Submission to the Parliamentary/Senate Inquiry into NDIS Integrity, Sustainability and Service Quality

Date: 13/04/2026

Introduction

This submission outlines significant integrity, quality, and governance issues currently affecting the National Disability Insurance Scheme (NDIS). These issues have been observed across multiple providers, support coordinators, behaviour support practitioners, and participant households. Collectively, they undermine participant outcomes, inflate scheme costs, and erode public trust. The concerns raised here reflect systemic vulnerabilities that require urgent reform.

Inflated and Non – Genuine Billing Practices

A widespread pattern of inflated billing has emerged across the sector, including:

• Excessive travel claims far beyond actual travel time.
• Overcharging administrative tasks such as emails, case notes, and session planning.
• Exaggeration of behaviours or functional impairments to justify higher funding.
• Providers claiming services not delivered or delivered at a significantly lower standard.
• Over recommendation of therapy hours driven by financial incentives rather than clinical need.

These practices divert funding away from participants with genuine needs and contribute to unsustainable scheme expenditure.

Misuse of Funding by Participants and Families

NDIS supports are increasingly being used for purposes outside the scheme’s intent:

• Support workers and respite used as babysitting, not capacity building.
• Parents using children respite for their own convenience rather than participant benefits.

• Household tasks such as cleaning and gardening are included in children’s plans despite ordinary parental responsibilities.
• Recreational activities (e.g., swimming lessons, sports clubs) being billed as therapy.

This misuse shifts the scheme away from its purpose of enabling independence and long- term functional improvement.

4. Behaviour Support Quality and Practitioner Competence

Significant concerns exist regarding the quality of behaviour support services:

• Many practitioners lack qualifications in psychology, education, or disability.
• Behaviour Support Plans (BSPs) are often generic, templated, or AI generated without evidence-based strategies.
• Plans are rarely implemented due to lack of training for support workers and families.
• BSPs are sometimes produced solely to justify funding rather than improve outcomes.

This results in ineffective interventions, increased risk, and wasted funding.

5. Over – Diagnosis, Misdiagnosis, and Pressure on Families

A concerning trend has emerged where children are being diagnosed prematurely or inaccurately:

• Diagnoses made before children have had adequate developmental time to acquire speech or social skills.
• Families pressured by schools, providers, or even doctors to seek diagnoses to access funding or classroom support.
• Assessments conducted by practitioners without appropriate qualifications.
• Diagnostic inflation used to increase funding levels.

This undermines clinical integrity and exposes children to unnecessary stigma and inappropriate interventions.

6. Inconsistency in Support Worker Hours

Support worker hours are allocated inconsistently:

• Children attending school fulltime or childcare often receive more hours than children who are homeschooled due to severe disabilities.
• Children with the highest needs frequently receive the least support.
• Funding decisions appear influenced by schooling status rather than functional need.

A transparent, needs based allocation model is required.

7. Need for Therapy Caps and a Tiered Scheme

The absence of structured therapy guidelines has led to:

• Overservicing and excessive therapy hours.
• Inconsistent therapy budgets across participants with similar needs.
• Limited accountability for therapy outcomes.

A sustainable model should include:

• Evidence based therapy caps.
• A tiered system (low, moderate, high needs).
• Independent clinical reviews.
• Outcome based funding.

8. Excessive Fees for Report Writing and Assistive Technology Assessments

Providers frequently charge excessive fees for reports, including:

• AT assessment reports costing more than the AT item itself.
• High hourly rates for basic reports with minimal clinical value.
• Unnecessary reports are recommended solely to generate billable hours.
• Lack of transparency in pricing.

This drains participant budgets and inflates scheme costs.

9. Misuse of Consumables

Participants and providers continue to claim consumables that are explicitly not allowed, including:

• Items on the NDIS “No List.”
• General household goods and parenting supplies.

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• Non disability related items disguised as therapy tools.

This reflects inadequate enforcement and oversight.

10. Failure to Verify Informal Supports and Household Composition

The NDIS does not adequately verify:

• Who lives in participant households.
• Whether informal support exists.
• Emergency contacts.
• Providers instructed to withhold certain information.
• Functional impairments reported by families.

This allows households to hide informal carers or misrepresent support needs.

11. Lack of Cross – Agency Data Matching

There is little to no data matching with:

• Centrelink
• Homes NSW
• Utility providers
• Schools
• Hospitals and GPs
• Medicare (medical records)

This enables false reporting, inflated claims, and inconsistent information across government systems.

12. Short – Term Respite Misuse

Short-term respite (STR) is being used inconsistently and often inappropriately:

• Children with low needs and multiple carers receiving STR.
• Families using STR for convenience rather than disability related needs.
• In-home respite used as routine babysitting.

A structured system is required.

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13. Stricter Rules for STR and accommodation

To restore integrity:

• STR should be limited to group homes or registered centers.
• In-home resprite should be reserved for families with severe disability related needs or single carer households and adults.
• Introduce caps, limits, and a tiered resprite system.
• Eligibility should be based on functional need, not diagnosis alone, and not self- reporting.

14. Non – Evidence – Based Therapies and Programs

Many programs funded under the NDIS lack scientific support:

• Recreational activities are marketed as therapy.
• Programs delivered by unqualified staff.
• No measurable outcomes or clinical justification.
• High frequency sessions are recommended without evidence.

Funding should be restricted to evidence-based interventions delivered by qualified professionals.

15. Snapshot Assessments Leading to Inaccurate Plans

Snapshot assessments result in:

• Over- or underfunding based on a single day presentation.
• No longitudinal understanding of the child is important.
• No verification with schools, therapists, or medical professionals.
• Providers coaching families to maximise funding.

Funding decisions should not rely on single session assessments.

16. GPS Tracking to Prevent Fraud

To prevent inflated hours and ghost shifts:

• Mandatory GPS check-in/out for support workers, cleaners, gardeners, and in- home resprite.

• Verifies presence, prevents inflated travel claims, and protects participants from pressure to sign false timesheets.
• Already used in aged care and international disability systems.

This is a proportionate and necessary integrity measure.

17. Fear of Reporting, Slow Enforcement, and Tribunal Barriers

Workers and families are often too afraid to report fraud due to:

• Fear of losing their job.
• Retaliation from providers.
• Past experiences where no action was taken.

NDIS enforcement is slow, allowing misuse to continue for years. When participants challenge decisions:

• Tribunal costs are prohibitive.
• Many cannot afford legal representation.
• Taxpayers fund lawyers to defend the NDIA, creating a power imbalance.

This undermines fairness and access to justice.

18. Reassessments for Eligibility: Children Diagnosed from June 2019

Since June 2019, there has been a significant increase in childhood diagnoses. Many were made:

• Prematurely
• Without multidisciplinary assessment
• During COVID-19 disruptions and post
• By practitioners without pediatric expertise
• Through snapshot or telehealth or zoom assessments

To ensure accuracy and fairness, the NDIS should conduct mandatory reassessments for all children diagnosed from June 2019 onwards, prioritising:

• Children diagnosed before age 8
• Children with minimal functional impairment

• Children attending school fulltime without additional support needs
• Children with multiple overlapping diagnoses made in a single session
• Adulte diagnosed between 2019-2026 due to cost of living and post COVID-19

This ensures funding reflects genuine, current disability-related needs.

Preventing Duplication with Other Government Programs & Immediate Action

Reported Misuse

The NDIS must operate as a scheme of last resort, yet duplication with other programs is widespread.

A. Avoid duplication with existing programs

NDIS funding should only be provided when no other government program applies, including:

• NSW Spectacles Program
• Vision Australia
• Hearing Services Program
• Enable NSW Aids and Equipment Program
• State based health and disability equipment schemes
• Carers Gateway
• Carers Australia
• School based supports
• Assisted School Travel Program
• BASC Before and After School Care OSHC
• OOSH Outside of school hours
• PCYC NSW Out of School Hours Care
• Medicare funded services
• My Aged Care (older Australians should transition off the NDIS)
• IPTAAS Isolated Patients Travel and Accommodation Assistance Scheme

Duplication wastes funds and undermines sustainability schemes.

