Inquiry into National

Disability Insurance Scheme Amendment (Integrity and Safeguarding) Bill 2025

Submission by

THE ASSOCIATION OF PROFESSIONALS AUSTRALIA

February 2026

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Introduction

Professionals Australia welcomes the opportunity to make a submission to the Joint Committee of Public Accounts and Audit Inquiry into the National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Bill 2025 (Parliament of Australia, 2026).

Professionals Australia represents allied health professionals and related practitioners across Australia, including Occupational Therapists, Speech Pathologists, Physiotherapists, Psychologists, Social Workers, Exercise Physiologists, Dietitians, Behaviour Support Practitioners, Music and Creative Therapists, Equine Therapists, Disability Support Coordinators, and Interpreters, including AUSLAN Interpreters. These professionals deliver therapeutic, behavioural, developmental, psychosocial, and capacity building supports funded through the NDIS, often to participants with complex needs, communication barriers, trauma histories, or limited access to mainstream services (National Disability Insurance Agency, 2023; Australian Institute of Health and Welfare, 2022).

Our members work predominantly as sole traders, small and medium practice owners, not-for-profit providers, and clinicians embedded within community-based services. They interact daily with NDIA planners, payment systems, compliance mechanisms, and safeguarding frameworks, and experience firsthand the practical consequences of administrative and regulatory decisions made under the Scheme (Australian Neurodivergent Parents Association, 2026; Sweeney, 2026).

This submission addresses how the expansion of integrity and safeguarding powers under the Bill, if implemented without adequate procedural safeguards, market stewardship, and participant-facing resourcing, risks undermining access to clinically necessary supports, continuity and quality of care, provider viability, workforce stability and retention, and ultimately the long-term sustainability of the Scheme (Australian National Audit Office, 2024; Australian National Audit Office, 2025a; Australian National Audit Office, 2025b; Australian National Audit Office, 2025c; Australian National Audit Office, 2025d; Australian National Audit Office, 2026).

This submission is informed by extensive member experience, analysis of Auditor-General reports identified by the Committee, and issues raised in other submissions to this and related inquiries, including those of Sweeney (2026) and the Australian Neurodivergent Parents Association (2026). These submissions, grounded in lived experience and advocacy for children and families, raise serious and credible concerns about systemic administrative, legal, governance, and safeguarding risk. Professionals Australia submits that these voices should be amplified and treated as critical evidence in assessing the Bill’s likely real-world impact.

Integrity Reforms in the National Disability Insurance Scheme

The Bill introduces reforms aimed at enhancing integrity within the National Disability Insurance Scheme (NDIS), with key responsibilities shared between the NDIA and other entities such as the NDIS Quality and Safeguards Commission.

Key Elements of Reform

Public information accompanying the Bill indicates that key elements include stronger penalties for serious misconduct, broadened banning order powers, anti-promotion orders aimed at limiting predatory marketing, and measures to modernise claiming processes (including electronic claiming) to better prevent, detect, and disrupt fraudulent or inappropriate claims.

Notable Submissions

Notable submissions include those from People with Disability Australia and the Australian Federation of Disability Organisations, along with evidence raised in other submissions to parliamentary inquiries including Sweeney (2026) and the Australian Neurodivergent Parents Association (ANPA) (2026). These raise significant concerns about systemic administrative, legal, governance, and safeguarding risks.

Accordingly, Professionals Australia submits that the Committee’s scrutiny should focus not only on whether new powers exist but also on how these powers will be operationalised, what safeguards are present against overreach, and whether the Bill meaningfully distinguishes between exploitative conduct and legitimate professional judgment exercised in complex therapeutic contexts.

Integrity Reforms Must Not Undermine Access in Thin Markets and High-Need Cohorts

The NDIS continues to operate within thin markets, particularly affecting allied health services in regional and remote areas as well as cohorts requiring intensive support. This is supported by data indicating challenges faced across various sectors such as healthcare accessibility issues highlighted through studies conducted by organisations like the Productivity Commission among others.

Integrity reforms which increase administrative burdens could potentially lead providers away from participating where there’s already limited choice available for participants who might otherwise struggle due to long waiting periods or lack sufficient alternatives leading towards worse outcomes regarding both accessibilities provided alongside safety assurances ensured throughout service delivery processes involved here.

These market dynamics become even more pronounced when considering sole traders operating independently along with smaller scale practices providing essential care outside major urban centers; they typically don’t possess similar financial resilience nor robust infrastructural capabilities compared larger corporate entities do have at their disposal according to reports published recently showing trends observed nationwide concerning this matter specifically addressed now being considered under current legislative review phases taking place currently amongst relevant stakeholders engaged actively during discussions happening right now around these topics too.

