Submission to the

Inquiry into the Integrity of the National

Disability Insurance Scheme

Author: Alyson Lewis, Propel Pathways Pty Ltd

(Organisation submission)

Date: Friday 24 April 2026

1. Introduction and Author Standing

1.1. This submission is made in a professional capacity as Director of Propel Pathways Pty Ltd and as a practising NDIS Support Coordinator. It draws on direct frontline experience implementing participant plans, overseeing providers, reviewing compliance and supporting participants and families to navigate the Scheme.

1.2. It is also informed by a legal background, including a Bachelor of Laws, which provides a framework for analysing how legislative intent, decision-making and administrative processes operate in practice. This perspective is relevant to assessing whether the Scheme is being applied consistently, lawfully and in accordance with its intended purpose.

1.3. It is also informed by lived experience as the mother and Child Representative of an NDIS participant, responsible for safeguarding supports, funding and continuity of care.

1.4. Across these roles, a consistent conclusion emerges:

• integrity issues within the NDIS are not isolated incidents of fraud, but arise from systemic design, governance and operational weaknesses.

1.5. These weaknesses include:

• reactive rather than preventative compliance systems;
• inconsistent and opaque decision-making;
• gaps in oversight and accountability; and
• market behaviours that are technically permissible but practically harmful.

1.6. The cumulative effect is a Scheme in which participant funding is not consistently directed toward intended outcomes, safeguarding functions are displaced onto families and frontline actors and trust in the system is progressively eroded.

1.7. A central theme of this submission is that integrity risks within the NDIS are closely linked to systemic gaps in accountability.

2. Accountability and System Performance

2.1. A central integrity issue within the NDIS is the absence of consistent and effective accountability across all levels of the Scheme.

2.2. While participants, providers and Support Coordinators are required to comply with detailed operational and financial requirements, equivalent accountability is not consistently applied to:

• provider conduct in practice;
• plan management oversight;
• NDIA decision-making; and

• system-level performance and outcomes.

2.3. This creates a structural imbalance in which those with the least power within the system are subject to the highest level of scrutiny, while those responsible for oversight and decision-making are not held to the same standard.

2.4. In practice, this lack of accountability manifests in several ways.

2.5. First, provider conduct may go unchallenged for extended periods, even where patterns of billing irregularities or service concerns are evident. The absence of early detection mechanisms allows non-compliant behaviour to continue until participant funds are significantly depleted.

2.6. Second, plan management oversight does not consistently identify or respond to abnormal expenditure patterns. Rapid or unsustainable use of participant funding may occur without triggering review or intervention, allowing inappropriate charging to continue unchecked.

2.7. Third, NDIA processes themselves are not consistently accountable to their own requirements. Participants and Support Coordinators may be required to resubmit documentation, amend forms or repeat administrative steps despite valid information having already been provided and accepted. This results in participant funding being consumed in navigating and correcting system inefficiencies, rather than delivering supports.

2.8. Fourth, decision-making accountability is limited. Where decisions are inconsistent, inadequately reasoned or not aligned with available evidence, there are few immediate mechanisms to ensure correction. Instead, participants are required to pursue review or escalation pathways, often at significant time and resource cost.

2.9. As a result of these gaps, accountability is frequently displaced onto participants, families and frontline actors.

2.10. In practice, this means:

• participants and families monitor provider conduct and funding use;
• Support Coordinators identify patterns of non-compliance and escalate concerns; and
• individuals without formal authority undertake safeguarding functions necessary to protect participant interests.

2.11. These responsibilities are not formally recognised or consistently resourced, yet they are essential to the effective functioning of the Scheme in its current form.

2.12. The absence of clear and enforceable accountability mechanisms has direct implications for Scheme integrity.

2.13. Where:

• non-compliant behaviour is not detected early;
• oversight functions do not operate proactively; and
• decision-making is not consistently subject to quality control

integrity risks become embedded within normal system operation.

2.14. This results in:

• inefficient use of participant funding;
• delayed or reduced access to supports; and
• increased reliance on informal safeguards.

2.15. Integrity within the NDIS is not limited to identifying and responding to fraud. It also requires that all parts of the system operate in a manner that is:

• transparent;
• consistent;
• efficient; and
• accountable for outcomes.

2.16. Where accountability is fragmented or absent, the system itself contributes to the risks it is intended to manage.

2.17. Strengthening accountability across provider behaviour, plan management, NDIA processes and system performance is therefore critical to improving both integrity and participant outcomes.