B. Immediate action when misuse is reported

When credible reports of misuse occur, the NDIS should:

C. Ensuring funds go to those who genuinely need them

Rapid intervention, cross agency verification, and strict eligibility enforcement ensure:

• Funding is directed to participants with genuine disability related needs
• Misuse is stopped early
• Public confidence in the scheme is restored

20. Age Criteria for Support Workers & Reinforcing Parental Responsibility

A. Need for age-based criteria

Support workers are increasingly being used for very young children for tasks that fall under ordinary parental responsibility. Support workers should not be funded unless:

• The child has a severe, documented disability
• The tasks are disability specific, not general childcare
• The need exceeds what is expected of typical parenting

B. Reinforcing parental responsibility

The NDIS must clearly state that parenting tasks such as:

• Feeding, bathing, dressing
• Supervision
• Teaching basic skills
• Transport to recreational activities

are not NDIS funded supports unless disability specific.

C. Preventing misuse

Age criteria and parental responsibility guidelines will prevent:

21. Coaching, Manipulation, and Fraudulent Practices Used to Obtain Higher Funding

A. Coaching parents to misrepresent circumstances

Some providers actively coach families to:

• Exaggerate functional impairments
• Claim they have no informal supports
• Use specific language to trigger higher budgets
• Reframe or rewrite reports to emphasise deficits

B. Misuse of hospital systems

Providers have encouraged families to:

• Present to hospital unnecessarily
• Report crises that are not occurring
• Use hospital stays to justify additional supports
• Pressure medical staff to sign documents overstating needs

C. Manipulation of crisis pathways

Some families are coached to:

• Threaten relinquishment of care
• Self report to child protection
• Claim they cannot care for their child without more supports

D. Misuse of professional authority

There are instances of:

• Reports being rewritten by providers
• Clinicians pressured to sign documents they did not write
• Exaggerated or templated reports used to justify high-cost supports

E. Adults misrepresenting conditions

Reports include adults:

• Claiming or exaggerating autism or other conditions
• Coaching their children to present in certain ways during assessments

F. Impact

These practices:

• Inflate plans
• Divert funding from participants with severe disabilities
• Increase pressure on hospitals and child protection
• Undermine trust in the NDIS

G. Recommendations

The NDIS should:

• Impose strict penalties for coaching and manipulation
• Require verification of claims
• Mandate independent assessments for high-risk cases
• Strengthen clinical oversight
• Implement cross agency data matching
• Flag repeated crisis-based funding requests

22. Mandatory Accreditation and Minimum Qualifications for Support Workers

A. Lack of mandatory accreditation

The NDIS currently allows support workers to begin work with:

• No formal qualification
• No mandatory training
• No national accreditation
• No background in disability support

This creates significant safety and quality risks.

B. High-risk situations created by untrained workers

Unqualified workers may be placed in roles requiring:

-Behaviour support knowledge -Personal care skills -Communication strategies -Understanding of sensory needs -Safety awareness -Knowledge of medical vulnerabilities

Without training, workers may unintentionally cause harm.

C. Workers performing tasks outside their scope

Support workers are often asked to perform tasks they are not trained or legally permitted to do, including:

-Behaviour intervention -Complex personal care -Managing medical needs -Acting as informal therapists

D. Need for a national accreditation scheme

The NDIS should introduce mandatory:

-Minimum qualifications (e.g., Certificate III in Individual Support) -Training in disability awareness, child safety, behaviour basics, communication, duty of care, incident reporting, first aid -National background checks -Ongoing professional development -Registration with a national workforce regulator

E. Benefits

Accreditation will:

-Improve participant safety -Reduce risk of harm

• Increase workforce professionalism
• Prevent providers from hiring untrained staff to cut costs

23. Additional Integrity Risks: Offshore Services, Privacy Concerns, Misuse of Support Worker Hours, Questionable Diagnoses, and SDA Safety Failures

A.Offshore accountants and offshore service delivery

Some providers outsource:

• Accounting
• Invoicing
• Recordkeeping
• Online therapy or support services

to offshore companies, creating:

• Privacy risks
• Cybersecurity vulnerabilities
• Lack of regulatory oversight
• Inability to investigate misconduct

All NDIS-related data handling and service delivery must occur within Australia.

B.Support workers performing household duties while participants are absent

Support workers are frequently:

• Returning after school drop-off
• Cleaning, doing laundry, washing dishes
• “Making up hours” without the participant present

This is not disability support and must be prohibited.

C.Questionable use of Level 3 autism diagnoses

Some children receiving Level 3 autism funding demonstrate functional abilities inconsistent with severe autism, including:

• Fulltime school attendance including childcare

• Sleepovers with friends and extended family
• Participation in church, catering events, hosting events, community, concerts, weddings, christenings, holy communion, and social events
• Recreational activities such as camping, skiing, boating, swimming, surfing
• Strong verbal communication
• Ability to cope with multiple environments and support workers

Funding must be based on functional impairment, not diagnosis alone.

D. Undisclosed household composition and informal supports

Some families fail to disclose:

• Marital status
• Presence of additional adults
• Access to vehicles and transport
• Extended family support

This leads to inflated claims of “no informal supports.” Cross agency data matching is essential.

E. Misuse of STR for children with minimal impairment

Children with high independence are receiving:

• Frequent STR/STA
• Recreational respite
• Overnight support worker shifts

STR is being used as a holiday service, not a disability support.

F. SDA safety failures

Serious incidents, including fires and preventable deaths, highlight:

• Unqualified staff
• Lack of CCTV
• Poor supervision
• Inadequate emergency procedures

SDA Requires Urgent Safety Reform

24. Reducing the Cost of NDIS Provider Registration

A. Registration Costs Are Excessive

High registration and audit costs discourage ethical providers from becoming registered, resulting in:

• Fewer regulated providers
• More unregistered providers with no oversight
• Reduced competition
• Lower quality and safety

B. High Costs Reduce Quality and Compliance

When registration is too expensive:

• Providers avoid the regulated pathway
• Participants rely on unregistered workers
• Safeguards are weakened
• The Commission cannot enforce standards

C. Making Registration Cheaper Improves Integrity

Reducing registration costs will:

• Encourage more providers to become registered
• Increase accountability and transparency
• Reduce fraud and misuse
• Improve participant safety
• Strengthen the regulated workforce

D. Recommendations

The NDIS should:

• Subsidize registration audits
• Introduce tiered registration fees

Recommendations

Reduce administrative burdens for low-risk supports

• Provide free or low-cost compliance training
• Offer government-funded audit vouchers
• Simplify the registration process

25. Recommendations

To restore integrity, the NDIS should implement:

• Regular audits and penalties
• Minimum qualifications for support workers
• Functional reassessments for children diagnosed from June 2019
• Cross-agency data matching
• Prohibition of offshore service delivery
• Enforcement of parental responsibility
• Restriction of STR/STA to disability-specific purposes
• SDA safety reforms including CCTV and qualified staff
• GPS-verified attendance
• Cheaper, tiered provider registration
• Faster investigations and stronger whistleblower protections
• Transparent billing rules

Behaviour Support Reform

• Minimum qualifications
• Evidence based plans
• Mandatory training for implementers

Diagnostic Integrity

• Clear diagnostic pathways
• Oversight of assessors
• Separation of diagnosis from funding incentives

Fair Support Allocation

• Needs based support hours
• Transparent criteria for homeschooled children

####### Therapy Reform

Regulation

Evidence based caps

• Evidence based caps
• Tiered therapy system
• Independent reviews

Regulation of Reports and AT Assessments

• Price caps
• Standardised templates
• Clear guidelines

Consumables and Household Integrity

• Enforcement of the “No List” and update
• Verification of household composition
• Cross agency data matching

Respite Reform

• STR limited to registered facilities
• Tiered respite system
• Functional need-based eligibility

Technology – Based Integrity Measures

• GPS verified attendance for hourly services

Enforcement and Appeals Reform

• Affordable, accessible tribunal pathways

25. Conclusion

The NDIS is a vital national system that must remain sustainable, ethical, and participant centered. The integrity issues outlined in this submission demonstrate systemic vulnerabilities that require urgent reform. Strengthening oversight, improving practitioner standards, enforcing evidence-based practice, and ensuring funding is used as intended to protect participants, restore public confidence, and safeguard the future of the NDIS.

