Joint Standing Committee Inquiry into the Integrity of the National Disability Insurance Scheme

APM Submission

24 April 2026

Ability Insurance Scheme

Acknowledgement of Traditional Owners and Custodians

APM acknowledges the traditional custodians of the lands on which we live and work. We pay our respects to elders past and present of all Aboriginal and Torres Strait Islander nations.

globally, APM recognises the significance of indigenous communities and the important role they play within our own workforce and the world, underpinning our efforts to build a culture that embraces diversity, equity and inclusion.

Photography

photographs used in this document are for illustration only and should not be interpreted to mean that any person or organisation whose assets are shown in them endoreses this document.

APM Contact

communications regarding this document should be forwarded to:

Karen Rainbow CEO - Employment & Disability

Executive Summary

Integrity risks in the National Disability Insurance Scheme (NDIS) are not isolated instances of fraud or non-compliance – they are symptoms of structural weaknesses in market design, oversight and participant support. They are also well evidenced, having been the subject of multiple reviews, inquiries and consultations since the NDIS commenced in 2013.

The current state of the Scheme reflects the rapid growth of a large, complex and effectively unregulated marketplace characterised by insufficient visibility of who is delivering services and receiving payments, no consistent or universal payments gateway and limited price controls. This presents an unacceptable risk to:

participants, who may be exposed to poor-quality or inappropriate services
taxpayers, whose investment may not deliver intended outcomes and
providers seeking to deliver high quality, compliant services in an uneven market.

Framing the integrity challenge

Integrity in the NDIS must be understood as a whole of system issue, rather than a narrow compliance or fraud problem. Current system settings:

enable poor-quality and non-compliant providers to operate, often without oversight
penalise registered providers with higher costs, regulatory obligations, and pricing constraints, while much of the market operates without equivalent controls
fail to measure, monitor or reward quality and performance, limiting accountability and continuous improvement
leave participants without adequate support to navigate and an increasingly complex market

These conditions collectively create an environment in which non-compliance can emerge and persist.

Key system failures

This submission identifies a series of core interconnected system failures which are driving integrity risks within the Scheme:

Weak provider regulation (registration gap)

The absence of mandatory registration has resulted in a fragmented market with inconsistent oversight, limited visibility and uneven regulatory expectations.
Inconsistent and inequitable eligibility, assessment and reassessment processes

Current eligibility and needs assessments are highly variable with no standardised, transparent process, inconsistent use of functional and evidence-based frameworks and a reliance on planner discretion and interpretation.
Lack of accessible and reliable market information (information asymmetry)

Participants and their families lack access to usable, reliable information to identity appropriate supports and high-quality providers which contributes to poor decision making and increased exposure to risk.
Absence of performance, market and outcomes accountability

There is no nationally consistent system to monitor provider performance, measure participant outcomes or provide transparency across the market, limiting accountability, obscuring poor performance and weakening incentives for quality and continuous improvement.  Inadequate plan implementation and navigation support Participants are expected to operate as informed consumers in a complex system, often without sufficient support. This results in duplication of services, poor alignment of supports to participant goals and funds being exhausted without achieving intended outcomes. Priority reforms Addressing these system failures requires targeted, high-impact reform. This submission proposes three priority actions:

Mandatory registration of all providers Establish a risk-proportionate, nationally consistent registration framework for all providers, supported by a national payment gateway to improve oversight of services, visibility of payments data, quality and consistency.
A Consistent and transparent eligibility, assessment and reassessment pathway Implement a standardised, nationally consistent and transparent approach to eligibility and needs assessment that ensures consistency across geographies and cohorts, reduces reliance on subjective interpretation and strengthens the link between need, funding and expected outcomes.
National performance and outcomes framework Develop a system to:  monitor provider performance and market dynamics  measure and report on participant outcomes  improve transparency, inform participant choice and government decision making
Universal access to high quality navigation supports Ensure all NDIS participants have access to appropriate, high-quality navigation and plan implementation supports, enabling safe and effective engagement with the market. By addressing these core structural issues APM believes government can significantly strengthen integrity, reduce non-compliance, improve participant outcomes and restore long-term confidence in the Scheme.
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Contents Executive Summary …………………………………………………………………………………………………. 3

