CatholicCare NT
TO: Joint Standing Committee on the National Disability Insurance Scheme PO Box 6100 Parliament House Canberra ACT 2600
CatholicCare NT Response to Joint Standing Committee - Integrity of the National
Disability Insurance Scheme
(a) the nature and extent of non-compliance, including fraud and sharp practices, in the
NDIS;
Based on our direct experience working with participants from very remote communities, we have observed significant and concerning patterns of non-compliance, exploitation, and sharp practices by both registered and unregistered NDIS providers. These practices disproportionately target Aboriginal participants, people with intellectual or psychosocial disability, people with low levels of English literacy, limited knowledge of NDIS processes and their participant rights, and individuals living in poverty with limited access to support networks.
1. Targeting Of Vulnerable Participants Through Incentives
Many providers actively approach participants and their families with incentives such as cash payments, accommodation, vehicles, alcohol, drugs and other material goods. These incentives are used to secure service agreements or to persuade participants to transfer from their existing providers.
Providers are approaching participants in a wide range of public and private settings, including:
- Hospitals - Participants who are admitted to hospital while living in stable SIL accommodation often do not return to their original provider. During their hospital stay, other providers approach them, have them sign new Service Agreements, and the participant is then discharged into the care of the new provider.
- Bus stops - CCNT has encountered situations where participants are approached at bus stops and offered money or incentives to sign new Service Agreements with unfamiliar providers.
- Taxi - We have repeatedly seen participants being offered free transport for themselves and their families in exchange for signing a new Service Agreement.
- Churches - Some providers have been attending church services and offering incentives, including housing, to encourage participants to sign new Service Agreements.
- Shopping centres - Non-ethical providers have been observed loitering in shopping centres, approaching individuals who appear to have a disability, and persuading them to sign new Service Agreements. In some cases, participants have been directed to the provider’s vehicle and have left the centre with them.
- Participants’ homes and remote community locations - This occurs frequently and in various forms. We have seen non-ethical providers offering financial incentives to local Elders to identify community members who may be on the NDIS and to encouraghem to sign new Service Agreements. Providers have also travelled to participants’ homes in very remote communities—sometimes up to six hours away from their base—and offered fast food, money, alcohol, and accommodation to entice participants away from their communities.
This behaviour is predatory and undermines informed consent, particularly for participants with limited literacy, limited English, or cognitive impairments.
2. Relocation Of Participants Away From Their Communities
We have witnessed multiple cases where participants are removed from their remote communities and relocated to urban centres such as Alice Springs. Providers offer accommodation as an incentive, but the conditions are often unsafe and overcrowded. We are aware of properties housing more than 30 people at a time, including adults, children, and individuals from different cultural groups.
Once relocated, participants frequently lose connection to their community supports, cultural networks, and family structures. They consequently experience increased levels of vulnerability arising from a decline in access to health and other support services and living in overcrowded, unhygienic environments with high rates of alcohol and drug use and exposure to violence.
When participants express a desire to return home, providers often make this extremely difficult by:
- Intentionally causing them to miss scheduled transport
- Withholding or retaining their personal belongings
- Restricting access to communication devices
- Creating financial dependency through control of payments
These actions effectively trap participants in urban settings where they are isolated and extremely vulnerable.
3. Financial Exploitation And Control Of Income
Some providers have been known to link participants’ Centrelink payments directly to the provider. This leaves participants with even less financial autonomy and places them in a significantly worse economic position. Many participants already live below the poverty line
and have limited access to mobile phones or transport, making it difficult to seek help or report concerns.
When incentives run out, family members who were staying in the accommodation often leave, abandoning the participant in unsafe or unsuitable living conditions. This further entrenches the participant’s dependence on the provider.
4. Barriers To Changing Providers
Participants who transfer to these providers often find it extremely difficult to return to their original provider or to switch to a new one.
