as occupational therapy, speech pathology, assistive technology, and personal care. Physiotherapists frequently coordinate with other providers to ensure that supports are delivered in a safe, goal-directed, and integrated manner. This coordination is essential for reducing fragmentation in service delivery and for maintaining continuity of care, especially for participants with complex needs.

Too often, physiotherapy’s role is misunderstood, and this disconnect has shaped policy settings that undervalue physiotherapy’s essential contribution. The sustainability of physiotherapy services under the NDIS has become a significant concern. Recent survey data and sector consultations indicate that the current NDIS price limits are unsustainable for many practices, with nearly 30%8 of physiotherapy providers reporting they do not accept NDIS participants due to low fees. Many who do participate must cross-subsidise NDIS services from other client groups, raising the risk of further provider withdrawal from the Scheme9.

These concerns are reinforced by the Ability Roundtable’s (Australia’s largest benchmarking platform for disability service providers) financial and workforce benchmarking results for the 2023-24 financial year (Figure 1), which reveal entrenched sector-wide losses among NDIS registered providers10. The median profitability for participating organisations was -0.9% in 2023- 24, following a -2.1% median result in 2022-23.

Figure 1 | Ability roundtable modelling of median profitability of all organisations participating in the NDIS FY19-20 to FY22-23(**FY24 projection)

For NDIS registered therapy supports specifically, the situation is even more acute as outlined in Figure 2. Median losses for therapy providers were -14% in 2022-23, and mid-year data for 2023- 24 showed a median year-to-date loss of -7.9%. Only a small proportion of NDIS registered providers are making a profit, highlighting the growing risk of market withdrawals and failures.

8 Australian Physiotherapy Association (2025), Hourly rate for the provision of physiotherapy services 9 Australian Physiotherapy Association (2025), Hourly rate for the provision of physiotherapy services 10 Ability Roundtable (2025), IHACPA Consultation – NDIS Pricing Reform Opportunities

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | 8 |

Figure 2 | Ability Roundtable modelling of profitability of therapy supports for FY23 and FY24 with FY25 projection

It is noted that these concerns are not new. The APA has previously put forward robust recommendations to government highlighting key cost drivers, service delivery complexities and market sustainability pressures evident in the sector.

In its 2024-25 APR, the NDIA announced a 5.2% reduction in the national price limit for physiotherapy from $193.99 to $183.99 per hour for 2025-26 after five years without indexation since 2019-20, The APR cites benchmarking against broader market rates and a revised methodology as rationale for the reduction. The NDIA’s approach leverages data from the Medicare Benefits Schedule (MBS), Private Health Insurance (PHI), and other government schemes, as well as regression analysis of private website listings. The APR also reviewed the price limit differentials between jurisdictions, resulting in the previously higher price limit in WA, SA, NT and TAS being brought in line with other jurisdictions.

In addition to these price reductions, the APR introduced a change to travel funding: from 1 July 2025, the maximum claimable rate for provider travel associated with therapy supports will be halved, capped at 50% of the relevant hourly price limit per 10-minute increment. While travel supports access to services, it currently only represents approximately 1% of therapy expenditure ($26.1m) and around 0.1% of total scheme costs for July to December 2024 (~$21.8b11). The NDIA’s decision to cap travel reimbursement is likely to affect service delivery models, particularly in relation to the NDIS Practice Standards, which encourage access to therapy supports in natural environments. This change continues the existing practice of funding enablers of service delivery from therapy budgets, which is likely to have further implications for the availability and delivery of direct therapeutic supports.

11 NDIS (2025), 2024-25 Annual Pricing Review

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | 9 |

The NDIA’s revision of physiotherapy fees highlights a potential gap between federal pricing structures and wage policy.

After several years without indexation, providers are navigating rising wage and other operational costs, which stakeholders said could increase costs of employing physiotherapists by up to 30 per cent and is likely to increase more for entry-level employees (such as new graduates) than senior roles*. For example, the Fair Work Commission has announced provisional wage increases under the Health Professionals and Support Services Award 2020 (HPSS)—an award that covers the majority of allied health professionals employed in the private sector. These anticipated award changes are not isolated events—they are part of a broader pattern of rising costs that include insurance, compliance, administration, and workforce development.

