JOINT STANDING COMMITTEE

ON THE NDIS

INQUIRY INTO

THE INTEGRITY OF THE NDIS

SUBMISSION

DISABILITY INTERMEDIARIES AUSTRALIA LTD. APRIL 2026

SUBMISSION BY Disability Intermediaries Australia Limited.

CONTACT

Chief Executive Officer 1300 757 512 info@intermediaries.org.au

CITATION If you wish to cite this submission, please use:

DIA, 2026, SUBMISSION TO THE JOINT STANDING COMMITTEE ON THE NDIS - INQUIRY INTO THE INTEGRITY OF THE NDIS, DISABILITY INTERMEDIARIES AUSTRALIA LIMITED, SYDENY, AUSTRALIA.

Disability Intermediaries Australia Limited 2

Acknowledgement of Country

Disability Intermediaries Australia respectfully acknowledges Australia’s Aboriginal and Torres Strait Islander communities and their rich culture and pays respect to their Elders

past, present and emerging. We acknowledge Aboriginal and Torres Strait Islander peoples as Australia’s first peoples and as the traditional owners and custodians of the land and water on which we rely.

We recognise and value the ongoing contribution of Aboriginal and Torres Strait Islander peoples and communities to Australian life and how this enriches us. We embrace the

spirit of reconciliation, working towards the equality of outcomes and ensuring an equal

Acknowledgement of the Rights of People

with a Disability

Disability Intermediaries Australia acknowledges the objectives of the United

Nations Convention on the Rights of Persons with Disabilities which affirms that all persons with all types of disabilities must enjoy all

human rights and fundamental freedoms.

Disability Intermediaries Australia embraces

this Convention as we continue to support choice and control and the dignity of risk for all

Australians with a disability.

ABOUT DISABILITY INTERMEDIARIES AUSTRALIA

Formed in 2018, Disability Intermediaries Australia (DIA) is the national peak body for non- government disability intermediary organisations and practitioners. Members deliver Support Coordination, Plan Management, Psychosocial Recovery Coaching and digital intermediary services, reaching around two thirds of NDIS participants.

DIA maintains that a well-functioning support market is foundational to the NDIS. Intermediaries—when well designed, regulated and funded—make choice and control practical by translating rules into action, reducing administrative burden, and strengthening accountability in plan implementation.[13][14][15]

SCOPE OF SUBMISSION

DIA welcomes the opportunity to contribute to the Joint Standing Committee inquiry into NDIS integrity. This submission addresses the role Plan Management and Support Coordination play in protecting integrity, and what reforms are required to strengthen that role.

The submission proceeds on four core propositions.

Integrity extends beyond fraud to include non-compliant claims, inappropriate spending, conflicts, weak records and participant risk.[7][8][9]
Retrospective enforcement alone is insufficient in a large, dynamic market— preventative integrity is essential.
Plan Management and Support Coordination already perform important preventative integrity functions, even where not formally named as such in legislation or policy.
Governments have not yet fully aligned with the integrity work these intermediaries undertake.

EXECUTIVE SUMMARY

NDIS integrity is primarily determined at the point of plan use, not through retrospective enforcement. Current audit evidence shows limited downstream detection capacity and widespread provider activity outside full registration, increasing reliance on participant-facing intermediaries to manage risk early.[9][10]

Plan Management and Support Coordination already function as the Scheme’s first-line integrity layer—creating pre-payment checks, supporting compliant decision-making, maintaining traceability, and escalating risks before they escalate into loss or harm.[3][5][6][7]

However, these roles are not yet fully reflected in policy, system design, data access, or pricing, despite being central to how integrity is practically maintained in a distributed market. DIA submits they should be formally recognised as part of the NDIS preventative integrity architecture, with reforms focused on strengthening—not replacing—their early detection and protection functions.