Framing the integrity challenge ………………………………………………………………………………………………………………………………….. 3

Key system failures ………………………………………………………………………………………………………………………………………………………… 3

Priority reforms ..................................................................................................................................................................................... 4

       1. Mandatory registration of all providers .................................................................................................................... 4
       2. A Consistent and transparent eligibility, assessment and reassessment pathway .................................. 4
       3. National performance and outcomes framework ................................................................................................. 4
       4. Universal access to high quality navigation supports ......................................................................................... 4

About APM ……………………………………………………………………………………………………………… 6 About our submission ……………………………………………………………………………………. 7 Background and context ……………………………………………………………………………………. 7

Integrity as a system issue ……………………………………………………………………………………………………………………………………………. 7

Extensive evidence already exists ……………………………………………………………………………………………………………………………….. 8

A clear reform roadmap already exists……………………………………………………………………………………………………………….. 9

Opportunities for targeted, high impact reform have not been taken ……………………………………………………………….. 9 Defining integrity in the NDIS ……………………………………………………………………… 10

Integrity as a system function ………………………………………………………………………………………………………………………………. 10

Preconditions for system integrity ……………………………………………………………………………………………………………………………. 10

Implications for reform …………………………………………………………………………………………………………………………………………….. 12 Addressing system failures to strengthen integrity …………………………………………. 12

1. Weak provider regulation and the absence of mandatory registration .................................................................. 12

2. Inconsistent and inequitable eligibility and needs assessment .................................................................................. 15

3. Absence of performance and outcomes accountability .................................................................................               16

4. Inadequate plan implementation and navigation support .................................................................................. 17

Conclusion ………………………………………………………………………………………………….. 19

About APM

APM Group is a team of 16,000 Globally, APM supports more than 2.4 million people of all people in 11 countries with a ages to live a better quality of life every year. We deliver global purpose - to enable tailored solutions that reflect the unique strengths, needs better lives. and aspirations of the people and communities we serve to create lasting social impact.APM started in 1994 as an allied health and vocational APM’s breadth of both services and footprint provides a rehabilitation provider based in unique vantage point in the ecosystem. As a registered Perth, Western Australia. provider within the NDIS market, our skilled, multi- disciplinary workforce (professional and paraprofessional)Today we’re an international work with children, young people and adults, their familieshuman services provider with and carers to achieve outcomes in the areas of behaviour, more than 1,598 locations across social participation, life skills, communication, emotional Australia, the United Kingdom, development, education and employment success. Canada, the United States of America, New Zealand, We deliver Plan Management and Support Coordination Germany, Switzerland, Spain, nationally, and as a contracted Partner in the Community Sweden, Singapore, and South delivering Local Area Coordination (LAC), we support Korea. people with disability inside and outside of the NDIS connect to foundational and mainstream services and In Australia, our more than supports in their local community and foster close 6,353 strong team deliver key working relationships with local NDIS providers, health, services across the social education and community services, the National Disability services and care economy, Insurance Agency (NDIA) and the NDIS Quality and including assessments, early Safeguards Commission (NDIS QSC). intervention, allied health treatment and therapy, We deliver Plan Management and Support Coordination employment supports, training, nationally, and as a contracted Partner in the Community aged and disability care, delivering Local Area Coordination (LAC), we support community supports, people with disability inside and outside of the NDIS psychological, health and connect to foundational and mainstream services and wellbeing services, from 649 supports in their local community and foster close locations across the country. working relationships with local NDIS providers, health, education and community services, the National Disability Insurance Agency (NDIA) and the NDIS Quality and Safeguards Commission (NDIS QSC).