While the NDIA has positioned the physiotherapy price reduction as a cost-containment measure, its impact on the overall NDIS budget is expected to be relatively limited. As outlined in Table 2, Physiotherapy represents approximately 1% of the total NDIS budget. Even within therapy supports, physiotherapy accounts for just 9.2% of total therapy spending. The estimated annual reduction in physiotherapy expenditure resulting from the price change is approximately $23 million“, representing about 0.05% of estimated NDIS expenditure. Although modest in terms of overall budget impact, this change may have more pronounced implications for physiotherapy providers, particularly those already operating under financial pressure.

Table 2 | NDIS scale and the impact of proposed change (6 months Jul-Dec 24)

Total NDIS budget $22.6 billion
Total therapy spending $2.417 billion (excluding early childhood supports)’°
Total physiotherapy spending $222.7 million’®

Reduction from price change — $11.6 million (~$23 million annually)

There are concerns within the sector that the change pricing methodology employed by the NDIS for 2025-26 is flawed, particularly in its determination of session durations, data comparability, and the unique costs associated with serving NDIS participants.

As such, the APA has engaged Nous to review the NDIA’s data and methodology, identify potential flaws, and support advocacy efforts to ensure pricing arrangements are transparent, evidence-based and sustainable. This report provides a critical analysis of the NDIA’s 2024-25 APR methodology, drawing on sector expertise, independent data analysis, and stakeholder feedback.

The findings will inform ongoing advocacy to the NDIA and other relevant schemes, with the aim of supporting a viable and sustainable, high-quality physiotherapy market for NDIS participants.

It is noted that, while changes to the differential price limit between jurisdictions and to the travel funding are referenced in this report, the justification and implications of these changes were not explored in the scope of this review.

It is important to note that this report builds on a substantial body of existing work. Foundational recommendations and modelling have already been developed, including the Nous report on the value of physiotherapy in Australia and market research on a sustainable hourly rate for physiotherapy, which considered existing prices, sector sustainability, and economic value. In addition, the Ability Roundtable—Australia’s largest benchmarking platform for disability service providers—has produced comprehensive 2024–25 pricing analysis identifying key cost drivers, service delivery complexity, and market sustainability considerations. These studies have been referenced throughout this report and provide valuable insights, although they have not been a focus in recent reform discussions.

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | 11 |

2 Methodology review

2.1 The use of regression modelling to estimate session duration

resulted in hourly rates that are misaligned to prevailing
market prices.

While comparative pricing models can offer useful reference points, their new and extended application in the 2024–25 APR introduces several methodological flaws and data limitations that warrant closer scrutiny. Figure 3 outlines the NDIA’s approach to pricing in the APR.

Figure 3 | APR 2024-25 methodology

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | 12 |

2.1.1 Regression-based duration estimation

The APR methodology estimates session duration using a regression formula based on price, which is then used to calculate hourly rates. This introduces circular logic: the model defines the relationship between price and duration derived from website scraping, then uses that same relationship to impute duration and derive hourly rates for MBS and PHI services. This creates a deterministic link between price and time, assuming a fixed duration at each price point.

In reality, MBS and PHI session durations are generally either 30 or 45 minutes for any given price. For example, a $110 priced session might last either 30 or 45 minutes depending on provider, client needs, and context. Likewise, a 30-minute session can be priced differently across providers, overlapping with prices charged by some providers for 45-minute sessions. By enforcing a fixed duration at each price point based on a model that considers session duration as a continuous variable, the model does not reflect the market price variability at standard session durations.

As such, the 25“ percentile, median, and 75th percentile estimates for the duration of physiotherapy sessions generated by the regression model - particularly those based on PHI data - are unexpectedly high and show very little variation. Table 3 shows the APR estimates as 43.5 minutes for the 25th percentile, 45 minutes for the median, and 46.8 minutes for the 75th percentile.