Providers may:
- Mislead participants about their rights
- Use intimidation or coercion to prevent disengagement
- Change Plan Managers to limit other providers from claiming on supports being provided
This behaviour directly undermines participant choice and control, a core principle of the NDIS.
5. Misuse Of Positions In Government And Community Services To Channel
Participants To Associated NDIS Providers We have observed a recurring pattern in which individuals employed within government agencies, community health services, and other service systems use their professional roles to identify potential NDIS participants and refer them to NDIS businesses with which they have a personal, financial, or organisational connection.
CCNT has experienced multiple instances where newly employed Coordinators of Support failed to disclose their association with external NDIS providers. In several cases, these individuals were later found to be Directors or Owners of NDIS businesses. While employed by CCNT, they used their position to refer participants to their own or affiliated businesses without declaring any conflict of interest. These conflicts were only discovered by chance, after which CCNT reported the matter to the NDIS Quality and Safeguards Commission and followed internal processes that resulted in the staff member’s employment being terminated.
We have also encountered individuals working within Northern Territory Government roles who have direct links to NDIS providers. These individuals have used their positions of authority and trust to refer or connect participants to their associated NDIS businesses, often without transparency or proper consent.
Similar behaviour has been observed across multiple settings, including:
- NDIA staff
- Taxi drivers
- Hospital and health service staff
- Aged care providers
- Dialysis clinics
- Aboriginal Hostels
- Remote Community Connectors
In addition, we have seen individuals with strong connections to remote Aboriginal communities identify vulnerable people—particularly those with substantial NDIS funding— and pass their details on to providers in exchange for payment. This practice represents a serious breach of privacy, cultural safety, and ethical standards.
These behaviours distort the NDIS market, undermine participant choice and control, and create environments where vulnerable people are targeted for financial gain rather than supported for their genuine needs.
(b) the impacts of non-compliance on NDIS participants and their families;
Non-compliance, fraud, and sharp practices (Predatory Practices) within the NDIS have significant and far-reaching consequences for participants, their families, and their communities. The impacts extend beyond financial loss and service disruption—they affect safety, health and wellbeing, cultural connection, trust in the system, and long-term outcomes.
Based on the patterns observed across remote communities the following key impacts are evident.
1. Increased Risk And Exploitation And Abuse
Sharp practices—such as relocating participants, withholding possessions, controlling finances, or overcrowding accommodation—create environments where exploitation can flourish. Participants with intellectual or psychosocial disability are particularly vulnerable. Impact:
- Exposure to physical, emotional, and financial abuse
- Unsafe living conditions
- Increased vulnerability due to isolation from family and community
- Heightened risk of harm due to lack of oversight
- Diminished health and wellbeing
Families often feel powerless to intervene, especially when participants are moved far from home.
2. Disconnection From Family, Culture And Community
Relocating participants from remote communities to urban centres—often without proper consent—has severe cultural and social consequences. Participants lose connection to:
- Family
- Elders
- Country
- Cultural obligations
- Community support
Impact:
- Cultural harm and loss of identity
- Emotional distress
- Breakdown of family relationships
- Reduced engagement in culturally safe supports
3. Decline In Health And Wellbeing
Non-compliant providers often prioritise billable hours over genuine therapeutic outcomes. Participants may receive:
- Inappropriate supports
- Excessive or unnecessary services
- No meaningful support at all
Overcrowded accommodation, poor nutrition, lack of medication management, and limited access to healthcare further compromise wellbeing.
Impact:
- Deterioration in physical health
- Worsening mental health
- Increased hospitalisations
- Reduced functional capacity
4. Decline Of Trust In The NDIS And Service System
When participants and families experience exploitation or observe unethical behaviour from providers, government staff, or community workers, trust in the NDIS is severely damaged. Impact:
- Participants become reluctant to engage with supports
- Families avoid seeking help due to fear of exploitation
- Communities lose confidence in government systems
- Genuine providers face suspicion and reduced engagement
This decline of trust undermines the long-term success of the NDIS in remote and Aboriginal communities.