3. Nature and Extent of Non-Compliance

3.1. Non-compliance within the NDIS extends beyond deliberate fraud and includes a spectrum of behaviours that undermine participant outcomes while remaining difficult to detect or regulate.

3.2. In practice, misconduct frequently occurs through patterns over time, rather than single breaches. Repeated low-level irregularities such as misaligned billing, service substitution or cancellation practices may appear minor individually but cumulatively result in significant financial loss and reduced support access.

3.3. A consistent issue is the reliance on post-payment detection, meaning that non-compliance is often identified only after participant funds have already been spent. This limits the effectiveness of enforcement and creates a system that responds to harm rather than preventing it, including where billing practices raise clear indicators of inconsistency or irregularity when reviewing the invoices.

3.4. The increasing reliance on automated processing systems within the NDIS has introduced additional integrity risks. In practice, current system settings do not consistently detect duplicate invoices or prevent inappropriate charging practices, such as the application of provider travel costs in conjunction with late cancellation

fees. These types of claims can be processed without triggering review mechanisms, allowing non-compliant or inappropriate charges to be paid from participant plans. This reflects a gap in automated validation controls, where system efficiency has not been matched with adequate safeguards to ensure claim legitimacy prior to payment. These automation systems are relied upon by registered providers operating under audit oversight. In practice, discrepancies have been identified through frontline review rather than system detection.

3.5. When Plan Managers are contacted to resolve non-compliant billing, they may not always resolve the issue due to the impact it will have upon audit documentation.

3.6. Several recurring patterns are evident.

3.7. First, pattern-based billing practices can escalate into more overt forms of financial exploitation where providers claim for services that are not delivered and then disengage from the participant. Instances have been observed where participants are rapidly charged for ongoing services, followed by sudden withdrawal of support, with providers then seeking to impose extended cancellation fees despite no service delivery occurring during that period. This results in participants being left without supports while their funding continues to be depleted. Such practices highlight both a failure in real-time oversight and the absence of safeguards to prevent continued charging in the absence of actual service provision, particularly where patterns of behaviour are not identified early through longitudinal monitoring.

3.8. Second, provider travel charging practices allow both travel time and kilometre costs to be charged concurrently. While technically permitted, this creates disproportionate plan consumption and reduces funding available for direct supports, particularly for regional participants and those requiring frequent services. In practice, additional integrity concerns arise where providers conduct billable activities, such as phone calls to participants or representatives, while travelling. This creates scenarios in which multiple billable components—travel time, kilometre costs and direct support—are claimed simultaneously for a single period of time, resulting in what is effectively triple billing for the same activity. This further compounds the financial impact on participant plans and highlights a misalignment between pricing framework allowances and value-for-money principles.

3.9. Third, conflicts of interest arise where providers influence participant decisions or referral pathways, limiting genuine choice and control. In practice, this can extend beyond passive influence into active pressure, particularly where participants are vulnerable or reliant on a single provider for multiple supports. For example, instances have been observed where providers place participants or their representatives under implicit or explicit ultimata to discourage external scrutiny or

changes in service arrangements. This may include pressuring participants to disengage from Support Coordinators or other oversight mechanisms, effectively isolating them from independent advice.

3.10. Where such conduct occurs, the effectiveness of regulatory intervention becomes critical. However, delays or lack of timely response from oversight bodies can result in participants remaining exposed to undue influence for extended periods. During this time, the provider retains control over service delivery and funding utilisation, while the participant’s ability to exercise genuine choice and control is materially compromised. This creates a situation in which vulnerable participants are left without effective protection and where the intended safeguards of the Scheme do not operate in practice.

3.11. Fourth, a critical integrity issue arises where rapid and abnormal depletion of participant funding is not identified or acted upon by oversight mechanisms. In practice, participant plans may be consumed at an accelerated rate without corresponding scrutiny from plan managers or other system actors. This includes situations where expenditure patterns clearly deviate from expected utilisation, yet no flag, review or intervention is triggered. The absence of timely detection allows inappropriate or excessive charging to continue unchecked, resulting in significant loss of participant funding and reduced access to supports. This reflects a gap not only in provider behaviour, but in the effectiveness of financial oversight and monitoring within the Scheme.

3.12. These behaviours are not isolated. They are enabled by system design, gaps in oversight and limited early detection capability, creating an environment in which integrity risks emerge through ordinary operational processes.

4. Impacts on Participants and Families

4.1. The impacts of these integrity issues are direct, cumulative and measurable.

4.2. Financially, participant plans are often depleted earlier than intended due to inefficient or misaligned expenditure, including administrative engagement required to navigate inefficient NDIA processes. Funding is therefore diverted away from intended supports, reducing its overall effectiveness.

