Hireup

Submission

Inquiry into the Integrity of the National Disability Insurance Scheme

April 2026

About Hireup

Hireup is a national, NDIS-registered provider of disability support services. Through a secure online platform, Hireup provides people with disability the tools to find, hire and manage their own support workers who fit their needs and share their interests, enabling the principles of choice and control that underpin the NDIS. We are a modern provider: combining the quality and safeguarding mechanisms of NDIS registration with the flexibility and personalisation enabled by technology.

As an online platform for support work, Hireup is a rarity: we operate a contractor-free model and directly employ our support workers. This allows Hireup to offer its support workers the full range of conditions and protections guaranteed by Australian employment laws. In the past year, more than 11,000 people with disability used the Hireup platform, and we employed more than 14,000 support workers.

Introduction

The National Disability Insurance Scheme (NDIS) was established to address long-standing inequities in the design and delivery of support for people with disability in Australia. It replaced a fragmented and inconsistent system with one intended to provide greater certainty, fairness and individual control. Central to its design was the principle that people with disability should be able to exercise choice in the supports they receive, supported by a more flexible and responsive service market.

Over time, the Scheme has significantly expanded access to funded supports and brought greater visibility to previously unmet need. More importantly, it has reshaped what is possible for people with disability, enabling greater independence, participation and control over everyday life. It has also grown significantly in both scale and complexity, increasing from just over 7,000 participants at the early stages of trial in 2013–14 to more than 760,000 people currently supported in 2025–26, with total Scheme costs expected to reach approximately $50 billion over the same period.

As the Scheme has expanded to meet this demand, it has brought into scope a wider range of providers and service models — without establishing consistent oversight, accountability or alignment between funding settings and service delivery.

What began as a bold reform is now faltering under the weight of critical design flaws that have left the market unstable, uneven, and increasingly unsustainable.

How did the Scheme reach 760,000 participants and $50 billion without sufficient oversight, accountability, or alignment?

The current trajectory of the Scheme reflects deliberate design choices. In prioritising rapid access and individual flexibility, the NDIS has moved from a defined, state-managed service system to a broad and increasingly complex provider

landscape. This has expanded access and strengthened participant choice, but it has not been matched by a corresponding development in the structures required to govern it.

As the Scheme has grown, its core components have not evolved as a single, integrated framework. Planning, pricing, regulation and oversight have developed in parallel, rather than in alignment.

This fragmentation is most visible in the structure of the provider market. Supports of comparable intensity are delivered under different levels of oversight and obligations, and a significant proportion of providers operate outside the formal registration framework while accessing the same public funding and paid at the same level. Accountability, in effect, is unevenly applied.

Pricing arrangements reinforce these conditions. Current price limits do not consistently reflect differences in provider obligations, cost structures or risk. As a result, the system does not reliably recognise or reward investment in compliance, workforce capability or safeguarding, thereby weakening incentives for higher standards.

Visibility across the Scheme is constrained. There is limited real-time insight into how supports are delivered across the full provider market, particularly outside formal regulatory settings. This restricts the ability of the National Disability Insurance Agency (NDIA) and the NDIS Quality and Safeguards Commission (NDIS Commission) to consistently assess or promote quality, identify risk, and understand outcomes at a system level.

These structural conditions have been identified across successive inquiries, including the NDIS Review and the Disability Royal Commission. These have highlighted the need for stronger market stewardship, clearer accountability and improved alignment between funding and safeguards. While the direction of reform has been well established, implementation has not kept pace with the scale and evolution of the Scheme.

‘Securing the NDIS for future generations’ reform announcement, April 2026

Recent Government announcements signal a shift toward stronger integrity settings, including mandatory provider registration, tighter scheme settings and increased enforcement. These provider-targeted initiatives are necessary reforms and in the long-term, should rebalance the incentives driving the growth in low-overhead, low-accountability providers.

However, the impact of these reforms to the provider market will be determined by sequencing. Without clear alignment between pricing, registration and market design, these changes may not resolve the underlying structural issues. If implemented in a piecemeal way, they risk redistributing pressure across the system in the short-term, particularly onto providers already operating with higher compliance and safeguarding obligations.

