Submission to the Joint Standing Committee on the National

               Disability Insurance Scheme

     Inquiry into the Integrity of the National Disability Insurance Scheme

                       Anonymous Submission

                         May 2026

1 Purpose of this Submission 2

2 Core Administrative Concern 2

3 Due Process at Participant Level 3

4 Task Definition and Administrative Clarity 3

5 Monitoring of One-on-One Care in the Home 4

6 Participant Feedback 4

7 Worker Accountability and Supervision 5

8 Medication-Related and Complex Care Risk 6

9 Subcontracting and Substitute Workers 6

10 Family Burden and Administrative Substitution 7

11 Private Homes as Care Settings 7

12 Complaints and Evidence 8

13 Financial Integrity 8

14 Recommendations 9

15 Questions for the Committee 10

16 Conclusion 11

17 Personal Position 11

Purpose of this Submission

This submission concerns due process, accountability, and administration in the delivery of NDIS-funded supports at the participant level.

It is not a submission about general service dissatisfaction. It is not directed at criticising individual workers or providers as a class. It is about whether the administrative systems around the participant are strong enough to ensure that funded supports are delivered safely, transparently, and accountably.

The submission is based on family observations involving an adult NDIS participant with serious medical and support needs. Those observations raise broader questions about how the NDIS verifies care delivery, defines tasks, monitors workers in one-on-one home settings, collects participant feedback, manages subcontracting, and protects participants where accounts of events differ.

The central issue is this: public money is allocated for care, but at the participant level there may be insufficient due process to confirm what was delivered, by whom, under what authority, to what standard, and with what safeguards.

That is an integrity issue.

3. Due Process at Participant Level

The NDIS should not only approve funding. It should also ensure that there is a clear adminis- trative pathway from funding approval to safe delivery.

That pathway should answer the following questions:

   1. What support was approved?

   2. What task was the worker expected to perform?

   3. Was the participant told what to expect?

   4. Was the worker told what to do?

   5. Was the worker trained for that participant’s needs?

   6. Did the worker attend?

   7. Did the worker stay for the required time?

   8. Was the task completed?

   9. Was the participant asked for feedback?

 10. Was any concern recorded, reviewed, and escalated?

If the system cannot answer those questions clearly, then there is a due process gap.

The concern is not merely whether a participant is happy or unhappy with a service. The concern is whether there is an auditable administrative process that protects the participant, The worker, the provider, and public funds.

4. Task Definition and Administrative Clarity

A recurring issue is the lack of clear task definition at the point of delivery.

A participant may receive support hours, but the practical meaning of those hours may not be clear. For example, it may be unclear whether the worker is expected to provide personal support, domestic assistance, transport, prompting, supervision, companionship, medication- elated support, household support, or some combination of these.

This creates administrative risk.

If tasks are not clearly defined, then:

the worker may refuse tasks the participant believes are included;
the participant may expect support the provider says was not authorised;
the provider may invoice for time without a clear record of completed work;
the family may be asked to fill gaps; and
complaints may become difficult to resolve because there is no clear baseline.

A support shift should not be treated as merely a block of paid time. It should have a clear administrative purpose.

For recurring home-based supports

For recurring home-based supports, there should be a plain task schedule available to the par- ticipant, worker, provider, and nominee where relevant. It should state what is included, what is excluded, who decides disputes, and how incomplete tasks are recorded.

Monitoring of One-on-One Care in the Home

One of the most important concerns is the lack of visible monitoring in one-on-one home-based care.

A worker may spend hours alone with a vulnerable participant in a private home. In that setting, there may be no witness, no supervisor present, no independent observation, and no routine external check of the quality of the interaction.

This creates a “word against word” problem.

If the participant says one thing occurred and the worker says another, the system may have no reliable way to determine what happened. That is a serious safeguarding weakness.

This would not be considered acceptable in many settings involving children or vulnerable peo- ple, such as schools, where there are clearer supervision expectations, reporting obligations, professional boundaries, and institutional oversight.

The same principle should apply here. Vulnerable adults receiving paid care in private homes should not be placed in a weaker due process position simply because the care occurs behind closed doors.

The issue is not surveillance for its own sake. The issue is administrative assurance.

The Committee should consider whether one-on-one NDIS support in private homes requires stronger safeguards, such as:

scheduled participant feedback checks;
periodic supervisory contact;
written shift notes visible to the participant or nominee;
participant confirmation of attendance and task completion;
stronger incident recording; and
clearer dispute pathways.

Participant Feedback

A major missing safeguard is structured participant feedback.

The participant should not only be asked for feedback when there is a complaint. Feedback should be built into ordinary administration.

The system should clearly define:

when the participant is asked whether the worker attended;
when the participant is asked whether tasks were completed;

Feedback Mechanisms

When Should Feedback Be Sought?