Electronic Claiming Accessibility And Procedural Safeguards

Professionals Australia acknowledges stakeholder concerns that integrity measures tied directly into mandating electronic claiming methods may unintentionally exclude certain participant groups if not carefully managed appropriately while ensuring adequate procedural safeguards remain intact so everyone can benefit equitably without facing unnecessary barriers preventing them accessing necessary supports effectively whenever needed most critically within vulnerable populations identified earlier on whose needs require immediate attention given how sensitive situations often unfold unexpectedly sometimes requiring quick responses supported adequately through proper channels established beforehand ideally before any crisis occurs necessitating intervention later down the line after initial signs appear manifestly clear enough indicating potential problems arising ahead unless preemptive actions taken proactively instead reactive ones merely addressing symptoms rather than root causes underlying issues causing distress initially experienced by affected individuals concerned primarily about maintaining quality standards upheld consistently throughout all stages involved here regardless of circumstances encountered anywhere anytime.

and providers with limited digital access, limited English proficiency, or disability-related barriers, unless robust accessibility and alternative pathways are built in (Australian Federation of Disability Organisations, 2026; People with Disability Australia, 2026; Department of Health and Aged Care, 2025).

AFDO has raised the need for plain-language, accessible forms and processes, and cautioned against settings that would increase barriers for self-managed participants or those who rely on informal supports to navigate NDIS systems (Australian Federation of Disability Organisations, 2026).

PWDA has similarly emphasised that integrity settings must be designed to protect participants from harm while preserving autonomy and access, particularly for self-managed and plan-managed participants who may be affected differently by compliance settings and evidentiary requirements (People with Disability Australia, 2026).

Professionals Australia submits that any expansion of evidentiary requirements and any move toward mandated electronic claiming should be paired with clear reviewable decision points, transparent reasons, and time-limited processes so that routine claims by compliant providers are not delayed or withheld in a way that destabilises service continuity (Australian National Audit Office, 2025; Commonwealth of Australia, 2013; People with Disability Australia, 2026).

The Bill proposes expanded investigatory, compliance, and enforcement powers for the NDIS Quality and Safeguards Commission, including enhanced civil penalties, banning orders, compliance notices, and broader information-gathering powers under Schedule 1, Part 1 (Regulatory Powers) and Part 2 (Civil Penalties and Offences) (Commonwealth of Australia, 2025).

From an allied health perspective, these measures can strengthen participant safety where they:

• Are applied proportionately and transparently, consistent with procedural fairness obligations in Schedule 1, Part 4 (Reviewable Decisions and Notice Requirements) (Disability Royal Commission, 2023);
• Distinguish between intentional misconduct, systemic failure, and clinical complexity, particularly in the application of banning orders and penalty provisions under Schedule 1, Part 2 (NDIS Review, 2023);
• Support quality improvement rather than solely punitive responses, consistent with the Commission’s stated regulatory approach (NDIS Quality and Safegards Commission, 2024).

However, there is a risk that overly broad or unclear use of enforcement powers under Schedule 1, Parts 1–2 may contribute to defensive practice, reduced disclosure of concerns, and workforce attrition, particularly in complex clinical environments (Australian Institute of Health and Welfare, 2024). Safeguarding is most effective when clinicians are supported to escalate risk without fear of disproportionate regulatory consequences.

2.4 Integrity and safeguarding powers, procedural fairness, and administrative law risk

Professionals Australia submits that several elements of the Bill raise material concerns regarding procedural fairness, proportionality, and lawful exercise of statutory power.

Expanded information-sharing powers, enhanced compliance tools, and broader discretion to intervene in provider operations increase the risk of decision-making that is automated, template- driven, or insufficiently individualised. Where discretion is exercised through system defaults, risk flags, or standardised correspondence rather than genuine consideration of evidence, the risk of unlawful decision-making is heightened (Amato v Commonwealth of Australia [2019] FCA 1133; Australian National Audit Office, 2025a).

Safeguarding is not strengthened by reducing procedural fairness. On the contrary, clear reasons, proportionate action, timely review mechanisms, and genuine engagement with evidence are essential to identifying real risk, correcting error early, and maintaining confidence in the Scheme.

3. Interaction with Individualised and Therapeutic Supports

A core strength of the NDIS is its commitment to individualised funding and supports under the NDIS Act 2013. Allied health interventions are inherently individualised, requiring clinical discretion to respond to functional capacity, environmental context, trauma history, cultural context, communication needs, and participant goals (NDIS Review, 2023).

In practice, allied health-led planning relies on narrative clinical reasoning, longitudinal assessment, and professional judgement that cannot be meaningfully reduced to population-level averages or standardised templates without loss of safety and effectiveness (Disability Royal Commission, 2023).

