1 May 2026
Joint Standing Committee on the National Disability Insurance Scheme PO Box 6100 Parliament House Canberra ACT 2600 Submission via email
Dear Committee Secretary,
Thank you for the opportunity to respond to the latest Inquiry of the Joint Standing Committee on the integrity of the National Disability Insurance Scheme. The Down Syndrome Australia Consortium (DSA Consortium) welcomes this inquiry and we recognise the need to address real fraud and exploitation in the NDIS.
As a representative organisation for some of the most vulnerable people in the community, the DSA Consortium supports strong actions against individual and organisational wrongdoing. However, we are also concerned about the unintended impacts on people with intellectual disability, or high and complex support needs, and their families, carers and kin. We emphasise that actions to increase or improve integrity of the NDIS must strengthen participant safety and trust, and not undermine confidence in the scheme or access to supports.
We support a strong ecosystem of regulatory and governance practices which would allow fraudulent practices to be reduced and eliminated. This includes not only the functions of the NDIS Quality and Safeguards Commission, but where appropriate also the police, ATO, and approaches focusing on participants, such as community visitor schemes and other practices.
The DSA Consortium encourages the Committee to clearly define and separate out:
- Criminal fraud and organised exploitation of people with disability and the Scheme;
- Unethical or “sharp” practices which might operate within the law;
- Unintentional non-compliance by individual participants or their nominees caused by complexity in the Scheme or poor guidance material; and
With regard to the first two points, these are practices which are carried out by providers or others within the Scheme who rely on funding from individual participants. The systems which support this element of the Scheme are complicated, as they were not designed with or for people with intellectual disability, and therefore these participants are relying on plan nominees or service providers (including plan managers and support coordinators) to interpret the inaccessible information. In addition to fraud matters, this can also result in
gatekeeping practices or a lack of access to a range of providers which would give the participant choice and control.
Families, carers and kin report fear and confusion about “integrity actions”, including those such as the debt recovery changes which have been recently introduced. These changes have anecdotally increased anxiety about audits, debts and plan suspensions, and have resulted in a reluctance to self-manage NDIS plans, or report concerns about providers. The way that these NDIA measures are administered can be poorly explained, inaccessible for not only participants but also their nominees, and are experienced as adversarial rather than supportive. As a result, nominees and participants might have unmet needs and under- utilisation of funded supports, rather than any outcome reflecting better integrity practices.
Overall, the DSA Consortium wants to highlight the higher risks posed to people with intellectual disability. They face a higher risk of being targeted by sharp practices and other predatory practices. They also face a higher risk of being blamed for, or unaware of, decisions made by other individuals, such as plan nominees and service providers. A significant factor is the current settings within the Scheme which assume high literacy, the confidence to challenge providers and experts, and that there is equal power in provider relationships. We ask that measures around integrity are designed around support needs, not assumptions of bad faith.
The DSA Consortium would also like to draw the Committee’s attention to the issue of whistleblowing and reporting. Under current arrangements, reporting wrongdoing in the Scheme is complicated and inaccessible for many people. It can feel risky for family members, workers, and participants who are reliant on service providers (this is especially true in accommodation services). Stronger and simpler protections are needed to provide opportunities to improve safety and reduce fear of retaliation or loss of support.
Recommendations
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Continue to strengthen the role and responsibilities of the NDIS Quality and Safeguards commission with the aim of aligning with or embedding a rights-based integrity framework, consistent with the NDIS Act and CRPD.
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Invest more in market stewardship and early safeguards, not just enforcement. This should include better oversight of provider behaviour and pricing through risk proportionate tiered registration.
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Strengthen reporting and whistleblower protections across the NDIS.
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Require participant-tested, accessible communication for all integrity actions.
- Monitor and publicly report on the impact of integrity measures on participants, not only on financial measures.
Thank you for the opportunity to respond to this Inquiry. Please find information about the Down Syndrome Australia Consortium below.
Darryl Steff CEO Down Syndrome Australia
About the Down Syndrome Australia Consortium Down Syndrome Australia (DSA) was established in 2011 as the national peak body for people with Down syndrome and their families in Australia. Our vision is that people living with Down syndrome are valued and have full access to social and economic inclusion to reach their full potential. Down Syndrome Australia is one of twelve National Disability Representative Organisations (DRO) and leads a consortium of organisations to represent people with intellectual disability and their families and supporters, with a focus on intellectual disability caused by chromosomal variations (DSA Consortium).
People with these chromosomal variations experience intellectual disability varying from mild to severe, often accompanied by degrees of physical disabilities, higher rate of co- occurring neurodevelopmental conditions, communication disabilities and health issues.
It is important that the views of people with chromosomal variations and their families and supporters are represented in the development of policies and services that affect their lives. Families and supporters play a significant role in advocacy, skill development and providing supports and care. They are a critical part of the lives of a person with intellectual disability and form an important part of our advocacy work.
All our work is within the human rights model of disability and informed by the Convention on the Rights of Persons with Disabilities (UNCRPD).
Our consortium members are:
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Down Syndrome Australia and its’ member organisations - ACT Down Syndrome and Intellectual Disability, Down Syndrome and Intellectual Disability Queensland, Down Syndrome Victoria and Down Syndrome Western Australia
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Angelman Syndrome Association Australia
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Australian X and Y Spectrum Support
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Cri du Chat Support Group
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Fragile X Association of Australia
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Prader-Willi Syndrome Australia
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Smith-Magenis Syndrome Australia
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Turner Syndrome Association of Australia
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