In this context, fraud, misuse and non-compliance are not isolated incidents. They are a product of the uneven, low-barrier regulatory system in which they occur. Enforcement is necessary, but it cannot compensate for structural misalignment.

Addressing these issues requires coordinated reform to the settings that shape how the market operates. This submission makes three key recommendations.

Pricing

First, align pricing with the cost of safe and compliant service delivery. Current price settings do not recognise the real costs associated with workforce obligations, safeguarding and quality assurance. Introducing cost-reflective or differentiated pricing, including interim measures where necessary, is critical to sustaining providers who operate within the regulatory framework and ensuring that quality is both visible and viable. Done well, this does not require additional Scheme expenditure. It is a more disciplined use of existing funding, with the potential to deliver savings over time by reducing leakage and avoiding the far greater downstream costs of poor-quality supports and safeguarding failures.

Registration

Second, establish universal and functional provider registration. All entities that materially enable or deliver NDIS supports should operate within a consistent regulatory framework, proportionate to risk. This is foundational to improving visibility, ensuring accountability and restoring a baseline of participant safety across the market.

Administrative capability

Third, strengthen administrative capability and system integration. Planning, data and oversight functions must operate cohesively, with the capacity to support consistent, timely and evidence-informed decision-making. This will reduce reliance on retrospective enforcement and review processes, and enable earlier identification of risk.

The issues before this inquiry go far beyond individual misconduct. Control sits in one place but responsibility is spread across many, so it’s not always clear who is accountable. This submission argues that fraud and sharp practices are the predictable symptoms of a framework where funding and oversight are fundamentally disconnected. By analysing these structural flaws and their impact on participants, this work identifies the legislative reforms needed to augment reactive policing with robust market stewardship. Only by fixing these core settings can the Government truly protect the Scheme’s integrity and the people it was built to serve.

Context: integrity of the NDIS provider market

Today, the NDIS is the only major care sector in Australia where providers can, in large part, choose whether or not to be regulated. In practice, this has allowed most of the market to operate effectively outside the oversight of the NDIS Commission.

At the same time, the scheme applies a uniform pricing model that does not reflect the actual cost of delivering safe, high-quality support. It underprices compliant, high-quality support provision, and overpays for unregulated, low-overhead service models.

The combined effect of these two design flaws have resulted in unregulated service delivery and economically unviable pricing, which is now creating widespread risk, inefficiency, and instability across the sector.

Provider failures, workforce instability and uneven quality of care are symptoms of deeper structural flaws. Among the most urgent is a core design problem: the scheme sets national prices and expects consistent quality, but does not enforce consistent rules.

Registered providers are being asked to meet high standards on tight budgets, while unregistered providers face little-to-no regulation. This imbalance is distorting the market.

The current pricing structure also fails to reflect how support is actually delivered. Under the Disability Support Worker (DSW) Cost Model, providers are able to be reimbursed up to a set hourly maximum, regardless of whether they operate as a fully registered employer with audited systems, organisational overheads, and trained staff, or as an unregistered sole trader without insurance or experience.

These settings have enabled a parallel market to take shape. In this market, registration is optional, oversight is minimal, and compliance is treated by many as a choice. Registration is only mandatory for a small subset of support types. For most services, providers can enter the market and begin delivering services without any formal oversight or even any real barrier to entry other than signing up for an ABN.

Today, 94% of providers are unregistered.

Unregistered providers are not required to meet the NDIS Practice Standards. They are not audited, do not report incidents, and are not required to screen workers. While expected to follow the Code of Conduct, there is no mechanism to monitor or enforce compliance. In many cases, the system holds little to no information about who is delivering services or whether safeguards are in place.

For many providers, choosing not to register has become a financial decision. In a price-capped system with inadequate funding for compliance, registration becomes unaffordable. For some, avoiding regulation has become a commercially rational strategy. Registered providers cover the cost of audits, training, supervision, and

insurance, but are paid the same as those who do not. This has created a market where striving for quality is increasingly difficult to sustain.