Table 3 | The APA physiotherapy provider survey outputs compared with APR outputs“

Question 25“ percentile Median 75“ percentile
Excluding the initial 30 30 30
consultation, what is the
average session duration for a
private patient? (minutes)
Duration PHI 43.2 45.0 47
determined by
the APR (East MBS 30.0 30.0 34.0
Coast)

In practice, a typical standard follow-up session is around 30 minutes, with only enhanced sessions lasting 45.

This is supported by a survey deployed by the APA which reached 212 physiotherapy providers focusing on standard musculoskeletal care. As outlined Table 4most practices reported that the average session duration for a private patient is 30 minutes. While the APR’s duration estimate

17 APA deployed a survey which reached 212 providers focusing on traditional musculoskeletal care to validate assertions in the APR about session price, duration and rate as well as a test the validity of using MBS data as a price comparator. The survey was distributed to physiotherapy business owners, both members and non-members of APA (MS Excel file with the full questions and survey outputs can be obtained from APA on request).

Data for quantitative survey questions

Question 1:

How long should a standard physiotherapy consult be? This would not include initial consults, complex or specialised consults, or consults for more than one concern. (n=325)

Multiple choice <20min 20min 25min 30min 35min 40min 45min = >45min #ofresponses 11 50 14 218 3 11 18 0 % of responses 3% 15% 4% 67% 1% 3% 6% 0%

QUESTIONS TO GUIDE FURTHER EXPLORATION

e« What regression model was used? What were the regression coefficients? Was separate modelling undertaken for discrete session durations (e.g. 30 and 45 mins)?

e« How was the regression output cross-validated with MBS and PHI data, considering these data sources do not include session durations?

e What are the range of prices collected by web scraping for sessions which are 30 minutes and 45 minutes? (Rationale: Nous hypothesises that there will be clustering of durations around the 30 minutes and 45 minutes. This would suggest that the duration of physiotherapy sessions should considered discrete values rather than a continuous variable.)

¢ What are the range of durations collected by web scraping for sessions at the 25“ percentile, median and 75™ percentile prices?

2.1.2 Hourly rate calculation

The APR calculates hourly rates by dividing the 75th percentile session fee by the imputed 75th percentile duration. This method does not necessarily yield a valid 75th percentile hourly rate, given higher fees can be associated with shorter sessions resulting in higher hourly charges.

Table 5 | Hourly rate calculated using the 75th percentile duration compared to the median duration and median/average duration of reference sources

METHOD PHI East PHI West MBS East MBS West
Using the 75* percentile duration and 75% percentile price to estimate an hourly rate $118/s for 47min $104/s for 46.8min $90/s for 34min $79/s for 32.6min
$150.50/h $133.40/h $158.70/h $145.30/h
West PHI
East PHI $118/s $90/s
.
.
.
.
Using the median for duration and 75“ (median —_ (median 30min) ; (median . . )
percentiles price to estimate an hourly rate $163.88/h $143.45/h $180/h $158/h

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | 15

METHOD

PHI MBS

Using the West PHI West MBS . East PHI $118/s East MBS $90/s median/average duration . $104/s for . $79/s for for 32min . for 20min . of reference data sources 32min 20min (E.g. Mystery Shopper report (2022), intended i th MBS duration) and 75“ §221.25/h $195/h $270/h $237/h percentile price to estimate an hourly rate The methodology adopted in the 2024-25 APR consistently produced lower rates estimates than other reference methods mentioned in the review and outputs from research conducted in this review of the APR as shown in Figure 5 and Table 6 e Across therapy types, the APR methodology underestimates the 75th percentile hourly rate by an average of 33.0% compared to the other reference methods (Analysis of website listings and comparison to other government schemes). This is particularly the case for physiotherapy where it underestimates the 75“ percentile hourly rate by 47%. The survey of physiotherapy practices determined a 75th percentile average hourly rate of $259/h, 68% higher than the APR estimate. This data shows significantly stronger alignment with the reference methods than the APR-derived estimates.“ The APA requested price data for standard (subsequent) physiotherapy sessions from one of Australia’s largest private health insurers—representing approximately a quarter of the national market share—this indicated a 70th percentile session fee of $118.25, equating to $236.50 per hour.”° Importantly, with standard indexation applied, the current market rate would be higher, further widening the gap between the APR’s estimates and actual service costs.

