**Australian Federation of

Disability Organisations

Joint Standing Committee on the National Disability

Insurance Scheme

24 April 2026

AFDO author and contact: Matthew Hall National Manager - Systemic Advocacy & Policy

e

Reviewed and approved: Ross Joyce Chief Executive Officer

Contents

Acknowledgements ………………………………………………………………………………………………….. 4

Language used in this document ………………………………………………………………………………. 4

About AFDO ………………………………………………………………………………………………………….. 5

1. Acronyms and abbreviations ………………………………………………………………………………… 7

2. Executive summary …………………………………………………………………………………………….. 9

3. Review the effectiveness of recent reforms ………………………………………………………….. 12

4. Integrity and Safeguarding Act ……………………………………………………………………………. 12

   4.1 Cooling off period …………………………………………………………………………………………. 12

   4.2 Digital claiming and payment ………………………………………………………………………….. 13

5. Provider registration ………………………………………………………………………………………….. 14

   5.1 Background …………………………………………………………………………………………………. 14

   5.2 The NDIS Review ………………………………………………………………………………………… 15

   5.3 The Taskforce ……………………………………………………………………………………………… 15

   5.4 Department’s consultation ……………………………………………………………………………… 17

6. Co-design ………………………………………………………………………………………………………….. 19

Endnotes ………………………………………………………………………………………………………………… 22

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Australian Federation of Disability Organisations (AFDO)

Australian Federation of Disability Organisations (AFDO) Ltd is registered as a charity with the Australian Charities and Not for profit Commission. It is also a Public Benevolent Institution, endorsed by the Australian Taxation Office as a Deductible Gift Mae gail Recipient. A donation of $2.00 or more is tax deductible.

Consent to publication: Australian Federation of Disability Organisations (AFDO) consents to the publication of this submission, including the names and contact details of AFDO staff. The relevant AFDO staff also give that consent.

© 2026, Australian Federation of Disability Organisations (AFDO) Ltd

A.B.N. 25 105 510 898 gose

CC BY-NC-SA (version 4.0): AFDO publishes, distributes, and otherwise makes available its advocacy and policy materials, including this submission, under a Creative Commons licence.

This licence allows any person to distribute, remix, adapt, and build upon the material in any medium or format for non-commercial purposes only, and only if AFDO is credited as the creator of the material. If you remix, adapt, or build upon the material, you must also license your modified material under identical terms.

The CC BY-NC-SA (version 4.0) licence includes the following elements:

BY @® You must give appropriate credit, provide a link to the licence, and indicate if any changes have been made. You may do so in any reasonable manner, but not in any way that suggests AFDO endorses you or your use.

NC ;) You must not use the material for commercial purposes.

SA ©) If you remix, transform, or build upon the material, you must distribute your contributions under this licence.

No additional restrictions: You must not apply legal terms or technological measures that restrict others from doing anything permitted under this licence.

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Integrity of the NDIS— Joint Standing Committee on the National Disability Insurance

Acknowledgements

Aboriginal and Torres Strait Islander people

Australian Federation of Disability Organisations (AFDO) acknowledges Aboriginal and Torres Strait Islander people as the First Peoples and traditional custodians of the land now called Australia. We recognise their deep and continuing connection to Country and community. We pay our respects to the traditional custodians of Country where we work, connect, or meet, which always was, and always will be, Aboriginal land. We also pay our respects to Elders past, present, and emerging.

People with disability

AFDO acknowledges people with disability in all their diversity, particularly those individuals who have experienced or are continuing to experience violence, abuse, neglect, or exploitation. We also acknowledge their families, carers, supporters, and representative organisations and express our thanks for the continuing work done by the many people supporting, protecting, and advancing the rights of people with disability.

Language used in this document

AFDO has chosen to use person-first language (like “people with disability”) in this document. Person-first language puts the person before the disability and values the individual by seeing them as a person, not a condition. This aligns with the CRPD and matches the language used by all governments in Australia. Most other Australian disability peaks also use person-first language.

We recognise many people with disability prefer identity-first language. Disability is a part of their identity and shows a connection to their community and pride in disability. Views on language reflect people’s identities, experiences of disability, and community attitudes. It is a matter of individual choice and agency. AFDO respects everyone’s right to choose how to describe their identity and experiences.