The provider market is growing in numbers, but not in depth or stability. Without meaningful entry requirements, the NDIS has seen a sharp increase in sole traders delivering one-to-one supports. On paper, this looks like growth in provider numbers. In practice, it is fragmentation.

This shift is changing the nature of disability support work. What was once structured, team-based and clinically supported is becoming increasingly transactional, informal and isolated. While there will be examples of fantastic supports being delivered by well-trained, highly responsive, agile sole traders, the numbers are now so large (at least 116,000 according to the 2025-26 NDIS Annual Pricing Review Provider Consultation Paper), that it is impossible to adequately regulate or evaluate.

In the context of scheme integrity, these structural deficiencies create incentives and an environment attractive to business models less focused on quality services and more focused on stripping overheads and the costs of regulation in order to achieve the greatest margin. Where such incentives exist, alongside an opt-in regulatory framework, it is a perfect storm for overcharging, underdelivering, and waste.

The nature and extent of non-compliance

Non-compliance within the NDIS is often discussed in terms of fraud and misuse of funds, and it is appropriate that these issues are receiving increased attention. Recent enforcement activity, including investigations led by the Fraud Fusion Taskforce, has identified serious instances of misconduct, with millions of dollars in suspected fraudulent claims and assets linked to criminal activity. Public reporting has also pointed to the involvement of organised networks seeking to exploit weaknesses within the Scheme. These developments underscore that fraud within the NDIS is significant, and requires a coordinated and sustained response.

However, focusing solely on egregious cases risks narrowing the understanding of non-compliance. The more persistent issue lies in the everyday conditions that enable inconsistent practice across the Scheme. Non-compliance in this context is not limited to unlawful conduct, but includes a spectrum of behaviours that sit between clear compliance and clear breach, often described as “sharp practices”. These include over-servicing, inappropriate claiming, misrepresentation of services, and the structuring of arrangements in ways that avoid regulatory obligations while still accessing public funding.

The scale of these behaviours is closely linked to the structure of the provider market. A substantial proportion of supports are delivered outside the registered framework, with providers operating under differing levels of oversight despite delivering services of comparable risk and complexity. This creates an environment in which the

application of standards is inconsistent, and where accountability is not uniformly enforced.

Planning and funding arrangements also contribute to this landscape. Where plans do not adequately reflect participant need, or where funding is constrained relative to the cost of delivering safe and appropriate supports, providers are required to make real-time decisions about how services are delivered. In these circumstances, the boundaries between compliant delivery, “workaround”, and non-compliance can become blurred, particularly where participants rely on continuity of care and providers are balancing duty of care obligations.

Non-compliance cannot be understood in isolation from the broader system in which it occurs. As the market has grown, the supporting regulatory and funding settings have not kept pace. This has created conditions where inconsistent practices and accountability loopholes can emerge. Addressing this requires a more coordinated approach to reform, particularly in aligning pricing, planning and oversight with the level of risk in the system. Without that alignment, enforcement will remain limited in its impact. A more stable and effective system depends on these core elements working together.

Impacts on participants and families

The impacts of non-compliance and system misalignment are not evenly distributed across the Scheme. They are felt most directly by participants and their families, often in ways that are immediate, cumulative and difficult to mitigate. While the NDIS is designed to enable choice and control, the exercise of that choice depends on a consistent baseline of safety, quality and transparency across the provider market. Where these conditions are uneven, the burden of managing risk shifts back onto participants.

Uneven safeguards and participant risk

A central issue is the lack of consistent safeguarding across providers. Participants should be able to assume that any provider delivering NDIS-funded supports operates under comparable obligations in relation to quality, workforce standards and risk management. In practice, this varies wildly. Supports of similar intensity are delivered under differing levels of oversight, and those differences are not always visible at the point of choosing a service provider. What is presented as choice can, in effect, expose participants to uneven standards of care, limiting the ability to make informed decisions and weakening confidence in the system.

This lack of consistent standards and provider obligations results in many participants experiencing services as both the recipient and the regulator at once. Participants either must undertake onerous due diligence on every provider, in addition to comparing their service offering and prices, or accept significant risk when choosing

providers from a pool with widely varying standards, quality, and safeguarding. For unregistered providers, there is no baseline of independent standards that a participant can confidently know have been met.

