Psychotherapy and Counselling Federation of Australia Submission to the Joint Standing Committee on the National Disability Insurance Scheme
24 April 2026
This response is written by the Psychotherapy and Counselling Federation of Australia (PACFA), the leading national peak body for the tertiary-qualified counselling and psychotherapy profession. With more than 12,000 members, PACFA provides registration and quality assurance services for counsellors nationally.
In this response the terms “counsellor” and “psychotherapist” can be used interchangeably to refer to tertiary qualified allied health professionals registered with PACFA as Certified Practicing Counsellors (entry level), Registered Clinical Counsellors (full Scope of Practice) and Registered Clinical Psychotherapists (extended Scope of Practice).
Recommendations
- That the NDIS prioritise the engagement of PACFA‑registered counsellors to deliver mental health supports, supported by a pricing rate that more accurately reflects their qualifications, training, and professional responsibilities.
- That the use of Therapy Assistants within counselling therapy supports be discontinued to reduce risk for clients and practitioners.
- That PACFA‑registered counsellors be more effectively utilised in the delivery of counselling and therapeutic supports. Recognising the opportunity to draw on their specialised and profession‑specific expertise, including high quality provision of employment counselling and creative therapies.
Response to Terms of Reference
1. The nature and extent of non-compliance, including fraud and sharp practices,
in the National Disability Insurance Scheme
PACFA is concerned about the ability of unregistered or underqualified counsellors to deliver mental health services within the NDIS. Unregistered and undertrained
counsellors do not possess the training, supervised practice, or professional regulation required to deliver high-quality therapeutic supports. These practitioners are particularly ill-suited to providing therapeutic services to highly vulnerable or complex clients such as people with disabilities.
The vocational counselling workforce consists of practitioners trained through the TAFE or private training sector at Diploma or Certificate levels (AQF Levels 5 and 6 or below), particularly since 2010. These programs are typically shorter in duration, often taking weeks or months rather than years, and focus on developing foundational counselling skills. Designed to prepare “paraprofessionals,” they result in markedly different competencies, scopes of practice, and professional identities when compared with degree-qualified counsellors. This can result in inconsistent standards of care and limited accountability on the practitioner.
The inclusion of underqualified counsellors providing therapy supports has led to a Pricing structure that does not adequately reflect the training and professional responsibilities of tertiary qualified counsellors. Restricting counselling provision to highly trained and accountable PACFA registrants, supported by an appropriate Pricing rate, would ensure these supports are clearly linked to participants’ disability needs, deliver better value for money, and are effective in supporting participants to work towards their goals.
PACFA recommends that counsellors delivering NDIS supports hold tertiary‑level qualifications and are subject to robust professional accountability, including adherence to a Code of Ethics and professional conduct procedures. These standards are already met by PACFA’s 12,000+ registered practitioners. In addition to our ethical and practice safeguards, registrants are provided with consistent professional development opportunities to expand their practice and access to quality supervision.
2. The effectiveness and adequacy of successive government policies to
improve scheme integrity, safeguard participants, and tackle non-compliance.
The recent introduction of Therapy Assistants to support the delivery of counselling services introduces additional risk for both clients and providers. Counselling, as a professional mental health intervention, has not traditionally incorporated the use of Therapy Assistants (unlike some models within psychology and allied health), indicating the emergence of a new and untested model of care for counselling services.
This development raises significant concerns regarding clinical appropriateness, Professional boundaries, and risk management. Therapy Assistants providing counselling services would not be covered under the professional indemnity insurance of a supervising counsellor, as required under NDIS arrangements. As a
result, permitting Therapy Assistants to deliver counselling to NDIS participants creates a substantive risk, both to participants and to service providers, by enabling uninsured practice within a high‑risk clinical environment.
The absence of established standards, supervision frameworks, and insurance coverage for Therapy Assistants delivering counselling underscores the need for urgent clarification and safeguards to prevent unintended harm to NDIS participants.
3. Suggested Reforms to Strengthen Scheme Integrity:
Formal recognition of tertiary-qualified Counsellors
Formally recognising tertiary‑qualified counsellors as the profession best equipped to deliver counselling services would lead to more efficient use of funding and a more targeted therapeutic approach.
Counselling is a specialised professional practice focused on facilitating therapeutic change for individuals, couples, families and groups. Professional counselling is distinct from the use of counselling skills by other practitioners in various service settings. While many professionals employ basic counselling skills in their work, professional counselling represents a unique, relational discipline grounded in rigorous training and ethical standards. Professional counselling practice is underpinned by a combination of specialised knowledge, professional attributes and advanced interpersonal and therapeutic skills, all of which contribute to effective and ethical therapeutic work.