Yours faithfully

Submission: Concerns Regarding NDIS Integrity and Service Quality

Date: 13/04/2026 Author: Confidential

Overview

This submission outlines significant integrity issues currently observed within the National Disability Insurance Scheme (NDIS). These issues undermine participant outcomes, inflate scheme costs, and erode public trust. The concerns raised here reflect patterns seen across multiple providers, support coordinators, behaviour support practitioners, and participant families.

Inflated and Non – Genuine Billing Practices

Providers are engaging in billing behaviours that do not reflect genuine service delivery, including:

• Inflated travel hours far beyond reasonable or actual travel time.
• Claiming extra travel between clients.
• Excessive billing for administrative tasks such as emails, case notes, and session planning.
• Overreporting behaviours or exaggerating participant needs to justify higher funding levels.
• Over-diagnosis or over recommendation of services without clinical justification.
• Providers claiming payment for services not delivered or delivered at a significantly lower standard.

These practices divert funding away from participants who genuinely need support and contribute to unsustainable scheme expenditure.

Misuse of Funding by Participants and Families

Misuse of NDIS supports by families is increasingly common:

• Using support workers or respite babysitting rather than capacity building.
• Using children respite allocations for parental convenience rather than participant benefit.
• Including household responsibilities such as cleaning and gardening in children’s plans, despite these being outside the scope of disability-related needs.

This misuse shifts the scheme away from its core purpose of enabling independence,

participation, and long-term capacity building.

Behaviour Support Quality and Practitioner Competence

The quality of behaviour support services is a major concern:

• Many behaviour support practitioners lack relevant qualifications, including psychology or disability expertise.
• Behaviour Support Plans (BSPs) are frequently generic, poorly written, or copied from templates.
• Some plans contain AI-generated strategies that are not evidence-based or clinically sound.
• Plans are often not implemented due to lack of training for support workers, schools, TAFE, work, allied health and families.
• BSPs are sometimes produced solely to justify funding rather than to improve participant outcomes.

This results in ineffective interventions, increased risk, and wasted funding.

Over – Diagnosis, Misdiagnosis, and Pressure on Families

There is a concerning trend of children being diagnosed prematurely or inaccurately:

• Children are diagnosed before they have had adequate developmental time to acquire speech or social skills. Some are being diagnosed purely to stay on the scheme.
• Families report pressure from friends, schools, TAFE, work, NDIS providers, or even doctors to seek a diagnosis to access funding or classroom support.
• Some diagnoses are made by practitioners without appropriate qualifications in child development or psychology.
• Diagnostic inflation is occurring, with multiple overlapping diagnoses given without general justification. Snapshot assessments include more recent adult diagnoses.
• These practices can lead to unnecessary stigma, inappropriate interventions, long- term harm, and lifelong welfare dependencies.

This undermines the integrity of the diagnostic process and contributes to unnecessary NDIS expenditure.

Inconsistency in Support Worker Hours for Children with Similar or Greater Needs

• There is a clear inconsistency in how support worker hours are allocated to children, particularly when comparing:

• Children who attend school fulltime, who often receive more support worker hours despite spending most of the day in a structured educational environment.

• Children who are homeschooled due to significant disabilities, who frequently receive fewer hours, even though they require more intensive daily support, supervision, and capacity building opportunities.

• Teenagers capable of attending TAFE and work

This discrepancy results in:

• Inequitable access to support, where children with higher needs receive fewer funded hours.
• Perverse incentives attending school, TAFE, work leads to higher funding despite lower daily support requirements.
• Reduced capacity building opportunities for children who are homeschooled because of complex disabilities.

This inconsistency highlights the need for a more transparent, need based allocation model that does not rely on schooling status as a proxy for support requirements.

7. Need for Therapy Caps and a Tiered Scheme

The current therapy funding model lack’s structure, resulting in:

• Excessive therapy hours being recommended by providers with financial incentives to maximise billable sessions.
• Overservicing, where children receive more therapy than clinically necessary, often without measurable outcomes.
• Inequitable distribution, where some children receive large therapy budgets while others with similar or greater needs receive minimal support.

A more sustainable and clinically responsible approach would include:

• Therapy caps are based on evidence-based guidelines for each disability type and age group.
• A tiered therapy scheme, where: o Tier 1 = low needs / monitoring o Tier 2 = moderate needs / targeted intervention

Tiering System

Tier Definitions

• Tier 3 = high needs / intensive, multidisciplinary support
• Regular clinical reviews to adjust tiers based on progress, not provider recommendations alone.
• Outcome based funding, ensuring therapy hours are tied to measurable improvements rather than volume of sessions.

This would reduce overservicing, protect children from unnecessary interventions, and ensure funding is distributed fairly and sustainably.

8. Excessive and Unregulated Fees for Report Writing and Assistive Technology (AT) Assessments

A growing concern within the NDIS is the excessive and often unjustifiable fees charged by providers for report writing, particularly for Assistive Technology (AT) assessments. These practices include:

• Charging high hourly rates for basic reports, often far exceeding the time required to complete them.
• AT assessment reports costing more than the assistive technology item itself, such as low-cost communication devices, sensory tools, or mobility aids.
• Providers recommending unnecessary reports solely to generate billable hours, even when the participant’s needs are already well documented.
• Lack of transparency around how report fees are calculated, with some providers charging flat fees without itemisation or justification.
• Inconsistent pricing, where similar reports vary dramatically in cost depending on the provider, with no quality difference.

These practices:

• Inflate NDIS expenditure without improving participant outcomes.
• Create barriers for families who cannot afford to have their budgets drained by report fees.
• Incentivise providers to prioritise report writing over direct, meaningful intervention.
• Undermine the purpose of AT funding, which is to provide practical support — not to subsidise excessive administrative costs.

There is a clear need for price caps, standardised templates, and guidelines on reasonable report duration to prevent exploitation and ensure funding is used appropriately.

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9. Impact on Participants and the Scheme

These integrity issues result in:

• Lower quality services and reduced opportunities for genuine skill development.
• Misallocation of funding, reducing availability for those with legitimate needs.
• Ethical providers being undermined by those exploiting the system.
• Threats to the long-term sustainability of the scheme due to inflated claims and unnecessary diagnoses.

10. Misuse of Consumables and Claims for Items on the “No List”

Despite clear NDIS guidelines, many participants and providers continue to claim consumables that are explicitly not allowed under the scheme. This includes:

• Items listed on the NDIS Consumables “No List”, such as general household goods, personal care items not related to disability, and everyday parenting supplies.
• Claims for non disability-related items disguised as sensory tools, therapy aids, or behavioural support.
• Providers advise families to purchase items that are not permitted, then billing them under unrelated line items to avoid detection.
• Lack of enforcement or follow-up when participants repeatedly claim ineligible consumables.

This misuse drains funding from participants who genuinely require disability specific consumables and undermine the integrity of the scheme.

11. Lack of Verification of Informal Supports and Household Composition

The NDIS relies heavily on self-reported information about informal supports, yet there is minimal verification of:

• Who actually lives in the household, including adults who may be providing care but are not disclosed.
• Whether informal support exists, despite being claimed as unavailable to justify higher funded supports.
• Emergency contacts, which are often outdated or inaccurate.

Cross-Agency Data Matching

This creates opportunities for:

• Participants hide informal support to increase funded hours.
• Providers to inflate support needs without evidence.
• Households misrepresent care arrangements to maximise funding.

Without verification, the NDIS cannot accurately determine reasonable and necessary support.