About our submission This submission approaches integrity not as a narrow compliance issue, but as a function of system design and stewardship, in the context of a Scheme designed to build individual and community capacity and underpinned by insurance-based principles including early intervention to prevent downstream impacts. Addressing non-compliance in a meaningful and sustainable way will require:  moving beyond reactive enforcement approaches  strengthening the foundational settings of the Scheme  implementing reform directions already identified through extensive prior work.

Our response does not seek to reinvent the wheel or rehash the extensive body of evidence that already exists, but focuses on key structural reforms that, if implemented will not only reduce non-compliance, but improve participant outcomes, support long-term sustainability and restore confidence in the Scheme as a whole. Background and context The NDIS is one of Australia’s most significant social policy reforms, designed to enable people with disability to exercise choice and control and to build their capacity to participate as fully as possible in economic and community life. It is underpinned by insurance-based principles, recognising the value of intervening early to minimise downstream impacts where possible, and to provide long term, ongoing care and support where necessary. Its success, however, depends on the effective functioning of a complex, quasi-market system where participants, providers and government interact within a framework effectively shaped by regulation, pricing, accountability and support structures. This inquiry is focused on integrity and non-compliance within the Scheme. While this is an important and necessary focus, it is critical that non-compliance is understood in its full context. Integrity as a system issue Non-compliance in the NDIS is often narrowly framed as deliberate fraud or criminal behaviour. While these risks are real and must be addressed, this framing is incomplete. A significant proportion of risks within the Scheme arise not from isolated bad actors, but from structural weaknesses in system design, implementation and stewardship. These include, for example:  highly variable eligibility, assessment and funding decisions  gaps in provider regulation and oversight,  the absence of performance and outcomes monitoring,  lack of clear information and insufficient support to navigate a complex market,  constantly changing rules, definitions and service boundaries.

The NDIS is the only publicly funded scheme APM engage in1 that has:  no minimum mandatory provider registration requirements  no single structured payment gateway or pre-payment oversight requirement  inequitable rules of engagement  no formal outcome measures and reporting

In this context, integrity risks are not incidental, rather they are actively enabled by the current system architecture. Extensive evidence already exists It is also important to acknowledge that the government is not operating in an evidence vacuum. Since the roll out of the NDIS there has been an extensive body of work examining the function of the Scheme and making recommendations for change including:  Productivity Commission Review of NDIS Costs (2017)  Tune review of the National Disability Insurance Scheme Act (2019)  The NDIS Review (2023)  The Royal Commission into Violence, Abuse, Neglect, and Exploitation of People with Disability (2023)  26 reports from the Joint Standing Committee on the NDIS  ongoing consultations with providers, participants and peak bodies

Across these processes there has been consistent and converging evidence on:  the nature and the extent of non-compliance and poor-quality service delivery  the drivers of market failure including information asymmetry and weak market oversight  the impact on participants including exposure to harm, poor outcomes and inequitable access  the limitations of current policy and regulatory settings, particularly in relation to market stewardship

Reports have consistently highlighted that the NDIS market is:  highly fragmented, with variable quality across providers  not underpinned by consistent market information  characterised by information asymmetry that limits participants ability to make informed choices  lacks robust payments oversight and data collection

Similarly, evidence on the existing Quality and Safeguarding Framework has identified that the system has:

1 APM works across and engages with a range of funded programs and compensable schemes including workers compensation, vocational rehabilitation, Veterans’ support, transport accident schemes, public and private health services and aged care services both in Australia and globally.

 failed to effectively measure, monitor and report on provider quality and participant outcomes,  constrained incentives for providers to improve quality  relied heavily on participant capacity to act as informed consumers in the absence of adequate information A clear reform roadmap already exists The NDIS Review (2023) synthesised this body of evidence and provided a comprehensive framework for system-wide reform. Central to the Review’s findings was the recognition that:

 Thecurrentmarketdesignisnotconsistentlydeliveringquality,safetyor
 outcomesforparticipantsandrequiresmoreactivestewardshipby
  government.

