NDIA Accountability Project

Systemic integrity issues within the National Disability Insurance Scheme

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Submission to the Joint Standing Committee on the National Disability Insurance Scheme

Inquiry into Scheme Integrity and Non-Compliance

Date: 11 April 2026

1. Executive Summary

This submission outlines systemic integrity issues within the National Disability InsuranceScheme (NDIS), focusing on non-compliance, regulatory gaps, and structuralinefficiencies that undermine participant outcomes and scheme sustainability.

Non-compliance is not limited to isolated instances of fraud. It reflects broader andentrenched issues across provider practices, workforce capability, service deliverymodels, and weak enforcement of existing safeguards.

These failures result in:

  • Inefficient use of public funds
  • Reduced access to appropriate supports
  • Inconsistent service quality
  • Increased burden on participants and families

This submission identifies key risk areas and proposes practical, enforceable reformsaimed at strengthening accountability, improving value for money, and ensuring thescheme remains equitable and sustainable.

2. Key Systemic Issues

2.1 Provider charging Practices and Financial Integrity

There is strong evidence of widespread inconsistencies in provider billing practices, including:

  • Charging above reasonable market benchmarks
  • Excessive claims for non-face-to-face activities
  • Inflated service hours and travel claims
  • High-cost reporting that is disproportionate to outcomes

These patterns suggest systemic weaknesses in pricing oversight and compliance enforcement rather than isolated misconduct.

Workforce Capability and Regulation

The NDIS workforce operates with inconsistent regulatory oversight. Key concerns include:

  • Use of underqualified staff in complex support roles
  • Lack of enforceable minimum training standards
  • Limited monitoring of competency and professional accountability

This variability directly impacts participant safety and the quality of support delivery.

Misalignment in Use of Funded Supports

Certain supports are being used in ways that do not align with their intended purpose, including:

  • Short-term accommodation used for recreational or lifestyle purposes
  • Therapy supports delivered without clear evidence of benefit
  • Inconsistent allocation of support worker hours without standardised benchmarks

This reduces resources available for participants with higher and more complex needs.

Behaviour Support – Design and Implementation Gaps

The Behaviour Support framework demonstrates significant limitations:

  • Plans are often overly complex and not consistently implemented
  • Disconnect between clinical recommendations and real-world environments (particularly schools)
  • Variable practitioner qualifications impacting intervention quality

Data collection practices are frequently inconsistent and rely heavily on subjective reporting, reducing reliability.

Overall, the model risks high administrative burden with limited measurable outcomes.

Inequitable Access and Allocation of Supports

There are inconsistencies in how supports are allocated across participants:

  • Funding decisions may be influenced by diagnosis rather than functional impairment
  • Participants with higher needs may be under-supported
  • Lower-need participants may receive disproportionate funding

Greater alignment with functional impact and complexity is required.

Weak Enforcement of “Reasonable and Necessary” Criteria

There is insufficient scrutiny of whether supports:

  • Represent value for money
  • Are disability-specific
  • Are more appropriately funded through mainstream systems

This has led to duplication of services already available through government or community programs.

Lack of Cross – Agency Data Integration

Limited data sharing between systems (e.g. social services, housing, and health) creates risks including:

  • Undisclosed or underreported supports
  • Duplication of funding
  • Incomplete understanding of participant circumstances

Improved data integration is critical to informed decision-making.

Use of Supports as Substitute Care Rather Than Capacity Building

There is increasing concern that some supports function as general supervision or informal childcare rather than:

  • Building independence
  • Developing functional skills
  • Supporting long-term outcomes

While family support needs are valid, clearer boundaries are required to ensure alignment with scheme objectives.

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2.9 Consumables and Assistive Technology Misuse

Consumables funding lacks clear boundaries, leading to:

  • Purchase of items not directly linked to disability needs
  • Inconsistent interpretation of eligibility
  • Reduced funds for essential supports

The absence of clear guidance creates systemic ambiguity and misuse risk.

2.10 Data Security and Offshore Services Risks

Outsourcing of administrative and coordination functions introduces risks to:

  • Data privacy
  • Regulatory compliance
  • Service quality

Stronger safeguards are required to ensure participant information is protected under Australian standards.

2.11 Scope of Practice – Support Workers

Support workers are increasingly used outside their intended role, including for:

  • Specialist instruction
  • High-risk physical activities
  • Skilled or licensed tasks

This creates safety risks and undermines role clarity and accountability.

2.12 Tribunal and Dispute Resolution Inefficiencies

Current dispute processes are:

  • Lengthy and resource-intensive
  • Legally complex
  • Disproportionately costly relative to outcomes

This reflects failures in early decision-making and internal review processes.

