NDIS reform risks to provider sustainability and participant choice | External submission

SOCIAL WORK POLICY & ADVOCACY ACTION GROUP at RMIT UNIVERSITY

The Social Work Policy and Advocacy Action Group at RMIT University is made up of social work students and academics with a shared commitment to human rights, social and environmental justice. The group brings together researchers, practitioners and people with lived experience. In line with our professional code of ethics, we advocate on key social issues with a particular focus on marginalized and disenfranchised communities.

This submission represents the views of the authors and not RMIT University.

Date: April 2026

SUBMISSION TO Inquiry into the Integrity of the National Disability Insurance Scheme

Summary

Recent NDIS reform announcements have prompted signiﬁcant concern. While some measures are needed and overdue, such as tightening provider registration, strengthening payment oversight, and addressing misuse within the NDIS, the broader reform direction signals a shift toward ﬁscal restraint at the expense of the rights, safety and lived experience of disabled people. Proposed reductions to individual plans, the transition of more than 160,000 participants out of the NDIS, and the introduction of a redesigned eligibility model present serious risks with potentially devastating impacts. These changes will have immediate consequences, long before alternative systems or supports are designed, funded or operational. The Government’s own timeline underscores this concern, with key assessment tools not expected until 2028, creating a signiﬁcant gap between policy change and service availability.

At a minimum, participants must not be exited from the NDIS until viable, accessible replacement supports are in place. Funding for essential supports, those required for daily functioning, personal safety, and dignity, must be protected. Full transparency is also required regarding proposed functional capacity assessments, including who will conduct them, how decisions will be made, and what review and appeal mechanisms will exist.

There is broad agreement on the need for a stronger, more sustainable NDIS. However, sustainability must not come at the cost of reduced support, increased barriers to access, or erosion of the Scheme’s foundational principles of certainty, choice and control.

Our submission will focus on 5 key areas:

Defining Integrity in the NDIS
Transparency, Decision-Making, and Administrative Integrity
Participant Experience, Co-Design, and Equity
Provider Market Sustainability and System Pressures
Reform Context and Broader Fiscal Framing

Recommendations:

Recommendation 1: Establish a comprehensive Integrity Framework. Develop and implement an Integrity Framework integrating financial and participant-centred integrity, with clear actions, timelines and stakeholder engagement.

Recommendation 2: Strengthen transparency and administrative accountability- Release financial modelling and key documents. Respond systematically to ART outcomes, ensure clear appeal rights (including for new plans and participant exits), and improve transparency in decision-making.

Recommendation 3: Re-centre participant experience and co-design and resume meaningful co-design with clear reporting. Strengthen the Participant Service Guarantee, invest in decision-making supports, and implement safeguards for marginalised groups and participants.

Recommendation 4: Ensure provider sustainability and protect participant supports. Assess and report on the total cost of compliance. Ensure registration reforms support provider viability and participant choice. Avoid reducing supports without viable alternatives in place.

Recommendation 5: Prioritise equitable funding by avoiding NDIS cuts and reassessing broader tax expenditures and subsidies instead.

Response

Defining Integrity in the NDIS

The meaning of ‘integrity’ is not clearly deﬁned by the NDIA. In practice, integrity considerations have been largely constrained to financial and regulatory matters. This narrow framing does not reflect the full scope of what integrity should encompass within a

national social support scheme. The NDIS should instead be understood as a dual obligation: to safeguard public funds and to ensure the fair, consistent, and transparent administration of participant supports. Current reforms emphasise the former but pay insufficient attention to decision-making transparency, systemic consistency, and supported autonomy for participants. This imbalance risks embedding inefficiencies, increasing disputes, and undermining participant trust. Integrity is not only about preventing misuse of funds, but ensuring equitable, timely, and fair access to supports through processes that are transparent and reviewable.

For 2025–26, the Government has budgeted $52.3 billion (6.7% of total expenditure) for the NDIS, with projected growth of 10% annually, targeted to reduce to 5–6%. The Scheme has grown from approximately 400,000 to 650,000 participants, including 150,000 children, yet still serves only 15% of the 4.3 million Australians with disability. Growth reflects unmet need, not excess.

From a social work perspective, integrity requires prioritising participant rights, dignity, and choice and control, and being led by disabled people.

