To: Senate Community Affairs Legislation Committee

National Disability Insurance Scheme

From: Sisu Therapies Pty Ltd

Date: 06 Feb 2026

Subject: Submission in response to the National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Bill 2025

To whom it may concern,

On behalf of Sisu Therapies Pty Ltd, please accept the following submission in response to the National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Bill 2025 (the Bill).

About Sisu Therapies

Sisu Therapies is a multidisciplinary allied health practice, primarily comprising Occupational Therapists, providing integrated health and mental health services, including to participants of the National Disability Insurance Scheme (NDIS). This submission is provided from the perspective of an active NDIS provider, a small business operating within the Scheme, and advocates for NDIS participants and their families.

Sisu Therapies welcomes the opportunity to contribute to consultation on these important reforms and would welcome further engagement with government on the matters raised in this submission.

Kind regards,

Hannah Bridges Senior Mental Health Occupational Therapist and Clinical Director Sisu Therapies Pty Ltd www.sisutherapies.com.au Phone: Email: Address: 4B Post Office Plaza, 20 Main Street, Beenleigh QLD 4207

Schedule 1 – Strengthening Safeguards and Regulatory Powers

Sisu Therapies broadly supports the objectives of Schedule 1 of the Bill, which seeks to strengthen safeguards for NDIS participants through enhanced regulatory and enforcement powers of the NDIS Quality and Safeguards Commission. Measures that deter serious or systemic misconduct, reinforce accountability, and uphold public confidence in the Scheme are essential to participant safety and the integrity of the NDIS.

Sisu Therapies supports reforms that give effect to recommendations of the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, including stronger responses to conduct that undermines participant safety, dignity, and rights. Effective enforcement mechanisms play a critical role in ensuring that the NDIS operates as a rights-based, participant-centred system.

At the same time, Sisu Therapies urges caution in the introduction and implementation of blanket compliance and enforcement measures across all provider types. Allied health practitioners, including Occupational Therapists and other AHPRA-registered professionals, are already subject to extensive professional regulation, registration standards, ethical obligations, and disciplinary oversight through existing national regulatory frameworks. Additional regulatory requirements that duplicate or overlap with these safeguards risk imposing disproportionate compliance burdens on allied health providers without commensurate improvements in participant safety.

This risk is particularly acute for sole practitioners and small allied health businesses, many of whom already experience significant administrative and regulatory pressure within the NDIS. As has been highlighted in previous NDIS reviews and sector consultations, excessive compliance burden can contribute to workforce attrition, service withdrawal, and reduced access to essential supports for participants. Given the documented closure of small, allied health practices in recent years, Sisu Therapies emphasises the importance of proportionate enforcement, clear regulatory guidance, and staged implementation of Schedule 1 reforms.

Sisu Therapies further notes that existing professional regulation under AHPRA has successfully supported safe and effective service delivery in other publicly funded systems, including Medicare. Alignment between NDIS regulatory approaches and established health professional regulation will help ensure safeguards are strengthened without creating unnecessary duplication or unintended harm to service availability.

Schedule 2 – NDIA Processes and Participant Safeguards

Electronic Claim Forms and Submission of Payment Claims

Sisu Therapies supports, in principle, the modernisation of NDIS claims processes through the introduction of published forms and electronic claims systems. Reforms that improve clarity, reduce administrative burden, and support timely and accurate payment are beneficial to participants, providers, and Scheme sustainability.

Improved claims systems have the potential to better support participants, particularly those who are self-managed or supported by informal carers, to navigate the Scheme safely and effectively. Similarly, systems that reduce administrative complexity for providers contribute to workforce retention and continuity of care, both of which are essential to participant wellbeing.

However, Sisu Therapies emphasises that successful implementation of these reforms will depend on practical and inclusive design. This includes meaningful consultation with providers and participants, accessible guidance and training, and systems that are genuinely easy to use. Without these supports, there is a risk that electronic claims requirements may inadvertently increase administrative burden, particularly for small, regional, or less digitally resourced providers.

Sisu Therapies also encourages the NDIA to consider additional practical measures to improve claims accuracy and efficiency, including clearer labelling and definitions of NDIS support items and plain-language explanations of funding types for participants and providers. Current complexity in plan structures and funding categories places unnecessary strain on participants and families and contributes to avoidable errors in claims processing.