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2.13 Delays in Assistive Technology

Participants face significant delays in:

  • Approval processes
  • Equipment provision
  • Supplier coordination

These delays negatively impact independence and may increase long-term costs.

2.14 Misallocation in Child Plans

Supports such as domestic services are being included in child plans where:

  • They do not directly relate to the child’s disability
  • They fall within general household responsibilities

This diverts resources away from core support needs.

2.15 Blurring of Boundaries with Mainstream Systems

NDIS funding is increasingly used in place of:

  • Childcare services
  • Education-based supports
  • Welfare and family support systems

The scheme must complement—not replace—existing services.

2.16 Hospital and System Interface Failures

Use of hospital admissions for social reasons highlights:

  • Gaps in community-based supports
  • Poor system coordination

Clear thresholds and accountability are required.

2.17 Underutilisation of Community-Based Alternatives

Many community and charitable programs provide accessible, low-cost support.

NDIS funding should:

  • Facilitate access to these programs
  • Avoid duplicating existing services

2.18 Risks in SDA and SIL Environments

Participants in supported living environments face risks due to:

  • Limited transparency
  • Inconsistent oversight
  • Power imbalances

Stronger safeguards and monitoring are required.

2.19 Sustainability and Targeting of Supports

There is a need to ensure funding is:

  • Directed to those with greatest need
  • Allocated equitably
  • Financially sustainable over time

Policy consideration of targeted funding approaches may be warranted.

2.20 Non-Delivery of Services and Weak Compliance Monitoring

Instances of services being:

  • Partially delivered
  • Not delivered
  • Inadequently verified

highlight the need for stronger compliance systems.

2.21 Autism Access and Functional Assessment

Access processes would benefit from:

  • Greater emphasis on functional impairment
  • Consistent use of multidisciplinary assessment
  • Evidence across multiple settings and over time 6-12 months
  • Entry age limit to the scheme (currently over diagnosis) children not allowed time to develop at own pace
  • Many misdiagnoses and no catch-up reassessments children that on paper states nonverbal at 2 years of age now 6 can talk
  • Reassessments for all Autism Diagnosis starting from 2020 when influx commenced

What Counts as a “Thorough” Autism Diagnosis for NDIS?

A diagnosis must be completed by a qualified professional, typically:

  • Paediatrician
  • Clinical psychologist
  • Psychiatrist
  • Multidisciplinary team including occupational therapist and speech pathologist (mandated for children)

The NDIS and Autism CRC have developed national diagnostic guidelines to ensure consistency. These guidelines emphasise:

  • Standardised assessment tools
  • Developmental history
  • Observation across settings
  • Severity level classification (Level 1, 2, or 3)

Functional Capacity Evidence Required

How Autism affects:

  • Communication
  • Social interaction

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  • Learning
  • Mobility
  • Self-care
  • Self-management

This evidence must come from a treating professional who has known the person for at least one year (e.g., GP, OT, psychologist, psychiatrist, pediatrician, speech pathologist).

This would improve consistency and reduce variability in decision-making.

Impacts on Participants and Families

These systemic issues result in:

  • Reduced availability of supports
  • Increased financial inefficiency
  • Greater reliance on informal care
  • Exposure to inconsistent or poor-quality services
  • Erosion of trust in the scheme

Policy and Safeguard Limitations

Current approaches are largely reactive and fail to adequately address:

  • Routine non-compliance
  • Pricing and billing practices
  • Workforce regulation
  • Monitoring of service delivery

Stronger preventative and enforcement mechanisms are required.

5.1 Strengthen Pricing and Billing Oversight

  • Enforce transparent, itemised billing
  • Limit excessive non-face-to-face charges
  • Introduce pricing controls where necessary

5.2 Improve Workforce Regulation

  • Establish mandatory qualification standards

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5.3 Reinforce “Reasonable and Necessary” Boundaries

  • Prevent duplication with mainstream services
  • Strengthen value-for-money assessments

5.4 Enhance Monitoring and Compliance

  • Introduce real-time service verification mechanisms
  • Expand auditing and enforcement capacity

5.5 Reform Behaviour Support

  • Require appropriate clinical qualifications
  • Ensure plans are practical and evidence-based

5.6 Improve Assistive Technology Access

  • Streamline approval processes
  • Introduce fast-track pathways for standard supports

5.7 Strengthen System Integration

  • Improve cross-agency data sharing
  • Ensure more accurate funding decisions

5.8 Improve Dispute Resolution Processes

  • Strengthen early resolution pathways
  • Reduce reliance on adversarial tribunal processes

6. Conclusion

The issues identified in this submission reflect systemic weaknesses that undermine the integrity, equity, and sustainability of the NDIS. Without targeted reform, these challenges will continue to impact participant outcomes and erode public confidence. A stronger framework—focused on accountability, clarity, and enforcement—is essential to ensure the scheme delivers its intended purpose: supporting individuals with disability to achieve meaningful and equitable outcomes.