e As outlined in Table 6, the APR estimates the 75th percentile hourly rate for physiotherapy at a figure that is 54.6% lower than this insurer-derived benchmark of $236.50 per hour. These discrepancies are not insignificant given the 2024-25 APR relied on the MBS and PHI estimated hourly rates as a primary driver for reducing the price limit for 2025-26. ‘8 The APA conducted a parallel survey targeting practices specialising in podiatry, neurology, and disability, which received 154 responses. The 25th percentile, median, and 75th percentile hourly rates derived from this survey closely aligned with those from the survey focused on traditional musculoskeletal physiotherapy practices. 20 The 25th, 50th, 75th percentile claims/fees for a standard consultation (excluding initial) are presented by state at Appendix A.

  • The 75“ percentile hourly price from:

-e Analysis of website listings of charges and session times was $240. -e Other government schemes was $215.

e APA’s survey was $259.

e Supplementary PHI data?! was $236.

These illustrate a degree of convergence well above $200 per hour and well above the prices generated by the APR method for 2024-25, which estimated the PHI hourly price at $151 and the MBS hourly price at $159.

The variance between the non-APR outputs and the APR outputs appears implausible and indicate the need for further analysis of the methods used for 2024-25.

Figure 4 | Comparison of the 75th percentile hourly rate determined by the APR compared to reference methods, the APA survey data and data from one of Australia’s largest health insurers

300 + 9 ee fy 250 4 4 Y = ee n FA 200 ° e He id © J 4 : sd » - ° aso, mm q a “ 3 a 100 4 £ a wu Be 0 T qT T qT qT qT Physiotherapy Psychology Exercise Speech Occupational (East Coast) (East Coast) physiology pathology therapy MM 2024-25 APR methodology (PHI) @ Analysis of website listings @ APA survey data

§) 2024-25 APR methodology (MBS) ® Comparison to other government schemes @)APA reference PHI data

21 Refers to 70“ percentile.

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | 17

Table 6 | Hourly rates for physiotherapy as determined by the APR compared to reference

methods, the APA survey data and data from one of Australia’s largest health insurers

Question 25“ percentile Median 75“ percentile

Survey data: Excluding the initial $210.00/h $230.00/h $258.00/h consultation, how much do you charge private patients per session? N=212 (converted to $/h)

The APA reference PHI data (East $192.50/h $217.50/h $236.50/h Coast average): What is the 25th, 50th, 75th percentile claims/fees for a standard consultation (excluding initial), including high and low cut off (split by state)?

Rate determined by PHI $122.20/h $136.00/h $150.50/h the APR (East Coast)

MBS $116.60/h $116.60/h $158.70/h Rate determined by Analysisof — $182.00/h $200.00/h $240.00/h reference methods _ website (East Coast) listings

Comparison $136.00/h $202.00/h $215.00/h to other government schemes

It is also noted that the APR misinterprets the comparative data from other government schemes by claiming that most physiotherapy hourly rate limits for comparable schemes fall between $140 to $190 per hour. However, APR report shows Figure 6 that the median hourly rate limit around $200 per hour and the 75“ percentile is around $215 per hour which appears to contradict this assertion. The current hourly rate limit provided by NDIS sits between the 25“ percentile and median, which is well below the 75“ percentile.

The private health insurer provided APA fees per session for percentiles at an increment of 10. To maintain conservative estimates, the 20“ percentile and 70™ percentile fee was used in this table for the 25“ percentile and 75 percentile comparisons respectively. The assumption was made that the duration of a standard session was 30 minutes based on outputs of APA’s provider survey (MS Excel file with the full questions and survey outputs can be obtained from APA on request. As such, the hourly rate was determined by doubling the session fee.