COMPARATIVE INTEGRITY FUNCTIONS OF PARTICIPANT-FACING INTERMEDIARIES

Function	Plan Management	Support Coordination	Integrity effect
Understanding plans	Explains budgets, payments	Explains rules, categories	Reduces misuse
Provider choice	Enables structured payments	Supports provider selection/change	Reduces exploitation

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1. INTEGRITY IN THE NDIS BEGINS BEFORE PAYMENT AND BEFORE CRISIS

As a rights-based, participant-directed market, integrity depends on daily decisions made before claims or harm occur—provider suitability, rule compliance, budget use, pricing, and record quality.

The ANAO found compliance systems only partly effective and prevention controls historically limited, while most providers remain outside full oversight.[9][10] When prevention controls are weak at the centre, and when most provider interactions occur outside full regulatory supervision, participant-facing intermediaries become even more important as a practical source of early assurance.

DIA urges the Committee to adopt a broader definition of integrity encompassing: lawful expenditure, alignment with plans, protection from exploitation, early risk detection, traceable records, and informed participant choice.

2. PLAN MANAGEMENT: THE NDIS’S FINANCIAL GATEWAY AND FIRST LINE OF CLAIMING

INTEGRITY

2.1 The statutory and operational position of plan management

The NDIS Act expressly recognises plan management as a lawful funding management option.[2] In the June 2025 quarter, 66 per cent of participants chose a plan manager, with plan- managed payments accounting for 62 per cent of quarterly payments.[11] Plan management is therefore not peripheral — it is the operating environment through which scheme funds are translated into provider payments for most participants.

2.2 What plan managers actually do as an integrity control

Plan managers perform five key preventative integrity functions:

Create a checkpoint before payment — reviewing invoices for anomalies, pricing issues, duplication and inconsistency with the participant’s plan before a claim is lodged.
Maintain budget visibility — providing statements and tracking that allow participants and supporters to identify unsustainable expenditure patterns.
Preserve traceability — producing records of invoices, claims, statements and reconciliations that make later audit and review possible.
Improve separation of duties — creating an additional intermediary between service provision and payment, one of the simplest and most effective integrity design features in any payment system.
Identify emerging irregular patterns — including repeated invoices for cancelled services, rapid budget depletion, duplicated claims and inconsistent charging practices.

2.3 Why this role matters even more in the plan-managed market

In Q4 2024-25, 94 per cent of active providers were unregistered, receiving 42 per cent of plan- managed NDIS payments.[10] This is critical: a very large amount of market activity occurs in an environment where direct regulatory oversight is incomplete, and where the participant-facing

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intermediary provides essential practical assurance. The quality, capability and systems of plan management therefore become even more important to integrity outcomes in this environment.

2.4 Plan management is not enforcement - and should not be treated as enforcement

DIA does not suggest that plan managers should be converted into investigators or quasi- regulators. However, it is equally wrong to pretend that plan management is value-neutral administration.

The NDIA and NDIS Commission’s 2024 joint statement expressly reminded plan managers and support coordinators that they must meet record-keeping responsibilities, manage conﬂicts, and not engage in practices that facilitate the misuse of NDIS funds.[7] The state is already relying on these roles as part of its integrity ecosystem, but policy settings do not consistently support the expectation.

2.5 Current weaknesses in the plan management integrity environment

DIA sees ﬁve major weaknesses.

The integrity value of plan management remains understated in policy.
System design remains fragmented with avoidable compliance ambiguity.
Information asymmetry remains too high. Providers and participants often do not have sufﬁciently clear, timely or usable information about plan settings, spending rules, support categories or evolving policy expectations.
Plan management is carrying more integrity work in an environment of policy change. The ﬁrst-line control burden has increased, but policy has not always acknowledged that reality.
Pricing changes — including removal of the establishment fee and remote loadings from 1 July 2025[16] — risk underfunding the administrative discipline that protects scheme funds. Under-pricing ﬁrst-line integrity is a false economy.

2.6 What the Committee should conclude about plan management

The Committee should conclude that plan management is a primary preventative control in the Scheme’s most signiﬁcant non-agency payment pathway.

Any serious NDIS integrity architecture must therefore:  preserve participant access to plan management as an integrity-positive choice;  treat plan managers as legitimate integrity partners;  improve the clarity of rules and information available to them;  support high-quality record keeping, anomaly reporting and escalation pathways;  ensure pricing and system settings do not hollow out their capacity to do ﬁrst-line assurance work.