Submission to the Joint Standing Committee on the National Disability Insurance Scheme

Inquiry into Scheme Integrity and Non-Compliance

Date: 11 April 2026 Summary: How to Address and Rectify Systemic Issues in the NDIS Addressing integrity and non-compliance issues within the NDS requires a coordinated, system-wide reform approach focused on clarity, enforcement, accountability, and sustainability. The following priority actions provide a practical pathway for reform:

1. Strengthen Regulation and Enforcement

  • Introduce mandatory provider registration and minimum workforce standards across all service categories
  • Increase audits and targeted compliance checks
  • Regular audits with short term respite and accommodation
  • Apply stronger penalties for overcharging, non-delivery of services, and misuse of funds, impose repayments
  • Establish a consistent national enforcement framework rather than reactive oversight

2. Improve Pricing Transparency and Cost Control

  • Mandate itemised billing and justification for all charges, including non-face-to- face activities
  • Introduce caps or benchmarks for high-risk areas (e.g. therapy hours, support worker hours and short-term respite especially children capable of attending school), cleaning, gardening, reporting costs)
  • Strengthen value-for-money assessments in planning and reviews

3. Stricter Eligibility Criteria for Short Term Respite (STR aka STA)

Issue Short Term Accommodation and Respite (STR aka STA) is intended to provide temporary, disability-related support for participants with significant care needs and to sustain informal support arrangements.

Proposed Reform: Strengthened Eligibility Framework

A. Clear Eligibility Threshold Based on Functional Need/Capacity

Access to STR should require demonstrated:

  • High or complex functional impairment, and
  • Sustained reliance on informal supports, where carer capacity is at risk

Eligibility should prioritise participants who:

  • Require intensive daily support or supervision
  • Present behavioural, medical, or safety risks
  • Have limited alternative support options

B. Evidence – Based Justification

Approval of STR should require:

  • Documented evidence of carer fatigue (no other informal support), risk of breakdown, or inability to sustain care
  • Functional assessments demonstrating level of support required
  • Evidence across multiple settings home, community, ONLY children SSP school/Homeschooled (excluding children capable of attending mainstream school, support units, distance education)

Requests should clearly demonstrate the link between STR and:

  • Maintaining the participant’s current living arrangement
  • Preventing escalation to higher cost supports (e.g. hospital or residential care)

C. Defined Purpose and Use

STR funding should be explicitly linked to:

  • Respite for informal carer, and/or
  • Skill development and capacity building in a supported environment

It should not be routinely approved for:

  • Holidays or tourism-based activities
  • General recreation without therapeutic or functional purpose
  • Replacement of standard childcare or supervision

D. Tiered Access Model

Introduce a more structured approach to STR allocation:

  • High Needs (Complex/24-hour support) children attending SSP school Homeschooled: Regular, planned STR access with flexibility
  • Moderate Needs children distance learning: Limited, time-bound STR linked to specific goals or carer support needs
  • Low Needs children attending mainstream school including support units: STR generally not funded unless exceptional circumstances are demonstrated
  • Optional offer In Home Respite 2-4 hours per week maximum (ONLY for single carer household)

E. Caps, Frequency, and Review Requirements

  • Introduce reasonable caps on annual STR usage, with flexibility for high-need cases
  • Require regular review and re-justification of ongoing STR funding
  • Ensure usage aligns with participant goals and functional outcomes

F. Service Delivery Controls

  • Prioritise structured, provider-based settings where appropriate
  • Strengthen oversight of:
    • Pricing
    • Group vs individual delivery
    • Actual service provision
  • Improve transparency in how STR supports are delivered
  • Mandate Use to be ONLY in group homes or centers

G. Monitoring and Compliance

  • Implement clear reporting requirements linking STR use to outcomes
  • Introduce targeted audits in high-use cases
  • Strengthen consequences for misuse or misrepresentation

H. Outcome

A stricter, evidence-based approach to STR will:

  • Improve equity of access
  • Ensure supports are directed to those with genuine high-level need
  • Reduce misuse and duplication
  • Strengthen scheme sustainability and public confidence

Short Term Respite must be preserved as a targeted, high-value support, not diluted through inconsistent application. Clear eligibility, strong oversight, and alignment with functional need are essential to ensure it remains effective for those who rely on it most.

Stricter Eligibility for Short Term Respite (Aligned with “Reasonable and Necessary”)

Access to Short Term Accommodation and Respite (STR) should be more explicitly aligned with the “reasonable and necessary” criteria under the NDIS Act.