Figure 5: Comparison of NDIS Price Limits to other Government Schemes

Source: Figure 22 on page 81 of the NDIA’s 2024-25 Annual Pricing Review

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | 19 |

2.2 The data sources relied upon for the APR are too limited to

generate robust and reliable NDIS price limits.

The APR relies on publicly available website data to identify session duration and associated prices and MBS fee data and a single PHI dataset to estimate private patient hourly prices. However, several limitations in this approach raise concerns about the reliability and representativeness of the data:

The interpretation of MBS Item 10960 within the Annual Pricing Review must be understood in the context of broader market dynamics: It is widely acknowledged in the sector—though not yet formally validated—that MBS 10960 is frequently used in medical centres to fulfil the team care arrangement requirements that enable GPs to claim for the development of chronic disease management plans. These vertically integrated models streamline internal referrals and claiming processes, primarily serving the medical claiming budget rather than reflecting the complexity or duration of integrated allied health care. As a result, the service delivery data derived from MBS 10960 is skewed towards corporatised settings and does not represent the realities faced by independent providers, community clinics, or disability-specific services. The NDIA’s reliance on MBS 10960 for disability support pricing risks embedding these distortions, overlooking the greater complexity, duration, and relational depth required in NDIS participant care. This concern is further reinforced by evidence that the APR’s pricing outputs do not reflect real-world physiotherapy billing practices. For example, the APR’s median session price of $58.30 implies widespread bulk billing, yet the APA survey data indicates that 83.5% of physiotherapists do not bulk bill. Additionally, reported session prices are, on average, 76% higher than those presented in the APR, as outlined in Table 7.

Table 7 | Comparison of MBS (10960) session fees estimated by the APR using MBS data and

APA survey data

Method 25“ percentile Median 75“ percentile
APA survey data (N=212) $103 $118 $130
MBS (East Coast) $58.3 $58.3 $88

Website data is not transparent: Public listings often do not reflect internal pricing structures or MBS-specific arrangements. Many providers vary pricing based on the funding source (e.g. MBS vs. private billing), which is not always visible on websites and may misrepresent actual market prices and session durations for segments of the market.

PHI data is limited to one insurer: While the dataset includes 830,021 physiotherapy claims, it is drawn from a single insurer. The review does not clarify if this insurer is representative of the broader PHI market, if it operates preferred provider programs that may suppress fee levels or if service types that could distort the interpretation of the rate for standard care, such as groups or classes, were included in the data. Data from the APA’s reference insurer indicates that 30% of physiotherapy claims were made through preferred providers. If similar dynamics

apply to the dataset used by the NDIA, this could have exerted downward pressure on

observed prices. In addition, the PHI data is based on HICAPS codes, which do not capture important contextual factors such as client type, service model, or complexity of care. This potentially limits the dataset’s usefulness for informing national pricing decisions. In addition, as per section 2.1.2 the APR indicated an insurer-derived hourly rate 54.6% lower than data sourced by the APA from another major PHI organisation.

  • The NDIS has governance and compliance obligations, such as adherence to safeguarding protocols and audit requirements.

This system complexity reduces the time available for funded therapeutic engagement and significantly lowers productivity. This is situation illustrated in the findings from the Ability Roundtable, which shows consistently low billable productivity levels of among NDIS physiotherapy providers (Figure 6%). These levels are understood to be well below those expected by the market when compared to other the funding environments such as services within the of PHI and Medicare systems.

Figure 6 | Total billed time as a proportion of total paid time. July 2023 to Jun 2025.

75th: 47% sGroup Median: 44%“25th: 41%

J eo 2 £ a 2 o.

December February December February November September November nw Se

The apparent impact of the scheme’s complexity on service delivery highlights the need for pricing models that recognise and account for the distinct operational realities faced by clinicians working within the NDIS. If these realities are overlooked, the funding framework is likely to systematically undervalue and underfund physiotherapy service provision within the NDIS.

The following cost breakdown developed by developed by the Ability Roundtable illustrates the apparent disconnect between current NDIS pricing and the actual cost of delivering physiotherapy services. Figure 7”, shows the Ability Roundtable cost estimates have consistently exceeded the NDIA’‘s price limit over the past 5 years, with the gap widening over time. The $10 price cut in 2025-26 expanded this gap, with projected costs over $220 per hour and exceeding the reduced NDIS price limit by nearly 22%.