Other health professions are increasingly offering “counselling” services at significantly higher price points, despite not having the specialised training or qualifications required for professional counselling practice. PACFA counsellors, whose training meets rigorous accreditation standards, are equipped to deliver an integrative practice tailored to a client’s specific issues, distinguished from other health professionals trained in shorter or less specialised pathways.
Despite tertiary-trained counsellors holding equivalent qualifications and registration, NDIS pricing sets the remuneration for service delivery considerably lower than equivalent Allied Health professions such as Social Work or Occupational Therapy. Limiting the provision of counselling services to registered counsellors, and revising the pricing accordingly, would significantly increase safeguards for NDIS participants and reduce the risk of fraud.
The role for specialised counselling in creative therapies and employment supports
PACFA welcomed the Final Report of the Duckett Review, which affirmed the important role creative therapies provided by qualified counsellors play in supporting many NDIS participants. PACFA’s College of Creative and Experiential Therapies (CCET) is well positioned to provide the NDIS with a regulated, professionally
accountable workforce of creative therapists, directly addressing Dr Stephen Duckett’s concern that these developing professions are not yet nationally regulated.
CCET’s rigorous membership standards, ethical governance, and digital credentialing system offers the quality assurance the Review called for. This will further assist in clearly delineating between creative therapies delivered as clinical therapeutic supports, and non-therapeutic supports. Recognition of CCET practitioners as NDIS providers would enhance safety and strengthen access to clinically proven creative therapy supports.
Similarly, registered counsellors are well-placed to provide employment counselling, supporting participants to successfully engage in or return to paid employment. The findings of a systematic review into Return-to-Work interventions provide strong support for the role of counsellors in this space. Evidence indicates that low-intensity, CBT-informed approaches are effective in supporting individuals with both psychological and musculoskeletal conditions to re-enter the workforce, and that more intensive, costly interventions offer limited additional benefit.
Low-impact strategies, such as behavioural activation, goal setting, and cognitive reframing, can be effectively utilised by tertiary-trained counsellors and psychotherapists. As such, the profession is uniquely positioned to deliver accessible, evidence-based return-to-work support at scale. Increased opportunities and fair remuneration for appropriately trained counsellors will strengthen workforce capacity and enhance timely access to care for NDIS participants.
About PACFA registrants
PACFA registration allows employers and funding bodies to recognise verified counsellors who meet high professional standards to support their communities. PACFA maintains rigorous registration criteria and is proud to uphold the highest standards in the sector. All registrants must practise within PACFA’s Scope of Practice and adhere to the Code of Ethics and grievance procedures. To be registered with PACFA, practitioners must meet the following requirements:
- ‘Certified Practising Counsellors’ must have completed an accredited course or equivalent (this mandates that the course must be Bachelor or postgraduate level, (AQF 7-9) and include a placement and clinical supervision).
- ‘Registered Clinical Counsellors’ must have completed the above plus an additional 750 hours of client contact and 75 hours of clinical supervision over more than two years. This recognises the experience of senior counsellors.
- ‘Registered Clinical Psychotherapists’ must be a clinical member of PACFA as above and have completed significant specialised psychotherapy training as well as personalised therapy
As with PACFA’s clinical psychotherapists, counsellors can provide specialised counselling across a range of disciplines to provide the right care for a client’s needs. PACFA’s specialist colleges allow for registrants to be recognised as a specialist in the fields of Psychotherapy, Relationship Counselling, Indigenous Healing Practices, Creative and Experiential (art) Therapies, and Clinical Supervision for a range of service providers.
Incoming National Standards
Counselling is an underutilised asset in the mental health workforce and can play a significant role in prevention, early intervention and recovery. In October 2025, PACFA welcomed the National Standards for Counsellors and Psychotherapists published by the Australian Department of Health, Ageing and Disability.
The implementation of these standards, over the next three to five years, will promote greater access to registered counsellors in a wide range of clinical settings and will contribute to a more sustainable mental health system. This project will confirm counsellors and psychotherapists as a health and mental health workforce, signifying a turning point for the profession in addressing barriers to workforce utilisation and increasing our capacity to support Australians in distress.
PACFA’s high standards align closely with those established in the National Standards, and we are proud to see the quality and professionalism of our members recognised as the benchmark for the industry. This confirmation of counsellors and psychotherapists as a key part of the mental health workforce will assist in providing flexible and multidisciplinary healthcare that meets the needs of the community.
Further information
Please see our website for further information on PACFA’s work and publications. For further information about how the National Disability Insurance Scheme could utilise PACFA members, or the clinical practice of counselling and psychotherapy, please contact:
Johanna de Wever
Chief Executive
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