MHCA Submission to the Inquiry into the Integrity of the NDIS
April 2026
Submitted by: Katrina Armstrong
Position/Role: Chief Executive Officer
Contact Details:
Email: redacted
Acknowledgement of Country
Mental Health Carers Australia (MHCA) acknowledges the Traditional Custodians of the lands on which we work, live and play. We acknowledge that lands were never ceded, and the First Nations peoples experience of historical and ongoing trauma of dispossession and racism. We pay respects to their spiritual ancestors, elders, and emerging leaders across time. We acknowledge with gratitude their sharing of these lands, their strong connection to Country, community and culture, and their strength and the enduring resilience of their living cultures and ways of knowing, being, and doing. We believe we have a precious opportunity to learn about holistic and community-centred approaches to mental and emotional wellbeing from Aboriginal and Torres Strait Islander people.
About Mental Health Carers Australia
MHCA is the nationally funded mental health family, carer and kin peak body, focused solely on the needs of mental health families, carers and kin. We are led by, and represent, the voices of people with lived experience of supporting someone with mental health challenges. Our aim is to work constructively with governments to improve policies and programs that directly and indirectly affect mental health families, carers and kin.
About mental health families, carers and kin
Mental health family, carers and kin are everyday Australians providing significant emotional, practical and financial support to their family member or friend living with mental health challenges. This care is grounded in relationships, whether it be as parent, partner, sibling, grandparent or close friend, and is given to protect connection, safety and dignity when systems and services are fragmented or difficult to access. While this support is rarely recognised or resourced, its impacts on carers’ own lives are profound and well documented. Many experience emotional strain, declining mental health, financial and employment insecurity, and a gradual erosion of their own social networks and sense of belonging. Over time, the caring role can also alter the primary relationship itself, as shared identities and everyday connection give way to vigilance and responsibility.
In 2015, a report by the University of Queensland, commissioned by Mind Australia, estimated that the total annual replacement cost of informal mental health care was $14.3 billion. After adjusting for a $1.1 billion offset from Centrelink payments, the net cost was $13.2 billion.1 This figure represents what it would have cost governments at the time to replace the support provided by families and informal carers with formal mental health services such as the then- existing Partners in Recovery (PiR) and Personal Helpers and Mentors (PHaMS) programs or disability support workers.
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MHCA estimates, that due to inflation and the discontinuation of PHaMS following the introduction of the NDIS, this figure would now exceed $20 billion — likely by a significant margin. For context, the total expenditure on mental health by the Australian and state/territory governments in 2022–23 was estimated at $13.2 billion.2
Note on language
MHCA recognises that individuals who support someone with mental health challenges
identify in diverse ways based on their personal experiences and relationships. Some
prefer the term "carer”, while others identify as a family member, specifying their role
(e.g., mother, father, partner, son, daughter etc). Others may identify as a friend, support
person, or care partner, emphasising the reciprocal nature of care. To maintain clarity
and inclusivity in MHCA submissions, we strive to use concise and broadly inclusive
language. For this submission, MHCA will use the terms family, carers and kin
interchangeably. On occasion, the term “carer” is used as an umbrella term
encompassing family, carers and kin for brevity.
Executive summary Mental Health Carers Australia (MHCA) welcomes the opportunity to contribute to the Joint Standing Committee on the National Disability Insurance Scheme’s inquiry into the integrity of the National Disability Insurance Scheme (NDIS). Our submission focuses on scheme integrity as it affects people with psychosocial disability and the families, carers and kin who so often carry the risk when systems do not work as intended. For MHCA, integrity is not only a question of financial misuse, it is also a question of whether the design and administration of the scheme adequately protect participants from exploitation, poor practice and avoidable harm, while recognising the role and limits of informal support.
MHCA’s position is informed by longstanding work related to psychosocial disability and carer inclusion in the NDIS. In January 2018, the NDIA engaged Mental Health Australia to conduct consultations across Australia to inform the design of a tailored NDIS pathway to improve the experiences of people with psychosocial disability participating in the Scheme, with the final report released in May 2018. 3 In late 2018, the NDIA approached MHCA, Carers Australia and the Private Mental Health Consumer Carer Network (PMHCCN) to provide input to assist in implementing Recommendation 10 of that pathway work,4 namely that consumers’ families, carers and advocates are acknowledged and supported, including involvement in all relevant meetings and discussions. The resulting report was provided to the NDIA in 2019. 5
From a mental health family, carer and kin perspective, integrity failures in the NDIS are rarely experienced as abstract governance problems. They are felt in practical ways: supports that do not arrive, invoices that do not match what was delivered, plans depleted by over-servicing or poor coordination, participants being steered into closed provider networks, complaints that appear to go nowhere, and families left to monitor, escalate and hold everything together.