Safeguarding mechanisms that prioritise standardisation or population-level controls risk undermining this principle and may unintentionally reduce access to appropriate supports. Effective safeguarding must therefore be embedded within individualised planning, therapeutic goal-setting, supervision, and review processes, rather than imposed externally through blunt compliance tools (United Nations, 2006).

4. The Allied Health Workforce as a Core Safeguarding and

Integrity Mechanism

Allied health professionals are central to the integrity, safeguarding, and effective operation of the National Disability Insurance Scheme. The NDIS does not function without a skilled, stable, and ethically regulated allied health workforce capable of delivering individualised, evidence-based supports across diverse settings and participant cohorts. This includes, but is not limited to, occupational therapists, speech pathologists, physiotherapists, psychologists, social workers,

• exercise physiologists, behaviour support practitioners, dietitians, allied health assistants, music therapists, creative arts therapists, equine-assisted therapy practitioners, and disability support coordinators (Australian Institute of Health and Welfare, 2022; NDS Review, 2023).

These professionals do not merely deliver discrete services. They are embedded in the daily lives of participants and families and are often the first to identify emerging risk, deterioration, extploitation, neglect, or systemic failure. Through longitudinal engagement, allied health practitioners develop deep contextual knowledge of participants’ functional capacity, communication styles, trauma histories, family dynamics, and environmental risks. This positions them as critical safeguarding actors whose work aligns directly with the Bill’s stated objectives of preventing harm and strengthening integrity (Disability Royal Commission, 2023).

4.1 Allied health as an integrity safeguard, not a compliance risk

The Bill’s focus on integrity and safeguarding must recognise that allied health professionals are not a primary source of rorting or exploitation within the Scheme. Allied health practitioners are already subject to extensive professional regulation, including registration requirements (where applicable), codes of conduct, mandatory reporting obligations, clinical supervision standards, continuing professional development, and ethical accountability frameworks. These existing safeguards provide a strong foundation for integrity that differs materially from the risks associated with unregulated or exploitative provider models (NDIS Review, 2023; Disability Royal Commission, 2023).

Evidence before national inquiries indicates that most safeguarding failures arise not from allied health misconduct, but from system fragmentation, lack of continuity, poor information sharing, and market instability. Compliance-heavy regulatory approaches that treat allied health practice as a risk category rather than a safeguarding asset risk driving ethical practitioners out of the Scheme, reducing access to early intervention, and increasing reliance on crisis responses (Productivity Commission, 2011; World Health Organization, 2022).

4.2 The safeguarding role of diverse therapeutic modalities

Safeguarding under the NDIS requires recognition of the full range of therapeutic modalities that support participant safety, wellbeing, and participation.

4.2.1 Music Therapy and Creative Arts

Music therapists and creative arts therapists play a critical role in supporting children and adults with complex communication needs, trauma histories, and psychosocial disability. These practitioners often enable participants to communicate distress, regulate emotions, and engage safely in therapeutic relationships where traditional verbal therapies are ineffective or inaccessible. Their work can surface safeguarding concerns that would otherwise remain hidden, particularly for

Non-Verbal Communication Modalities

Case Study: Music Therapy Enabling Disclosure for a Non-Verbal Child

A registered music therapist working with a non-verbal child with complex disability identified behavioural changes during structured music sessions that indicated distress associated with a support environment. Through therapeutic engagement and collaboration with the family and multidisciplinary team, concerns were escalated and addressed before harm occurred. Traditional verbal therapies had not enabled the child to communicate distress. This case demonstrates the safeguarding value of specialised therapeutic modalities and the risk of harm if such services are excluded through rigid compliance or registration frameworks (Disability Royal Commission, 2023; World Health Organization, 2011).

Equine-Assisted Therapy

Equine-assisted therapy practitioners support participants with psychosocial disability, trauma, and neurodevelopmental differences through structured, relationship-based interventions that emphasise emotional regulation, trust, and embodied communication. For some participants, particularly those disengaged from clinic-based services, equine therapy provides a critical point of connection and early risk identification. Safeguarding frameworks that fail to accommodate such modalities risk excluding participants from effective supports and undermining safety outcomes (NDIS Review, 2023).

Case Study: Equine-Assisted Therapy and Engagement for a Disengaged Adolescent

An adolescent with trauma history and repeated disengagement from clinic-based services was able to re-engage through equine-assisted therapy delivered by a small, community-based provider. The therapeutic relationship enabled early identification of escalating self-harm risk and facilitated referral to appropriate clinical and safeguarding supports. The provider operated as a sole trader and relied on flexible service delivery and non-face-to-face coordination. This case highlights how safeguarding outcomes depend on access to diverse therapeutic models, particularly for participants who do not engage with standard service settings (NDIS Review, 2023).

