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Integrity of the NDIS - OTA Submission - April 2026
Australia
Introduction
About Occupational Therapy Australia
OTA is the peak membership body representing occupational therapists nationally. We empower and elevate over 34,000 exceptional professionals who in turn work in partnership with individuals and communities to enable meaningful participation in the activities of life. We’re the single, unifying connection point for occupational therapists in the nation, leading the profession through education, support, and advocacy, so every occupational therapist is informed, inspired and fulfilled in their profession.
As one of Australia’s largest allied health workforces, occupational therapists provide essential supports across primary care, aged care, disability, mental health, veteran care and more.
Terms of Reference
The Joint Standing Committee on the National Disability Insurance Scheme will inquire into and report on:
- the nature and extent of non-compliance, including fraud and sharp practices, in the National Disability Insurance Scheme;
- the impacts of non-compliance on NDIS participants and their families;
- the effectiveness and adequacy of successive government policies to improve scheme integrity, safeguard participants, and tackle non-compliance; and
- any legislative or other reforms required to strengthen scheme integrity.
Recommendations
OTA’s recommendations for the Standing Committees on the NDIS are:
- Recommendation 1: Government NDIS Reference Group: OTA requests an opportunity to be part of the Government NDIS Reference Group, so we can provide ongoing feedback to improve the integrity of the NDIS.
- Recommendation 2: Integrity Measures for Early Career Practitioners: OTA encourages the Australian Government to consider integrity measures that explicitly recognise workforce development and clinical supervision as protective factors for early career occupational therapist practitioners.
Integrity of the NDIS - OTA Submission - April 2026
Australia
OTA Feedback
Occupational Therapy Australia (OTA) welcomes the Australian Government’s efforts to take stronger measures to find and stop fraud and serious organised crime in the NDIS.
As the national peak body for occupational therapy, OTA takes its role in supporting the occupational therapy profession seriously, which includes supporting the workforce to enhance clinical governance. Clinical governance is strongly connected to the subject of this inquiry, and strengthening clinical governance across the sector will help to prevent fraud and organised crime.
Integrity Measures to Support Early Career Practitioners
OTA is concerned about the heightened vulnerability of early career practitioners working in or alongside the NDIS. New graduates and clinicians in their first years of practice may have limited experience navigating complex funding rules, high workloads, and competing expectations from participants, families, support coordinators, and providers. In some settings, early career practitioners may be asked to sign off on assessments, reports, or invoices without adequate time, mentorship, or access to senior clinical review - creating risk for unintentional non-compliance, poor-quality recommendations, and, in the worst cases, exposure to coercion or sharp practice.
These risks are amplified where employers of occupational therapists are not occupational therapists or do not have allied health clinical leadership embedded in governance structures. OTA’s Essential Guide to Early Career Practitioners is directed to employers and sets clear expectations for clinical governance: defined scope of practice, appropriate delegation and sign-off processes, protected supervision time, transparent billing and record-keeping practices, and a culture that supports escalation and speaking up. Effective clinical governance is a practical integrity safeguard - it reduces opportunities for fraud and sharp practice, and it helps ensure that every claim is supported by clinically appropriate assessment, documentation, and participant- centred outcomes.
OTA encourages the Committee to consider integrity measures that explicitly recognise workforce development and clinical supervision as protective factors. This could include clearer guidance on minimum supervision expectations for early career practitioners delivering NDIS-funded services; stronger requirements for provider policies on documentation, conflicts of interest, and clinical independence; and procurement and pricing settings that do not inadvertently incentivise volume over quality. Supporting employers to implement robust governance - particularly in multidisciplinary and
Integrity of the NDIS - OTA Submission - April 2026
Australia
corporate settings - will help protect participants from harm, support early career clinicians to practise safely, and strengthen community confidence in the NDIS.
Without measures that facilitate, enable, and require strong clinical governance, there is a risk that the issues outlined above are exacerbated by national and global environmental conditions. There is growing uncertainty amongst the Occupational Therapy sector about the NDIS Reforms, and events overseas are not making it easy for Occupational Therapists to fuel up and provide services to clients in their homes, as well as to travel to and from work.
To aid the Australian Government’s efforts to improve the integrity of the NDIS, OTA wishes to be part of a Government NDIS Reference Group to provide ideas and assist the Government in improving the financial sustainability of the scheme, and tackle issues such as fraud, over-charging and waste in the scheme.
OTA Policy & Advocacy
OTA continues to develop policy & advocacy papers on a range of issues. In March 2026 we developed OTA’s NDIS Rules - New Framework Planning Submission. One area for improved scheme integrity is around assessments. In the past the NDIS assessment process has been overly, and many reports are not fully read by the NDIA.
Under the NDIS Reforms and the move to NDIA Assessors there is an opportunity to streamline assessment reports and the scheme costs. However, if the Australian Government intends to create a new NDIA Assessors public servant role, then it is vital that occupational therapists are employed within the assessment team. Occupational therapists are uniquely trained and qualified to do this work and the occupational therapy workforce has the experience and expertise to complete support needs assessments & replacements assessments in ways that optimise outcomes for participants and sustainability for the NDIS. Please see the Appendix below for the:
- 2026 OTA’s NDIS Rules - New Framework Planning Submission.
- 2026 OTA Federal Budget Submission.
- 2026 OTA Annual Pricing Review Submission.
OTA would welcome the idea of the NDIS Quality and Safeguards Commission and the NDIA providing regular briefings to OTA Members on the NDIS Reforms and the ongoing work to improve the integrity of the NDIS. OTA holds regular Member Forums with occupational therapists around the country, and they would be highly interested in hearing directly from the NDIA & the NDIS Quality and Safeguards Commission.
Integrity of the NDIS - OTA Submission - April 2026
Australia
Finally, OTA wishes to note that the Australian Government has recently passed the National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Bill 2025. This bill delivers tough new laws to protect people with a disability and safeguard the NDIS from exploitation. The bill will ensure tougher penalties for those responsible for serious misconduct and unsafe practices within the scheme. However, whilst recent legislation is a positive step, there is always more the Government can do to ensure that the intent of the legislation is delivered in practice. Hence, why OTA requests an opportunity to be part of the Government NDIS Reference Group, so we can provide ongoing feedback to improve the integrity of the NDIS.
Conclusion
OTA welcomes the opportunity to provide this submission to this Inquiry into the Integrity
of the NDIS. OTA is always available to brief this committee about OTA’s submission. We
are available at redacted
Integrity of the NDIS - OTA Submission - April 2026
Occupational Therapy Australia | 5 / 340 Gore St, Fitzroy VIC 3065 | 1300 682 878 | OTAUS.COM.AU