The review identified key structural issues that directly related to integrity risks, including:  inconsistent and incomplete provider regulation  inequitable allocation and availability of resources  lack of accessible, reliable information about provider quality and performance  insufficient navigation and coordination support  over-reliance on market mechanisms in the absence of strong stewardship.

Importantly, the review did not call for incremental adjustments but for a reset of how the Scheme is designed, governed and supported. Opportunities for targeted, high impact reform have not been taken In this context, the challenge is not identifying the problem, it is prioritising and implementing the reforms that will have the greatest impact. Despite the Review findings and recommendations being released in 2023, few recommendations have been acted on to date; and where they have, implementation has been fragmented and/or slow. Significant gains in scheme integrity, participant outcomes and long-term sustainability can be achieved by focusing on a small number of high-leverage system reforms that remain unrealised. This submission highlights four priority areas that based on our experience will deliver the greatest returns:

Strengthening provider regulation through mandatory registration and a regulated payment gateway
Implementing a nationally consistent, transparent eligibility and assessment framework
Establishing a national performance and outcomes monitoring and reporting framework
Ensuring all participants have access to high quality navigation and plan implementation supports

These reforms directly address the structural drivers of non-compliance by:  increasing transparency and accountability  increasing data availability and reducing information asymmetry

 strengthening oversight and market visibility  supporting participants to engage effectively Defining integrity in the NDIS A clear and shared understanding of integrity is essential to ensuring that policy and reform responses are appropriately targeted. In the context of the NDIS, integrity should not be understood solely as the absence of fraud or non-compliance. Integrity should reflect the extent to which the Scheme functions as intended, delivering safe, high quality and effective supports to participants while ensuring public resources are used appropriately and sustainability. Integrity as a system function At its core, integrity within any publicly funded system rests on three foundational principles:

Funds are used for their intended purpose. Public investment is directed toward outcomes focussed capacity building and reasonable and necessary ongoing supports that align with participants needs and Scheme objectives and insurance-based principles.
Participants receive safe, high quality and effective supports. Services delivered contribute to improved outcomes, uphold participant rights and minimise the risk of harm.
The system operates transparently, accountably and sustainably. Governments, providers and intermediaries are accountable for their roles and system setting to support long-term viability. Where these conditions are not met, integrity is compromised, even in the absence of deliberate fraud. Preconditions for system integrity For these principles to be realised several core system functions must be in place. These are consistent across complex, market-based human services systems and are particularly critical in the NDIS context.
Clear and enforceable rules Integrity requires a regulatory framework that:  clearly defines acceptable practice and expected standards  applies consistently across the provider market  is enforceable, with proportionate consequences for non-compliance

Without this there is increased risk of:  variable service quality  regulatory arbitrage  erosion of trust in the system

Consistency in design and implementation

Integrity depends not only on the existence of rules and frameworks, but on their consistent application across the system. This includes:  consistent application of eligibility, assessment, planning and funding decisions  uniform regulatory expectations across providers, regardless of business model or registration status  alignment between policy intent and operational delivery at all levels of the Scheme.

In the absence of consistency:  participants experience inequitable outcomes based on capacity to advocate, geography, planner discretion or system pathway  providers operate with uneven regulatory environments distorting market behaviour  gaps and inconsistencies create opportunities for non-compliance and exploitation

Consistency is fundamental to both fairness and integrity, ensuring that the Scheme operates predictably and equitably for all participants and providers.