SUPPORT COORDINATION: THE SERVICE-SIDE INTEGRITY LAYER

3.1 Support coordination as an integrity function

The NDIA describes support coordination as a capacity-building support helping participants understand and use their NDIS plan, connect with providers, and build conﬁdence and skills.[5] That role is inherently concerned with integrity because many of the Scheme’s most harmful failures occur before a claim is made — Participants can be steered into unsuitable providers[*],

sold supports that do not ﬁt their plan, exposed to conﬂicts and over-servicing, or left without the evidence needed for reassessment. [*] This risk is directly relevant to the Committee’s terms of reference on sharp practices.

3.2 The ofﬁcial description of support coordination already contains integrity work

DIA submits that support coordinators protect scheme integrity in at least seven ways:

Improve the likelihood that participants use supports in line with their plans and goals. [5][6]
Reduce the risk of exploitative provider selection. [6]
Identify conﬂicts and sharp practices early.
Protect continuity of support through service change management.
Maintain the boundary between NDIS-funded supports and other systems.
Produce evidence and reporting for the NDIA.
Uphold a participant-centred integrity model that supports informed, safe and rights- based choice.

3.3 Why support coordination must be recognised as part of integrity architecture

Support coordination is sometimes excluded from integrity discussions because it is not the payer, but this confuses ﬁnancial control with broader scheme assurance. By the time a payment issue reaches a formal control point, poor providers may already be embedded, conﬂicts entrenched, and service gaps developed into crisis. The NDIA and Commission’s 2024 joint statement recognises this, conﬁrming that support coordinators play a signiﬁcant role in helping participants spend plans appropriately — recognition that must now be reﬂected in formal policy and legislation.[7]

3.4 Current weaknesses in the support coordination integrity environment

Recent ministerial announcements reﬂect growing government recognition that Support Coordination and Plan Management should operate as ‘panel’ roles — carrying the highest integrity standards, independence and professional qualiﬁcations. DIA supports this direction and submits that the following weaknesses must be addressed as part of that reform:

Structural segregation from service delivery. Support coordinators delivering, or linked to providers delivering, funded supports present a direct conﬂict of interest. Diversion of participants and inappropriate claiming risks require segregation to be mandated, not encouraged.
Prevention of SC-as-decision-maker dynamics. The trusted position of Support Coordinators can enable steering behaviours, where participants are directed toward convenient or preferred providers. Regulatory settings must explicitly address this risk.
Plan Management integrity pressure from SC referral practices. Where Support Coordinators dispute non-compliant spending decisions, participants may be shifted to more permissive plan managers. This undermines ﬁrst-line controls and should be treated as integrity circumvention.
Independence as a genuine standard. Independence must be operationalised through clear requirements, including conﬂict declarations, audit obligations and enforceable standards under proposed panel arrangements.
Reporting intelligence is underused. Support Coordinator reporting is not consistently captured or used as structured integrity intelligence by the system.
Pricing has not kept pace with growing integrity expectations. Pricing has not kept pace with increasing compliance demands, creating risk where integrity functions are under- resourced.

3.5 What the Committee should conclude about support coordination

The Committee should conclude that support coordination is a core service-side integrity mechanism. A stronger integrity system must therefore:  formally recognise support coordination as part of the ﬁrst-line integrity architecture;  strengthen conﬂict-of-interest controls and enforcement;  improve information clarity and structured reporting pathways;  stage regulatory reform in a way that lifts quality without collapsing supply;  ensure pricing and policy do not erode capacity in the very role expected to perform early assurance.