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For MHCA, scheme integrity must therefore be understood as both a financial and relational issue. It is about protecting participants from fraud and sharp practices, but also about protecting the relationships that sustain safety, stability and recovery. Where integrity settings are weak, the cost is shifted onto families and carers in the form of unpaid monitoring, crisis response, advocacy, financial stress and emotional exhaustion.
MHCA supports stronger action to address fraud and sharp practices in the NDIS, particularly following Minister Butler’s National Press Club address on 22 April 2026. However, reforms should be proportionate and carefully implemented. They should avoid stigmatising people with disability or assuming families and carers can simply fill safeguarding failures. MHCA also notes that while misuse by nominees or family members can occur and must be taken seriously, this should be approached carefully and in context. In psychosocial disability, harm within the relational unit can sometimes arise not only from deliberate abuse, but also from poor information, unsupported decision-making, burnout, crisis and the cumulative pressure created when formal systems fail. Safeguards in this area should therefore be supportive as well as protective.
MHCA broadly welcomes efforts to strengthen the integrity of the scheme. Stronger integrity settings are important not only for participant safety and value for public money, but also to prevent reputational damage, mistrust and stigma from being transferred onto people with disability and their families. Integrity failures are failures of scheme design, regulation and oversight. They should not be allowed to deepen public suspicion of the people the NDIS exists to support.
Summary of recommendations:
1.1. Strengthen minimum standards for high-risk psychosocial roles through mandatory
competency requirements
1.2. Introduce a more proactive, risk-based integrity model for psychosocial disability
supports, including randomised audits, stronger invoice scrutiny and clearer
corroboration of service delivery in high-risk settings and service types
2.1. Strengthen complaints handling and reporting pathways, including timely
acknowledgement, regular updates, clear explanations of outcomes and a no wrong
door pathway for participants, families, carers, kin and workers raising concerns
2.2. Embed family, carer and kin insight into psychosocial safeguarding processes,
recognising that families often hold critical information about changing risk and
support sustainability
3.1. Mandate inclusion of psychosocial and family-carer lived experience representation
in formal NDIS reform structures and working groups
3.2. Improve transparency and consultation processes so that lived experience
organisations have a realistic opportunity to consult their communities on fast-
moving reforms
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3.3. Embed a “family and carer support and risk assessment” as part of any proposed planning workflow, including plan creation and review, to ensure informal support intensity and sustainability risk are consistently captured 4.1. Embed structured, consent-based family, carer and kin input into psychosocial safeguarding arrangements. 4.2. Require integrity-related reforms to assess the impact of and mitigate the risk of shifting support needs or physical, financial and emotional costs onto families and carers. 4.3. Ensure integrity reforms are accompanied by careful public messaging that frames safeguards as protection against exploitation and poor conduct, not suspicion of participants and their families and carers.
- The nature and extent of non-compliance, including fraud and sharp practices, in the NDIS
Integrity issues in psychosocial disability supports often arise in ways that are less visible than headline fraud, but deeply harmful in practice. They include non-delivery of supports, poor- quality delivery, inflated charging, excessive administrative billing, support coordination that consumes budget without genuine coordination benefit, and pressure on participants to remain within particular provider or worker networks. They also include circumstances in which participants are influenced away from trusted supporters or steered toward providers whose commercial interests are not transparent.
This is especially concerning in psychosocial disability, where a person’s functioning and capacity to navigate complexity may fluctuate over time. MHCA is particularly concerned about sharp practices in service environments where distress, trauma, executive functioning issues or social isolation make it harder to detect and challenge poor conduct. In these circumstances, apparently small integrity failures can have cascading impacts. A few weeks of poor support coordination, unchecked billing or service non-delivery can rapidly drain a plan, destabilise the participant, intensify distress within the family and increase the likelihood of crisis.
Psychosocial disability must not be treated as if support need can be understood only through static tasks or snapshots in time. The integrity question is not just whether a service was nominally funded, but whether it was delivered in a way that genuinely supported safety and stability for the participant and the wider relational unit.