Visibility and transparency A system cannot maintain integrity if it cannot “see” what is happening within it. This requires:  comprehensive data on providers, service delivery and outcomes  mechanisms to monitor and detect risks early  transparency that enables informed decision making by participants and government

In the absence of visibility:  poor-quality providers can operate undetected  emerging risks are not identified or addressed early  participants are unable to distinguish between high and low-quality services

Accountability mechanisms Integrity also depends on the ability to hold actors accountable for their performance and conduct. This includes:  monitoring provider performance and participant outcomes  linking funding and market access to quality and compliance  ensuring consequences for poor performance or misconduct

Without effective accountability:  incentives to deliver quality are weakened  non-compliance can persist without consequence  system performance deteriorates over time

Informed and supported participants The NDIS is predicated on participants exercising choice and control within a market which requires participants to be:  able to access clear, reliable information
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 supported to understand their options  assisted to navigate complex decisions where required

Where participants are not adequately supported:  decision making is constrained or sub-optimal  exposure to poor-quality or inappropriate services increases  the effectiveness of market mechanisms is undermined

Active market stewardship In market-based systems like the NDIS, integrity is not self-sustaining. It requires active and ongoing stewardship by government including:  monitoring market behaviour and performance  intervening where markets are not delivering desired outcomes  aligning pricing, regulation and policy settings to support quality and sustainability.

Without active stewardship:  market failures can persist or worsen  incentives favour low-cost and/or low-quality provision  system objectives are not achieved  public trust and social licence are eroded Implications for reform As outlined earlier, the NDIS is a complex system characterised by information asymmetry, variable participant capability and a highly fragmented and evolving provider market. These features mean that integrity risks are inherently systemic rather than isolated. As a result, approaches to strengthening integrity that focus solely on compliance enforcement, fraud detection and individual bad actors, while necessary, will always be insufficient to make significant and enduring difference. A stronger integrity framework must address the underlying system conditions that enable non-compliance and poor outcomes to occur. The evidence is clear that:  gaps in regulation undermine enforceability  lack of performance and payments data limits transparency and accountability  insufficient navigation support weakens participant decision-making  passive stewardship allows market failures to persist.

The reforms outlined in this submission are directed at strengthening these foundational elements of system integrity to deliver better outcomes for participants, government, and the broader community. Addressing system failures to strengthen integrity

Weak provider regulation and the absence of mandatory registration

The absence of a universal mandatory provider registration framework is a foundational weakness of the current NDIS architecture. The Scheme operates in a mixed market of registered and unregistered providers with a significant and growing portion of services being delivered outside the formal regulatory framework. While this approach was intended to promote flexibility and market growth, it has resulted in inconsistent regulatory oversight across the provider market, limited visibility of service delivery and provider behaviour and uneven application of quality and safeguarding requirements. Data from the most recent NDIS Quarterly Report to Disability Ministers indicates that in the three months to 31 December 2025 only 6.5% of providers (17,982 of 276,581) receiving a payment were registered, and more than $3.8bn in funding flowed to unregistered providers. Further, $1.2bn in payments flowed through self-managed plans which operate with no payment oversight and outside of Scheme pricing arrangements and payment (PAPL) rules. This dual system creates a structural imbalance where registered providers are disproportionately subject to regulatory, compliance, quality, workforce capability and Pricing obligations (including the additional costs of meeting these requirements), effectively disincentivising registration and complex capable service delivery.2

Impact on integrity The lack of mandatory registration of providers directly undermines system integrity. It limits the ability of government to monitor and respond to non-compliance, and where providers operate outside the registration system there is reduced capacity to detect fraud and sharp practices, enforce stands and intervene early where risks emerge. Options introduced to support the use of unregistered providers like self-management of plan funding further degrades payment visibility and equity, as rules related to payment rules and price limits do not apply. As mentioned, in the December quarter alone, $1.2bn in payments were made to 136,652 providers via self-management. Importantly, this is not only a financial integrity risk, but also presents a significant equity issue, given that participants with higher risk profiles, support needs and vulnerabilities are those least likely to be able to opt in to Self-Management and most likely to be Agency Managed and are therefore unable to access supports and providers that other Scheme participants are. The weak regulatory environment also creates distorted market incentives which include incentivising non-registration to avoid regulatory burden and costs, reducing investment in quality, governance and workforce capability and eroding the viability of high quality, complex capable, compliant providers. The impact of this market distortion is felt greatest by participants who already face significant barriers to accessing the market, as registered providers are the only option for service access for participants whose plan funds are

2 Registered providers are the most complex capable providers in that they are the only providers able to provide supports to NDIA managed participants who by definition are generally more complex and with higher risk profiles and support needs. Registered providers therefore are providers who have the organisational, systems and workforce capability and capacity to manage such complex caseloads and support needs - i.e., clinical governance, supervision, graduate pipelines, training, research, specialised capability, and continuity for high-need participants.