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About AFDO

Since 2003, the Australian Federation of Disability Organisations (AFDO) has been the pre-eminent national peak for people with disability, championing their rights through our extensive member organisation network uniquely representing both disability-specific and cross-disability population-based communities with a reach of over 4.5 million Australians.

We are, firstly, a Disabled People’s Organisation (DPO), led, governed, and predominantly staffed by people with disability. We are also a Disability Representative Organisation (DRO) funded by the Australian government. Our member organisations are national disability-specific peak bodies, other disability-specific advocacy and support organisations, and population based disabled people’s organisations. This ensures that our work is informed by lived expertise and experience, truly representing our communities.

AFDO is a strong, trusted voice for the disability sector. We advocate on national policy, inquiries, and initiatives with the Federal and state and territory governments. We work to build a community where people with disability:

• have real participation in community life
• can build respectful, valued relationships
• participate socially and economically, and
• contribute as valued citizens.

Our vision

All people with disability can take part equally in all aspects of social, economic, political, and cultural life.

Our mission

Using the strength of our member organisations to harness the collective power of uniting people with disability to change society into a community where everyone is equal.

Our strategic objectives

• To represent the interests and united voice of our members and people with disability at a national and international level in all relevant forums.
• To build the capacity, profile, reputation, and sustainability of AFDO through the strength of our member organisations.
• To enhance the connection and influence in international disability initiatives by

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policy, advocacy, and engagement, focused on the Asia Pacific region.

Our members

AFDO’s member organisations contribute to the national policy agenda and address issues that impact the lives of people with disability in Australia. We understand that disability-specific organisations play a key role in the provision of information and peer support to people with disability and their families. This role keeps them closely connected to their grassroots communities. Each community has its peak organisation that uses its voice to advocate on issues.

Information about AFDO’s members can be found on our website.

Every Australian Counts

AFDO has been involved in Every Australian Counts since the beginning of the grassroots campaign that successfully advocated for the introduction of the NDIS.

AFDO continues to support Every Australian Counts by auspicing the campaign, holding a position on the Steering Committee, and providing administrative, governance, marketing and communications support.

More information about Every Australian Counts, including its current priorities and activities, is available on the Every Australian Counts website.

Australian Consumers & Carers Mental Health Forum

The Australian Consumers and Carers Mental Health Forum (Forum) is a national initiative that brings together consumer and carer perspectives to develop shared positions on mental health, suicide prevention and psychosocial disability reform. The Forum supports stronger connections between mental health and disability policy and promotes collaboration across a diversity of lived experience communities.

AFDO supports the Forum by providing administrative, coordination and organisational support as well as holding a position on its Steering Committee. More information is available at The Forum.

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1 Acronyms and abbreviations

This list of terms may assist users of this document to understand what we mean when we use the following terms or abbreviations.

Term	Definition
2024 Act	National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Act 2024 (Cth)[1]
AFDO	Australian Federation of Disability Organisations
Commission or NDIS Commission	NDIS Quality and Safeguarding Commission
Committee	Parliamentary Joint Standing Committee on the National Disability Insurance Scheme
DPO	Disabled People’s Organisation. A non-government organisation governed, led, and constituted by people with disability, to be distinguished from organisations for people with disability,
DRCO	Disability Representative and Carer Organisations funded by the NDIA to work with the NDIA on reforms, changes and improvements to the NDIS. AFDO is one of 27 DRCOs
DRO	Disability Representative Organisation funded by the Commonwealth government to represent people with disability. AFDO is a DRO
Department	Department of Health, Disability and Ageing. Before 1 July 2025, Department of Social Services
Integrity and Safeguarding Act	National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026 (Cth)[2]
Minister	Hon. Mark Butler MP, the Minister for Disability and the National Disability Insurance Scheme
NDIA or Agency	National Disability Insurance Agency
NDIS or Scheme	National Disability Insurance Scheme
NDIS Act	National Disability Insurance Scheme Act 2013 (Cth)[3]

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Term	Definition
NDIS Review	Independent Review into the National Disability Insurance Scheme
Provider definition consultation paper	The Department’s consultation paper “Getting It Right: A New Definition for NDIS Providers”[4]
Taskforce	NDIS Provider and Worker Registration Taskforce

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2 Executive summary

AFDO welcomes the opportunity to provide this submission to the Committee, and to address:

1. the nature and extent of non-compliance, including fraud and sharp practices, in the National Disability Insurance Scheme;
2. the impacts of non-compliance on NDIS participants and their families;
3. the effectiveness and adequacy of successive government policies to improve scheme integrity, safeguard participants, and tackle non-compliance; and
4. any legislative or other reforms required to strengthen scheme integrity.[5]

This response is informed by discussions with our members and member feedback, to be constructive and focused on strengthening the integrity of the Scheme, viewed through the lens of human rights principles, and assessed from a systemic advocacy perspective that is centred on the rights and experiences of people with disability.