Exercise Physiology

Exercise physiologists and physiotherapists contribute directly to safeguarding by addressing mobility, falls risk, chronic pain, and physical deconditioning, particularly for participants with degenerative conditions, ageing-related disability, or complex physical needs. Early intervention in these areas reduces hospitalisation, prevents secondary injury, and supports safe participation in daily activities, directly aligning with the Scheme’s preventative and sustainability objectives (Australian Institute of Health and Welfare, 2022; World Health Organization, 2022).

Case Study: Exercise Physiology Preventing Escalation to Acute Care

An exercise physiologist supporting an older participant with degenerative neurological disability identified rapid functional decline and increased falls risk during routine sessions. Early intervention and coordination with allied health and primary care prevented hospitalisation and supported safe participation at home. Administrative delays and uncertainty around claiming non-face-to-face coordination time would have undermined this preventative intervention. This case demonstrates how allied health practice contributes directly to safeguarding, cost containment, and participant safety when supported by flexible administrative settings (Australian Institute of Health and Welfare, 2022; World Health Organization, 2022).

4.2.4 Disability Coordinators

Disability support coordinators, while not always classified as allied health professionals, are integral to the allied health ecosystem and safeguarding architecture of the NDIS. They coordinate services, support informed decision-making, identify gaps and risks, and assist participants to escalate concerns or change providers. Support coordinators often act as the connective tissue between allied health providers, families, and safeguarding systems, and their role is especially critical for children, First Nations participants, CALD communities, and participants with complex needs (NDIS Review, 2023; Disability Royal Commission, 2023).

4.2.5 Dietitians and nutritional safeguarding

Dietitians play a critical and often under-recognised role in safeguarding NDIS participants from neglect, harm, and preventable health deterioration. Under the NDIS Practice Standards, including the core module relating to neglect and abuse and the supplementary modules relating to dysphagia and mealtime management, dietitians are uniquely qualified to identify, assess, and respond to risks that may not be visible through compliance-based oversight alone.

Dietitians are frequently the first professionals to detect unsafe feeding practices, including unauthorised restrictive practices, inappropriate texture modification, and failure to adhere to approved Mealtime Management Plans. These failures place participants at significant risk of choking, aspiration pneumonia, malnutrition, and avoidable hospitalisation. In many cases, dietitians identify that restrictive feeding practices are being implemented without authorisation, training, or clinical oversight, constituting a safeguarding concern under the NDIS Practice Standards.

Dietitians also play a critical role in identifying poor nutrition provision in disability accommodation services, including supported accommodation and group homes. Delegate evidence provided to Professionals Australia highlights repeated instances where inadequate food quality, insufficient meal frequency, inappropriate portion sizes, and nutritionally deficient menus have led to chronic health conditions, unintended weight loss, micronutrient deficiencies, and deterioration in

Safeguarding Functions of Dietitians

Participants’ physical and mental health. These issues often amount to neglect under the Practice Standards but may go undetected in the absence of regular dietetic review.

In addition, dietitians are often the first clinicians to identify swallowing difficulties requiring referral to Speech Pathologists. Early detection of dysphagia is a critical safeguarding function. Without timely referral and coordinated intervention, participants face heightened risks of choking, aspiration, respiratory infection, and death. Dietitians’ role in recognising red flags and escalating concerns is therefore central to both safeguarding and clinical integrity.

Dietitians are also uniquely positioned to identify food insecurity and poor food hygiene practices, particularly in private homes where participants with psychosocial disability and/or intellectual disability live independently. Delegates report frequent situations where participants lack reliable access to food, rely on nutritionally inadequate options due to poverty or executive functioning challenges, or are exposed to unsafe food storage and preparation practices. These conditions create cumulative harm that may not trigger immediate compliance responses but represent serious safeguarding failures over time.

A recurring theme in member feedback is the inadequate training of paid support staff in nutrition, feeding support, and mealtime safety. Dietitians routinely identify that support workers lack the knowledge required to implement Mealtime Management Plans safely, recognise signs of aspiration or malnutrition, or support participants with dignity and choice around food. Inadequate training places participants at ongoing risk of harm and undermines the effectiveness of safeguards that exist on paper but not in practice.

To fulfil these safeguarding functions, dietitians must be funded to provide supports in participants’ home environments, including private homes, supported accommodation, and other community settings. Many of the risks identified by dietitians cannot be detected through clinic-based appointments alone. Home-based assessment is essential to observe real-world feeding practices, food availability, hygiene standards, and staff behaviour. Integrity or compliance settings that discourage home visits, limit travel claiming, or restrict non-face-to-face coordination directly undermine safeguarding outcomes.