STR should only be funded where it can be clearly demonstrated that the support:

  • Relates directly to the participant’s disability, rather than general care, supervision, or lifestyle needs
  • Is necessary to support functional capacity and maintain informal care arrangements, particularly where there is evidence of carer fatigue or risk of breakdown (NO OTHER INFORMAL SUPPORT evidence required)
  • Represents value for money, compared to alternative supports that could achieve the same outcome at lower cost
  • Is effective and beneficial, with a clear link to participant outcomes such as stability of living arrangements, reduced risk, or capacity building
  • Is not more appropriately funded or provided through mainstream, community, or family supports, including childcare or recreational services

Clarify “Reasonable and Necessary” Boundaries

  • Develop and enforce clear guidelines distinguishing disability supports from:
  • childcare
  • school drop offs and pick ups
  • general household responsibilities
  • lifestyle or recreational activities
  • Prevent duplication with mainstream services (health, education, community programs)

Reform Assessment and Access Processes

  • Prioritise functional impairment over diagnosis alone
  • Require multidisciplinary assessments for complex conditions (autism)
  • Standardise assessment tools and introduce independent review mechanisms
  • Ensure evidence is gathered across multiple settings and over time 6-12 months

Strengthen Monitoring of Service Delivery

  • Implement real-time or near real-time service verification systems
  • Introduce digital attendance tracking where appropriate and consent-based
  • Expand data matching across government systems to detect duplication and undisclosed supports

Improve Workforce Quality and Role Clarity

  • Define and enforce scope of practice for support workers
  • Require minimum qualifications and ongoing training standards
  • Prevent substitution of unqualified workers for specialised or licensed services

Reform Behaviour Support and Therapy Models

  • Require evidence-based, practical, and implementable plans
  • Ensure appropriately qualified clinicians deliver specialised supports
  • Introduce outcome-based measures to assess effectiveness

Formal Recommendations / Reform Section

Recommendations for Reform of Behaviour Support Systems (NDIS and Education Interface)

To address the systemic failures in Behaviour Support Plan development and implementation, the following reforms are recommended:

  • Mandatory Implementation Auditing

Introduce independent auditing of BSP implementation across environments (home, school, community, and therapy settings), not just plan creation. Funding and compliance should be linked to demonstrated implementation of fidelity, not documentation alone.

  • Minimum Training Standards for Implementation

Require mandatory, standardised training for all individuals responsible for implementing BSP strategies, including school staff, support workers, and family support. Training must be competency-based and refreshed periodically.

  • Integration with School Behaviour Frameworks

Require formal alignment between BSPs and school-based behaviour management systems. Schools should not operate parallel or conflicting behaviour frameworks. BSP strategies must be embedded into Individual Education Plans (IEPs) or equivalent structures.

  • Allied Health Accountability for Monitoring (Not Just Writing Plans)

Behaviour support practitioners should be required to demonstrate ongoing monitoring, review, and adjustment of BSPs within defined timeframes. Plan development alone should not satisfy professional obligations.

  • Funding for Implementation Support, Not Just Documentation

NDIS funding should prioritise implementation supports (training, supervision, and coaching) rather than primarily funding report writing and plan production.

Standardisation and Evidence Thresholds for Strategies

Require that all BSP strategies meet a defined evidence threshold, with clear classification

between evidence-based interventions and non-evidence-based or experimental approaches. Non-evidence-based strategies should not be funded or endorsed.

Cross – System Coordination Requirement

Establish formal coordination requirements between NDIA, schools, and allied health providers to ensure consistency of behavioural strategies across environments, including shared documentation systems and accountability pathways.

  1. Increase Oversight of High – Risk Funding Areas

    • Establish clear consumables guidelines (approved vs excluded items)
    • Items people are still claiming trampolines, swing sets, weighted animals, weighted toys, weighted blankets, sensory pods, sensory blankets, sensory toys, sensory clothing, compression clothing, crash mats, crash pads, muscle mats, mellow mats, jetproof shorts, shirts, socks, nook couch, pens, educational books, spinning chairs, vibrating cushions, wobble cushions, chewable necklaces, fidget toys, fidget kits, sleep support night lights, dream pods, white noise machine, noise cancelling headphones instead of ear defenders, nelli calendar, skylight calendar, ipads or tablets (only approved AAC device for communication). These items should all be clearly listed on the NO LIST/ excluded items
    • Consumables must be items for modified eating aids. adaptive equipment/tools, grab bar, incontinent products, disposable pads, pants, underwear, catheters, leg bags, bed chair protection, wound and skincare, nutritional support, daily living aids, personal safety
    • Strengthen oversight of: o short-term accommodation/respite o supported living (SDA/SIL) o therapy and program-based supports
    • Introduce targeted audits in high-expenditure categories