“Agency managed” (by definition those with the most complex support needs and/or highest vulnerability or risk). As the registered market continues to shrink, these participants are being losing true choice and control as their choice of providers reduces. Lack of registration also contributes to information asymmetry, where participants are unable to distinguish between providers based on quality, safety or performance, weakening a core premise of the NDIS as a market based on informed choice. The absence of a consistent regulatory baseline increases the risk of poor-quality or unsafe service delivery, exploitation of participants and misuse of public funds, reaffirming integrity is as much a safeguarding issue as it is a sustainability issue.

Reform: Mandatory registration of all providers To address these issues, mandatory registration of all NDIS providers is required and should be implemented as soon as possible, leveraging the extensive work already done by the NDIS Provider and Worker Registration Taskforce post the NDIS Review. 3 The regulatory framework should be risk-based and proportionate. It should be streamlined and accessible, minimising barriers to entry, while creating clear and enforceable standards and expectations. Baseline requirements would include:  ABN/TFN verification attached to a unique NDIS provider number (like Medicare, enabling linking of all payments to a provider through a structured consistent national payment system)  fit and proper person tests  minimum quality standards, with escalating obligations based on risk and participant vulnerability  mandatory clinical and service governance components including incident reporting and quality controls

Establishing a universal registration framework is the minimum first step toward restoring and strengthening integrity by ensuring that all providers operating within the Scheme are visible, accountable, and subject to appropriate oversight. APM notes that coupling mandatory registration with a nationally consistent payments system would also strengthen the collection of standardised transaction-level data across the market and reduce current fragmentation and administrative burden. Better payments infrastructure and minimum datasets would support more effective market stewardship, improving transparency on what is being delivered, by whom, where, and at what cost - and enabling a stronger link between expenditure patterns and outcomes over time. It also

3 NDIS Provider and Worker Registration Taskforce | Australian Government Department of Health, Disability and Ageing (accessed April 2026)

provides an opportunity to strengthen pre-payment screening and auditing if existing scalable infrastructure (i.e., plan management4) is leveraged. 2. Inconsistent and inequitable eligibility and needs assessment A fundamental requirement of system integrity is that access to the Scheme and access to funding are consistent, equitable and based on accurate assessment of capacity and need. However, there is substantial evidence that eligibility decisions and needs assessments within the NDIS are highly variable and inconsistently applied.5This variability arises from:  differences in assessment approaches and tools,  lack of standardised, transparent methodologies  reliance on planner discretion and interpretation  inconsistent use of functional and evidence-based assessment frameworks

As a result, participants with similar levels of functional impairment and support needs can receive significantly different access outcomes and funding packages depending on their individual (or family/carer) capacity to advocate, access to external resources, and how, where and by whom their assessments are conducted. This inconsistency is compounded by limited transparency, with participants often unable to clearly understand how decisions have been made, how funding amounts have been determined or how to challenge or review decisions effectively.

Impact on integrity Inconsistent and inequitable assessment processes represent a core integrity risk within the scheme as they:  undermine the principle that funding should be allocated on objective need, creating inequities across participants and cohorts  introduce structural inefficiency and cost pressure including: o over-allocation of funding in some cases where advocacy is strong o under-allocation in others leading to crisis driven service use or plan breakdown o increased demand for reviews, appeals and administrative processes  opportunities for manipulation and gaming  weakened confidence in the Scheme as a result of reduced trust in decision making, increased perceptions of unfairness and arbitrariness and increased adversarial relationships between participants and the Agency.