4.3. Functionally, participants may fail to achieve plan goals where supports are inconsistent, inappropriate or reduced due to funding constraints. In some cases, progress stalls or regresses. Delays in accessing supports, particularly early intervention for children, have long-term consequences for development and independence.

4.4. At a system level, repeated exposure to inconsistency, inefficiency and non-compliant practices erodes trust. Participants and families frequently experience confusion regarding entitlements, funding and processes and are required to rely on others to interpret the system.

4.5. In practice, safeguarding is often performed informally by families and Support Coordinators, who monitor provider behaviour, track funding use and escalate concerns. These functions are critical but not formally recognised or resourced.

4.6. For families, the cumulative burden is significant. Navigating complex systems, managing providers and compensating for gaps in support contributes to burnout, increased unpaid care and ongoing emotional and administrative strain.

4.7. These impacts are not evenly distributed. Children, participants with high-complexity needs and those without strong advocacy support are disproportionately affected, increasing their exposure to systemic risk.

5. Effectiveness of Current Policies

5.1. Current policy settings are not consistently effective in maintaining Scheme integrity.

5.2. The system operates largely as a reactive model, relying on complaints and retrospective review rather than early detection and prevention.

5.3. Decision-making is inconsistent, with variability in how evidence is interpreted and applied. Participants with similar needs may receive different outcomes, resulting in inequity and increased reliance on review processes.

5.4. Further integrity concerns arises in relation to the quality and capability of NDIA decision-making.

5.5. In practice, determinations are often made by staff who do not hold equivalent clinical expertise to the professionals whose reports they are assessing and who may not be sufficiently trained in the application of the legislative framework underpinning those decisions.

5.6. This can result in limited engagement with the substance of existing evidence, with a tendency to focus on perceived gaps or what the evidence does not explicitly state, rather than the overall weight and consistency of what it demonstrates.

5.7. The consequence is that clinically informed recommendations may be discounted or narrowly interpreted, leading to decisions that are not fully aligned with participant need or the intent of the legislation. This reflects a broader capability and training issue, where the authority to make determinations is not consistently matched by the expertise required to assess complex evidence appropriately.

5.8. Transparency is limited. Participants often lack access to clear budget breakdowns or decision reasoning, reducing their ability to understand and manage their plans. This

leads to confusion and inconsistent messaging when funding is not clearly outlined in plan documentation. In one instance, NDIA decision-making contributed to significant participant distress, resulting in hospitalisation and placing additional strain on adjacent healthcare services.

5.9. Value-for-money principles are applied inconsistently. At the same time, permitted practices, such as cumulative travel charging, can undermine efficient use of participant funding.

5.10. A further integrity concern arises in relation to the application of value-for-money principles and the absence of equivalent accountability for system performance.

5.11. While participants are routinely required to justify the value for money of proposed supports, there is limited scrutiny applied to whether NDIA decision-making and internal processes themselves represent efficient use of Scheme resources.

5.12. In practice, decisions to refuse or limit supports can result in prolonged administrative engagement, internal resource expenditure and escalation to external review mechanisms such as the Administrative Review Tribunal.

5.13. This raises a fundamental question as to whether such outcomes represent value for money for the Scheme as a whole, particularly where the cost of refusal and dispute exceeds the cost of providing the support in the first instance.

5.14. The absence of a reciprocal value-for-money lens applied to system decision-making reflects a broader accountability gap, where participants are held to a standard that is not consistently applied to the operation of the Scheme itself.

5.15. Process inefficiencies, including delays, duplication and repeated information requests, create additional administrative burden. Critically, the time required to navigate these processes is often funded through participant plans, resulting in inefficient consumption of participant funding due to system design and operation.

5.16. Accountability mechanisms for decision-making quality are limited. There are few effective feedback loops and known issues persist over time without consistent correction.

5.17. Taken together, these factors indicate that integrity within the NDIS is not only a matter of provider behaviour, but also of how effectively, consistently and efficiently the system itself operates.

6. Case Study: Systemic Integrity Failure in Practice

6.1. The following de-identified case study is provided to illustrate how multiple integrity risks can intersect within a single participant context and how system safeguards may fail to respond in a timely or effective manner.

6.2. In this instance, a provider engaged in a pattern of conduct from November 2025 that included:

• rapid and unsustainable depletion of participant funding over a very short period (less than two months) and this was not identified by the Plan Managers (Registered Providers);
• rostering practices that accelerated expenditure without regard to plan sustainability;
• inconsistent representations regarding participant circumstances, including to a formal justice proceeding; and
• pressure placed on professionals to retrospectively remediate funding through escalation processes.