Supporting Information Requirements and Risk of Service Disruption

Sisu Therapies is concerned about the potential implications of provisions requiring supporting information to be provided before payment is released. Greater clarity is needed regarding what constitutes appropriate “supporting information”, the limits of information that may be requested, and safeguards to protect sensitive clinical and therapeutic records.

From an allied health perspective, there is a risk that requests for detailed clinical notes or sensitive health information may compromise participant confidentiality and impose significant administrative burden on providers. Further, delays or non-payment of claims while information requests are resolved may threaten business viability and, critically, risk interruption to services that are essential to participant safety, health, and quality of life.

Given the documented pressures on small providers within the NDIS, Sisu Therapies urges that these provisions be implemented with clear boundaries, transparent processes, and safeguards to ensure continuity of supports for participants.

Plan Variations, Review, and Appeal Rights (Sections 47, 47A, and 48)

Sisu Therapies is particularly concerned about amendments relating to plan variations and reassessments under sections 47, 47A, and 48 of the NDIS Act. Decisions to vary a participant’s plan, including decisions that may increase or decrease total funding, can have profound impacts on participant health, safety, wellbeing, and family stability.

The capacity for plan variations to occur without a full reassessment or new Support Needs Assessment creates a risk of unintended harm if robust procedural safeguards are not embedded in the primary legislation. Reductions in supports may affect participants’ ability to meet basic needs, maintain safety, and participate meaningfully in daily life. These risks are compounded where appeal avenues are limited, delayed, or ineffective in practice.

An effective and fair NDIS requires that participants have access to timely, meaningful review and appeal mechanisms. Public reporting has highlighted that significant expenditure has been incurred by the NDIA in defending appeals, with a high proportion of matters ultimately resolved in favour of participants. This suggests that many contested decisions may not be well-founded and that earlier, more transparent decision-making and appeal rights could reduce both harm to participants and systemic costs.

Embedding clear rights to procedural fairness, review, and appeal in the primary legislation would provide certainty, protect participant trust, and ensure alignment with fundamental principles of administrative law. It would also support Australia’s obligations under the United Nations Convention on the Rights of Persons with Disabilities, including the right to access justice and effective remedies.

Sisu Therapies strongly supports the minimum safeguards outlined in the submission of the Occupational Therapy Society for Hidden and Invisible Disability (OTSi), including:

time-critical pathways for urgent circumstances where participant health, safety, or wellbeing is at risk;
a genuine right for participants to submit participant-led evidence, including clinical and functional evidence from treating professionals;
transparency and procedural clarity, including defined processes, timeframes, and written reasons for decisions; and
effective tribunal safeguards that enable meaningful scrutiny of decisions, rather than deferral to internal tools, scores, or automated processes.

Sisu Therapies supports OTsi’s recommendation that sections 47 and 48 of the NDIS Act be amended to expressly enshrine all participants’ rights to procedural fairness, review, and appeal in relation to plan variations and reassessments. Any decision made under sections 47, 47A, or 48 that materially affects a participant’s supports or funding should be a reviewable decision, supported by written reasons and the ability to provide participant-led evidence, including evidence from treating health professionals. These legislative safeguards should be complemented by rules that provide urgent pathways where required and ensure effective access to independent tribunal oversight.

Conclusion

This submission is limited to matters arising directly from the National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Bill 2025. Sisu Therapies acknowledges that other significant reforms to the NDIS framework, including changes relating to Support Needs Assessments, Thriving Kids reforms, and pricing reviews, are not addressed in this submission due to the scope of the current inquiry. These matters will be addressed separately as part of future consultations.

Across all reforms, Sisu Therapies emphasises the importance of meaningful consultation, transparency, workforce sustainability, and the safety and rights of NDIS participants. When effective, the NDIS provides people with disability not only with essential supports but with the opportunity to thrive and participate fully in community life. At the centre of all legislative and policy decisions must be the rights, dignity, and safety of people with disability, informed by the findings of the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability.

An effective and sustainable NDIS must balance participant protections, provider viability, and long-term Scheme sustainability. The comments and recommendations in this submission are offered in that spirit, and Sisu Therapies looks forward to continuing to engage constructively in future NDIS consultations and reform processes.