4 Plan Management represents one of the most extensive and effective (and currently underutilised) mechanisms available to government to strengthen Scheme integrity. As a function that sits at the point of payment, quality Plan Managers provide real- time financial oversight, pre-payment validation and early detection of non-compliance, while also supporting participants to safely navigate a complex and fragmented market, and build their capacity as an informed consumer. 5 In raising this system issue in this inquiry context, APM acknowledges work underway on New Framework Planning which will change the current planning approach. We note that we have actively engaged in consultation on that process as it pertains to the applicability, adequacy, equity and transparency of the framework and chosen assessment tool.

Critically, where the entry point and funding baseline for the Scheme are not reliable or consistent it becomes significantly more difficult to maintain integrity across the broader system.

Reform: Nationally consistent transparent eligibility and assessment framework Addressing this issue requires the implementation of a nationally consistent and standardised approach to eligibility and needs assessment. This should include:  the use of standardised, validated evidence-based assessment tools that capture functional capacity and support needs  clear and transparent methodologies for translating assessed need into funding allocations  delivery by an appropriately skilled, capable workforce (allied health professionals)  processes that allow participants to view, understand and verify assessment outcomes prior to finalisation  streamlined and accessible mechanisms for review and appeal

Assessment reform must be designed to reduce reliance on subjective interpretation, ensure consistency across cohorts and geographies and strengthen the link between assessed need, funding and expected outcomes. Ensuring consistent and equitable access and assessment is critical to establishing a fair starting point and underpins integrity of the Scheme as a whole. Without it, integrity risks will continue to emerge across the Scheme regardless of improvements elsewhere. 3. Absence of performance and outcomes accountability The absence of a nationally consistent framework to measure, monitor and report on provider performance and participant outcomes remains a critical failure in the current system. Despite the scale and maturity of the NDIS, there remains no comprehensive system that tracks the quality and effectiveness of services at a provider level, measures participant outcomes in a consistent and meaningful way, enables comparison across providers or markets and effectively informs participant choice, commissioning, or pricing decisions While some data is collected across parts of the Scheme, it is fragmented, inconsistent, and not systematically used to drive accountability or continuous improvement.

Impact on integrity Without clear measures of quality and outcomes participants cannot make informed decisions about which providers to engage, government cannot identify underperformance or emerging risks, and high-performing providers are not recognised or incentivised. This creates an environment where poor-quality providers can continue to operate without consequence, funding may be directed toward supports that do not deliver meaningful outcomes and variation in quality remains hidden and unaddressed. Critically, this undermines both transparency and accountability, which are core preconditions of system integrity. It also weakens the effectiveness of other policy levers. For example:

 pricing decisions are made without a clear understanding of the relationship between cost and outcomes  regulatory oversight is reactive rather than proactive  market stewardship is constrained by limited evidence

In this context, the integrity risks are not only about misuse of funds but also include the systematic failure to ensure that public investment delivers value for money and outcomes for participants.

Reform: National performance and outcomes framework Addressing this gap requires the establishment of a national performance and outcomes framework for the NDIS. This framework should:  define standardised outcome measures across key support types  enable provider-level performance monitoring, including quality, safety, and outcomes  support the collection, integration, and analysis of market data  benchmark service delivery and costs across disability and outcome types  provide accessible, transparent information to participants, government, and the sector

Over time, once data is firmly established and systems have matured, this framework should be integrated with pricing and funding decisions, commissioning and market stewardship functions, regulatory oversight and quality assurance processes. Importantly, the goal is not to introduce additional reporting burden for its own sake, but to create a system where:  performance is visible  quality is incentivised  accountability is embedded  costs are managed based on data and evidence