  2. Improve System Integration and Mainstream Interface

    • Strengthen coordination between the NDIS and: o health o education o childcare o social services
    • Ensure NDIS funding complements—not replaces—existing systems

Streamline Processes and Reduce Administrative Burden

  • Introduce fast-track approvals for standard supports (e.g. assistive technology)
  • Reduce excessive reporting requirements
  • Improve internal decision-making quality to minimise disputes

Reform Dispute Resolution

  • Expand early intervention and mediation pathways
  • Reduce reliance on lengthy and adversarial tribunal processes
  • Ensure dispute processes are accessible and proportionate

Strengthen Safeguards in Supported Living Environments

  • Increase monitoring and transparency in SDA and SIL settings
  • Improve participant complaint mechanisms
  • Introduce additional safeguards for high-risk and vulnerable participants

Support Scheme Sustainability and Equity

  • Ensure funding is prioritised based on functional need and complexity
  • Consider targeted funding approaches to improve equity
  • Reinforce consistent and fair allocation of supports across participants

Evidence Based Therapies and Use of Music and Art Based Interventions

Legislative Alignment (“Reasonable and Necessary”)

Therapeutic supports funded under the NDIS should meet the “reasonable and necessary“ criteria by demonstrating that they are:

  • Evidence-based and clinically supported
  • Effective in improving functional capacity or reducing impairment-related impact
  • Appropriate to the participant’s specific needs and goals
  • Value for money compared to alternative interventions

While music and art-based therapies may provide engagement or general wellbeing benefits, the current evidence base for consistent, measurable functional outcomes— specifically in moderate to high-cost, ongoing formats—is variable and, in many cases, limited or inconclusive.

Policy Position

Balanced but Firm

Music and art-based therapies should:

  • Not be funded as default or ongoing therapeutic supports
  • Not replace clinically established, evidence-based interventions (e.g. speech therapy, occupational therapy, behavioural interventions)
  • Be considered only where they are: o Targeted, o Goal-directed, and o Demonstrably effective for the individual participant

Where these criteria are not met, such supports are more appropriately classified as:

  • Recreational activities
  • Community participation supports
  • Informal or mainstream services

Policy Position (Balanced and Strong)

Hospital-based care should be reserved for situations where there is:

  • Acute medical necessity
  • Clinically assessed mental health risk requiring immediate intervention
  • Severe incapacity where no safe alternative care arrangement exists

Admissions for primarily social, respite, or support-related needs should be avoided where:

  • Appropriate community-based or disability supports can safely meet the need
  • The issue relates to caregiver strain without clinical risk requiring hospitalisation
  • Require independent clinical assessment prior to admission where feasible, particularly in non-emergency cases
  • Strengthen triage protocols to clearly distinguish between:
    • Acute clinical need, and
    • Social or support-related circumstances
  • Improve coordination between hospitals, NDIS, and community services to enable:
    • Rapid access to alternative supports
    • Safe discharge planning
  • Establish clear thresholds and guidelines for social admissions, prioritising individuals with:
    • Severe disability
    • High support needs (not just behavioural issues)
    • No safe or viable care alternatives

Hospital admissions should be reserved for cases involving acute medical need, clinically assessed mental health risk, or severe incapacity where no safe alternative exists. The use of hospital settings to address primarily social or support-related needs reflects gaps in system coordination and should be addressed through strengthened community and disability responses. Clear clinical thresholds, independent assessment, and improved integration between hospital and NDIS services are essential to ensure hospital resources are used appropriately and remain available for those in genuine need of urgent care.

16. Appropriate Response to Reported Suicide Risk in Children

Issue

Presentations to hospitals involving reported suicide risk in children must be treated with the highest level of seriousness. However, there are concerns about inconsistent assessment processes and system responses, particularly where underlying issues may relate to caregiver stress, support gaps, or social circumstances rather than acute clinical risk.

Policy Position

Any report that a child is at risk of self-harm or suicide must trigger an immediate, immediate comprehensive clinical assessment by qualified mental health professionals.

