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Submission to the Joint Standing Committee on the National Disability Insurance Scheme

Inquiry into the Integrity of the National Disability Insurance Scheme

Focus: Rural and Remote Allied Health Perspectives
Sector: Allied Health Practitioners and Services in Rural and Remote Australia

April 2026

About Services for Australian Rural and Remote Allied Health

Services for Australian Rural and Remote Allied Health (SARRAH) is the peak body representing rural and remote allied health professionals (AHPs) working in the public, private and community sectors, across primary and other health settings, disability, aged care, and other service systems. SARRAH was established in 1995 as a network of rurally based allied health professionals and continues to advocate on behalf of rural and remote communities to improve access to allied health services and support equitable and sustainable health and well-being. SARRAH maintains that every Australian should have access to health services wherever they live and that allied health services are fundamental to the well-being of all Australians.

Executive Summary

Rural and remote allied health professionals play a critical role in enabling National Disability Insurance Scheme (NDIS) participants living in rural and remote areas to access essential supports. However, geographic isolation, workforce shortages, thin service markets, and high operational costs shape both how services are delivered and how compliance frameworks are experienced outside metropolitan areas.

This submission argues that while protecting the integrity of the Scheme is essential, integrity measures must be context-sensitive. Current approaches to non-compliance risk unintentionally penalising ethical rural and remote providers, exacerbating service withdrawal and reducing choice and control for participants.

Strengthening NDIS integrity must therefore involve:

  • Targeted action against genuine fraud and exploitative “sharp practices”, and

  • Regulatory, pricing, and oversight reforms that support ethical practice in rural and remote markets, rather than destabilise them.

                      Services for Australian Rural and Remote Allied Health
   G490 Northbourne Avenue Dickson ACT 2026 | 1800 338 061 |www.sarrah.org.au

1. Nature and Extent of Non-Compliance, Including Fraud and Sharp Practices

SARRAH acknowledges that fraud and sharp practices undermine confidence in the Scheme and risk harm to participants. However, evidence from service delivery on the ground suggests that systemic non-compliance is not driven by small rural allied health practices, who are typically:

  • Highly visible in their communities
  • Personally known to participants and families
  • Operating under significant professional, cultural, and reputational scrutiny

Reported sharp practices—such as over-servicing, inducements, or high-pressure sales—are far less prevalent in rural and remote settings, where:

  • Choice of provider is limited
  • Relationships are long-standing
  • Overservicing is impractical due to workforce constraints

Conversely, rural allied health providers report being caught by compliance flags designed for metropolitan markets, including higher service costs driven by travel time, accommodation, and low client density.

2. Impacts of Non-Compliance Responses on NDIS Participants and Families

For rural and remote participants, the consequences of integrity crackdowns can be severe, even when non-compliance is not established.

Reported impacts include:

  • Sudden withdrawal of services when providers exit the Scheme due to regulatory burden or financial risk
  • Increased wait times or complete lack of access to allied health supports
  • Participants travelling hundreds of kilometres for care or going without services altogether

When ethical providers reduce or cease NDIS participation due to changes in pricing arrangements, participants bear the cost. In thin markets, loss of a single provider can eliminate all local service options.

Families and participants report confusion and distress when services are interrupted, particularly where providers are forced to make business decisions based on changes to funding rules and pricing arrangements.

3. Effectiveness and Adequacy of Government Policies to Improve Scheme Integrity

Successive integrity measures have emphasised compliance enforcement, audit activity, and payment controls. While these are necessary tools, their uniform application has had disproportionate impacts in rural and remote contexts.

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Key concerns include:

  • Pricing structures that fail to reflect rural realities, in particular the high costs associated with delivering services to rural and remote participants
  • Insufficient guidance distinguishing unethical sharp practices from legitimate rural service adaptations
  • Compliance systems that prioritise transactional data over participant outcomes and professional standards

Positive steps—such as stronger registration requirements and clearer provider conduct expectations—have improved baseline quality. However, allied health professionals are already among the most regulated workforces in the care economy. Whether through Ahpra registration or robust professional self‑regulation, there are clear entry standards, scopes of practice, codes of conduct, and mechanisms for addressing quality and safety concerns.

If new integrity settings fail to recognise these existing safeguards—and instead layer on costly, duplicative requirements—they risk pushing ethical providers out of the NDIS entirely. In metropolitan markets, that may reduce choice for participants. In rural and remote markets where allied health supply is fragile, it can eliminate access altogether.