In all other insurance schemes (e.g., workers compensation, motor vehicle accident, private health) there are benchmark costs frameworks for ‘plan’ duration and expected outcome measures – ensuring consistency in delivery, outcomes and accountability. This reform reflects a foundational shift from a compliance-focused model to an outcomes- driven system and is essential to not only strengthening performance and outcomes accountability but also to ensuring that the Scheme delivers on its objectives and sustainability is supported not only in how funds are spent, but in what they measurably achieve. 4. Inadequate plan implementation and navigation support The NDIS is designed as a participant-led market, premised on individuals exercising choice and control over their supports. However, this model assumes a level of market capability and system navigation that many participants do not have access to. Over time, key elements of the system that support effective plan implementation have been weakened or underdeveloped through:

 the diversion of Local Area Coordinator (LAC) functions away from ongoing implementation support towards planning  constrained and underfunded Support Coordination  increasing reliance on informal supports to navigate complex decisions

At the same time, the NDIS market has become more complex, with a growing and diverse provider base, variable quality and pricing structures and limited accessible information about services. This has created a significant gap between the expectations placed on participants and the supports available to enable them to engage effectively.

Impact on integrity This gap has direct and significant implications for system integrity as where participants are not adequately supported to navigate the system:  plans may be under-utilised, misdirected, or inefficiently implemented  participants are more vulnerable to poor-quality providers or exploitative practices  decision-making is driven by limited information or constrained options

This results in suboptimal outcomes for participants, inefficient use of Scheme funding and increased exposure to non-compliance and misuse. Importantly, this gap creates systemic inequity, as positive outcomes are heavily influenced by the presence of strong informal supports and/or individual capability to navigate the system. In effect, integrity risks are amplified not only by provider behaviour, but by the absence of structured support to guide participant decision-making.

Reform: Universal access to high-quality navigation supports To address this, navigation and plan implementation support must be recognised as a core system function, not a discretionary add-on. This requires a model where all participants have access to appropriate levels of navigation support, based on need. In this context high- quality navigation would include tiered layers of support:  universal navigation for information, orientation, pathway explanation and light touch connection (supporting mainstream/foundational/access pathways predominantly).  targeted navigation for people who need active help to understand options, connect services, coordinate next steps or manage transition points (i.e., co-ordinated case management/current support coordination)  specialised/intensive navigation for people facing complexity, elevated risk, fragmented systems (i.e. justice, health, housing etc), weak informal supports, communication barriers or major transition challenges (i.e., complex coordinated case management/complex support coordination)

Navigation supports would focus on:  supporting participants to understand and implement their plans within the context, rules and boundaries of the scheme  facilitating choice and control and informed decision making within the provider market  ensuring alignment between supports and participant goals  identifying and responding to risks early

Strengthening navigation is not simply a service improvement, it is a core integrity intervention, ensuring that participants are supported to engage safely and effectively in the market, and that funding is directed toward appropriate and high-quality supports. Critically, navigation should not be seen as solely a participant amenity, it is a key market stewardship, safeguarding and sustainability mechanism. By assisting participants to understand pathways, connect to the right mix of supports, make workable choices and stay on track with their plans, it mitigates the risks of costs showing up elsewhere through inappropriate access requests, poor plan use, crisis-driven demand, over-reliance on higher- cost funded supports, complaints, safeguarding failures etc. Conclusion As outlined at the beginning of this submission, integrity in the NDIS is not simply a matter of preventing fraud, it is a function of how well the system is designed, implemented and stewarded. The evidence that integrity risks are being driven be key structural weakness including gaps in provider registration, lack of performance and outcomes visibility and insufficient support for participants to navigate a complex market is well established. The NDIS review has already provided a clear roadmap for addressing these issues. The challenge now is to act. This submission identifies four priority reforms which based on our unique position in the market, we believe will deliver the greatest impact:  mandatory registration of all providers  nationally consistent eligibility and assessment processes  a national performance and outcomes framework with reported provider and service information  universal access to high quality navigation supports

Together these reforms strengthen the core conditions for integrity – visibility, equity, accountability and informed participation. APM would welcome the opportunity to continue to work with both the Joint Committee and government to realise these practical, high impact changes that will reduce non- compliance, improve participant outcomes and strengthen confidence in the Scheme.