Dietitians delivering NDIS supports frequently operate as sole traders or within small practices, particularly in regional and outer-metropolitan areas. Payment delays, retrospective claim scrutiny, and uncertainty around claiming for home visits, report writing, and multidisciplinary coordination disproportionately affect dietitians and risk service withdrawal. In thin markets, the loss of even one dietitian can eliminate access entirely, escalating safeguarding risk and shifting costs to hospitals and emergency services.

Professionals Australia Submits That Dietitians Must Be Explicitly Recognised Within The Integrity And Safeguarding Framework As Frontline Safeguarding Professionals

Professionals Australia submits that dietitians must be explicitly recognised within the integrity and safeguarding framework as frontline safeguarding professionals, whose work directly engages the NDIS Practice Standards relating to neglect, dysphagia, and participant safety. Integrity reforms that destabilise dietetic services, fail to fund home-based assessment, or treat professional clinical judgement as a compliance risk will undermine participant safety and contradict the intent of the Bill.

Sole Traders And Small Practices As The Backbone Of Access And Safeguarding

A significant proportion of allied health services under the NDIS are delivered by sole traders and small-to-medium enterprises. These practitioners provide flexible, localised, and relationship-based services, particularly in regional, rural, and outer-metropolitan areas where large providers do not operate (Australian Institute of Health and Welfare, 2024).

Sole traders and small practices often deliver services that are highly responsive to participant needs, including home visits, school-based interventions, after-hours support, and culturally safe practice. They are also more likely to provide continuity of care over long periods, which is essential for safeguarding and early risk detection. However, these providers are particularly vulnerable to administrative burden, payment delays, and regulatory uncertainty introduced through integrity reforms (Australian National Audit Office, 2025).

Integrity and safeguarding measures that increase compliance complexity without proportionality risk collapsing these parts of the market, reducing access, and concentrating services in larger, less flexible providers. This outcome would be inconsistent with the Bill’s intent and with the Committee’s responsibility to assess the financial and operational sustainability of the Scheme.

Allied Health Workforce Stability As A Safeguarding Issue

Workforce stability is itself a safeguarding issue. High turnover, service withdrawal, and loss of experienced clinicians disrupt therapeutic relationships, delay intervention, and increase participant risk. The Disability Royal Commission found that continuity of trusted relationships is a key protective factor against abuse, neglect, and exploitation, particularly for children and people with complex needs (Disability Royal Commission, 2023).

Allied health professionals consistently report moral injury arising from being unable to deliver clinically necessary supports due to administrative constraints, pricing pressures, or compliance uncertainty. This moral injury drives workforce exit and reduces the Scheme’s capacity to deliver safe, effective supports. Integrity reforms that do not account for these dynamics risk increasing harm rather than preventing it (NDIS Review, 2023).

4.5 Relevance to the Committee’s terms of reference

The issues outlined above are directly relevant to the Committee’s consideration of the Bill, particularly in relation to:

• whether expanded integrity and safeguarding powers will improve participant safety in practice;
• whether the Bill adequately considers impacts on access, continuity of supports, and thin markets;
• whether regulatory approaches are proportionate and aligned with existing professional safeguards;
• whether implementation risks undermining the allied health workforce on which the Scheme depends.

Professionals Australia submits that safeguarding and integrity cannot be achieved through enforcement activity alone. They depend on a viable, diverse, and ethically regulated allied health workforce that is supported, not destabilised, by regulatory reform. The Bill must therefore be assessed not only on its enforcement intent, but on its capacity to sustain the professionals who make safeguarding real in participants’ daily lives.

5. Illustrating Safeguarding in Practice

5.1 Financial and workforce impacts of compliance actions in safeguarding contexts

Professionals Australia submits that safeguarding cannot be separated from provider viability and workforce stability. When payment holds, manual claim reviews, or extended compliance processes occur without timely resolution, the practical effect can be service withdrawal, clinic closure, and loss of experienced clinicians, which in turn increases participant risk (Australian National Audit Office, 2025; Disability Royal Commission, 2023; World Health Organization, 2022).

Members have reported that even in the absence of any finding of fraud or serious non- compliance, extended payment holds can rapidly destabilise small allied health practices that operate on narrow margins, including sole traders and small-to-medium enterprises that do not have reserve capital or external financing (Australian Institute of Health and Welfare, 2024; Australian National Audit Office, 2025).

In the disability services context, sudden loss of a trusted allied health provider can lead to care disruption, repeated assessment and onboarding costs, delayed intervention, and participant disengagement, all of which undermine safeguarding objectives and may increase downstream costs borne by families and other service systems (Disability Royal Commission, 2023; Productivity Commission, 2011; World Health Organization, 2022).

