Submission Details
- Submitted To: Joint Standing Committee on the National Disability Insurance Scheme
- Submitted By: Support Management Solutions Pty Ltd, trading as First2Care
- Contact Person: Peter Withey, Chief Executive Officer
- Contact Information: 1300 322 273
- Submission Date: 24 APR 2026
1.1 Terms of Reference
- 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.
2. Overview of Feedback
- Purpose of Submission:
This submission provides a position of understanding and experiences of integrity within the NDIS from the position and perspective of a Registered Plan Manager. First2Care is a plan manager with mature systems, powerful bespoke technology, and lived experience of disability.
Integrity is essential not only to prevent fraud and misuse, but also to preserve public trust and long-term viability of the NDIS.
- Key Areas of Focus:
- This submission will focus on observations and challenges identified in the scope of financial administration
- The role of the Plan Manager, including de-identified case studies
- Recommendations and opportunities in the context of the terms of reference
3. Observations and Challenges
3.1. Ambiguity in Support Eligibility
One of the most significant integrity risks arises from unclear or broadly interpreted support categories. Where guidance is not explicit:
- Plan Managers are used by the Agency as a knowledge and claims backstop, shifting accountability and support away from the Agency in the intent or allowance of Plan funds.
- Providers may submit claims for items that fall outside NDIS scope, invoiced as a compliant NDIS Support
- NDIA policy is slow to release, unclear, and contradictory.
- Participants and stakeholders receive inconsistent advice from all areas of the NDIA.
This ambiguity increases the risk of both unintentional misuse and deliberate exploitation.
3.2 Inconsistent Application of Pricing Arrangements
The NDIS Pricing Arrangements and Price Limits provide essential safeguards. However, integrity risks emerge where:
- Incorrect claiming methods are used
- Non-face-to-face, travel, or cancellation claims are misapplied
- Pricing limits are exceeded, incorrectly interpreted, or bypassed through manipulation of evidence (invoices)
Without consistent enforcement, these inconsistencies can lead to significant financial misuse of NDIS funds. Training and requirements of support coordinators and service providers should be mandated by NDIA
3.3 Funding Period Misuse
A common area of inconsistent advice provided is in the understanding and allowance of spend applied to funding periods. This increases risk on the Scheme, Participants and Service Providers.
Risks include:
- System allowances and NDIA advice for services to be back-paid from future funding periods when they are released. Resulting in onboarding funding overspend.
- Pressure on Plan Managers to submit claims outside or and across funding periods
- Misunderstanding by providers not being informed of the limitations or funding periods and support allocation, by either providers and/or support coordinators.
Strict adherence to funding period rules is essential to maintaining financial integrity, but places participants at risk of not being able to access funds.
3.4 Provider Conduct and Invoice Quality
Plan Managers regularly encounter:
- Vague or non-descriptive invoices
- Inconsistent, or not transparent pricing or quantities
- Services that are difficult to verify against the intent of the plan
While Plan Managers are not regulators, these issues present clear integrity risks and require escalation pathways to provider clarity on accountability of involved parties.
3.5 Role Confusion Across the Scheme
Integrity is weakened when roles are misunderstood:
- Participants, Service Providers, LACs and Coordination of Supports may expect Plan Managers to approve supports outside guidelines
- Providers may rely on informal advice rather than formal approvals or development and adherence to service agreements
Clear delineation of responsibilities is essential.
4. Our Role as Plan Manager in Supporting Scheme Integrity
Plan Managers play a frontline role in safeguarding NDIS funds by:
- Submission of claims against limited information, with expectation that all services align with NDIS rules and an individual’s NDIS Plan.
- Ensuring claims comply with NDIS Pricing Arrangements and Price Limits
- Identifying and flagging potential risks or inconsistencies
- Maintaining financial accountability and transparency
However, the role is administrative and compliance-based — not discretionary or regulatory.
Strengthening integrity requires supporting Plan Managers with:
- Clear, unambiguous guidance
- Access to authoritative interpretations
- Defined escalation pathways inside the Agency
In short, Plan managers occupy a unique position in the journey of an NDIS claim, yet are not treated as an integrity ally by the NDIA despite the unavoidable reality that plan managers have visibility over most claims.
4.1 New Framework Plans
It is unclear on the infrastructure or system changes that will be experienced by Plan Managers in the context of claims processing and budget management from 01 April 2027, particularly in relation to the 12 areas of stated supports, and Plan Spending Rules. As an additional plan ‘type’ to be introduced to the Scheme, the NDIA and Commission must be clearer in how this will be communicated and implemented. At present, the assumed risk of confusion which lead to areas like Short Term Respite and Funding Periods will increase. This further increases risk to the Plan Manager in support of the individual participant who has a current plan in place but receives advice from an Agency representative that a claim, such as Short Term Respite, cannot be claimed because of New Framework Rules.