Ability Roundtable (2025), Therapy Insights, unpublished.

25 Ability Roundtable (2025), Therapy Insights, unpublished.

Figure 7 | Ability Roundtable physiotherapy support hourly cost breakdown compared to the NDIS Price Limit (NSW, Vic, ACT, Qld) 2021 to 2025-26.

In addition, Nous previously supported the APA in modelling a sustainable and value-based hourly rate for standard physiotherapy sessions. That analysis identified a sustainable and value-based hourly rate of $261 per hour26 based on sector sustainability, economic value, and service quality. It also identified additional premiums for experience, titling or equivalent, specialisation, and rural or remote service delivery to reflect the higher costs and/or value associated with these contexts.

Together, these estimates reinforce the need for a pricing methodology that reflects the unique service delivery profile of NDIS participants—characterised by lower utilisation rates, higher resource requirements, and more complex compliance obligations.

26 Australian Physiotherapy Association (2025), Hourly rate for the provision of physiotherapy services

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | 23 |

3 Alternative methodologies

Approaches to pricing in the short term and long term should be different as the most evidence- based approaches to pricing are likely to include data collection, cleaning and analysis that may not be plausible in the short term. Regardless, the approach should be well grounded in a set of agreed principles

We note the NDIA has in recent years moved towards a more data-driven approach and see this as essential to determining the hourly rates of services. However, we also know that leveraging data to determine prices requires cleaning and analysing data and the use of modelling assumptions. This is complex and often requires validation with stakeholders (e.g. data custodians, physiotherapists delivering services and practice managers responsible for managing costs and budgets).

Below we outline alternative approaches for how a pricing methodology could be leveraged for physiotherapy, or allied health more broadly, in the NDIS or other government schemes.

Foundational principles should underpin the pricing methodology

It is essential to articulate the foundational goals that should underpin any alternative methodology for pricing as adopted by other major pricing reforms (e.g. Independent Health and Aged Care Pricing Authority (IHACPA)27).

These could include:

  • Sustainability: Supporting the ongoing viability of the sector, so that pricing arrangements do not inadvertently drive providers out of the market or undermine continuity of care.

  • Market alignment: Avoiding pricing that distorts the broader allied health market, by ensuring NDIS rates are competitive but not so high as to significantly draw providers away from other sectors, including aged care and acute care.

  • Transparency and evidence: Basing methodologies on clear, evidence-based processes, with all assumptions and data sources open to scrutiny.

Embedding these principles will ensure that any alternative pricing methodology delivers fair, sustainable, and market-responsive outcomes. This will help maintain sector viability and participant access, while supporting trust and transparency in NDIS pricing decisions.

3.1 Short term approach

The NDIA has already undertaken significant work to collect and benchmark market data, including the use of advertised website prices and comparisons to other compensable schemes. While these methods are not without limitations, our review suggests these would provide a more appropriate basis for pricing than the current regression-based methodology. We would also suggest

27 IHACPA, Pricing Framework for Australian Public Hospital Services 2025–26

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | 24 |

consulting with the data custodians and the sector on the assumptions used for analysing this data to ensure they capture the nuance of delivering supports through the NDIS or relevant scheme.

Building on this foundation, we recommend the following actions:

  • Benchmarking against website data: Continue to utilise advertised private session prices and durations from provider websites to establish a more accurate picture of prevailing market rates for physiotherapy services.

  • Benchmarking against other schemes: Maintain and strengthen the practice of comparing NDIS rates to those paid by other compensable schemes (e.g. State Insurance Regulatory Authority, Lifetime Care and Support and Comcare) to ensure alignment with broader market conditions.

  • Consulting with key stakeholders: Consult with the data custodians and the sector (through peak bodies) on the assumptions used for analysing this data to ensure they capture the nuance of delivering supports through the NDIS or relevant scheme.