MHCA further notes concerns raised by families, carers and kin about the absence of mandatory qualifications or minimum experience for some key roles. In a market-based system, low barriers to entry combined with participant vulnerability create clear integrity risks. In psychosocial disability, these risks are amplified because supports operate within a relational unit. Participants are often not navigating the scheme alone, and the quality and safety of support can depend on whether workers understand family dynamics and needs, alongside
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crisis risk and the sustainability of caring relationships. A scheme that is relational by design must ensure that workers in high-impact roles are equipped to work safely and competently with this complexity. Without that capability, integrity failures are more likely to occur and more likely to spill over into harm for both participants and their families, carers and kin.
Recommendations 1.1. Strengthen minimum standards for high-risk psychosocial roles through mandatory competency requirements 1.2. Introduce a more proactive, risk-based integrity model for psychosocial disability supports, including randomised audits, stronger invoice scrutiny and clearer corroboration of service delivery in high-risk settings and service types
- The impacts of non-compliance on NDIS participants and their families
For people with psychosocial disability, integrity failures can have disproportionate consequences. Poor practice does not just waste public money, it can intensify distress, undermine trust, disrupt recovery and contribute to relapse. Participants may disengage from supports altogether after negative experiences or become reluctant to accept new providers because previous services were exploitative or unsafe. MHCA’s earlier psychosocial pathway work highlighted that negative NDIS experiences can disproportionately worsen wellbeing, and that poor communication, delay and process failure can have substantial impacts on people with psychosocial disability and their families and carers.
MHCA is wary that the current system places too much responsibility on participants and families to detect non-compliance. Families and carers often become the de facto integrity backstop for the scheme: checking invoices, comparing billed hours with actual contact, monitoring whether providers have turned up, and escalating concerns across multiple agencies. These roles are neither sustainable nor equitable. They also carry the emotional impact of seeing a loved one manipulated, overcharged, isolated or destabilised by the very supports that were meant to assist.
The impacts on families, carers and kin are substantial. They can affect carers’ own mental health, employment, finances and relationships, and can change the character of the caring relationship itself, as everyday connection is replaced by vigilance and system navigation. The 2019 pathways report similarly found that families and carers continue to provide support above and beyond what is “reasonable” and are worn down trying to navigate the complexity of the NDIS.
Recommendations
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2.1. Strengthen complaints handling and reporting pathways, including timely acknowledgement, regular updates, clear explanations of outcomes and a no wrong door pathway for participants, families, carers, kin and workers raising concerns 2.2. Embed family, carer and kin insight into psychosocial safeguarding processes, recognising that families often hold critical information about changing risk and support sustainability
- The effectiveness and adequacy of successive government policies to improve scheme integrity, safeguard participants, and tackle non-compliance
While MHCA acknowledges the government’s increasing focus on fraud, non-compliance and scheme sustainability, this has not yet translated into a sufficiently strong, psychosocially informed safeguarding architecture. Families, carers and kin continue to report that concerns can be difficult to raise, slow to progress and unclear in outcome. That gap between reporting and visible action contributes to mistrust and to a perception that raising concerns is burdensome, risky and often futile.
As a recently appointed Disability Representative and Carer Organisation (DRCO), MHCA welcomes the opportunity to contribute lived experience expertise to NDIS reform processes. We have been pleased to engage constructively in reform discussions, including through the NDIA’s Mental Health Sector Reference Group and work relating to the psychosocial early intervention pathway, prior to that work being placed on hold, as well as navigation reform. MHCA values these opportunities and recognises the importance of ensuring that mental health families, carers and kin are represented in national reform conversations.
At the same time, MHCA notes that mental health and psychosocial lived experience representation within formal NDIS representative structures has only recently begun to strengthen. Alongside the National Mental Health Consumer Alliance, MHCA is one of the only mental health and psychosocial lived experience organisations to have only recently joined the DRCO structure. This matters because psychosocial disability brings a distinct set of safeguarding, integrity and service design issues, including episodic need, relational dependence, cross-system complexity and heightened vulnerability to service failure and poor practice. These issues cannot be assumed to be adequately captured without specific expertise at the table.
MHCA is also concerned about the limited transparency that continues to characterise parts of the reform process. Too often, reforms are moving at a pace that makes meaningful consultation with our members, and with mental health families, carers and kin more broadly, extremely difficult. This is particularly challenging in the context of fast-moving changes to planning, budgeting and eligibility settings, including those flagged in Minister Butler’s National
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Press Club address. Where major reform directions are announced or progressed before lived experience organisations have a realistic opportunity to consult their communities, there is a real risk that psychosocial-specific concerns are identified too late, or not at all.