However, responses must be:

  • Clinically led, not automatic or punitive
  • Based on objective risk assessment, not solely reported statements, not just based on parent reporting
  • Proportionate to the level of identified risk

Involuntary admission should only occur where there is:

  • Clear, clinically assessed risk of harm, and
  • Legal thresholds under mental health legislation are met

Mandatory Independent Mental Health Assessment

  • All such presentations should be assessed by a qualified child and adolescent mental health clinician
  • Assessment should include:
    • Direct engagement with the child
    • Collateral information (school, history, supports, allied health)
    • Evaluation of environmental and family factors

Clear Differentiation of Risk

Protocols should distinguish between:

Appropriate System Pathways

Where clinical risk is not established, responses should prioritise:

  • Community mental health supports
  • Family and child support services
  • NDIS or disability-related interventions (where appropriate)

Safeguarding and Oversight

Where concerns arise about the accuracy or consistency of reported information:

  • Further multi-agency review may be warranted
  • Involvement of child protection or family services should be considered where there are broader welfare concerns

All reports of suicide risk in children must trigger immediate clinical assessment; however, responses must be based on independent, evidence-based risk evaluation rather than automatic or punitive measures. Involuntary admission should only occur where legal and clinical thresholds for risk are clearly met. Where risk is not substantiated, appropriate responses should focus on community-based supports and system coordination, with multi-agency oversight where concerns about presentation or underlying circumstances arise. This ensures both child safety and appropriate use of hospital resources.

17. Reassessments and Changing Needs as Children Age Issue

Children’s developmental needs, functional capacity, and support requirements change significantly over time. However, current reassessment practices within the NDIS can be inconsistent, with some support continuing without sufficient review of whether they remain appropriate, effective, or necessary.

This creates risks of:

  • Supports no longer aligning with the child’s current functional needs
  • Over- or under-allocation of funding
  • Reduced capacity to redirect resources to participants with higher or emerging needs

Policy Position (Aligned with “Reasonable and Necessary”)

NDIS-funded supports for children should be regularly reassessed to ensure they continue to meet the “reasonable and necessary” criteria, including that they:

  • Reflect the child’s current functional capacity and developmental stage
  • Remain effective and beneficial in achieving outcomes
  • Represent value for money
  • Are not more appropriately provided through mainstream systems (e.g. education) as the child grows

Supports that were appropriate at an earlier developmental stage should not automatically continue without evidence of ongoing need and effectiveness.

Recommended Reform

Mandatory Developmental Review Points

Introduce structured reassessment at key stages, such as:

  • Early childhood (0–6 years)
  • Transition to primary school
  • Transition to high school
  • Transition to adulthood

These points reflect major functionality and environmental changes.

Evidence Based Reassessment Reassessments should require:

  • Updated functional assessments
  • Evidence of progress, plateau, or regression
  • Demonstrated link between supports and outcomes
  • For children capable of attending school reports or contact school staff

Outcomes and Progress Monitoring

  • Continued funding should be contingent on demonstrated benefit or clear justification for ongoing need
  • Where limited progress is identified, supports should be:
    • Adjusted,
    • Replaced, or
    • Discontinued

Alignment with Mainstream Supports

As children age, greater consideration should be given to:

  • School-based supports
  • Community and developmental programs

NDIS funding should complement—not duplicate—these systems.

Proportionate Adjustment of Supports

Support levels should be adjusted to reflect:

  • Increased independence where achieved
  • Changes in family capacity
  • Evolving complexity of needs

NDIS support for children should be subject to structured, evidence-based reassessment at key developmental stages to ensure they continue to meet the “reasonable and necessary” criteria. Funding must reflect the child’s current functional capacity, demonstrate ongoing effectiveness, and remain value for money, with clear alignment to evolving needs and increasing integration with mainstream supports such as education. Supports that are no longer appropriate or beneficial should be adjusted or discontinued to ensure equitable and efficient allocation of resources.

Legislative Alignment

Hospital admissions should align with principles like “reasonable and necessary”, essuring that:

  • Supports are appropriate to the setting
  • Resources are used efficiently and proportionately

18. Programs Not Evidence – Based or Within Parental Responsibility

Issue

There is increasing use of NDIS funding for programs and activities that either:

  • Lack clear evidence base for improving functional outcomes, or
  • Fall within ordinary parental responsibility or general childhood development

This includes activities that are recreational, lifestyle-based, or broadly developmental in nature, rather than targeted, disability-specific interventions.

As a result, funding may be directed toward supports that:

  • Do not deliver measurable functional benefit
  • Duplicate mainstream or community-based services
  • Are inconsistent with the intent of the NDIS

Legislative Alignment (“Reasonable and Necessary”)

Support funded under the NDIS must meet the “reasonable and necessary” criteria. Programs should only be funded where they:

  • Are directly related to the participant’s disability
  • Provide evidence-based or clinically supported intervention
  • Deliver measurable improvements in functional capacity
  • Represent value for money
  • Are not more appropriately provided by families, community, or mainstream systems

Programs that are primarily recreational, general developmental, or social in nature— without a clear therapeutic or functional outcome—do not meet these criteria.