No Cross - Agency Data Matching or Integrity Checks

A major systemic weakness is the absence of data matching between the NDIS and other government agencies. Currently, there is little to no cross-referencing with:

• Centrelink (carer payments, disability payments, household composition).
• Homes NSW / public housing records (household members, tenancy details).
• Utility bills (to confirm who resides at the property).
• Work/TAFE/School staff or attendance records (to verify functional impairments, behaviour concerns, or support needs).
• Hospital and GP records (to confirm diagnoses, functional impact, or frequency of medical intervention).
• Medicare

The lack of cross agency verification allows:

• False reporting of impairments.
• Inflated support needs that do not align with school or medical records.
• Undisclosed carers living in the home while claiming paid support.
• Duplicate or inconsistent information across government systems.
• Adults false reporting to access the scheme
• Providers and allied health are not held accountable for withholding information.

Data matching is a standard integrity measure in other government programs, yet the NDIS remains vulnerable due to siloed systems and reliance on self reporting.

Misuse of Short -Term Respite and Lack of Clear Eligibility Controls

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Short-term respite (including Short-term Accommodation, STA) is increasingly being used in ways that do not align with its intended purpose. Current rules allow broad interpretation, resulting in:

• Children capable of attending TAFE, school fulltime receive STR despite having multiple carers and low daily support needs.
• Families using STR as a convenience option, rather than for genuine carer relief or participant benefit.
• In-home respite being used as routine babysitting, rather than targeted support for families with high needs children.
• Participants with minimal functional impairment accessing STR while families with children who have severe disabilities struggle to obtain even a few hours of in- home respire per week.

This inconsistency reflects a lack of clear eligibility criteria and insufficient oversight.

14. Need for Stricter Rules: STR/STA

To restore integrity and ensure respite is used for its intended purpose, stricter rules are required:

• Short-term respite should be limited to group homes, respite centers, or registered facilities, not private homes.
• In-home respite should be reserved only for families with severe disability related needs, such as children requiring constant supervision, complex medical care, or behavioural support.
• Clear functional criteria must be introduced to determine eligibility for STR, preserving low needs participants from accessing high cost respite options.

This would prevent misuse, reduce unnecessary expenditure, and ensure respite is available for families who genuinely require it.

15. Caps, Limits, and a Tiered Respite System

The current STR model lacks structure, resulting in inequitable distribution and overuse. A more sustainable and fair system would include:

A. Respite Caps

• Annual caps are based on functional need, not diagnosis alone.

Limits on the Number of STR/STA Nights

Low- and Moderate Needs Participants

Example: 2–4 nights per year.

Higher Caps for Severe Care Burdens

Higher caps apply exclusively to participants facing severe (handicapped—not children with behavioural issues) documented care burdens—especially those who are sole carers.

Tiered Respite System

A structured tier model would ensure consistency:

• Tier 1 – Low Needs: Occasional in-home respite; no STA unless exceptional circumstances arise.
• Tier 2 – Moderate Needs: Limited STA access; in-home respite is available solely when justified through functional assessment.
• Tier 3 – High Needs: Accessible regular respite services including STA at registered facilities; priority allocation reserved specifically for families managing severe behavioral, medical, or supervisory requirements. Excludes children capable of attending mainstream schools or support units. Reserved ONLY for SSP schoolchildren/home-schooled students as well as adults.

Independent Review Process

Respite tiers must be determined independently without provider influence that might create financial incentives. Follow-up actions should involve TAFE institutions along with educational personnel ensuring emotional impacts upon affected youth remain mitigated throughout implementation phases. Annual reviews—or whenever there’s a change regarding individual functionality levels—are essential components within this framework.

Current Inequities Identified Within Allocation Practices

The lack of standardized guidelines has resulted in notable disparities across various groups receiving assistance:

• Children suffering from profound disabilities unable to attend traditional schooling frequently receive limited home-based relief despite requiring continuous attention and supervision.
• Conversely, those exhibiting mild impairments who regularly participate full-time education programs often benefit significantly more comprehensively via STR/STA provisions alongside extra hours dedicated towards their overall welfare enhancement initiatives.
• Additionally observed discrepancies include situations where households possessing numerous informal caregiving resources successfully obtain access to both STR & STA options while single parent arrangements dealing with high demand scenarios encounter difficulties securing even fundamental forms of temporary reprieve measures necessary during critical times when they need them most severely impacted individuals require immediate intervention strategies tailored precisely according to unique personal circumstances rather than generalized approaches currently being applied which fail adequately address true underlying needs effectively addressing these issues requires comprehensive reform efforts aimed at rectifying existing imbalances promptly through targeted policy adjustments designed specifically for achieving equitable distribution outcomes benefiting all stakeholders involved equally without exception whatsoever.

Therapies And Programs Lacking Evidence-Based Support

A significant and growing concern within the NDIS

A significant and growing concern within the NDIS is the widespread use of therapies, programs, and interventions that lack evidence, clinical validation, or regulatory oversight. Many of these programs are marketed aggressively to families yet offer little or no measurable benefit to participants.

Key issues include:

A. Non – evidence – based therapies being funded without scrutiny

• Providers offering programs with no scientific backing yet billing them at high therapy rates.
• Interventions that have been disproven or shown to be ineffective continue to be recommended because they are profitable.
• Therapies that rely on pseudoscience, untested methods, or alternative practices being funded under the guise of “capacity building.”

B. Providers misrepresenting programs as therapeutic

• Some providers label generic activities (e.g., arts and crafts, playgroups, exercise classes, tutoring which falls under education) as “therapy” to justify higher billing.
• Programs are often marketed as “specialised” or “clinical” despite being delivered by staff with no relevant qualifications.
• Families are misled into believing these programs are necessary for progress, creating dependency and unnecessary expenditure.

C. Lack of outcome measurement or clinical justification

• Many programs do not include baseline assessments, progress tracking, or measurable goals.
• Providers continue delivering therapy indefinitely without demonstrating improvement or reassessing needs.
• Families are encouraged to continue programs simply to “use funding,” rather than based on clinical benefits.

D. Financial incentives driving over - servicing

• Providers recommend high frequency sessions (e.g., 3–5 times per week) without evidence that such intensity is appropriate.
• Some programs are designed to maximise billable hours rather than participant outcomes.

• Children are placed in multiple overlapping therapies that are not coordinated, not evidence based, and not necessary.

Impact on participants and the scheme

• Children miss out on genuine, evidence based interventions because budgets are consumed by ineffective programs.
• Families experience false hope, financial stress, and confusion about what is actually beneficial.
• The NDIS incurs significant unnecessary costs, contributing to sustainability concerns.

Need for stronger regulation

To address this issue, the NDIS must:

• Introduce evidence-based practice standards for all therapeutic programs.
• Require providers to demonstrate clinical justification and measurable outcomes.
• Prohibit funding for therapies that lack scientific support or rely on pseudoscience.
• Mandate minimum qualifications for anyone delivering therapeutic interventions.
• Conduct regular audits of therapy outcomes and remove funding for ineffective programs.

Fear of Reporting, Lack of Enforcement, and Barriers to Justice

A critical integrity issue within the NDIS is the widespread fear among workers, families, and even providers about reporting fraud, misconduct, or misuse of funds. Many individuals who witness wrongdoing feel unable to speak up due to:

• Fear of losing their job, especially support workers, therapists, and coordinators employed by providers engaging in unethical practices.
• Fear of retaliation, including being removed from rosters, losing clients, or being targeted by management.
• Previous experiences where reporting resulted in no action, leading to a belief that reporting is pointless or unsafe.
• Lack of whistleblower protections that are meaningful, accessible, and enforced.

This culture of fear allows fraudulent and unethical behaviour to continue unchecked.

Slow Enforcement and Continued Misuse of Funds

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The NDIS Quality and Safeguards Commission and the NDIA are often slow to act on reports of misconduct or fraud.

As a result:

• Participants and providers who misuse funds are allowed to continue claiming, sometimes for years.
• Providers under investigation continue to operate, bill, and take on new participants.
• Families who are doing the right thing are left waiting while others exploit the system.
• The lack of timely action undermines trust in the scheme and discourages further reporting.

This slow response creates a perception that misuse is tolerated, and that consequences are rare or delayed.