As stated above, the NDIS is the only major care sector in Australia where providers can choose whether or not to be regulated, and this makes the job of participants particularly challenging in assessing quality and risk in the market.

Funding misalignment and continuity of support

These risks are intensified when funding does not reflect participant need. Where plans are insufficient, poorly scoped or slow to respond to changes in circumstances, supports are reduced or reshaped within the constraints of the existing plan. This creates a gap between need and available support, the consequences of which are borne directly by participants, affecting whether essential supports can be maintained and delivered safely. For participants with complex or ongoing needs, this can result in disruption to continuity of care and increased reliance on informal supports to fill gaps.

Once funding falls out of alignment with need, a cycle is created. Participants are required to seek reassessment or variation of their plans, often while continuing to rely on supports that exceed available funding. Providers support this process by documenting changes in circumstances and assisting with requests for review, but they do not control the timing or outcome of decisions. This creates a period of uncertainty in which access to support becomes contingent on administrative processes rather than participant need.

This dynamic generates sustained tension across multiple parties. Providers must operate within the limits of the current plan while also meeting their obligations under the NDIS Code of Conduct to act in the participant’s best interests. Decisions about continuing, modifying or reducing supports are made in real time, balancing duty of care against funding constraints. These decisions directly affect participant safety and continuity of care, and are often made in the absence of clear system guidance.

Escalation to Review and System Burden

The growing reliance on formal review mechanisms reflects the scale of these pressures. There is a sustained volume of disputes relating to NDIS funding and supports progressing to the Administrative Review Tribunal (ART), with a persistent pipeline of cases. While these processes are an essential safeguard, their use at this scale indicates that participants are being drawn into complex and protracted pathways to secure or maintain support, often navigating proceedings without representation while the Scheme incurs significant legal costs.

This raises questions about the consistency and quality of initial decision-making, particularly where a material proportion of matters are resolved through review rather than at first instance. It also reflects a system in which disputes are escalated rather than resolved early, increasing both administrative cost and participant burden.

The cumulative effect is a weakening of trust. Where participants cannot reliably distinguish between providers, where safeguards are not consistently applied, and where access to supports depends on navigating complex administrative processes, the principle of choice and control becomes harder to realise in practice. In this context, the impacts of non-compliance extend beyond individual instances of misconduct, shaping participant experience, system confidence and the overall credibility of the Scheme.

Recent reforms to strengthen integrity are necessary and reflect the seriousness of the issues now emerging across the Scheme. At the same time, new changes being foreshadowed, including increased reliance on functional capacity assessments within planning, signal a shift in how access to supports and funding decisions will be determined. These assessments are expected to play a more central role in shaping participant plans and the allocation of resources.

This places greater weight on the quality of decision-making within the system. Functional capacity assessments do not determine outcomes on their own; their impact depends on how they are interpreted and applied. Where agency capability is strong, they have the potential to support more consistent and evidence-informed decisions. Where it is not, they risk introducing further variability into planning outcomes, increasing disputes, and placing additional pressure on participants to challenge decisions in order to secure appropriate supports.

In this context, the effectiveness of reform will not be defined solely by new mechanisms, but by whether the system has the capability to apply them consistently and fairly. Without that, the underlying pressures identified throughout this section will remain, and the burden of navigating and experiencing those pressures will continue to fall on participants and their families.

3. Effectiveness and adequacy of successive

government policies

Across successive reform cycles, there has been a consistent and well-documented understanding of the factors contributing to non-compliance and integrity risk within the NDIS. Reviews, audit findings and stakeholder evidence have repeatedly identified gaps in regulatory coverage, pricing settings that do not reflect the cost of compliant service delivery, and administrative systems that do not reliably support early risk identification or consistent decision-making.

The persistence of these findings over time is significant. It indicates that the core challenges facing the Scheme are not contested or poorly understood. Rather, they have been clearly articulated across multiple processes and remain materially unchanged.

The effectiveness of government policy must therefore be assessed by the extent to which these known issues have been addressed in practice.