Policy Position

NDIS funding should not routinely support programs that:

  • Replicate ordinary childhood experiences (e.g. play-based activities, general social groups)
  • Replace parental responsibilities, including supervision, routine care, or participation in standard activities
  • Lack clear, evidence-based justification linked to disability-related goals

Examples may include:

  • General recreational programs presented as therapy
  • Activities such as art, music, or social groups without defined therapeutic outcomes
  • Programs that function as informal childcare or supervision

While these activities may provide enjoyment or general wellbeing, they are not, in isolation, disability-specific support.

Recommended Reform

  • Establish clear guidance distinguishing funded supports from parental responsibility
  • Require evidence of functional benefit and goal alignment for all program-based supports
  • Introduce outcome-based review requirements for continued funding
  • Strengthen value-for-money assessments, particularly for group programs and high-cost activities
  • Encourage use of community and mainstream programs, with NDIS funding limited to: o Access support (e.g. assistance to attend), rather than o Funding the activity itself

NDIS funding should not be used for programs that are not evidence-based or that fall within ordinary parental responsibility, including recreational, social, or general developmental activities without clear therapeutic intent. To meet the “reasonable and necessary” criteria, support must be directly related to disability, demonstrate measurable functional benefits, and represent value for money. Activities that replicate typical childhood experiences or function as informal supervision should be considered the responsibility of families or mainstream systems, with NDIS funding limited to disability- specific supports and access assistance where required.

19. Accountability for Over – Exaggeration Reports/FCA/Assessments

There is a growing and serious concern regarding the over-exaggeration and inflation of participant needs within reports, assessments, and Behaviour Support Plans. In some instances, functional impairments, behavioural risks, and support requirements appear to be overstated beyond what is clinically observable or objectively evidenced.

This practice undermines the integrity of the system and raises significant ethical concerns. Reports that amplify risk, severity, or complexity without sufficient supporting evidence to distort funding decisions, misdirect resources, and erode trust in allied health and behaviour support professions.

Over-exaggeration also has downstream consequences. It can result in inappropriate service intensity, unnecessary restrictive practices, and mislabeling of participants, particularly children, in ways that may negatively impact their development, education, and long-term outcomes.

Where documentation is not grounded in consistent, observable evidence across settings, it should not be relied upon for funding or planning decisions. The current system lacks sufficient safeguards to identify and address these practices.

Targeted Reform Recommendations (Provider Accountability)

Independent Verification of High-Impact Reports

Require an independent review of reports that recommend high cost supports, restrictive practices, or significant functional impairment. Verification should include cross-setting evidence (home, school, community) rather than reliance on single-source reporting.

Evidence Thresholds and Documentation Standards

Mandate clear evidence requirements for all claims made in reports, including:

  • direct observations across multiple settings
  • corroboration from independent sources (e.g. school, third-party providers)
  • objective data (incident logs, frequency tracking, functional assessments)

Reports that do not meet these thresholds should be deemed non-compliant.

Audit and Compliance Mechanisms

Introduce routine and random audits of providers whose reports consistently recommend

high levels of support. Patterns of overstatement or inconsistency should trigger formal investigation.

Professional Consequences for Misrepresentation

Establish clear consequences where exaggeration or misrepresentation is identified, including:

  • removal from provider panels
  • referral to professional regulatory bodies
  • suspension of ability to deliver NDIS-funded assessments

Separation of Assessment and Service Delivery

Where possible, separate the role of assessing need from the role of delivering ongoing funded supports, to reduce conflicts of interest and financial incentives linked to inflated recommendations.

Cross – Setting Consistency Requirement

Require that reported behaviours, risks, and functional impairments are consistent across environments. Significant discrepancies between home, school, and clinical settings must be investigated before funding decisions are made.

Strengthening NDIA Decision – Making Scrutiny

Decision-makers should be required to critically assess provider reports rather than accepting them at face value, particularly where language is subjective, non-specific, or not supported by measurable evidence.

20. Diagnosis Integrity

There are increasing concerns that diagnostic practices—particularly in relation to developmental and behavioural conditions—are being influenced by access pathways to funded supports (NDIS and school or access to support units) rather than strictly adhering to clinical necessity.

In some cases, diagnoses appear to be applied or emphasised to facilitate eligibility for therapies and funding, rather than being grounded in rigorous, multidisciplinary assessment. This creates a risk of over-diagnosis or diagnostic inflation, where children

are labelled in ways that may not accurately reflect their functional presentation across settings.

Such practices undermine the integrity of clinical diagnosis and distort the allocation of limited resources. When diagnoses are used as a gateway to access services, rather than precise clinical tools, the system incentivises diagnostic expansion rather than targeted intervention based on genuine need.