20. Tribunal (ART/AAT) Barriers and Inequity

When participants disagree with NDIA decisions, they are often forced to take their case to the Administrative Reviews/Appeals Tribunal (ART/AAT). However:

• The cost of tribunal proceedings is prohibitive for many families, especially those already under financial strain due to disability-related expenses.
• Participants often cannot afford legal representation, leaving them at a disadvantage.
• Meanwhile, taxpayers fund lawyers to defend the NDIA, creating a power imbalance where families face a government funded legal team if available.
• Many participants abandon their appeals because the process is too stressful, extensive, or complex.

This creates a system where those with resources can fight for their rights, while others simply go without essential support.

21. Consequences of Weak Enforcement and Reporting Barriers

The combined effect of fear, slow action, and inaccessible appeals processes results in:

• Ongoing fraud and misuse that drains funding from those who genuinely need it.
• Ethical providers being disadvantaged while unethical ones continue to profit.
• Participants with legitimate needs being denied support, while others exploit loopholes.

• A loss of public confidence in the NDIS as a fair and sustainable system.

Without stronger protections, faster enforcement, and accessible pathways for justice, the scheme remains vulnerable to exploitation.

22. Preventing Duplication with Other Government Programs and Ensuring Immediate Action on Reported Misuse

A major integrity issue within the NDIS is the ongoing duplication of supports that are already funded through other government programs, resulting in unnecessary expenditure and double-dipping. The NDIS was designed to be a scheme of last resort, yet in practice it is frequently used as the first and only funding source, even when other programs exist.

A. NDIS should only fund supports when no other government program applies

There are multiple established programs that already provide supports for vision, mobility, aids, equipment, and age-related needs, including:

• NSW Spectacles Program
• Vision Australia
• Hearing Services Program
• Enable NSW Aids and Equipment Program
• State based health and disability equipment schemes
• Carers Gateway
• Carers Australia
• School based supports
• Assisted School Travel Program
• BASC Before and After School Care OSHC
• OOSH Outside of school hours
• PCYC NSW Out of School Hours Care
• Medicare funded services
• My Aged Care (older Australians should transition off the NDIS)
• IPTAAS Isolated Patients Travel and Accommodation Assistance Scheme

Despite this, many participants and providers continue to claim items and services through the NDIS that should be accessed through these existing programs.

This results in:

Issues Identified

A. Double-funding and Inflated Expenditure

• Double-funding
• Inflated NDIS expenditure
• Reduced availability of funds for participants with genuine disability related needs
• Providers directing families to the NDIS because it pays higher rates

B. Older Australians Should Transition to My Aged Care

The NDIS is increasingly supporting older Australians who should be transitioned to My Aged Care, which is specifically designed for age-related needs. Continuing to fund older Australians through the NDIS:

• Strains the scheme
• Creates inequity between age groups
• Diverts funding from younger participants with lifelong disabilities

A structured transition pathway is needed.

C. Immediate Action When Misuse Is Reported

Currently, when misuse or fraud is reported:

• Investigations are slow
• Participants and providers continue to claim funds
• No interim restrictions are applied
• Misuse continues for months or years
• Reporters lose confidence because “nothing happens”

This allows for significant financial loss and ongoing exploitation of the scheme.

D. Flagging Participants and Providers in the System

When a credible report is made, the NDIS should:

• Immediately flag the participant or provider in the system
• Trigger automatic review of all claims
• Restrict high risk categories of spending
• Require additional evidence for claims
• Conduct rapid reassessment of the participant’s plan
• Suspend questionable line items until the investigation is complete

Rapid Reassessments to Stop Ongoing Misuse

This prevents further misuse while ensuring genuine supports continue.

E. Rapid reassessments to stop ongoing misuse

Delays in reassessment allow misuse to continue unchecked. A rapid reassessment process should be triggered when:

• Fraud is reported
• Claims appear inflated
• Household composition is inconsistent
• Informal supports are misrepresented
• Providers show patterns of overclaiming

Immediate reassessment ensures:

• Funding reflects genuine need
• Misuse is stopped early
• Funds are redirected to participants who truly require support

F. Ensuring funds go to people who genuinely deserve them

By preventing duplication, enforcing rapid action, and restricting misuse:

• The scheme becomes more sustainable
• Participants with legitimate needs receive timely support
• Public confidence in the NDIS is restored
• Providers are held accountable
• Vulnerable families are protected from exploitation

23. Age Criteria for Accessing Support Workers and Reinforcing Parental Responsibility

A significant integrity issue within the NDIS is the increasing use of support workers for very young children, including toddlers and preschool aged children, for tasks that fall squarely under ordinary parental responsibility. This has resulted in:

• Support workers being used as substitute parents, not disability supports
• Families outsourcing routine childcare tasks to the NDIS
• Providers encouraging parents to request support workers for non-disability-related activities

A rapid increase in support worker hours for children who do not require disability

specific assistance

This trend is inconsistent with the intent of the NDS and contributes to unnecessary expenditure.

A. Need for Age Criteria for Support Worker Access

To ensure supports are genuinely disability related, the NDLS should introduce clear age-based criteria for when support workers can be funded.

Support workers should not be funded for children below a certain age unless:

• There is a severe, documented disability
• The child requires specialised care beyond typical parenting
• The support worker is performing disability specific tasks, not general childcare
• The need cannot be met through ordinary parental responsibility or mainstream services

This prevents the NDIS from being used to replace parenting for young children.

B. Reinforcing Ordinary Parental Responsibility

Many tasks currently being claimed under the NDIS are typical responsibilities of parents, including:

• Feeding, bathing, dressing, toileting
• Supervising play
• Teaching basic skills
• Transporting children to recreational activities
• Enrolling children in swimming lessons, sports, or social groups
• Managing behaviour typical for the child’s age

These tasks should not be funded unless there is a clear, documented disability related need that exceeds what is expected of parents.

The NDIS must reinforce that:

Parenting does not become a NDIS-funded service simply because a child has a diagnosis.

C. Preventing Misuse of Support Workers

Without age criteria and parental responsibility guidelines, the following issues continue:

• Support workers used as babysitters
• Providers encouraging families to request unnecessary hours
• Children with mild or no functional impairment receiving high levels of support
• Families with multiple informal supports still claiming paid support workers
• Children capable of attending school fulltime receiving more hours than children with severe disabilities who are homeschooled

This creates inequity and misallocation of funding.

D. Recommendations

To address these issues, the NDIS should:

• Introduce minimum age thresholds for support worker funding
• Require functional evidence, not just a diagnosis, to justify support worker hours
• Enforce parental responsibility guidelines consistently across all plans
• Require planners to consider informal supports and household capacity
• Prevent support workers from being used for routine childcare or supervision
• Prioritise support worker funding for children with severe, complex, or high-risk needs

E. Impact of Reform

Implementing age criteria and reinforcing parental responsibility will:

• Reduce misuse of support worker funding
• Ensure supports are disability specific
• Improve fairness for families with children who have severe disabilities
• Reduce pressure on the NDIS budget
• Restore the scheme’s original intent
• Ensure children receive the right supports at the right time

24. Coaching, Manipulation, and Fraudulent Practices Used to Obtain Higher NDIS

Funding

A serious and growing integrity concern within the NDIS is the deliberate coaching of families, participants, and even medical professionals to obtain inflated or inappropriate funding. These practices undermine the intent of the scheme, distort eligibility, and place significant financial strain on the NDIS.

A. Coaching Parents to Manipulate Assessments and Funding Decisions

Some providers actively coach parents on how to present their circumstances in a way that maximises funding, including:

• Encouraging parents to exaggerate or misrepresent functional impairments
• Advising families to claim they have no informal supports, even when multiple adults are present in the home
• Instructing parents to use specific language during planning meetings to trigger higher budgets
• Rewriting or reframing reports to emphasise deficits rather than actual functioning

This results in plans that do not reflect genuine need and divert funding away from participants with significant disabilities.

B. Misuse of Hospital Systems to Influence NDIS Funding

There are increasing reports of providers advising families to use hospital admissions as a strategy to obtain additional support. This includes:

• Encouraging unnecessary hospital presentations to demonstrate “carer burnout” or “unsafe home environments”
• Advising parents to report crises or emergencies that are not occurring
• Using hospital stays to justify requests for additional in-home supports or respite
• Pressuring medical staff to sign documents that overstate functional limitations

These practices place unnecessary strain on hospitals, misrepresent clinical needs, and distort NDIS decision-making.