This is not only a problem of process. It is also a safeguarding issue. If planning and budget reforms misread elevated family support as evidence of lower need, or if changes in eligibility, budgeting or scheme boundaries transfer support needs back onto unpaid carers without visibility or mitigation, then reform may entrench rather than reduce risk. Families and carers cannot be bystanders to reform when they are so often the ones absorbing the consequences of system failure. In MHCA’s view, major reforms of this kind should be accompanied by a structured assessment of likely impacts on families, carers and kin, including whether support responsibilities, financial costs or crisis risk are being shifted from the scheme into the home.
MHCA also considers that integrity reform should not unintentionally weaken the diversity and quality of the support market. A stronger regulatory and safeguarding framework is needed, but this should be designed in a way that supports flexibility, innovation and quality service delivery, including by smaller providers who are doing good work with psychosocial cohorts. The objective should not be to narrow the market to a small number of large providers, but to lift integrity and quality across the system.
Recommendations
3.1. Mandate inclusion of psychosocial and family-carer lived experience
representation in formal NDIS reform structures and working groups
3.2. Improve transparency and consultation processes so that lived experience
organisations have a realistic opportunity to consult their communities on fast-
moving reforms
3.3. Embed a “family and carer support and risk assessment” as part of any proposed
planning workflow, including plan creation and review, to ensure informal support
intensity and sustainability risk are consistently captured
- Legislative or other reforms required to strengthen scheme integrity
In addition to the reforms outlined above, any integrity reform should include explicit attention to whether scheme changes are shifting risk or private costs onto families and carers. Where reforms alter eligibility, budgeting rules, service pathways or market settings, government should be required to assess impacts on families, carers and kin, including where they are being left to absorb needs that were previously met, or should properly be met, through funded supports. For psychosocial disability, this is particularly important because the effects of under- support are often not immediate or visible. They are absorbed gradually through heightened vigilance, reduced workforce participation, deteriorating wellbeing and increased crisis response within the relational unit.
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Likewise, integrity reform must be designed and communicated with care. Stronger safeguards are necessary, but public confidence in the NDIS should not be rebuilt by increasing suspicion of people with disability or the families and carers around them. MHCA broadly welcomes efforts to strengthen the integrity of the scheme. However, those efforts should be accompanied by public messaging that makes clear that exploitation, fraud and sharp practices reflect failures of scheme design, regulation and oversight, not a failure of the people who rely on the scheme. This is especially important for psychosocial disability, where stigma and mistrust already create barriers to help-seeking and engagement.
Recommendations 4.4. Embed structured, consent-based family, carer and kin input into psychosocial safeguarding arrangements. 4.5. Require integrity-related reforms to assess the impact of and mitigate the risk of shifting support needs or physical, financial and emotional costs onto families and carers. 4.6. Ensure integrity reforms are accompanied by careful public messaging that frames safeguards as protection against exploitation and poor conduct, not suspicion of participants and their families and carers.
Conclusion
MHCA supports stronger action to improve the integrity of the NDIS. For people with psychosocial disability, this is not simply a matter of recovering funds or tightening compliance. It is about whether the scheme can be trusted to protect people from exploitation and support the relationships that so often hold safety and stability in place. MHCA’s previous submission to the NDIA’s new framework planning highlighted that psychosocial disability is episodic and highly sensitive to system failure, with carers often expected to absorb complexity and risk when formal safeguards fall short.
MHCA therefore urges the Committee to recommend reforms that are proactive and relationally aware: reforms that raise standards, strengthen oversight, improve complaints handling and recognise that families and carers cannot remain the scheme’s invisible safeguarding infrastructure.
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1 Diminic S, Hielscher E, Lee Y, Harris M, Schess J, Kealton J, & Whiteford H, (2017) The economic value of informal mental health caring in Australia: technical report, The economic value of informal mental health caring in Australia summary report.pdf 2 Australian Institute of Health and Welfare: https://www.aihw.gov.au/mental-health/topic- areas/summary 3 Mental Health Australia, National Disability Insurance Scheme Psychosocial Pathway (Canberra: Mental Health Australia, May 2018), https://admin.mentalhealthaustralia.org.au/sites/default/files/2025- 06/ndis psychosocial pathway consultation project - final report - may 2018.pdf.
4 Mental Health Carers Australia (MHCA), Carers Australia, and Private Mental Health Consumer Carer Network (Australia), Report to the National Disability Insurance Agency - National Disability Insurance Scheme Psychosocial Pathway: Improvements for Mental Health Carers Supporting NDIS Participants with Psychosocial Disability (Canberra: Mental Health Carers Australia, 2019), 6.
5 Ibid, 6.
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