STRENGTHENING INTERMEDIARIES STRENGTHENS SCHEME INTEGRITY

Recent ministerial announcements are intended to strengthen—not weaken—intermediaries. Minister McAllister has afﬁrmed that plan managers play a key integrity role, with primary risks being conﬂicted service diversion and inappropriate claiming. DIA supports this framing and submits that reform should deepen and enforce these functions, not replace them with retrospective controls. The Committee should be cautious of inadvertently treating participant-facing intermediaries as peripheral or optional. Weakening Plan Management and Support Coordination does not reduce integrity risk — it displaces it in ﬁve ways:

Displacement into retrospective enforcement. Weak ﬁrst-line integrity increases reliance on slower, costlier, less participant-centred controls (analytics, complaints, debt recovery), despite limited review coverage.[9]
Displacement of risk onto participants and families. Without intermediaries, participants must navigate rules, invoices and crises alone—disproportionately increasing risk for more vulnerable cohorts.
Displacement into thin markets. Reduced intermediary capability lowers transparency, leading to ﬁrst-available rather than best-ﬁt provider choices, especially in regional areas.
Displacement into the NDIS as default payer. Weakening support coordination increases boundary confusion and reliance on the NDIS for unmet needs.[5][6]
Displacement into participant harm. Reduced ﬁrst-line integrity heightens risks of service disruption, ﬁnancial confusion, crisis and conﬂicted provider inﬂuence.
RESPONSE TO THE COMMITTEE’S TERMS OF REFERENCE

5.1 The nature and extent of non-compliance

Non-compliance in the NDIS extends beyond fraud. It includes improper claims (e.g. expired or out-of-scope plans, undelivered or overstated services, overcharging, duplication and double- dipping)[9] and sharp practices such as over-servicing, inducements and services contrary to plans.[8] Plan managers are best placed to detect billing anomalies, while support coordinators identify over-servicing, conﬂicted steering and provider misrepresentation.

5.2 The impacts of non-compliance on participants and their families

Non-compliance leaves participants with depleted budgets, locked into unsuitable provider arrangements, missing essential services, and bearing unpaid advocacy and complaint management burden. In serious cases, participants experience exploitation, ﬁnancial confusion and pressure to consent. Support coordinators and plan managers directly mitigate these harms when functioning well.[3][6]

5.3 The effectiveness and adequacy of successive government policies to improve scheme integrity

Government has clearly increased its focus on scheme integrity. However, the current policy mix remains incomplete in three respects:

It remains too retrospective.
It remains too dependent on registration-based logic in a market where most providers are not registered.[10]
It has not yet fully incorporated participant-facing intermediaries into the integrity design, despite expecting them to perform integrity-relevant work without commensurate data access, escalation pathways, pricing recognition or formal standing.

5.4 Legislative and other reforms required to strengthen scheme integrity

DIA submits that reform should proceed on the basis that integrity in a participant-directed scheme must be layered. The architecture should include:  clear legislative settings about plan management, payment on claim, acquittal and support boundaries;[2]  robust central prevention and detection systems within the NDIA;[9]  stronger risk-based regulatory capability in the Commission;[10]  participant-facing ﬁrst-line integrity through Plan Management and Support Coordination;[3][5][6][7]  better data-sharing, referral pathways and conﬂict controls across the system.

LEGISLATIVE AND ADMINISTRATIVE REFORMS REQUIRED DIA submits that a layered integrity architecture is required. Speciﬁcally, these reforms should include:
Formal recognition. Recognise Plan Management and Support Coordination as core components of the NDIS preventative integrity architecture.
Escalation pathways. Establish a national reporting pathway for misuse, anomalies, service breakdowns and conﬂicts, with clear feedback loops.
Data visibility. Improve plan and budget visibility (with consent) to support ﬁrst-line assurance.
Clear guidance. Provide practical guidance on funding rules, evidence requirements, pricing and support boundaries.
Conﬂict enforcement. Strengthen conﬂict-of-interest controls, including structural separation of support coordination from service delivery.
Independence standards. Introduce enforceable independence, qualiﬁcation, audit and disclosure requirements for panel intermediaries.
Use of intelligence. Treat intermediary reporting as formal integrity and market intelligence.
Preventative reporting. Publicly report on preventative integrity indicators, not just enforcement outcomes.
Staged reform. Sequence support coordination reforms to lift quality without reducing access in thin markets.
Pricing alignment. Align pricing with integrity functions, including onboarding, record keeping, education, reporting and escalation.
Embed expertise. Incorporate intermediary expertise into future integrity, claiming and participant-protection reforms.