This submission focuses on paragraphs 3 and 4 of the Committee’s Terms of Reference.

AFDO remains concerned that recent reforms, justified by fraud prevention or the need to strengthen Scheme integrity, have restricted participant choice, control, and access to supports. This has often happened without clear evidence of their likely effectiveness.

Areas of reform of concern include:

• funding periods
• “NDIS supports” definition
• debt raising framework, and
• spending restrictions.

AFDO supported the Integrity and Safeguarding Act. The reforms have the potential to enhance participant safety, deter misconduct, and promote higher standards across the Scheme. Most of the amendments are consistent with the recommendations of the NDIS Review and the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability. However, several of the amendments continue to raise significant issues that affect the integrity of the Scheme.

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Also, some of the recently announced reforms to be made to the Scheme to address integrity and fraud, particularly around provider registration and digital claiming and payment systems, must, in both design and implementation, address some serious issues.

Recommendations

AFDO makes the following recommendations:

1. That the Committee must carefully scrutinise the available evidence on the effectiveness of recent changes to: (a) funding periods (b) “NDIS supports” definition (c) debt raising framework, and (d) spending restrictions. This scrutiny should establish whether these changes have delivered and continue to deliver, a demonstrable, positive impact on the integrity and sustainability of the Scheme. It should also assess whether they avoid adverse impacts on a participant’s choice and control, and whether they appropriately balance Scheme integrity with the Scheme’s social and individual goals, objectives and benefits.

2. Amend paragraph 81(3)(a) of the NDIS Act (introduced by item 3, Schedule 2 of the Integrity and Safeguarding Act) so that the paragraph does not apply to a notice given under the new section 29A, and ensure that only a participant or a participant’s plan nominee can withdraw a notice to withdraw from the Scheme during the cooling-off period.

3. Amend subsection 9A(2) of the NDIS Act (introduced by Item 4, Schedule 2 of the Integrity and Safeguarding Act) to require the NDIA CEO to ensure that the representations of approved forms published on the NDIA website pursuant to that subsection, are accessible, or provided in accessible formats.

4. Amend subsections 45(3A) –(3E) (introduced by Item 5, Schedule 2 of the Integrity and Safeguarding Act), and subsection 45A(3A) (introduced by Item 7, Schedule 2 of the Integrity and Safeguarding Act) to ensure that the way the NDIA CEO enables a participant to make a claim is accessible by the participant, or provided in an accessible format as required by the participant.

5. In the context of the announced reforms to provider registration, that:

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(a) the government should accept the Taskforce’s advice that not all providers must be registered and co-design amendments to the Act with people with disability and their representative organisations that define: (i) “NDIS provider”; and (ii) “registered NDIS provider”.

(b) the government accepts the Taskforce’s advice to include: (i) a category of registration for participants who self-direct their supports, with appropriate processes for registration and audit, and (ii) a Worker Registration Scheme for all “workers”.

(c) the government co-designs amendments to the Act with people with disability and their representative organisations that define: (i) “self directed support registration”; and (ii) “worker”; and co-design the associated registration and audit processes for self-directed support registration.

6. In the context of the other reforms to strengthen the integrity of the Scheme announced by the Minister on 22 April 2026 (which AFDO supports in principle), that:

   (a) each of those significant structural changes is properly co-designed by government with people with disability and their representative organisations through a process that is participative, inclusive, respectful, centred on lived experience and lived expertise, iterative and outcomes focused (b) the reforms are grounded in data and target provider behaviour, and do not restrict participants, and (c) the effectiveness of the reforms is measured and assessed by the extent to which the changes improve the lives of participants, in addition to the amount of costs saved or the level of reduction of fraud or other unlawful practices.