5. Market Distortion And Reduced Access To Quality Supports
Non-compliant providers often dominate vulnerable markets by using incentives, coercion, or insider referrals. This pushes out ethical providers who cannot compete with illegal or unethical tactics.
Impact:
- Participants have fewer quality providers to choose from
- Remote communities become saturated with exploitative operators
- Ethical providers struggle to maintain viability
- Long-term service quality declines
6. Emotional Distress And Family Breakdown
Families experience significant stress when their loved ones are exploited, relocated, or financially controlled. They may spend months trying to bring participants home or re-establish safe supports.
Impact:
- Anxiety, fear, and emotional exhaustion
- Breakdown of trust between participants and family members
- Long-term trauma for both participants and relatives
(c) the effectiveness and adequacy of successive government policies to improve
Scheme integrity, safeguard participants, and tackle non-compliance; and
From our experience as an ethical, place-based NDIS service provider working with participants in remote and very remote Aboriginal communities, the effectiveness of successive government policies aimed at improving Scheme integrity has been limited. While policy frameworks and regulatory bodies exist, the practical implementation and enforcement of these measures have not been sufficient to protect participants from predatory behaviour or to support providers who report wrongdoing.
Further, the failure to implement commissioned NDIS services in remote communities that are community led and participant driven as recommended in the NDIS reform review has left the door open for a plethora of poor quality, profit driven, predatory providers to exploit remote Aboriginal NDIS participants who experience high levels of vulnerability.
1. Limited Action Following Reports To The NDIS Quality And Safeguards
Commission And Fraud Teams As an organisation, we have made numerous reports to both the NDIS Quality and Safeguards Commission and the NDIS Fraud Team regarding serious concerns about provider misconduct, exploitation, and systemic non-compliance. Despite the seriousness of these matters, we have observed:
- Little to no visible action taken in response
- Minimal feedback on the outcome of investigations
- Long delays before any acknowledgement or follow-up
- No apparent reduction in the behaviour of the providers reported
- Lack of data integration and information sharing across NDIS agencies
- Deflection of responsibility for investigation and action between the Commission, the Fraud Team and the NDIA.
- Commission staff being more concerned about maintaining engagement with predatory providers than taking discernible action against them.
In several cases, after lodging a complaint about another provider, we have received a complaint made against us shortly afterwards. While we take all complaints seriously and respond appropriately, this pattern creates the perception of a retaliatory “tit-for-tat” environment rather than a robust, impartial regulatory system. This dynamic discourages providers from reporting misconduct and emboldens non-compliant operators who face little consequence for their actions.
2. Misalignment Between Government Agencies
We are currently working with the NDIS Internal Integrity Strike Force Operations regarding concerns about clusters of predatory providers who appear to be working together to target vulnerable participants. This engagement has been constructive and indicates that some parts of government are actively attempting to address systemic issues.
However, at the same time, we have experienced the NDIA encouraging us to collaborate with these very same providers—particularly in very remote Aboriginal communities where service options are limited. This creates a direct conflict between:
- Integrity and compliance efforts, and
- Operational pressures to maintain service delivery in remote areas
The result is a confusing and contradictory environment where one arm of government identifies certain providers as high-risk or predatory, while another arm encourages partnership with them to meet service gaps.
This misalignment:
- Undermines confidence in regulatory processes
- Creates uncertainty for providers attempting to act ethically
- Exposes participants to ongoing harm
- Signals to non-compliant providers that consequences are unlikely
3. Insufficient Protection For Participants And Ethical Providers
Despite multiple policy reforms over the years, the current system does not adequately safeguard participants—particularly those who are:
- Living in poverty
- Experiencing homelessness or overcrowded housing
- Living with intellectual or psychosocial disability
- From remote Aboriginal communities with lower levels of literacy
- Lacking access to phones, transport, or advocacy
Participants continue to be targeted, relocated, financially exploited, and coerced with little intervention from heavily resourced regulatory bodies.