6.3. Concerns were raised through appropriate channels, including requests for:

• invoicing transparency;
• shift and service delivery records; and
• clarification of billing practices.

6.4. These requests were not responded to substantively. Instead, scrutiny of billing and service delivery was followed by escalation, including:

• legal correspondence;
• attempts to restrict professional activity; and
• court-based action, which was ultimately dismissed.

6.5. At the same time, the participant was placed under ultimatum to either stay with the Provider or remain under my safeguarding and ultimately remained engaged with the provider and continued to be exposed to the same service environment.

6.6. Further integrity concerns arose where:

• the participant appeared to be subject to influence discouraging external oversight;
• attempts were made to limit independent communication and engagement; and
• safeguarding concerns were not resolved in a timely manner despite escalation to regulatory bodies.

6.7. This resulted in a period during which:

• the participant remained vulnerable to ongoing financial and service-related risk (assuming the Participant themselves was not involved in the fraudulent billing practices);
• independent oversight was materially constrained; and
• no immediate corrective action was taken by the relevant oversight bodies.

6.8. This case demonstrates that integrity risks within the NDIS are not limited to billing practices alone, but arise from the interaction between:

• provider misconduct;
• participant vulnerability; and
• the timeliness and effectiveness of regulatory response.

6.9. In particular, it highlights that:

• rapid funding depletion may occur without immediate detection or intervention, even by Providers under audit oversight (plan managers);
• participants may be exposed to undue influence where provider dependence exists;
• professionals undertaking safeguarding activities may face deterrence or escalation; and
• regulatory processes may not operate with sufficient speed to prevent ongoing harm.

6.10. This case is directly relevant to the inquiry in that it demonstrates:

• the nature and extent of non-compliance, including pattern-based behaviour and sharp practices;
• the impacts of such conduct on participants, including financial harm, reduced supports and vulnerability to influence; and
• the limitations of current safeguarding and regulatory frameworks in preventing or responding to these risks in real time.

7. Case Study: Failure of Complaint Handling and Participant Communication

7.1. A further example of integrity risk arises in the handling of formal complaints and communication with participants.

7.2. In this case, a formal complaint was submitted to the NDIS Commission and NDIA on behalf of a participant, supported by:

• a signed complaint from the participant;
• supporting documentation including service agreements, invoices, shift records and compliance review; and
• clear articulation of safeguarding, billing and conduct concerns.

7.3. Despite this, the following issues arose:

• No substantive acknowledgement or update was provided following submission and resubmission of the complaint;
• Follow-up contact by the Support Coordinator on behalf of the participant did not result in meaningful engagement;

• The participant, experiencing distress, independently contacted the Commission and NDIA seeking an update;
• The participant was informed that the matter was closed and that no information could be provided, despite the complaint being made with her informed consent and signed authority.

7.4. This scenario highlights several systemic concerns.

7.5. First, it demonstrates a disconnect between complaint submission processes and participant recognition, where a complaint submitted on behalf of a participant does not translate into meaningful engagement with that participant.

7.6. Second, it reflects a lack of transparency in complaint outcomes, where participants are not informed of:

• whether their complaint has been assessed;
• what action, if any, has been taken; or
• why the matter has been closed.

7.7. Third, it creates a situation where:

• participants must escalate or re-engage independently;
• distress is compounded by uncertainty and lack of communication; and
• safeguarding concerns remain unresolved in practice.

7.8. The impact of this process on the participant was significant.

7.9. The absence of communication and clarity resulted in:

• increased emotional distress;
• reduced confidence in the complaints system; and
• a perception that concerns had not been taken seriously.

7.10. This undermines the purpose of the complaints framework, which is intended to provide:

• protection;
• accountability; and
• confidence in the safety and integrity of supports.

7.11. This case is directly relevant to the inquiry as it demonstrates:

• the impact of non-compliance and poor oversight on participants and their wellbeing;
• the limitations of current complaint and safeguarding processes; and
• the need for improved transparency, communication and participant-centred engagement within regulatory systems.

8. Recommended Reforms

8.1. Addressing integrity issues within the NDIS requires both strengthened enforcement and targeted system reform. The issues identified in this submission are not isolated to provider misconduct, but arise from the interaction between market behaviour, system design and regulatory gaps. As such, reform must address both participant-facing risks and system-level accountability.