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3 Review the effectiveness of recent reforms

AFDO endorses and adopts the submission to this Committee by the Justice and Equity Centre, dated 24 April 2026, including the recommendations made in that submission. As that submission recognises

It is critical, to ensure public confidence in the NDIS and the Government’s ongoing reform program, that claims about fraud reduction are tested, substantiated, and the underlying policies subject to careful weighing and deliberation by Parliament.[6]

Any measures that seek to strengthen the integrity of the NDIS must be clearly evidence-based and must maintain participants at the centre of the Scheme while preserving their choice and control.

RECOMMENDATION 1

That the Committee must carefully scrutinise the available evidence on the effectiveness of recent changes to:

• funding periods
• “NDIS supports” definition
• debt raising framework, and
• spending restrictions,

This scrutiny should establish whether these changes have delivered and continue to deliver, a demonstrable, positive impact on the integrity and sustainability of the Scheme. It should also assess whether they avoid adverse impacts on a participant’s choice and control, and whether they appropriately balance Scheme integrity with the Scheme’s social and individual goals, objectives and benefits.

4 Integrity and Safeguarding Act

4.1 Cooling off period

Item 2 of Schedule 2 inserts a new section 29A into the NDIS Act, providing for a “cooling off” period for any request by a participant to withdraw from the Scheme. In addition, the Act (see item 3, Schedule 2) amends paragraph 81(3)(a) of the NDIS Act so that the paragraph does not apply to a notice given under section 29A. The effect is that section 82

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of the NDIS Act applies. A correspondence nominee can cancel the request to withdraw from the Scheme on behalf of the participant, including where the participant has been provided with a copy of the cooling-off notice.

This is inconsistent with section 79(1)(a) of the NDIS Act, which makes it clear that a correspondence nominee cannot do any act that “relates to the preparation, review or replacement of the participant’s plan”.

RECOMMENDATION 2

Amend paragraph 81(3)(a) of the NDIS Act so that the paragraph does not apply to a notice given under the new section 29A, and ensure that only a participant or a participant’s plan nominee can withdraw a notice to withdraw from the Scheme during the cooling-off period.

4.2 Digital claiming and payment

Subsection 9A(2) of the NDIS Act (introduced by Item 4, Schedule 2) authorises the NDIA CEO to provide for “representations” of approved forms to be published on the NDIA website. However, there is no requirement on the NDIA CEO to ensure that the representation is accessible, or provided in accessible formats.

The government asserts that the amendments to sections 45 and 45A of the NDIS Act made by the Integrity and Safeguarding Act[7] support flexibility by enabling the NDIA CEO to determine how a claim is required to be made and what kinds of claims are required to be made in that way. For example, the amendments will enable the CEO to require NDIS providers to submit claims using the my NDIS Provider Portal only, while giving the CEO flexibility to enable participants to make claims in a variety of ways.[8]

However, the provisions allow for such flexibility that the NDIA CEO may also require participants to submit claims only by a particular means or process. There is no requirement on the CEO to ensure that the means of claims submission by a participant is accessible.

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RECOMMENDATION 3

Amend subsection 9A(2) of the NDIS Act (introduced by Item 4, Schedule 2 of the Integrity and Safeguarding Act) to require the NDIA CEO to ensure that the representations of approved forms published on the NDIA website pursuant to that subsection, are accessible, or provided in accessible formats.

RECOMMENDATION 4

Amend subsections 45(3A) –(3E) (introduced by Item 5, Schedule 2 of the Integrity and Safeguarding Act), and subsection 45A(3A) (introduced by Item 7, Schedule 2 of the Integrity and Safeguarding Act) to ensure that the way the NDIA CEO enables a participant to make a claim is accessible by the participant, or provided in an accessible format as required by the participant.

5 Provider registration

5.1 Background

Earlier this year, the Department consulted on a proposed new definition of “NDIS provider”, as a necessary step to implement mandatory registration of providers.[9] This followed both the NDIS Review and the Taskforce making detailed recommendations on provider registration.

On 22 April 2026, the Minister announced a number of significant reforms to the Scheme,[10] including increased mandatory registration of providers. According to the Minister, as a result of this change, once implemented, approximately 90% of providers will be required to be registered. This was framed as a key measure to reduce fraud and protect Scheme integrity.

The Minister‘s announcement did not include any indication that the proposed changes would allow for self-directed management of providers by participants.

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5.2 The NDIS Review

The NDIS Review recommended:

• a “risk-proportionate model for the visibility and regulation of all providers and workers” in the Scheme’’

• aproposed model to regulate providers based around four broad categories of registration related to the risk associated with different types of supports and providers, with corresponding mandatory registration or enrolment requirements, namely:

  (a) advanced registration for all high-risk supports.