Ethical providers who report misconduct often face:
- Administrative burden
- Retaliatory complaints
- Lack of support
- Conflicting instructions from different agencies
This environment discourages transparency and weakens the integrity of the Scheme.
(d) any legislative or other reforms required to strengthen Scheme integrity.
Based on our experience working with participants in remote and very remote communities, there are several critical reforms that would significantly strengthen Scheme integrity, improve oversight, and reduce opportunities for predatory behaviour. These reforms relate to workforce screening, provider registration, regulatory presence in remote communities, and systemic transparency.
1. Strengthening The NDIS Workers Screening Check To Capture Conflict Of
Interest The current NDIS Worker Screening Check focuses primarily on criminal history and risk of harm, but it does not adequately address conflicts of interest, which are a major driver of non-compliance and exploitation.
We recommend legislative reform to expand the Worker Screening Check to include:
- Mandatory disclosure of all NDIS provider affiliations held by an individual
- Visibility of how many NDIS businesses a worker is linked to
- Identification of workers who hold ownership, directorship, or financial interests in multiple providers
- A centralised system accessible to employers, allowing them to verify whether staff have undeclared connections to other providers
This would help:
- Prevent staff from using their employment to funnel participants to their own businesses
- Reduce hidden conflicts of interest
- Support providers to make informed hiring decisions
- Identify individuals connected to clusters of high-risk or predatory providers
This reform would close a significant loophole currently exploited by individuals operating across multiple NDIS entities without transparency.
2. Implementing Commissioning Models In Remote Communities
The NDIS Royal Commission recommended establishing Commission-led models in remote communities to provide stronger oversight, cultural safety, and on-the-ground regulation. We strongly support this recommendation.
Implementing these models would:
- Provide a visible regulatory presence in communities where predatory providers currently operate with minimal oversight
- Allow for real-time monitoring of provider behaviour
- Improve cultural safety and ensure supports are delivered in ways that respect local community structures
- Reduce the ability of external providers to enter communities, recruit participants through incentives, and relocate them to urban centres
- Strengthen relationships between regulators, community leaders, and participants
This reform is essential to safeguarding vulnerable Aboriginal participants who are disproportionately targeted by unethical providers.
3. Enabling The NDIS Commission To Conduct Its Own Registration Audits
Currently, the NDIS Commission relies heavily on third-party auditors to assess provider compliance during registration and renewal. This system has several weaknesses, including inconsistent audit quality, limited cultural competence, and the ability of non-compliant providers to “shop around” for lenient auditors.
Allowing the NDIS Commission to conduct its own audits—particularly for high-risk providers—would:
- Improve consistency and quality of assessments
- Reduce opportunities for providers to manipulate or influence audit outcomes
- Strengthen enforcement of standards
- Increase accountability for providers operating in remote and vulnerable communities
- Ensure that cultural safety, participant safeguarding, and ethical conduct are assessed directly by the regulator
This reform would significantly enhance the integrity of the provider registration system.
4. Improving Inter-Agency Alignment And Information Sharing
As noted earlier, there are significant inconsistencies between the actions of different government bodies—for example, the Integrity Strike Force identifying high-risk providers while the NDIA simultaneously encourages collaboration with them.
Legislative or policy reform should mandate:
- Clear information-sharing protocols between NDIA, the NDIS Commission, and integrity units
- Unified risk assessments so that all agencies operate from the same evidence base
- Consistent messaging to providers about who is safe to collaborate with
- Joint enforcement strategies in remote communities
This would reduce confusion, strengthen compliance, and prevent predatory providers from exploiting gaps between agencies.
Contacts:
redacted
CatholicCare NT
17 Hidden Valley Road, Berrimah NT 0828
Email: redacted