Transparency, Decision-Making, and Administrative Integrity

Concerns about integrity are particularly evident in transparency and administrative decision-making. The NDIA continues to announce changes without sufficient detail while maintaining internal guidelines that are not publicly accessible. Participants and families may be significantly impacted and deserve full transparency, including access to financial modelling and independent reports informing reforms.

The NDIA does not systematically respond to findings from the Administrative Review Tribunal (ART) or courts. These are critical feedback mechanisms. Applications to the ART have increased by 95%, with a high proportion of NDIA decisions overturned. This indicates systemic issues in primary decision-making, with participants bearing the weight of navigating complex review processes.

Appeal rights within new framework plans remain unclear, particularly regarding whether budget outcomes generated through assessment will be reviewable. Decision-making cannot be fully outsourced to automated systems without safeguards, transparency, and accessible review pathways. There is also insufficient clarity regarding appeal rights and

transition processes for the 160,000 participants proposed to exit the Scheme, raising significant concerns about continuity of supports and administrative fairness.

Participant Experience, Co-Design, and Equity

Participant experience is central to scheme integrity, yet current reforms risk weakening participant-centred approaches. Meaningful co-design has not been consistently implemented. A 2025 independent report identified concerns regarding how the NDIA conceptualises and delivers co-design, and this work has been deprioritised. There is limited transparency regarding how participant input translates into decisions and outcomes. The Participant Service Guarantee also requires renewed focus. Persistent delays in processes such as plan reviews indicate ongoing non-compliance with timeliness standards, undermining access to supports. The current reform direction reflects a shift toward risk- focused regulation and plan reductions, rather than enabling creative, participant-centred solutions. Mechanisms such as circles of support or Microboards can offer preventative safeguarding and responsive care but are not formally supported.

Participants from culturally and racially marginalised (CARM) backgrounds face additional risks. Evidence shows they are more vulnerable to exploitation, including fraud, and face barriers due to language and system knowledge. In practice, this can result in individuals paying for services they do not receive, losing funds while essential supports are not delivered.

Provider Market Sustainability and System Pressures

Provider sustainability is critical to scheme integrity. Current reforms risk destabilising the provider market.

Data indicates (National Disability Services, State of the Sector Report 2024-25):

Approximately 50% of providers operate at a loss
77% deliver unfunded services
81% report they cannot continue under current pricing levels

Mandatory registration introduces further costs, with median costs of $1000 (certification) and $6000 (verification) audits, in addition to compliance costs. While tiered registration is a positive step, it must not reduce provider participation or limit participant choice, particularly in rural and remote areas.

Fraud must also be understood in context. The NDIA estimates 6–10% of expenditure ($3.1B–$5.2B) relates to incorrect, non-compliant, or fraudulent claims. Many of these may reflect system issues rather than intentional misuse. Proposed reductions in average plan budgets, from $31000 to $26000, occur in the context of rising costs, including 3.8% inflation. This reduces real purchasing power and access to essential supports.

Transitioning participants out of the NDIS without established alternatives represents a cost shift rather than a cost saving. Foundational supports are not yet operational, with key reforms not expected until 2028, creating a significant service gap.

Reform Context and Broader Fiscal Framing

Recent reforms include necessary improvements but also significant risks. Reductions in plans, tighter eligibility, and the transition of over 160,000 participants will have immediate impacts, while replacement supports are not yet available.

The framing of the NDIS as a fiscal problem must be contextualised. Other expenditures demonstrate alternative policy choices:

$13.3 billion (projected to $23 billion) in tax expenditures for property investment
Approximately $14.9 billion annually in fossil fuel subsidies in 24/25.

Positioning the NDIS as a primary site for cost containment risks disproportionately impacting people with disability. The NDIS was founded on principles of certainty, choice, and control. Reforms must reinforce, not erode, these principles.

Recommendation 5: Prioritise equitable funding by avoiding NDIS cuts and reassessing broader tax expenditures and subsidies instead.

We would welcome the opportunity to further discuss any of the points raised in this submission.

Submission written by: Bridget White, Evelyn Dowling, Freya Boopalan, Jennifer Thomas, and Pushkar Sebastian Cordoba.

For any queries please contact:

Dr Pushkar Sebastian Cordoba Social Work and Human Services School of Global, Urban & Social Studies RMIT University Email: redacted