C. Manipulation of Child Protection and Crisis Pathways

Some families are being coached to use crisis pathways to secure higher funding, including:

• Threatening to relinquish care of their child
• Self reporting to family services or child protection services to demonstrate “risk”
• Claiming they cannot care for their child without additional NDIS supports
• Using crisis language to pressure planners into approving higher budgets

These actions exploit systems designed to protect children and create false urgency that undermines genuine cases.

D. Misuse of Professional Authority

There are concerning instances where:

• Reports are rewritten or edited by Ndis providers (support coordinators or managers) before being sent back to participants
• Occupational therapists or medical staff are asked to sign off on documents they did not write
• Clinicians are pressured to endorse claims that do not reflect their professional judgement
• Providers use templated or exaggerated reports to justify high cost supports

This compromises clinical integrity and places professionals in ethically inappropriate positions.

E. Adults Misrepresenting Conditions to Access Funding

There are increasing reports of adults:

• Claiming or exaggerating conditions such as autism to access higher funding
• Coaching their children to present in certain ways during assessments
• Using diagnostic labels as a pathway to secure additional supports rather than to address genuine functional needs

This behaviour undermines the credibility of legitimate diagnoses and contributes to diagnostic inflation.

F. Impact on the Scheme

These practices have significant consequences:

• Inflated plans that do not reflect genuine disability related needs
• Misallocation of funding away from participants with severe and complex disabilities
• Increased pressure on hospitals, child protection, and emergency services
• Erosion of trust in providers, clinicians, and the NDIS
• Increased appeals, reviews, and administrative burden
• Long-term sustainability risks for the scheme

G. Recommendations

To address these issues, the NDIS should:

• Introduce strict penalties for providers who coach families to misrepresent circumstances
• Require verification of claims made during planning meetings
• Mandate independent assessments for high-risk or high-cost plans
• Strengthen clinical oversight of reports submitted to the NDIA
• Implement cross agency data matching with hospitals and child protection
• Flag and review cases where crisis pathways are repeatedly used to obtain funding
• Require planners to consider objective evidence, not solely self report
• Introduce mandatory reporting obligations for clinicians pressured to falsify or exaggerate information

25. Additional Integrity Risks: Offshore Services, Privacy Concerns, Misuse of Support Worker Hours, Questionable Diagnoses, and SDA Safety Failures

Several emerging integrity risks within the NDIS require urgent attention due to their impact on participant safety, data security, and scheme sustainability.

A. Use of Offshore Accountants and Offshore Service Providers

Some NDIS providers are outsourcing:

• Accounting
• Invoicing

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Recordkeeping

• Administrative functions
• Online therapy or support services

to offshore companies or individuals.

This raises significant concerns:

• Privacy breaches — participant data stored or accessed outside Australia
• Cybersecurity risks — increased vulnerability to hacking, data theft, and unauthorized access
• Lack of regulatory oversight — offshore workers are not subject to Australian law, NDIS Practice Standards, or worker screening
• No accountability — difficult to investigate or prosecute misconduct occurring overseas

The NDIS must prohibit the use of offshore service delivery and require all administrative and therapeutic functions to be performed by Australian based, accredited, and regulated personnel.

B. Support Workers Performing Household Duties While Participants Are Absent

A widespread misuse of funding involves support workers:

• Returning to participant homes after school drop-off
• Performing general household duties (cleaning, laundry, dishes)
• “Making up hours” when the participant is not present
• Providing no disability related support or capacity building

This is not:

• Reasonable and necessary
• Disability related
• Capacity building
• Permitted under NDIS rules

This practice inflates hours, misuses public funds, and shifts ordinary household responsibilities onto the NDIS.

C. Questionable Use of Autism Diagnoses to Access High Level Supports

There is increasing concern about the misuse of Level 3 autism diagnoses as a gateway to:

• High support worker hours
• STA/short-term respite
• Centrelink payments
• Government housing
• Additional school-based supports and childcare
• Assisted travel programs

In many cases, the functional presentation of the child is inconsistent with a Level 3 diagnosis.

Examples include children who:

• Attend school fulltime or childcare
• Participate in sleepovers with friends
• Attend church, catering events, hosting events, community events, wedding, engagements, christenings, holy communion and social gatherings
• Travel independently through assisted travel programs
• Engage in recreational activities such as camping, skiing, fishing, charter boating, surfing, swimming
• Demonstrate strong verbal communication and social engagement
• Cope with multiple environments and multiple support workers

These behaviours are not consistent with the functional profile of Level 3 autism, which typically involves:

• Severe communication impairments
• High rigidity and need for routine
• Significant difficulty coping with unfamiliar environments
• High dependence on a primary caregiver
• Limited capacity to manage transitions or unpredictable settings

The NDIS must implement functional reassessments, not diagnosis-based funding, and require evidence of impairment across multiple environments.

D. Undisclosed Household Composition and Misrepresentation of Informal Supports

Some families fail to disclose:

• Marital status
• Presence of additional adults in the home
• Access to extended family support
• Ability to drive or access transport
• Household income or assets

This leads to inflated claims of:

• “No informal supports”
• “Carer burnout”
• “Inability to transport the child”
• “Need for high support worker hours”

When families have:

• Two licensed drivers
• Multiple vehicles
• Extended family support
• School based assisted travel
• Fulltime school attendance

the justification for high level NDIS supports is significantly weakened.

Cross agency data matching is essential to verify household composition and prevent misrepresentation.

F. SDA Safety Failures and Lack of Oversight

Serious incidents in Specialist Disability Accommodation (SDA) highlight:

• Insufficient staff training
• Lack of CCTV or monitoring
• Inadequate supervision
• Poor emergency response procedures
• Unqualified workers placed in high-risk environments

A recent incident involving a fire and the death of a participant underscores the urgent need for:

• Mandatory CCTV in common areas
• Minimum qualifications for SDA staff
• Higher staffing ratios
• Mandatory fire safety and emergency training
• Regular compliance audits

SDA is one of the most expensive components of the NDIS; safety and quality must be non-negotiable.

G. Recommendations

To address these risks, the NDIS should:

• Prohibit offshore service delivery and offshore data handling
• Require all administrative and therapeutic functions to be performed in Australia
• Enforce strict rules preventing support workers from performing household duties without the participant present

• Require functional reassessments for children with high-level autism diagnoses
• Mandate disclosure of household composition and informal supports
• Implement cross-agency data matching with Centrelink, schools, and state agencies
• Restrict STA to disability-specific, evidence-based purposes
• Strengthen SDA safety standards, staffing requirements, and monitoring
• Introduce penalties for misrepresentation of functional capacity or informal supports

26. Reducing the Cost of NDIS Provider Registration to Improve Quality and Compliance

A major barrier to improving quality and integrity within the NDIS is the high cost of provider registration, particularly for small, ethical providers who want to operate legitimately but cannot afford the current fees and audit requirements. This has created a distorted market where:

• Unregistered providers dominate, despite having fewer obligations
• Registered providers face significant financial burden
• High-quality providers are discouraged from entering the sector
• Low-quality or non-compliant providers operate freely without oversight
• Participants are pushed toward cheaper, unregistered providers with lower safeguards

This undermines the purpose of the NDIS Quality and Safeguards Commission and weakens participant protections.

A. Registration Costs Are Excessive and Disproportionate

Current registration costs include:

• Expensive third-party audits
• Ongoing compliance fees
• Administrative burdens
• Costs that disproportionately impact small and regional providers

For many small businesses, sole traders, and culturally diverse providers, the cost of registration is prohibitive, forcing them to remain unregistered even when they want to comply.