5.2 Travel and non-face-to-face work as safeguarding enablers, not optional extras

In many safeguarding-relevant circumstances, travel and non-face-to-face clinical work are necessary components of safe practice. This includes travel to undertake home-based risk assessments, school collaboration, workplace visits, and multidisciplinary meetings, as well as non- face-to-face time for safety planning, behaviour support documentation, mealtime management plans, manual handling plans and coordination with families and services (National Disability Insurance Agency, 2025; National Disability Insurance Agency, 2025).

NDIA guidance and pricing arrangements recognise travel and some non-face-to-face work, but providers report uncertainty and perceived compliance risk in claiming, particularly where retrospective scrutiny is applied inconsistently or without clear clinical appreciation of why the work was required (National Disability Insurance Agency, 2025; Australian National Audit Office, 2025).

Professionals Australia submits that integrity reforms should explicitly acknowledge that travel and non-face-to-face work are core safeguarding enablers for many participants, especially in thin markets, and that compliance processes should not deter clinically necessary activity through unclear or punitive application of claiming rules (National Disability Insurance Agency, 2025; Australian Institute of Health and Welfare, 2024; NDIS Review, 2023).

Case Study: Early Identification of Coercion

A speech pathologist supporting a young adult with intellectual disability observes increasing deference to a family member and heightened anxiety during goal-setting discussions. Using supported communication strategies, the clinician identifies coercive control affecting the participant’s decision-making. Consistent with safeguarding obligations, the clinician documents concern, seeks supervision, and escalates risks through appropriate channels while maintaining participant trust (NDIS Quality and Safeguards Commission, 2023; United Nations, 2006).

Case Study: Restrictive Practices and Behaviour Support

An occupational therapist identifies informal restrictive practices being implemented by untrained support workers for a participant with complex behaviour. Allied health-led behaviour support, combined with clear safeguarding escalation pathways, enables early intervention that prevents harm and reduces reliance on restrictive practices, consistent with national behaviour support frameworks (NDIS Quality and Safeguards Commission, 2023).

Case Study: Service Withdrawal and Participant Safety

A participant with psychosocial disability faces abrupt withdrawal of allied health services due to provider exit. Safeguarding mechanisms that mandate notice periods, transition planning, and continuity of care under Schedule 2 (Participant Protections and Continuity of Supports) prevent deterioration, hospitalisation, and increased system costs, aligning with recommendations of the

Identified risks to children and adults with a disability

Children under 9 years with neurodevelopmental disability are at particular risk of harm if the integrity and safeguarding measures in the Bill are not applied consistently during the transition of early childhood supports, including the Thriving Kids program, to States and Territories (Commonwealth of Australia, 2025; NDIS Review, 2023).

This cohort relies on timely, intensive, and individualised early intervention delivered by specialist allied health practitioners during critical developmental windows, where delays or disruption can have lifelong consequences (World Health Organization [WHO], 2022; Australian Institute of Health and Welfare [AIHW], 2023).

Fragmentation between Commonwealth NDIS safeguards and State and Territory based early childhood systems risks creating gaps in oversight, inconsistent safeguarding thresholds, and loss of continuity of care, particularly where responsibilities for monitoring provider conduct, responding to concerns, and ensuring continuity of supports under Schedule 2 (Participant Protections and Continuity of Supports) are not clearly aligned across jurisdictions (Disability Royal Commission, 2023; Commonwealth of Australia, 2025).

Further, without nationally consistent safeguarding standards, effective information-sharing mechanisms, and clear transition protections, there is a significant risk that early indicators of developmental regression, neglect, family and/or caregiver stress, or inappropriate practice are missed or inadequately escalated, resulting in long-term functional harm and increased downstream system costs (NDIS Review, 2023; WHO, 2022).

For children with neurodevelopmental disability, safeguarding failures in early childhood are not temporary; they can permanently undermine developmental trajectories, family capacity, and future participation, directly conflicting with the Bill’s stated intent to protect participants from harm during periods of system transition (United Nations, 2006; Disability Royal Commission, 2023).

Risks for First Nations children and families

These risks are significantly amplified for First Nations children and families, particularly those in rural, remote, and discrete communities. First Nations people experience higher disability prevalence and greater exposure to social determinants that compound functional need and safeguarding risk, including poverty, overcrowded housing, family violence, and limited access to mainstream services (AIHW, 2020; AIHW, 2025; Disability Royal Commission, 2023). In the NDIS context, these factors intersect with thin allied health markets, limited availability of culturally safe

Risks for Culturally and Linguistically Diverse (CALD)

services, and high travel burdens, which can delay assessment, reduce continuity of care, and increase reliance on short-term or fragmented supports (NDIS Review, 2023; Productivity Commission, 2011).