In relation to provider oversight, policy settings have continued to allow a substantial proportion of supports to be delivered by unregistered providers outside of consistent regulatory arrangements. This has limited the reach of safeguarding mechanisms and reduced the ability of the system to maintain visibility across the full provider market. While reforms to expand registration have been proposed and are now progressing, this gap has existed for a prolonged period despite being well recognised.

In relation to pricing, there is sustained evidence that existing settings do not adequately account for differences in provider obligations or the cost of delivering compliant, high-quality supports. Uniform price limits have remained in place across providers operating under materially different conditions, constraining the system’s ability to recognise and support compliance-related costs. This has implications not only for provider behaviour, but for the overall effectiveness of quality and safeguarding measures.

Administrative capability presents a further limitation. Audit findings and operational experience indicate that agencies continue to face challenges in data quality, system integration and risk targeting, affecting their ability to apply oversight in a timely and preventative manner. In practice, this has contributed to a reliance on retrospective compliance activity, including audits and payment controls, rather than earlier intervention based on clear and consistent system signals.

Taken together, these examples demonstrate that policy responses have addressed individual components of the system without resolving their interaction. Pricing, registration and compliance mechanisms have each been the subject of reform activity, but have not been implemented in a coordinated way that supports consistent outcomes across the Scheme.

Recent legislative changes and the broader reform agenda indicate a shift toward a more integrated approach, including stronger integrity measures, expanded oversight and more structured decision-making processes. These developments respond directly to the issues that have been identified over time.

However, the adequacy of these reforms will depend on their execution. In particular, their effectiveness will be determined by whether they are implemented in a way that aligns core system settings and supports consistent application in practice. Where alignment is not achieved, there is a risk that reforms will operate within existing system constraints, limiting their impact on non-compliance and integrity outcomes.

On this basis, successive government policies have been effective in identifying the drivers of integrity risk, but less effective in resolving them. The continued presence of these issues reflects a gap between policy design and system implementation. Addressing this gap will require a more deliberate focus on coordination, sequencing and delivery across the key components of the Scheme.

4. Reforms required to strengthen scheme

integrity

The reform priorities for the NDIS are already well established in the existing evidence base. The central challenge lies not in the identification of policy solutions, but in the absence of a deliberate and coordinated approach to their implementation. In particular, insufficient attention has been given to sequencing and alignment across the Scheme’s governing components. The effectiveness of reform will depend on the extent to which these elements are implemented in a structured and integrated manner.

The Government’s Securing the NDIS for Future Generations agenda represents a significant step in this direction. It acknowledges the need to bring greater discipline to access, funding and oversight, and signals a shift toward more structured decision-making and stronger integrity settings across the Scheme. This reflects a maturing of the reform approach and provides a clear foundation for system-wide change.

However, the effectiveness of this agenda will depend on how it is implemented in practice. Registration, pricing and administrative capability remain interdependent, but without concrete reform timeframes. In the past, progressing these elements in isolation, and with regular delays, has consistently limited the effectiveness of reform.

Expanding provider registration is essential to improve visibility, accountability and safeguarding across the market. However, extending regulatory obligations without addressing underlying pricing settings will not achieve this objective. Higher standards cannot be sustained where the cost of compliant service delivery is not recognised.

Pricing must reflect the real cost of operating within a regulated framework. At present, it does not. Price limits are applied broadly across providers with materially different cost structures and obligations.

For example, recent benchmarking from Ability Roundtable shows that, for organisations that are registered providers, the existing Cost Model underestimates the base hourly price limit ($70.23) by 10% ($7.07). The financial pressure is most severe for those delivering complex supports in high intensity and behaviour supports, where greater training, management, and safeguarding are essential.

The Cost Model assumes that the most efficient 25 percent of providers should be able to deliver services at or below the price limit, but in reality, it overlooks the day-to-day costs of operating a regulated, quality-focused organisation, particularly those supporting complex or high-risk participants.

This creates a structural imbalance in the market. Price does not signal quality, risk or accountability, and providers investing in safeguarding and workforce capability are

required to absorb costs that are not recognised. Over time, this compresses or eradicates margins, constrains service delivery and weakens incentives to maintain higher standards. In that same benchmarking data, 54% of providers reported operating at a loss in 2024–25 — and it was the fourth consecutive year of median benchmarking group losses. That is unsustainable.