B. High Registration Costs Reduce Quality and Safety

When registration is too expensive:

• Providers avoid the regulated pathway
• Participants receive services from unregistered workers with no oversight
• The Commission cannot enforce standards
• Safeguarding becomes reactive instead of preventative

Lowering registration costs would increase the number of providers under formal regulation, improving:

• Worker screening
• Complaint handling
• Incident reporting
• Quality assurance
• Participant safety

C. Making Registration Cheaper Will Improve Integrity

Reducing registration costs will:

• Encourage more providers to become registered
• Increase accountability and transparency
• Reduce the number of unregistered, unqualified workers
• Improve compliance with NDIS Practice Standards
• Strengthen safeguarding for vulnerable participants
• Reduce fraud and misuse by bringing more providers under regulated oversight

This is a cost-effective integrity measure that strengthens the entire system.

D. Recommendations

To improve quality and integrity, the NDIS should:

• Subsidise registration audits for small and medium providers
• Introduce tiered registration fees based on provider size and risk
• Reduce administrative burdens for low-risk supports
• Provide free or low-cost training to help providers meet compliance requirements
• Offer government-funded audit vouchers for new providers
• Simplify the registration process while maintaining safeguards
• Encourage unregistered providers to transition into the regulated system

This will expand the pool of high-quality providers and reduce reliance on unregulated services.

27. Mandatory Accreditation and Minimum Qualifications for Support Workers

A major integrity and safety issue within the NDIS is the absence of mandatory accreditation, minimum qualifications, and competency standards for support workers. This has resulted in a workforce where many individuals enter the sector with:

• No prior experience working with people with disability
• No training in child safety, behaviour management, or communication needs
• No understanding of duty of care or professional boundaries
• No knowledge of disability rights, safeguarding, or restrictive practice rules

This creates significant risks for participants, particularly children and individuals with complex needs.

A. Lack of Mandatory Accreditation

Unlike other care sectors (aged care, childcare, health), the NDIS currently allows support workers to begin work with:

• No formal qualification
• No mandatory training
• No national accreditation
• No background in disability support

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B. High-risk Situations Created by Untrained Workers

Unqualified support workers are often placed in situations requiring:

-Behaviour support knowledge -Personal care skills -Communication strategies for nonverbal participants -Understanding of sensory needs -Safety awareness in community settings -Knowledge of medical vulnerabilities

Without training, workers may unintentionally:

-Escalate behaviours -Breach safety protocols -Mismanage medication or personal care -Fail to recognise signs of distress or risk -Cause harm through lack of skill or judgement

This is a systemic safeguarding failure.

C. Workers Being Asked to Perform Tasks Outside Their Scope

Support workers frequently report being asked to perform tasks they are not qualified or legally permitted to do, including:

-Behaviour intervention without training -Personal care requiring clinical knowledge -Transporting children without proper safety training -Managing complex medical needs -Acing as informal therapists -Providing supervision in high-risk environments

This exposes both participants and workers to significant risk.

D. Need for a National Support Worker Accreditation Scheme

To ensure safety and quality, the NDIS should introduce a mandatory national accreditation system for all support workers, including:

• Minimum qualification requirements (e.g., Certificate III in Individual Support or equivalent)
• Mandatory training in:
  • Disability awareness
  • Child safety
  • Behaviour support basics
  • Communication strategies
  • Duty of care and boundaries
  • Incident reporting
  • First aid
• National background checks
• Ongoing professional development requirements
• Registration with a national workforce regulator

This would align the disability sector with other regulated care sectors.

E. Benefits of Mandatory Accreditation

Introducing accreditation will:

• Improve participant safety
• Reduce risk of harm
• Ensure workers understand their scope of practice
• Increase workforce professionalism
• Reduce exploitation of inexperienced workers
• Improve service quality
• Prevent providers from hiring untrained staff to cut costs

This reform is essential for safeguarding vulnerable participants.

F. Recommendations

The NDIS should:

• Mandate minimum qualifications for all support workers
• Establish a national accreditation and registration scheme
• Require providers to verify worker competency before assigning shifts
• Prohibit workers from performing tasks outside their training
• Introduce penalties for providers who use unqualified staff in high-risk roles
• Require ongoing training and professional development

28. Snapshot Assessments Leading to Inaccurate and Misleading Plans

A major integrity issue within the NDIS is the reliance on snapshot assessments—brief, one off observations or short interviews used to determine a participant’s functional capacity, support needs, and funding levels. These assessments are often:

• Conducted in a single session, sometimes as short as 30–60 minutes.
• Performed by assessors who have limited knowledge of the child, their daily functioning, or their long-term developmental trajectory.
• Based on parent-reported information without verification from schools, therapists, medical professionals, or informal support.
• Influenced by how the child presents on the day, which may not reflect their typical functioning.

This approach leads to significant inaccuracies in NDIS plans.

A. Over – or Under – Funding Due to Incomplete Information

Snapshot assessments frequently result in:

• Overfunding, when a child has a bad day, is tired, distressed, or overwhelmed during the assessment.
• Underfunding, when a child masks, performs well in structured environments, or has strengths that temporarily overshadow their daily challenges.
• Plans that do not reflect the child’s true functional capacity, leading to inappropriate support.

This creates inequity, inconsistency, and unnecessary appeals.

B. No Longitudinal Understanding of the Child

Children’s needs fluctuate across:

Snapshot Assessments

Limitations of Snapshot Assessments

What They Fail To Capture:

• Behavior patterns
• Fatigue levels
• Sensory triggers
• Learning needs
• Daily living challenges
• Variability across environments

Without longitudinal data, plans are built on incomplete and unreliable information.

C. Lack Of Verification With Key Stakeholders

Snapshot assessments often proceed without consulting:

• Teachers
• School learning support teams
• Paediatricians
• Therapists
• behaviour support practitioners
• informal supports
• hospital or gp records

This allows:

• inflated claims
• misreported impairments
• unverified functional limitations
• inaccurate descriptions of daily care needs

The absence of cross-checking enables misuse and fraud.

D. providers coaching families before assessments

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Some providers coach families to:

• Emphasise certain behaviours
• Downplay informal supports
• Use specific language to secure higher funding
• Present the child in a way that maximises plan budgets

Snapshot assessments make this manipulation easier because assessors have no long- term context.

Consequences for the Scheme

Snapshot assessments contribute to:

• Inconsistent funding decisions
• Inflated plans for some participants
• Underfunded plans for others
• Increased appeals and tribunal cases
• Higher scheme costs
• Reduced trust in the assessment process

This undermines the fairness and sustainability of the NDIS.

Recommendations for Reform

To improve accuracy and integrity, the NDIS should:

• Require multisource verification, including schools, medical professionals, and informal support.
• Use longitudinal assessments over multiple sessions or environments.
• Implement standardised functional assessment tools validated for children.
• Mandate cross agency data matching to confirm reported impairments.
• Prohibit funding decisions are based solely on single day observations.
• Introduce independent assessors with relevant qualifications in child development, psychology, or allied health.

29. GPS Tracking to Prevent Fraud and Inflation of Hours

A significant integrity risk within the NDIS is the inflation of hours by support workers,

cleaners, gardeners, and other service providers who bill for time not actually worked. Current systems rely heavily on:

• Self-reported timesheets
• Manual logging
• Provider controlled rostering systems
• Participant signatures that can be pressured or forged

This creates opportunities for:

• Ghost shifts (billing for services never delivered)
• Inflated hours (e.g., claiming 3 hours for a 1-hour visit)
• Billing for overlapping shifts across multiple participants
• Claiming travel time that never occurred
• Support workers signing in from home or another location

These practices significantly inflate NDIS expenditure and undermine trust in the scheme.

A. GPS Tracking as a Mandatory Integrity Measure

To address these issues, the NDIS should introduce mandatory GPS-verified check-in and check-out systems for all hourly billed services, including:

• Support workers
• Cleaners
• Gardeners
• In-home respite workers
• Community access workers
• Therapy assistants

GPS verification would:

• Confirm the worker was physically present at the participant’s home or community location
• Accurately record start and finish times
• Prevent inflated travel claims
• Reduce fraudulent billing
• Provide transparent, auditable data for compliance checks

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B. Benefits of GPS Tracking

Implementing GPS-verified attendance would:

• Eliminate ghost shifts
• Prevent inflated hours and double-billing
• Ensure accurate travel claims
• Protect participants from being pressured to sign false timesheets
• Provide real-time data for audits and investigations
• Reduce administrative burden by automating attendance records

It also protects ethical providers, ensuring they are not undercut by competitors who inflate hours.