Inconsistent safeguarding arrangements, limited information sharing, and the absence of culturally safe escalation pathways risk undermining the National Agreement on Closing the Gap, including Priority Reform Two (Building the Community-Controlled Sector) and Priority Reform Three (Transforming Government Organisations) (Commonwealth of Australia, 2020). Where safeguarding approaches are implemented primarily through provider compliance tools and registration settings, without corresponding investment in participant-facing safeguarding functions and culturally safe engagement, families may disengage from services, leading to delayed intervention, unmet developmental needs, and cumulative harm (Disability Royal Commission, 2023; NDIS Review, 2023).

Professionals Australia submits that effective safeguarding for First Nations children requires nationally consistent settings that can operate in thin markets without collapsing local service availability, and that prioritise cultural safety, community governance, and sustained relationships. This includes co-designed safeguards with Aboriginal Community Controlled Organisations and First Nations disability organisations, culturally safe decision-making and review processes, and market stewardship settings that support continuity of allied health supports where travel and non-face-to-face coordination are essential to safe care (Commonwealth of Australia, 2020; NDIA, 2025a; ANAO, 2025a).

Case Study: First Nations Child and Continuity of Care

A First Nations child receiving allied health supports through a community-connected provider experienced disruption when administrative changes resulted in provider withdrawal. The loss of trusted relationships led to disengagement and delayed intervention. Re-engagement required significant time and coordination through culturally safe pathways. This case highlights the safeguarding importance of continuity, cultural safety, and market stewardship for First Nations children, particularly in thin markets (Commonwealth of Australia, 2020; Disability Royal Commission, 2023).

8. Risks for culturally and linguistically diverse (CALD) children and families

These risks are also significantly amplified for culturally and linguistically diverse (CALD) children and families. CALD communities face barriers to NDIS access and plan utilisation including language barriers, limited access to qualified interpreters, lower familiarity with Australian service systems, and reduced capacity to navigate complex administrative processes, particularly where families are managing disability-related care alongside insecure work, caring responsibilities, or trauma histories

Self-Managed and Plan-Managed Participants

Self-managed and plan-managed participants rely fundamentally on autonomy, flexibility, and informed choice to manage risk and exercise self-determination under the NDIS. These arrangements are intentionally designed to allow participants and families to select providers that best meet their needs, including sole traders, community-based services, culturally specific providers, and allied health practitioners who may not participate in formal registration systems but who are nevertheless professionally regulated and clinically accountable (Productivity Commission, 2011; Disability Royal Commission, 2023).

Support coordinators play a critical safeguarding role within self-managed and plan-managed arrangements. Far from being administrative intermediaries, support coordinators are often the primary mechanism through which participants identify risk, navigate complex service systems, coordinate multidisciplinary care, and respond early to concerns about service quality, provider conduct, or participant safety. This role is particularly important for participants with cognitive impairment, psychosocial disability, communication barriers, or complex family dynamics, where safeguarding depends on sustained relationships, trust, and contextual knowledge rather than compliance status alone (NDIS Review, 2023; Disability Royal Commission, 2023).

Support Coordinators as Early Warning Systems for Safeguards

Support coordinators frequently act as early warning systems for safeguarding risk. Through regular contact with participants and families, they are well placed to identify changes in behaviour, service gaps, coercion, neglect, or inappropriate practice that may not be visible through incident reporting or provider audits. They also support participants to escalate concerns, change providers, or engage complaints mechanisms in a way that preserves autonomy and minimises distress. These functions are inherently relational and cannot be replicated through registration or enforcement frameworks alone (NDIS Quality and Safeguards Commission, 2024).

Blanket mandatory registration requirements risk undermining these safeguarding functions by reducing the diversity and availability of providers that self-managed and plan-managed participants can engage. Many support coordinators, allied health sole traders, and small community-based providers operate outside formal registration due to cost, administrative burden, or the unsuitability of registration frameworks for their scope of practice, rather than because of safety or quality concerns. Removing these providers from the market would disproportionately affect participants who rely on flexible, culturally safe, or relationship-based supports, particularly in regional and remote areas and within First Nations and CALD communities (Productivity Commission, 2011; NDIS Review, 2023).

Evidence before the Disability Royal Commission demonstrated that safeguarding failures often arise not from the absence of registration, but from fragmented oversight, lack of continuity, poor information sharing, and insufficient participant-facing support. In this context, strengthening the role of support coordination, improving access to information, and ensuring participants can exercise informed choice are more effective safeguards than restricting provider choice through blunt regulatory tools (Disability Royal Commission, 2023).