This has broader consequences:

  • children may receive unnecessary or mismatched interventions
  • resources may be diverted from those with higher or more complex needs
  • diagnostic labels may follow children long-term, affecting educational and social outcomes

A system that indirectly rewards diagnosis over demonstrated functional impairment risks prioritising access strategies over clinical accuracy.

Targeted Reform Recommendations (Diagnostic Accountability)

Mandatory Multidisciplinary Assessment for Key Diagnoses

Require that access-relevant diagnoses (e.g. developmental or behavioural conditions) are confirmed through multidisciplinary assessment (e.g. medical, psychological, and functional domains), rather than reliance on a single practitioner.

Functional Impairment as Primary Eligibility

Shift decision-making emphasis away from diagnosis alone and toward clearly evidenced functional impairment across multiple settings (home, school, community).

Independent Review of High – Risk or Borderline Diagnoses

Introduce independent secondary review where:

  • diagnoses directly trigger significant funding
  • presentations are inconsistent across environments
  • reports rely heavily on subjective or parent-reported information without corroboration

Standardised Diagnostic Criteria Enforcement

Require strict adherence to recognised diagnostic frameworks such as DSM-5-TR and ICD- 11, with documented justification for how criteria are met.

Separation of Diagnosis and Financial Incentives

Limit conflicts of interest by ensuring clinician diagnosing conditions are not financially linked to the provision of ongoing funded therapies tied to that diagnosis or welfare benefits.

Audit and Oversight of Diagnostic Patterns

Implement monitoring systems to identify practitioners with unusually high diagnosis rates or patterns inconsistent with population norms, triggering review and potential regulatory action.

Ensure families are clearly informed about:

  • the purpose and implications of a diagnosis
  • alternative supports that do not require diagnostic labelling
  • the potential long-term impacts of diagnostic classification
  1. Funding Inconsistencies

There are significant and persistent inconsistencies in NDIS funding decisions that undermine fairness, transparency, and system integrity.

Participants with similar functional impairments often receive markedly different funding outcomes, while others with less severe or inconsistently evidenced needs are approved for disproportionately high levels of support. These discrepancies are frequently linked to the quality, tone, or assertiveness of provider reports, rather than objective and standardised assessment of functional capacity.

This creates a system where outcomes are influenced by who writes the report, rather than what the participant requires. Participants with access to more experienced or commercially motivated providers may receive inflated recommendations that translate into higher funding, while others are underfunded despite comparable or greater needs.

Inconsistencies are further exacerbated by:

  • reliance on subjective language rather than measurable functional evidence
  • lack of cross-setting verification (home, school, community)
  • variable interpretation of evidence by decision-makers
  • absence of standardised benchmarks for “reasonable and necessary” supports

The result is a fragmented and inequitable system, where funding decisions lack consistency, c omparability, and accountability. This not only leads to inefficient use of public resources but also erodes trust in the fairness of the scheme.

Targeted Reform Recommendations (Funding Consistency and Integrity)

Standardised Functional Assessment Framework

Introduce a nationally consistent framework for assessing functional impairment, with defined benchmarks that guide funding decisions. This reduces reliance on subjective report writing.

Benchmarking of Funding Against Comparable Profiles

Require decision-makers to compare funding outcomes against participants with similar functional profiles to identify and correct inconsistencies.

Independent Review of Outlier Plans

Automatically flag and review plans that fall significantly above or below expected funding ranges for similar levels of impairment.

Reduced Reliance on Narrative Reports

Limit the weight given to descriptive or persuasive report writing. Greater emphasis should be placed on objective data, standardised assessments, and demonstrated functional impact.

Cross – Setting Evidence Requirement

Funding decisions should only be made where functional impairment is consistently demonstrated across multiple environments (e.g. home, school, community). Conflicting evidence must be resolved before funding is approved.

Require clear, documented reasoning for funding decisions, including how evidence was weighted and why certain recommendations were accepted or rejected.

Separation of Advocacy and Assessment Roles

Reduce conflicts of interest by separating providers who advocate for higher funding from those responsible for independent assessment of need.

Ongoing Plan Reassessment and Adjustment

Introduce more frequent and structured reassessments to ensure funding remains aligned with actual functional needs over time, particularly for children whose developmental profiles change.

Final Statement

Restoring integrity to the NDIS requires a shift from reactive oversight to proactive system design, where clear rules, strong enforcement, and consistent decision-making underpin all aspects of the scheme.

By strengthening regulation, improving transparency, and ensuring funding is directed toward genuine disability-related needs, the NDIS can better achieve its core objective— delivering fair, effective, and sustainable support to those who need it most.