C. Addressing Privacy and Safety

GPS tracking can be implemented in a way that protects privacy:

• Only logs arrival and departure, not continuous tracking
• Data stored securely and accessed only for compliance
• Participants can view their own logs for transparency
• Workers are only tracked during paid shifts, not outside work hours

This balances integrity with worker rights.

D. Consequences of Not Implementing GPS Verification

Without GPS tracking, the NDIS remains vulnerable to:

• Ongoing fraud
• Inflated claims
• Inaccurate billing
• Providers exploiting participants
• Significant financial loss to the scheme
• Reduced funding availability for participants with genuine needs

Given the scale of misuse already occurring, GPS verification is a necessary and proportionate integrity measure.

30. Recreational Activities Being Misrepresented as Therapy (e.g., Swimming Programs, Rainbow Club)

A growing issue within the NDIS is the misclassification of recreational activities as therapy, particularly swimming programs such as those offered through Rainbow Club and similar organisations. While these programs may provide social or physical benefits, they are not clinical therapies and should not be billed under therapeutic line items unless delivered by qualified allied health professionals with evidence-based goals.

Key concerns include:

A. Recreational programs being billed as therapy

• Swimming lessons, sports clubs, dance classes, gymnastics, and general fitness programs are increasingly being claimed as “therapy.”$
• Providers market recreational activities as “therapeutic” to access higher NDIS rates, despite lacking clinical justification.$
• Many programs are run by instructors with no allied health qualifications yet are billed at therapy prices.$

B. Rainbow Club and similar programs

• Rainbow Club and comparable organisations provide swimming lessons, not clinical hydrotherapy.$
• Sessions are often delivered by swim instructors, not physiotherapists,$ octuplet therapists, or exercise physiologists.$
• Families are encouraged to claim these lessons as therapy, despite them being recreational and part of normal childhood activities.$

C. Lack of evidence-based practice

• Recreational swimming is not an evidence-based intervention for most disabilities.$
• Programs often lack:$
  • Functional goals$$
  • Baseline assessments$$
  • Progress measures$$
  • Clinical oversight$

D. Parental Responsibility

Many recreational activities being claimed under the NDIS fall under ordinary parental responsibility, including:

• Teaching a child to swim
• Enrolling a child in sports or recreational clubs
• Providing opportunities for social participation
• Ensuring children engage in physical activity

These are typical responsibilities of parents and should not be shifted onto the NDIS unless there is a clear, clinically justified disability-related need.

E. Impact on the Scheme

Misrepresenting recreational activities as therapy leads to:

• Inflated therapy budgets
• Reduced funding availability for participants with genuine clinical needs
• Providers profiting from non-clinical services
• Families being misled into believing recreational activities are essential therapies
• Increased inequity between families who follow the rules and those who exploit loopholes

F. Recommendations

To address this issue, the NDIS should:

• Clearly distinguish therapy from recreation in guidelines and funding rules.
• Require therapy to be delivered only by qualified allied health professionals.
• Prohibit recreational programs from being billed under therapy line items.
• Introduce audits of recreational providers claiming therapy rates.
• Reinforce the principle of ordinary parental responsibility for non-disability-specific activities.
• Require evidence-based goals and measurable outcomes for any program billed as therapy.

31. Reassessments for Eligibility: Urgent Review of All Children Diagnosed from Mid

2019

Since June 2019, there has been a significant and unprecedented increase in childhood disability diagnoses, particularly autism, developmental delay, ADHD, and behavioural disorders. This surge coincides with:

• COVID-19 disruptions and post
• Reduced access to early childhood services
• Increased pressure on families
• Schools encouraging diagnoses to access classroom support
• Providers recommending diagnoses to secure NDIS funding
• A rapid expansion of private assessment services with inconsistent quality

As a result, many children may have been diagnosed prematurely, inaccurately, or without adequate developmental observation.

A. Need for Systematic Reassessment

To ensure fairness and integrity, the NDIS should conduct mandatory reassessments for all children diagnosed from June 2019 onwards, particularly those diagnosed:

• Before age 8
• Older Adults that entered the scheme under Autism
• Through brief or snapshot assessments
• Without multidisciplinary evaluation
• By practitioners without paediatric or developmental expertise
• During periods of lockdown or restricted schooling
• Through telehealth assessments with limited observation

This reassessment process is essential to determine whether:

• The diagnosis remains accurate
• The child’s functional needs have changed
• The child has developed skills naturally with age
• Supports are still reasonable and necessary
• Funding levels reflect current, not historical, needs

B. Why Reassessment is Necessary

Risks Associated With Increased Diagnoses

The surge in diagnoses has created several risks:

• Over-diagnosis and misdiagnosis due to pressure from schools, providers, or overwhelmed families.
• Children labelled with lifelong disabilities before they had time to develop speech, social skills, or emotional regulation.
• Diagnostic inflation used to access higher funding levels, government housing, and welfare benefits.
• Children who have since improved or no longer met criteria continue to receive high-level funding.
• Inconsistent diagnostic standards across private assessors with snapshot assessments or telehealth.
• Significant strain on NDIS budgets, reducing funding availability for children with genuine, lifelong disabilities.

C. Reassessment Should Be Evidence-Based and Multidisciplinary

Reassessments must:

• Use validated, standardised tools
• Include school input is child on partial school attendance can child attend school events, does child have an IEP
• Include medical and developmental history
• Consider longitudinal functioning
• Be conducted by qualified paediatric specialists
• Verify impairments across multiple environments

This ensures accuracy and prevents reliance on single-session or parent-only reports.

D. Benefits of Reassessment

A structured reassessment program would:

• Ensure funding is directed to children with genuine disability-related needs
• Reduce unnecessary or inflated plans
• Identify children who have outgrown early developmental delays
• Provide clarity for families
• Improve scheme sustainability
• Restore public confidence in the fairness of the NDIS

E. Prioritisation

Reassessment should prioritise:

1. Children diagnosed between 2020–2026
2. Children diagnosed before age 8
3. Children with minimal functional impairment
4. Children attending school fulltime without additional support needs, IEP,
   partial school attendance, suspensions, is child able to attend school events
5. Children with multiple overlapping diagnoses made in a single session
6. Adults diagnosed between 2020-2026

This ensures resources are focused where the risk of misdiagnosis is highest.

32. Recommendations for Strengthening Integrity

A. Provider Accountability

• Mandatory audit of travel claims, administrative billing, and service logs.
• Clearer guidelines on reasonable and necessary administrative time.
• Stronger penalties for repeated nongenuine billing.

B. Behaviour Support Reform

• Minimum qualification standards for behaviour support practitioners.
• Prohibition of AI-generated or template based strategies without clinical oversight.
• Mandatory training for support workers implementing BSPs.
• Regular quality reviews of BSPs for evidence-based practice and individualisation.

C. Diagnostic Integrity

• Clearer guidelines for diagnostic pathways, especially for young children.
• Oversight of practitioners conducting assessments to ensure appropriate qualifications.
• Monitoring diagnostic patterns to identify inflation or pressure-driven diagnoses.
• Separation of diagnosis from funding incentives to reduce perverse pressures.

D. Participant and Family Education

• Clear communication about appropriate use of NDIS funding.
• Monitoring of respite usage to ensure participant benefits.
• Removal of household tasks from children’s plans unless directly related to disability needs.

E. Strengthened Oversight

• Increased random audits of providers and participants.
• Improved data matching to identify patterns of over-claiming or diagnostic inflation.
• Collaboration with professional bodies to ensure clinical standards are upheld.

33. Conclusion

The NDIS is a vital system that must remain sustainable, ethical, and participant centred. Addressing the integrity issues outlined in this submission is essential to protect vulnerable participants, ensure high-quality service delivery, and maintain public confidence in the scheme. Strengthening oversight, improving practitioner standards, and signing funding is used as intended will help restore integrity and safeguard the future of the NDIS.

Yours faithfully,