  (b) general registration for all medium risk supports

  (c) basic registration for all lower risk supports, and

  (d) enrolment of all providers of lowest risk supports

3. whilst recognising the NDIS was designed to offer choice and control to people with disability through a market-based system of supports’, the model should include mandatory registration or enrolment of all providers, including Navigators, Lead Practitioners and foundational support providers, and all other new supports and functions proposed in other recommendations ’.

5.3 The Taskforce

The Taskforce was tasked to give expert advice to the government on designing and setting up this new model to make sure it upholds the rights of people with disability to have choice and control.’*

The Taskforce advice notes significant concerns with mandatory registration for all NDIS providers and considered that this would:

(a) significantly impact on choice and control for NDIS participants without further design incorporating the current ways supports are managed

(b) be costly or burdensome to providers, particularly smaller providers, causing some to leave the NDIS market, which will reduce the number of providers in the NDIS and cause further barriers to accessing quality supports within the Scheme that are right for people with disability

(c) limit or stifle innovation and different models of supports NDIS participants and their families are exploring and effectively.[16]

The Taskforce made 11 recommendations, including that:

Not all providers should be registered. Further consultation with the disability community and sector is needed on this. It is recommended that those who would not be registered would include, but are not limited to:

• unregistered providers who support participants who are self-directed
• goods bought off-the-shelf from mainstream providers.[17] (our emphasis)

The Taskforce also recommended:

1. platform providers are registered,[18]

2. ways to support NDIS participants to register themselves for self-directed supports, including: (a) having support providers automatically registered and visible to the Commission. (b) putting self-directed supports in a new category, which are reviewed and audited to make sure people are safe and have quality supports (c) people with disability co-designing the registration and audit processes[19]

3. a worker registration scheme for all workers, with the disability community and sector co-designing the definition of ‘worker’[20]

4. the registration model must recognise any existing professional registrations that are held by providers, including allied health professionals[21] (noting that within the legislative framework, there needs to be consideration of the recognition of other professional registration for allied health practitioners[22], and

5. four types of registration, namely: (a) Advanced registration - providers who offer high-risk supports and services in high-risk settings, including daily living supports in closed settings like group homes. (b) General registration - providers who offer medium-risk supports like: high intensity daily personal activities, supports that need extra skills and training,

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and supports where there is a lot of one-on-one contact with people with disability

(c) Self-directed support registration - participants, their guardian or legal representative who contract all their supports directly, and

(d) Basic Registration - providers who offer lower-risk supports, such as sole traders or supports where social and community participation involves limited one-on-one contact with people with disability.[23]

The Taskforce identified a fifth category (goods or services from mainstream suppliers) for which registration is not required.

Whilst the Taskforce thought that the framework provided by the NDIS Review provides a useful framework for understanding risk, and it adopted three of the four categories of registration proposed,[24] the Taskforce’s recommendations differ from the NDIS Review in the following ways:

(a) recognising the paramountcy of choice and control (b) accepting that not all providers need to be, nor should be, registered (c) including a self-directed support registration category (d) not adopting the concept of “enrolment” for lowest risk supports, (e) not categorising any risks as “lowest”, (f) specifically including platform providers, and (g) insisting the new definition of “NDIS provider” is co-designed by people with disability.

5.4 Department’s consultation

The Provider definition consultation Paper creates strong impression the proposal to register providers is the same as, or at least closely aligned to, the recommendations of the Taskforce. None of the significant differences are noted, and insufficiently precise language is used to create the impression of much closer alignment than is, in fact, the case. However, a careful reading of the consultation paper demonstrates that the government is not proposing to implement all the recommendations of the Taskforce,

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ignores the Taskforce’s clear advice[25] that the definition must be co-designed by people with disability.

It is not clear to us if the government has accepted the Taskforce’s advice in relation to self-directed support registration, or that not all providers must be registered.

The Provider definition consultation paper states that “the Taskforce agreed with the NDIS Review that a mandatory provider regulatory model” is required.[26] This does not accurately represent the Taskforce’s work or recommendations. The use of “mandatory” makes it very unclear as to the government’s position. In one sense, any regulatory model is mandatory. That is the whole purpose of regulation. If, however, the use of mandatory is included as a reference to the NDIS Review’s model of requiring registration of all providers, the Taskforce does not agree with that position.