8.2. First, there is a clear need to strengthen early detection and monitoring systems, particularly in relation to pattern-based non-compliance. Current reliance on post-payment detection allows participant funds to be depleted before intervention occurs. The Scheme should implement automated and human oversight mechanisms capable of identifying:

• duplicate invoicing;
• accelerated or abnormal plan depletion; and
• cumulative billing patterns over time.

8.3. These systems must operate proactively and trigger timely review before further claims are processed.

8.4. Second, automation and claim validation controls must be strengthened. While automated systems improve efficiency, they must include safeguards to prevent inappropriate claims from being processed. This includes ensuring that:

• duplicate invoices are flagged prior to payment;
• incompatible charges (such as travel costs applied alongside late cancellation fees) are prevented; and
• claims involving multiple simultaneous billable components are subject to scrutiny.

8.5. Automation should not replace oversight; it must be designed to support it.

8.6. Third, travel charging practices require reform to ensure alignment with value-for-money principles. The current framework allows for cumulative charging that disproportionately impacts participant funding. Consideration should be given to:

• restricting travel claims to either time-based or distance-based charging, rather than both;
• prohibiting concurrent billing of travel time, kilometre costs and direct support for the same activity period; and
• introducing clearer limits and transparency requirements within service agreements and invoices.

8.7. Fourth, financial oversight and plan management functions must be strengthened. The failure to identify and act on rapid or abnormal depletion of participant funding

represents a critical integrity gap. Plan managers and relevant system actors should be required to:

• monitor expenditure patterns against expected utilisation;
• flag and investigate accelerated spend; and
• take timely action where expenditure deviates from reasonable expectations.

8.8. Oversight mechanisms must be responsive, not passive.

8.9. Fifth, conflict of interest protections and participant safeguarding must be enhanced. Participants must be protected from undue influence, particularly where they are reliant on a single provider or have limited capacity to advocate for themselves. This includes:

• strengthening independence requirements across providers;
• ensuring participants retain access to independent advice, including Support Coordination; and
• requiring timely regulatory intervention where undue influence or coercive practices are identified.

8.10. Safeguarding frameworks must operate in real time, not after harm has occurred.

8.11. Sixth, decision-making capability and legislative application within the NDIA must be improved. Decision-makers should be required to demonstrate:

• appropriate training in the legislative framework;
• the ability to assess and interpret clinical evidence; and
• consistent application of evidence-based reasoning.

8.12. There should also be greater accountability where decisions fail to properly consider existing evidence or result in avoidable escalation.

8.13. Seventh, transparency must be increased across planning and decision-making processes. Participants should have access to:

• clear and detailed budget breakdowns;
• understandable reasoning for decisions; and
• consistent information regarding how funding can be used.

8.14. Transparency is critical to enabling participant control and reducing reliance on informal interpretation.

8.15. Eighth, NDIA process efficiency must be addressed as an integrity issue. Where participants and Support Coordinators are required to repeatedly engage with inefficient processes—such as re-submitting documentation already accepted or correcting administrative inconsistencies—participant funding is consumed without delivering supports. Reform should ensure that:

• internal processes are streamlined and consistent;
• duplication and unnecessary administrative steps are eliminated; and

• participants are not required to expend funding to enforce system compliance with its own requirements.

8.16. This is essential to maintaining value for money across the Scheme.

8.17. Ninth, value-for-money principles must be applied consistently to both participants and the system itself. While participants are required to justify the cost of supports, there is currently limited scrutiny applied to whether NDIA decisions represent efficient use of Scheme resources. Reform should include:

• evaluation of the cost of decision-making processes, including refusals and appeals;
• consideration of whether escalation pathways represent value for money compared to initial decisions; and
• application of a reciprocal value-for-money standard to NDIA operations.

8.18. Finally, reform should focus on prevention, not just enforcement. Strengthening penalties for misconduct is necessary but insufficient if underlying system conditions continue to enable integrity risks. A balanced approach is required that:

• identifies risks early;
• supports participants and safeguarding actors; and
• ensures accountability across all levels of the Scheme.

also focus on preventing harm, rather than relying primarily on post-breach enforcement.

9. Conclusion

9.1. Integrity issues within the NDIS are systemic, predictable and preventable.

9.2. The current system relies heavily on participants, families and Support Coordinators to perform safeguarding functions that should be delivered structurally. Without reform, inefficiencies will continue to consume participant funding, outcomes will be compromised and trust in the Scheme will decline.

9.3. Strengthening integrity requires not only addressing fraud, but ensuring that the system operates in a way that is efficient, accountable and consistently aligned with participant outcomes.