Feedback should be sought in the following situations:

when the participant is asked whether they felt safe;
when the participant is asked whether the worker understood their needs;
who receives that feedback;
whether the provider sees it;
whether the NDIA or Commission can access it; and
what happens when feedback identifies a concern.

Without routine feedback, problems may remain invisible until they become serious.

Some participants may not complain because they fear losing support, being treated differently, or being dismissed as difficult. Others may have communication, cognitive, psychological, or medical vulnerabilities that make formal complaint processes difficult.

For that reason, feedback should not rely only on the participant making a complaint. The system should actively ask for participant input at appropriate intervals.

The following questions are basic examples of how to gather feedback:

Did the worker attend at the expected time?
Did the worker stay for the expected duration?
Did the worker complete the agreed tasks?
Did the worker treat the participant respectfully?
Did the participant feel safe?
Was any task refused or left incomplete?
Was the participant pressured or confused about any instruction?
Does the participant want follow-up from a supervisor or advocate?

These questions are basic. They should not require a major complaint before being asked.

Worker Accountability and Supervision

The participant and family should know who is monitoring the worker. This includes knowing:

who the worker reports to;
whether the worker is directly employed, casual, agency-based, or subcontracted;
whether a supervisor reviews their work;
whether shift notes are checked;
whether attendance is verified;
whether participant feedback is compared with worker records; and
whether repeated concerns trigger review.

The need for due process becomes more serious where the participant has complex medical needs or regulated medication requirements.

One family concern involved a worker who appeared not to understand the participant’s med- ication process and allegedly pressed the participant by suggesting ambulance or hospital consequences.

The issue is not whether the worker intended harm. The issue is that an unclear role boundary in a medically sensitive situation can create serious risk.

For participants with complex medical or medication-related needs, the system should clearly document:

what the worker is allowed to do;
what the worker is not allowed to do;
what the participant’s routine is;
what escalation pathway applies;
who is contacted first;
when medical advice is required; and
what must be recorded after an incident or disagreement.

Workers should not be placed in situations where they are expected to interpret medical processes beyond their training. Participants should not be pressured by workers who do not understand the relevant care framework.

This is an administrative design issue.

whether they are insured;
who supervises them; and
how concerns about that worker are reported.

Subcontracting should not dilute accountability. If a provider arranges care, the participant should not be left to navigate an unclear chain of responsibility.

Family Burden and Administrative Substitution

Another due process issue is the transfer of responsibility onto family members.

Family members often provide support voluntarily. That is not the concern. The concern is where family members are expected to fill operational gaps in funded supports without that being formally recognised, reviewed, or accounted for.

If a parent or family member is asked to travel, provide supplies, manage conflict, complete tasks, or stabilise a situation because paid supports have not functioned properly, that should be recorded as an administrative signal.

It may indicate:

the task was not properly defined;
the provider failed to deliver;
the worker was not properly briefed;
the participant’s plan does not match actual need; or
the system is relying on unpaid labour to make paid support appear adequate.

This affects integrity because it hides the true cost and workload of support.

Private Homes as Care Settings

Many NDIS supports are delivered in private homes. This creates administrative and legal uncertainty.

Where a private home becomes the site of paid support work, participants and families should be told:

whether the home is considered a workplace;
who assesses risks;
who is responsible for worker safety;
who is responsible for participant safety;
what insurance applies;
what duties the provider has;
what duties, if any, fall on the property owner; and

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how incidents are reported.

Families should not be expected to guess their obligations.

This is particularly important where the home is older, owned by family, occupied by the par- ticipant, and regularly entered by paid workers.

The submission does not ask the Committee to resolve individual liability. It asks the Commit- teeth to consider whether the NDIS should require clearer guidance before home-based services commence.

12. Complaints and Evidence

Complaint systems must account for the realities of one-on-one care.

If a participant raises a concern after a private one-on-one interaction, the process should not simply become the participant’s word against the worker’s word.

There should be supporting records, such as:

roster records;
arrival and departure records;
task notes;
participant feedback;
supervisor check-ins;
incident reports;
prior complaint history; and
records of worker training.

Without these, complaints may be difficult to prove and easy to dismiss.

This creates an unfair position for vulnerable participants. It may also discourage complaints because participants and families may believe nothing can be proven.

The Committee should consider whether complaint processes need stronger evidentiary founda- tions for home-based supports.

13. Financial Integrity

Financial integrity depends on more than correct invoicing.

A claim may be submitted correctly, but the underlying support may still be poorly delivered, unverified, or of limited value.

Integrity requires knowing:

whether the worker attended;
whether the worker stayed;

whether the worker performed the task;
whether the participant received meaningful support;
whether the participant had an opportunity to provide feedback; and
whether concerns were acted upon.