The Consultation paper also states (in connection with the purpose of the current consultation)

The Taskforce also recommended a category of registration for participants who self-direct their supports. Participants who register to self-direct would continue to use unregistered NDIS providers, as their arrangements would be visible to the NDIS Commission under their own registration. From 29 November 2024 to 7 February 2025 the Department of Social Services conducted a public consultation on self-directed supports, and the Government is carefully considering the submissions to this consultation alongside the Taskforce Advice.[27] (our emphasis)

AFDO is concerned that neither the Provider definition consultation nor the Minister’s reform announcement on 22 April 2026 fixes a position on this very important aspect of provider registration. Again, there is no commitment to securing the input from people with disability and their representative organisations on the co-design of the registration and audit processes.

The regulatory model must be designed and considered holistically, and not in the piecemeal, fragmented way that the Department appears to have adopted under the Provider definition consultation paper. Any proposal for increased mandatory provider registration must also include the Taskforce’s recommendations in relation to self-directed supports providers, a workforce registration system, and the definition of “worker”.[28] We also note that the need to take an holistic approach is consistent with the government’s

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approach (as published by the Department of the Prime Minister and Cabinet) to achieving the government’s vision and goals for the care and support economy, in which an “holistic, harmonised approach to the implementation of these reforms is vital”.[29]

RECOMMENDATION 5

(a) The government accept the Taskforce’s advice that not all providers must be registered and co-design amendments to the Act with people with disability and their representative organisations amendments that define:

• “NDIS provider”, and
• “registered NDIS provider”.

(b) That the government accept the Taskforce’s advice to include:

• a category of registration for participants who self-direct their supports and provide for processes for registration and audit, and
• a Worker Registration Scheme for all “workers”.

(c) That the government co-designs with people with disability and their representative organisations amendments to the Act that define:

• “self-directed support registration”, and
• “worker”, and co-design the associated registration and audit processes for self directed support registration.

6 Co-design

On 22 April 2026, the Minister stated that

the deeper reform – rebuilding how the NDIS will operate into the future – will be done through genuine and respectful work with the States, and with the community … reforms that go to the nature of the Scheme and the type of supports it delivers should always be framed by the commitment: ‘Nothing about us, without us!’.[30] (our emphasis)

The Minister described this work as “engagement”, which will include:

(a) the design of the Inclusive Communities Fund

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(b) commissioning supported independent living, plan management and support

co-ordination, and

(c) differentiated pricing, ongoing implementation of New Framework Planning, “and more”.31

Despite invoking the phrase “Nothing about us, without us!”, the Minister made no

commitment to the co-design of any part of the reforms.

Similarly, the Department is

committed to engaging with the disability community and states and territories on longer-term reforms.32 (our emphasis)

We remind the Committee that “consultation” is not “co-design”. The term

co-design is increasingly common in government discourse like this,
 yet a clear and shared definition is lacking. Like co-production, co
design has been ‘granted an influential role in the future of … public

governance … Consequently, co-design risks being little more than a buzzword in the public sector.33

True “co-design” is

a design-led process, involving creative and participatory principles and tools to engage different kinds of people and knowledge in public problem-solving.34

Central to co-design is recognition that it

goes beyond consultation by building and deepening equal collaboration between citizens affected by, or attempting to, resolve a particular challenge. A key tenet of co-design is that users, as ‘experts’ of their own experience, become central to the design process.35

This requires the following three key elements:

• Process: an iterative, design-led approach oriented towards creation or innovation.
• Principles: participative, inclusive, equal collaboration, respectful, iterative and outcomes-focused values are at the heart of this approach
• Practice: creative and tangible methods for telling, enacting and making.36

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If the integrity (and other) reforms to the Scheme are to be successful, it is essential that

these reforms are co-designed by the disability community - people with disability,

their families, carers and representative organisations. The government must recognise

that

people with disability are the experts in their own lives and must lead the design of solutions.37

RECOMMENDATION 6

That:

(a) the government co-designs all the reforms to strengthen the integrity of the Scheme announced by the Minister on 22 April 2026 with people with disability and their representative organisations through a process that is participative, inclusive, respectful, centred on lived experience and lived expertise, iterative, and outcomes focused (b) the reforms are grounded in data and target provider behaviour, and do not restrict participants, and (c) the effectiveness of the reforms is measured and assessed by the extent to which the changes improve the lives of participants, in addition to the amount of costs saved or the level of reduction of fraud or other unlawful practices.