  • Reviewing insights from this report: Review the insights from this report, particularly those related analysis of the APA survey of providers and additional PHI data and the alignment with existing APR benchmarking using website data and data from other schemes.

If the NDIA is open to reconsidering prices for physiotherapy in the second half of 2025-26, these approaches could be principally relied upon to inform the price limits. Although these measures may not capture the nuance of the physiotherapy market for NDIS participants, they represent a significant improvement over the current methodology and provide a more robust foundation for short-term pricing decisions.

3.2 Longer term approach

Looking ahead, a more sophisticated and sustainable pricing methodology should be developed. This approach outlined below blends detailed, bottom-up costing with reference pricing, ensuring that price limits are both reflective of actual service delivery costs and responsive to market signals.

1. Bottom-up costing

Historically, the NDIS undertook annual financial benchmarking surveys of disability service providers, which provided valuable insights into sector costs and informed pricing decisions28. These surveys, conducted over several years, collected detailed data from a representative sample of providers and set a precedent for evidence-based pricing in the sector.

Building on this foundation, a robust long-term approach should involve conducting periodic, statistically robust cost surveys of a representative sample of physiotherapy providers, stratified by geography, provider size, and service model. These surveys should be designed to capture all relevant cost components for both standard and extended sessions, including:

  • direct labour (wages, superannuation, on-costs)

28 NDIS, Financial benchmarking

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | 25 |

  • non-billable time (documentation, care coordination, travel, supervision)

  • compliance and regulatory costs (NDIS-specific governance, safeguarding, audit)

  • overheads (rent, IT, insurance, administration)

  • workforce development (training, supervision, professional development)

  • sustainable profit margin (to support reinvestment and sector viability).

By reinstating and refining such cost surveys, the NDIS can ensure that pricing remains transparent, evidence-based, and responsive to the actual costs of delivering high-quality physiotherapy services to participants. This approach is consistent with the methodologies used by IHACPA29 in Australia and NHS England30, all of which use bottom-up costing methods to ensure that prices reflect actual service delivery costs and remain aligned with broader market conditions.

2. Compare with reference pricing

To ensure that NDIS price limits remain competitive and do not create market distortions, bottom- up cost estimates should be validated against:

  • Rates paid by government schemes that are more closely aligned in complexity and service demand (e.g. TAC, SIRA, ACC NZ).

  • Prevailing private market rates (PHI, website listings).

  • International benchmarks where relevant (e.g. NHS England, New Zealand ACC).

This triangulation helps avoid “cost-plus” drift and ensures that NDIS pricing does not inadvertently draw providers away from other sectors or inflate costs.

Establishing a long-term pricing methodology grounded in cost transparency and market validation will enable the NDIS to move beyond reactive adjustments and toward a stable, strategic framework. This will support long-term sector viability, foster investment in service innovation, and ensure pricing remains responsive to evolving participant needs and market dynamics.

29 IHACPA, Costing overview 30 NHS, Approved costing guidance

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | 26 |

4 Recommendations

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | 27 |

Appendix A _ Private health insurance claims data

Question 1: What is the 25th, 50th, 75th percentile claims/fees for a standard consultation (excluding initial), including high and low cut off (split by state)?

Breakdown by percentile fees:

Item: T1505 Extraction period: 1** Nov 23 — 31* Oct 24

Percentile ACT NSW QLD WA TAS NT SA VIC
Values
10th 100 80 90 80 92 90 715 719
20th 110 90 96 86 99 95 80 89
30th 110 98 100 92 102 99 85 95
40th 115 100 105 95 111.25 100 90 100
50th 120 110 110 99 111.25 110 94.5 105
60th 120 115 115 102 118 110 99 110
70th 123 120 120 106 124.6 115 104 115
80th 125 132 128 114 127 115 109 125
90th 133 QLD 140 120 140 119 115 130

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | 28 |

  • Question 2: What proportion of claims is from preferred provider programs?
Network Non-Network
Services 242,839
Distinct Person Count 78,342

Nous Group | Review of the 2024-25 APR with respect to physiotherapy | 21 October 2025 | 29