RECOMMENDATIONS

DIA recommends that the Committee make the following recommendations to government.

No.	Recommendation
1	Recognise Plan Management and Support Coordination in legislation, policy and performance reporting as part of the NDIS’s preventative integrity architecture.
2	Preserve participant access to plan management as an integrity-positive funding management option under the Act.
3	Establish a structured national escalation pathway for plan managers and support coordinators to report suspected misuse, sharp practices, systemic billing anomalies, service breakdown and serious conﬂicts of interest.
4	Create feedback loops so intermediaries who raise serious integrity concerns know their report has been received, triaged and actioned.
5	Improve ﬁt-for-purpose plan and budget visibility for plan managers and support coordinators, with participant consent, so they can perform legitimate ﬁrst-line assurance tasks.
6	Publish clearer operational guidance about what can and cannot be funded, what evidence or process is required, and how support boundaries and pricing rules apply.
7	Strengthen enforcement of conﬂict-of-interest expectations applying to support coordination, especially where a provider also delivers other funded supports.
8	Treat intermediary reporting and escalation data as a formal source of integrity and market-stewardship intelligence for the NDIA and NDIS Commission.
9	Report publicly on preventative integrity indicators, not only retrospective enforcement activity and savings.
10	Ensure support coordination regulatory reform is staged, funded and sequenced so it improves quality and integrity without collapsing thin-market access.
11	Review pricing and payment settings for Plan Management and Support Coordination so that integrity-based work is properly recognised.
12	Embed Plan Management and Support Coordination expertise in future integrity reform, including portal, claiming, fraud-prevention and participant-protection reforms.

CONCLUSION

The Committee’s inquiry is timely. Audit evidence highlights both the scale of integrity risks and gaps in the current system.[9][10] DIA’s central submission is that Plan Management and Support Coordination already provide ﬁrst-line integrity—creating pre-payment checkpoints, maintaining traceability and escalating risks early.[3][5][6][7] In a market with limited registration-based oversight and maturing central controls, these roles are critical to the Scheme’s practical integrity architecture. Ministerial recognition must now translate into legislative alignment and pricing that reﬂects their integrity function. NDIS integrity will not be achieved through enforcement alone, but by ensuring its ﬁrst line— Plan Management and Support Coordination—is visible, capable, connected and properly valued.

TABLE OF CITATIONS

Citation	Source
[1]	National Disability Insurance Scheme Act 2013 (Cth), including Chapter 3 provisions relating to plan management, payment on claim and acquittal.
[2]	NDIS, ‘Plan management’, participant guidance page, accessed April 2026.
[3]	NDIS, ‘Support coordination’, participant guidance page, accessed April 2026.
[4]	NDIS, ‘What your support coordinator should do’, participant guidance page, accessed April 2026.
[5]	NDIA and NDIS Quality and Safeguards Commission, ‘Plan managers and support coordinators obligations’, 27 May 2024.
[6]	NDIS Quality and Safeguards Commission, Code of Conduct - Provider Guidance, guidance on sharp practices and conﬂicts of interest.
[7]	Australian National Audit Ofﬁce, National Disability Insurance Agency’s Management of Claimant Compliance with National Disability Insurance Scheme Claim Requirements, Performance Audit, 2025.
[8]	Australian National Audit Ofﬁce, Effectiveness of the NDIS Quality and Safeguards Commission’s Regulatory Functions, Performance Audit, 2025.
[9]	NDIS Quarterly Report / Scheme Actuary Presentation, Q4 2024-25, including participant funding-management and payment-share data for the June 2025 quarter.
[10]	Disability Intermediaries Australia, Submission: Inquiry into the Administration of the National Disability Insurance Scheme, January 2026.
[11]	Disability Intermediaries Australia, Submission: National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Bill 2024, July 2024.
[12]	Disability Intermediaries Australia, Submission: NDIA Planning Policy for Personalised Budgets and Plan Flexibility Discussion Paper, February 2021.
[13]	NDIS Annual Pricing Review 2024-25 outcomes page, including recommendations affecting support coordination and plan management from 1 July 2025.