Without that, the system may pay for support activity without confirming support outcomes.

This is not only a safeguarding issue. It is a public administration issue.

Recommendations

The Committee should consider recommending:

  1. Participant-level due process framework - A participant-level due process framework
   should be developed for recurring home-based NDIS supports. The framework should
    define the minimum administrative record required before, during, and after support
     delivery.

  2. Written task schedules - Recurring support shifts should have written task schedules,
    including included tasks, excluded tasks, escalation points, and dispute pathways.

  3. Routine participant feedback - Participant feedback should be collected after, or period-
     ically during, recurring supports. Feedback should cover attendance, task completion,
     safety, respect, and unresolved concerns.

  4. Feedback governance - Feedback should cover attendance, task completion, safety, re-
   spect, and unresolved concerns.

  5. Attendance and task verification - Attendance and task verification systems should
   not rely only on provider or worker records.  Participant confirmation or nominee
   confirmation should be available where appropriate.

  6. Supervisory monitoring - Providers delivering one-on-one home-based support should
   have supervisory monitoring requirements. This may include supervisor check-ins, re-
   view of shift notes, or periodic participant contact.

  7. Feedback governance - Where a participant and worker give different accounts of an in-
    cident, the complaint process should examine supporting records, including shift notes,
    feedback, supervisor contact, training records, and prior patterns.

  8. Supervisor monitoring - Providers delivering one-on-one home-based support should
   have supervisory monitoring requirements. This may include supervisor check-ins, re-
   view of shift notes, or periodic participant contact.

  9. Participant-facing worker profiles - Participants should have access to a plain worker
    profile showing screening, participant-specific training, supervision arrangements, and
   provider responsibility.

 10. Subcontractor disclosures - Subcontracted or substitute workers should be disclosed
     before attendance where practicable. Their identity, provider relationship, screening

Status Recording

The status, training status, and supervision chain should be recorded.

Disputed Accounts - Where a Participant and Worker Give Different Accounts of an Incident

The complaint process should examine supporting records, including shift notes, feedback, supervisor contact, training records, and prior patterns.

Medication Boundaries

Clear rules should be provided for medication-related boundaries and escalation. Workers should know what they may do, what they may not do, and who to contact when uncertain.

Family Substitution Recording

Unpaid family intervention should be recorded where it substitutes for funded support. Repeated family substitution should trigger plan or provider review.

Plain-language Guidance on Private Homes as NDIS Care Settings and Workplaces

Plain-language guidance should be provided on private homes as NDIS care settings and workplaces, including insurance, risk assessment, safety duties, and incident reporting.

Escalation Pathways

Participants should receive clear escalation pathways for different concerns, including missed shifts, task refusal, worker conduct, medication concerns, subcontractor issues, privacy issues, suspected misuse of funds, and urgent safety risks.

Complaint Adequacy Review

The Committee should review whether current complaint systems are adequate for one-on-one home-based care where independent evidence may be limited.

Who explains liability, safety, and insurance when a private home becomes a care setting?

Conclusion

This submission is about due process, accountability, and administration at the participant level. The NDIS should not only fund supports. It should ensure that those supports are delivered through a clear, auditable, and fair administrative process.

At present, home-based one-on-one care can leave participants in a weak evidentiary position. A vulnerable participant may be alone with a worker, with limited monitoring, limited feedback collection, and limited independent verification. If something goes wrong, the matter may become one person’s word against another’s.

That is not a strong safeguarding model.

The Committee is asked to consider integrity in practical administrative terms. A scheme has integrity when:

Personal Position

This submission is provided as a family-observation submission. It uses personal experience only to identify possible system-level administrative issues. The submission does not seek to name individual workers or providers. Its focus is the due process framework around participant-level delivery of NDIS-funded home supports.

The central recommendation is that integrity should include participant-level delivery verifica- tion, not only funding approval and post-event complaint handling.

responsibilities are clear;
workers are trained and supervised;
participants are asked for feedback;
care is verified;
complaints can be tested against records;
families are not used to hide service gaps; and
public money can be traced to actual support delivered.

That is the participant-level due process needed for home-based NDIS supports.

— End of Submission —

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I was hoping to add an addition.

Tonight I’m in ICU with my sister as she is quite sick.

It came to my attention this evening that her NDIS support workers immediately stop being paid the moment my sister was hospitalised.

That came as a surprise to me. It is exactly at times like this that the support my sister has been receiving is the most required.

Her support worker recognises the roles that needed to be completed to assist her living, the support worker has voluntarily spent significant time providing support for free.

There appears to be a mismatch between what recipients receive and are provided and what is required at times of crisis.

Concerns about due process in NDIS-funded care delivery