4.2 NDIA Policy in Scheme integrity
NDIA policy has, in many instances, contributed to confusion and poorer outcomes. The most prominent example concerns “stated supports”. Differing interpretations have contributed to significant negative outcomes for participants as the NDIA published and retracted contradictory guidance on the topic on no less than three occasions.
At its core, stated supports is an issue defined by the wording in a participant plan. The quality and level of detail in plan documents varies significantly, making interpretations
under s46 difficult. Our experience indicates that plans are commonly produced with wording included that is contrary to the intent of the plan writer (delegate of the CEO). When NDIA guidance is finally published, it is often very general in nature and does not use real-world plan examples.
In the case of STR (Short Term Respite, formerly short-term accommodation), the NDIA published their guidance one year late.
5. Data and Evidence (extent of non-compliance)
As the Federal government has recently pointed out, plan managers are the providers that hold the evidence for most claims. Some generalised statistics include:
- 5% of all claims lodged to First2Care by service providers are identified and rejected as duplicates.
- A further 10-15% of claims have some level of non-compliance and require amendment
- A further 6% of claims are flagged and intercepted for additional manual review based on various anomaly detection methods and principles designed by First2Care. These are not necessarily non-compliant but meet certain risk thresholds based on the context of the claim.
- 0.5% - 1% of invoices are manually intercepted and placed on hold by participants (our client). Approximately half of these are voided or otherwise declined.
5.1 Comments and observations:
- The complexity of claiming rules makes accidental non-compliance very common, especially for incidental claims such as travel costs.
- Service providers, registered and unregistered, often have little to no understanding of why their claim is non-compliant.
- Often, the non-compliance is administrative in nature and not related to the quality of services delivered. In these instances, delays are perceived as unnecessary bureaucracy that harms participant and provider relationships.
It is common practice for service providers, support coordinators, and participants to manipulate invoice information to bypass claiming rules or exploit weaknesses in NDIS arrangements. First2Care have previously submitted to government consultations with
recommendations and concerns in this space, such as the NDIS Supports Consultation: NDIS Supports rules – engage.dss.gov.au. Some examples of this behaviour include:
- Support item 04_210_0125_6_1 – an item with no price controls, readily accessible as part of flexible funding in most plans.
- Support item 15_056_0128_1_3 – Other Professional – leveraged by unqualified practitioners or by practitioners seeking to have services not funded in a participant plan paid for, such as diagnostic assessments.
- Reverse-engineering the quantity for items governed by hourly unit prices based on the desired total divided by the unit price capped by the NDIA.
5.2 Participant Reimbursements
Reimbursements to participants for supports already purchased are disproportionate in their non-compliance. These claims are far more likely to fail evidentiary requirements (valid tax receipt or invoice), s10 rules, and false reimbursement claims constitute a large proportion of fraud reports lodged to the NDIA.
The NDIA’s claiming template does not allow for both the provider ABN and an attribute indicating it is a reimbursement to the participant, as they comprise a single field. This impedes the Agency from cross-referencing a participant reimbursement with provider ABNs. Doing this reveals trends in providers who may require payment in advance (not permitted under NDIS rules) or sharp practices. It also highlights participants with disproportionate levels of reimbursements – a known risk identifier.
5.2 Date Ranges
First2Care have previously communicated with the NDIA about concerns that allowing providers to lodge a single claim across a range of days is a significant payment integrity risk. Permitting this means:
- It is not possible to allow for participant plans ending during a date range of services
- It is not possible to allow for new pricing arrangements published by the NDIS during a date range of services
- It is not possible to detect duplicate services across different invoices by having granularity of individual service dates (and potentially timestamps)
- It is not possible to determine the correct funding period to lodge the claim against
Most support items have an hourly unit of measure. By definition, then, claims must be granular to the quantity of hours involved in the service delivery. Yet, they are then permitted to be lodged in a range that in some cases be as broad as an entire month, which facilitating poor claiming practices and turns what should be an explicitly-defined claim into a black box of time.
Claims should require a single service date unless there are exceptions for certain types of supports and circumstances (e.g. shift boundary provisions required by certain Awards).
6. Participant Case Studies
Case Study 1
- Issue: Identified fraudulent activity by participant and service provider, communicated
to the NDIA. The activity included:
- Falsification of the plan document, identified through the attempt of describing therapy types against a capital support category.
- Claims for allied health professional types without the qualifications or registration groups required as described in the NDIS Pricing Arrangements
- Potential claims not in line with the Plan or s10.
Communication was made with the NDIA on multiple times, including the submission of suspected fraud form and phone calls with Participant Support Officers and the Fraud Reporting Team to detail concerns and seek assistance and authorised instruction. No support or return communication has been received to date, with concerns lodged in December 2025.
This risk was further magnified when the role was ended and communicated to the participant, and the NDIA then intervened to reinstall the roles of plan manager and my provider with no communication to either party.