SARRAH has commissioned the report “Outreach or Out-of-reach? Access to Occupational Therapy Services in Australia”1 to demonstrate the impact of broad scale changes to pricing arrangements on access to services. Key findings from the report show that more than 550,000 Australians had no Occupational Therapist (OT) within a 30-minute drive, meaning they had no practical access to basic OT assessment or intervention. This includes:

  • 126,548 children
  • 273,00 people with chronic conditions
  • 111,473 older adults
  • 88,311 First Nations people
  • 53,625 unpaid carers
  • 29,549 people requiring assistance with daily activities

These groups often had the highest need for functional support, home modifications, assistive technology, early intervention, and rehabilitation.

Further, access gaps fall overwhelmingly on rural and remote Australia:

  • 93% of people without an OT within 30-minutes live in medium and small rural towns, remote, and very remote communities (Modified Monash Model (MMM 4-7).
  • Very remote communities (MMM 7), 64.1% of residents had no OT access within 30- minutes.

These patterns reflect structural spatial inequities, where service models and funding arrangements reflect metropolitan assumptions, leaving rural communities reliant on long- distance outreach, limited local workforce, and fragile markets.

The findings suggest that access inequities are predictable, systemic, and spatially patterned. The people and places most in need of OT due to complex intersecting needs, including, rural

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communities, First Nations people, children, older adults, and low-income populations, are the least able to obtain it from an in-person occupational therapist. Recent changes to NDIS travel reimbursement, which reduce billable travel time for therapists, set a dangerous precedent for the financial sustainability of out-reach services. The realities of rural practice, including necessity for travel, the existence of thin markets, and limited workforce availability must be factored into funding policies and integrity measures. These inequities cannot be solved by workforce growth alone. They require targeted, place-responsive policy action that recognises geographic disadvantage and corrects the structural conditions that currently limit equitable service provision.

4. Legislative and Other Reforms Required to Strengthen Integrity Without Harming Access

To protect both scheme integrity and participant access, reforms should recognise rural and remote allied health service delivery as a distinct service context.

4.1 Context-Sensitive Compliance Frameworks

  • Introduce rural and remote compliance assessment guidelines that explicitly account for distance, workforce scarcity, and service integration

  • Ensure audits and investigations include clinical, cultural, and geographic expertise

4.2 Clearer Definitions of Sharp Practices

  • Provide practical, profession-informed guidance on what constitutes sharp practice versus ethical, efficient service delivery in low-density markets

  • Avoid blanket assumptions based on service volume or cost alone

4.3 Pricing and Market Stewardship Reform

  • Review NDIS pricing to ensure it supports lawful, sustainable service provision in rural and remote areas

  • Recognise that underpricing can incentivise poor practice while driving ethical providers out of the Scheme

4.4 Support for Ethical Providers

  • Establish advisory or remediation pathways for minor or unintentional non-compliance, rather than default punitive responses

  • Partner with professional bodies and rural health organisations to deliver education- focused integrity initiatives

4.5 Participant-Centred Integrity Measures

  • Assess integrity not only through financial compliance, but through participant outcomes, continuity of care, and access equity

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Conclusion

Rural and remote allied health providers are critical partners in achieving the objectives of the NDIS. They share a strong commitment to ethical practice, participant wellbeing, and scheme sustainability.

A one-size-fits-all approach to integrity risks damaging the very service markets the Scheme depends upon. Genuine fraud and sharp practices must be addressed decisively—but in ways that do not erode access for people with disability living outside major cities.

Strengthening NDIS integrity must therefore mean protecting participants from harm while also protecting ethical providers from unintended system harm—particularly in rural and remote Australia, where the consequences of policy misalignment are felt most acutely.

Recommendations:

  • Strengthen modelling of government funding to reflect geographic realities including analysis of distance and costs in rural and remote areas.
  • Invest in a rural and remote allied health workforce strategy with long-term system supports, rural pipeline development and investment in allied health rural generalist training.
  • Support First Nations-led models of allied health service delivery, strengthening community governance and local workforce pathways.
  • Commission services in thin markets, including multidisciplinary outreach teams, rather than relying on fee-for-service viability.
  • Prioritise disadvantaged communities (both urban and rural) for targeted investment.
  • Improve national allied health workforce data to support evidence-based workforce planning.
  • Adopt a national health service access index to guide equitable funding and infrastructure distribution.

1 Hayes, K., McDonald, S., Coxon, K., Thyer, L., Bye, R. (2026). Outreach or Out-of-reach? Access to Occupational Therapy Services in Australia. Services for Australian Rural and Remote Allied Health (SARRAH). https://pub-a88cfd0f28594a8ab1a31dc90c073b60.r2.dev/Outreach%20or%20Out%20of%20Reach%201.1.pdf

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