Meanwhile, for an unregistered sole trader, the likely real cost of delivering an hour of support is 20-25% lower than the price limit. In this context, it is worth noting the Cost Model assumes a margin of 2%, so some providers are operating at margins tenfold the intended amount. In light of the Annual Pricing Review Consultation Paper reporting that unregistered providers claim at the top of price limit 64% of the time, there is room to seek a better value proposition than “one size fits all” pricing.

Without pricing aligned to the real cost of supports, the system risks eroding the very providers it relies on to deliver safe, high-quality and sustainable supports.

Given the time required to implement structural pricing reform, interim measures are essential. A differentiated or cost-reflective pricing approach should be introduced to recognise the additional regulatory, workforce and safeguarding obligations borne by registered providers and employer organisations. Current settings require these providers to absorb costs that are not reflected in price limits, effectively subsidising the integrity of the Scheme. This is neither sustainable nor consistent with the objective of maintaining a high-quality, compliant provider market. Without transitional pricing measures, there is a material risk that providers operating within the formal framework will withdraw or reduce service delivery, undermining both market stability and participant outcomes.

The success of the ‘Securing the NDIS for Future Generations’ agenda will ultimately depend on whether it delivers alignment across these core settings. Registration improves visibility. Pricing supports viability. Administrative capability enables consistent application. These are not discrete reforms. They are the conditions required for a system that can operate predictably, fairly and at scale.

A coordinated and sequenced approach would improve the consistency of decision-making, reduce reliance on retrospective compliance and review mechanisms, and strengthen the conditions for safe, high-quality and sustainable service delivery. Without this alignment, reform risks continuing to adjust individual components of the system without resolving how they function together. In that context, the underlying drivers of non-compliance will persist, and the burden of managing system complexity will continue to fall on participants and providers.

Conclusion and recommendations

The evidence points to a clear and consistent conclusion: integrity challenges within the NDIS are not isolated failures of behaviour, but the predictable outcome of a system where funding, delivery and accountability are not aligned. Enforcement will always be necessary, but it cannot substitute for a system that is structurally sound.

In recent years, these structural issues have meant the NDIS sometimes operates like a service procurement system that places little importance on value, or even on the quality of the service being procured.

If the Scheme is to deliver on its original promise, reform must move beyond incremental adjustments and focus on establishing a coherent operating model. This requires deliberate sequencing and alignment across the core levers of the system.

Three priorities emerge that should be executed in a timely manner.

Pricing

First, align pricing with the cost of safe and compliant service delivery. Current price settings do not recognise the real costs associated with workforce obligations, safeguarding and quality assurance. Introducing cost-reflective or differentiated pricing, including interim measures where necessary, is critical to sustaining providers who operate within the regulatory framework and ensuring that quality is both visible and viable. Done well, this does not require additional Scheme expenditure. It is a more disciplined use of existing funding, with the potential to deliver savings over time by reducing leakage and avoiding the far greater downstream costs of poor-quality supports and safeguarding failures.
Registration

Second, establish universal and functional provider registration. All entities that materially enable or deliver NDIS supports should operate within a consistent regulatory framework, proportionate to risk. This is foundational to improving visibility, ensuring accountability and restoring a baseline of participant safety across the market.
Administrative capability

Third, strengthen administrative capability and system integration. Planning, data and oversight functions must operate cohesively, with the capacity to support consistent, timely and evidence-informed decision-making. This will reduce reliance on retrospective enforcement and review processes, and enable earlier identification of risk.

Taken together, these reforms would shift the Scheme from a model that reacts to non-compliance, to one that prevents it.

The NDIS represents a substantial public investment and a foundational element of Australia’s social policy framework. Its integrity will not be secured through regulatory expansion alone, but through the establishment of a system in which funding, delivery and oversight are coherently aligned. Without this, the drivers of non-compliance will persist, irrespective of enforcement intensity. The critical task, therefore, is not simply to respond to system failures, but to address the structural conditions that produce them.