- Recommendation: The regulators must make more timely instructions available in
response to suspected fraud concerns lodged, during an investigation taking place,
including:
- Acknowledgement and communication of lodgement
- Instruction with authorisation relating to payments during a review phase, and where possible upon lodgement.
- Clarity is required on the expectation and level of communication available to Plan Managers, and the limitations placed by the Regulators to be communicated to the participant and service providers to ensure the role of the ‘decision maker’ is clear.
Case Study 2
- Correspondence Limitations: NDIA Payment Integrity
- Issue: Correspondence and the nature of correspondence is not timely, relevant, or accurately lodged within the scope of plan management, removing the accountability of service providers who are potentially lodging inappropriate claims.
Below are summaries of two different natures of correspondence received:
- ‘SUBJECT: Operating compliantly within the NDIS market’
The messaging of this correspondence was to advise that the NDIA’s Payment Integrity Response team are currently investigating a provider who has received payments through First2Care as the Plan Manager. There was no further instruction, or confirmation of who the service provider was.
A response was sent to seek confirmation of the service provider under review, and the Agency’s instruction regarding financial administration of invoices received during their instruction.
No response has been received to date, communication commenced February 2026.
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Integrity requests for information communicated to First2Care often require the provision of information relating to payslips, rosters, employment details or support workers and shift notes. Plan managers are not privy to, nor able to compel providers to share this information.
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Recommendation: The partial information provided to Plan Managers, in addition to the level of information and accountability expected by the Agency is inconsistent and does not align with published information.
This inconsistency results in misinformation provided to the plan manager, participant and their service providers, placing growing risk of access to continuity of supports and awareness to accessing service providers that may or may not be under investigation by the Agency but able to be engaged in services.
7. Recommendations
As the scheme looks to move toward mandated electronic claim forms (NDIS Amendment (Integrity and Safeguarding) Bill 2025), the revision and administration of participant budgets and providers have growing importance in the role of plan management. The following recommendations seek to identify opportunities to further strengthen the role of plan managers in integrity of the Scheme.
7.1 Improve Clarity of Support Inclusions and Exclusions
- Expand and regularly update guidance on what constitutes an NDIS Support, including reference to commonly queried items, such as noise cancelling headphones.
- Provide more detailed examples of excluded items, and expansion of why these items are excluded to assist in communication and understanding of participants.
- Address emerging grey areas (e.g. low-cost assistive items, digital supports, sensory products)
- NDIA policy should be published quickly and reflect real examples. Currently, the Agency is apparently shy of being definitive, instead outsourcing interpretations to plan managers.
7.2 Strengthen Enforcement of Pricing Rules
- Increase education for providers on correct claiming methods
- Implement system-level controls to prevent incorrect claims
- Improve accountability through communication to the service provider attached to the ABN on the claim, as well as the Plan Manager lodging the claim
- Consistency of rules and expectations applied across different plan structures received and implemented both under the SAP CRM (Service Bookings) and various PACE formats
7.3 Funding Period Compliance Requirements and Consistent Messaging
- Improve participant and provider education on funding period rules
- Introduce system rules and messaging to manage or prevent cross-period claiming
- Provide clearer messaging at plan implementation stage and by all levels of the NDIS participant and provider communication channels
7.4 Improve Invoice and Documentation Standards
- Mandate minimum invoice requirements across all providers, including capital support item claiming
- Encourage standardised invoicing formats (including electronic invoicing)
- Publish clear standards that participant reimbursements must meet
- Remove the ability to submit claims across a date range
- Enhance the bulk upload template to identify both provider ABN and whether the claim is a reimbursement to a participant
7.5 Clarify Roles and Decision-Making Authority
- Reinforce that only NDIS Planners can approve or vary supports described in a Plan
- Provide consistent messaging across all Scheme participants and the accountability of Support Coordinators in providing incorrect guidance or assumed authority
- Reduce reliance on informal or verbal advice
- Proactively support Plan Managers to uphold claiming rules, rather than provide
7.6 Enhance Risk Identification and Escalation Pathways
- Provide clear guidance on when and how Plan Managers should escalate concerns
- Strengthen collaboration with the NDIS Quality and Safeguards Commission
- Develop feedback loops to inform systemic improvements
Plan Managers are uniquely positioned to support integrity outcomes but require clearer rules, stronger system controls, and well-defined boundaries to do so effectively.
First2Care appreciates the opportunity to provide feedback on integrity and observed risks, with the importance that high quality plan management providers have in the longevity of the Scheme. We believe that implementing the above recommendations will improve outcomes for participants and ensure the sustainability of the NDIS.
Submitted By: Joshua Sigley Position: Quality Assurance and Systems Improvement Manager Organisation: Support Management Solutions Pty Ltd, trading as First2Care Date: 24 APR 2026