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Endnotes

1 Retrieved from https://www.legislation.gov.au/C2024A00081/asmade/text.

2 Retrieved from https://www.legislation.gov.au/C2026A00041/asmade/text.

3 Retrieved from https://www.legislation.gov.au/C2013A00020/latest/text.

4 Department of Health, Disability and Ageing, “Getting It Right: A New Definition for NDIS Providers”, Commonwealth of Australia,19 December 2025, retrieved from https://consultations.health.gov.au/disability-and-carers-group/ndis-provider- definition-consultation/, accessed 7 January 2026.

5 Joint Standing Committee on the National Disability Insurance Scheme, Inquiry into Integrity of the National Disability Insurance Scheme, Terms of Reference, Parliament of Australia, 25 March 2026, retrieved from https://www.aph.gov.au/Parliamentary Business/Committees/Joint/National Disability Insurance Scheme/NDISIntegrity, accessed 1 April 2026.

6 Justice and Equity Centre, Submission to the Inquiry into the Integrity of the National Disability Insurance Scheme, 24 April 2026, p.2.

7 Item 5, Schedule 2, inserting new subsections 45(3A) –(3E) and Item 7, Schedule 2, inserting new subsection 45A(3A).

8 National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Bill 2025 Explanatory Memorandum, p. 39.

9 Note 4.

10 Hon Mark Butler MP, Speech at the National Press Club, Canberra, 22 April 2026, retrieved from https://www.health.gov.au/ministers/the-hon-mark-butler-mp/media/minister- butler-speech-at-the-national-press-club-22-april-2026?language=en, accessed 22 April 2026.

11 Independent Review into the National Disability Insurance Scheme, Working together to deliver the NDIS, Final Report, Commonwealth of Australia, October 2023, recommendation 17, p. 21, retrieved from https://www.ndisreview.gov.au/resources/reports/working- together-deliver-ndis/, accessed 9 January 2026.

12 Note 11, pp. 178-179.

13 Note 11, p. 49.

14 Note 11, p. 186.

15 NDIS Provider and Worker Registration Taskforce, NDIS Provider and Worker Registration Taskforce Advice, Commonwealth of Australia, 2025, p.11, retrieved from https://www.health.gov.au/sites/default/files/2025-07/ndis-provider-and-worker- registration-taskforce-advice.pdf, accessed 3 February 2026.

16 Note 15, p. 13.

17 Note 15, recommendation 1, p. 5.

18 Note 15, recommendation 4, p. 5.

19 Note 15, recommendation 6, p. 6.

20 Note 15, recommendation 10, p. 8.

21 Note 15, recommendation 11.

22 Note 15, p. 9.

23 Note 15, recommendation 3, p.5 and Table 1 (Annexure A), p. 109.

24 Note 22.

25 Note 15, p. 23.

26 Note 4, p. 6.

27 Note 4, p.2

28 Note 20.

29 Department of the Prime Minister and Cabinet, Care and support economy – state of play, 28 May 2024, retrieved from https://www.pmc.gov.au/resources/care-and-support- economy-state-play, accessed 24 February 2026.

30 Note 10, p. 12.

31 Note 10, pp. 12-13.

32 Department of Health, Disability and Ageing, Securing the NDIS for future generations, Commonwealth of Australia, April 2026, retrieved from https://www.health.gov.au/sites/default/files/2026-04/securing-the-ndis-for-future- generations 0.pdf, accessed 22 April 2026.

33 Blomkamp, E. (2018), The Promise of Co-Design for Public Policy. Australian Journal of Public Administration, 77: 729-743, retrieved from https://doi.org/10.1111/1467- 8500.12310, accessed 20 February 2026.

34 Note 33.

35 Design for Europe, quoted in Sunlight foundation, Guide to co-design, Learn how to create a participatory design process, retrieved from https://communities.sunlightfoundation.com/action/codesign/, accessed 20 February 2026.

36 Blomkamp, E. What is co-design? Understanding the process, principles and practice, retrieved from https://www.newknow.how/resources/define-co-design, accessed 20 February 2026.

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37 Media Statement from Australia’s Disability Representative Organisations, Disability advocates call on Government to ensure critical supports remain while NDIS changes are made, 22 April 2026, p. 2.

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