Professionals Australia submits that a compliance-heavy approach that prioritises provider registration over participant-led risk management may inadvertently shift control away from participants and families toward system-level compliance mechanisms, without delivering commensurate improvements in safety. For self-managed and plan-managed participants, safeguarding is most effective when it supports transparency, informed decision-making, and rapid response to emerging risk, rather than limiting autonomy and flexibility (United Nations, 2006; NDSI Review, 2023).

A risk-based approach that recognises the safeguarding role of support coordinators and allied health professionals, differentiates between professional clinical practice and exploitative conduct, and preserves participant choice is therefore essential. Without this, there is a significant risk that integrity reforms will reduce access, destabilise trusted support relationships, and ultimately undermine the very safeguarding outcomes the Bill seeks to achieve.

Case study: Self-managed participant support

A support coordinator working with a self-managed participant with psychosocial disability observed a pattern of increasing service disengagement, missed appointments, and growing reliance on a single informal support person. Through regular contact and coordination with allied health providers, the support coordinator identified indicators of coercive control and financial exploitation that were not visible through incident reporting mechanisms or provider audits. Early intervention, including support to change providers and engage appropriate safeguards, prevented escalation and preserved the participant’s autonomy. This case illustrates how safeguarding in self- managed arrangements relies on relational oversight and contextual knowledge, rather than provider registration status alone (NDIS Review, 2023; Disability Royal Commission, 2023).

Translators, interpreters, and AUSLAN access as safeguarding issues

Professionals Australia supports the regulation of translators and interpreters as a core integrity and safeguarding function within the National Disability Insurance Scheme. Interpreters, including AUSLAN interpreters, perform a critical professional role in enabling informed consent, supporting participant autonomy, and ensuring that people with disability can safely communicate concerns about quality, risk, and harm (Disability Royal Commission, 2023; United Nations, 2006).

For Deaf participants who use AUSLAN and for participants from culturally and linguistically diverse (CALD) backgrounds, access to qualified interpreters is a prerequisite for meaningful participation in NDIS planning, plan review, complaints processes, incident reporting, and safeguarding responses. Where interpreter access is unavailable, delayed, or substituted with informal arrangements, participants may be unable to understand decisions affecting their supports, challenge unsafe practice, or disclose harm in a timely and culturally safe manner, significantly increasing safeguarding risk (NDIS Review, 2023; Disability Royal Commission, 2023).

Professionals Australia recognises that interpreters are already subject to professional accreditation, ethical standards, and quality controls through the National Accreditation Authority for Translators and Interpreters (NAATI). These frameworks are a critical integrity safeguard and distinguish professional interpreting services from unregulated or informal communication supports that may compromise accuracy, confidentiality, and participant safety (NAATI, 2023).

However, evidence consistently demonstrates that the interpreter workforce, including AUSLAN interpreters, is experiencing acute instability driven by insecure work arrangements, low and inconsistent pay, short-notice bookings, unpaid cancellations, high travel demands, and delayed or uncertain payment. Workforce shortages are now a material risk to safeguarding across health, disability, justice, and social services, including the NDIS (NAATI, 2023; Australian Broadcasting Corporation, 2024; Disability Royal Commission, 2023).

Reform Proposal: A Language Services Workforce Code

Professionals Australia submits that integrity and safeguarding reforms under the Bill must not exacerbate these workforce pressures. Regulatory expansion that increases administrative friction, delays payment, or introduces uncertainty for interpreters risks further destabilising an already fragile market, reducing interpreter availability, and undermining safeguarding outcomes for Deaf and CALD participants. In thin markets, particularly regional and remote areas, loss of even a small number of qualified interpreters can eliminate safe access altogether, forcing reliance on informal or inappropriate alternatives (NDIS Review, 2023; Productivity Commission, 2011).

Reform Proposal: A Language Services Workforce Code

Professionals Australia proposes the establishment of a Language Services Workforce Code as a complementary integrity and safeguarding measure. The Code would operate as a legally enforceable, co-regulatory framework designed to stabilise the interpreter workforce, protect professional standards, and guarantee safe, high-quality language services for NDIS participants.

The need for reform is well established. Translators and interpreters currently face insecure, low-paid, short-notice work with minimal protections, despite operating in high-risk environments that require accuracy, neutrality, confidentiality, and trauma-informed practice. Workforce instability is directly linked to sub-optimal interpreting outcomes, creating risks for people with disability, families, and service systems (Disability Royal Commission, 2023). Deloitte Access Economics (2025) has confirmed that the current market is unsustainable and warned of escalating system-wide risk without government intervention.

Traditional industrial mechanisms such as awards or enterprise bargaining are insufficient to address these issues, as interpreters are engaged across multiple Language Service Providers (LSPs), often as contractors, leaving them outside conventional sector-wide bargaining structures. Procurement-based regulation is therefore essential.

The proposed framework comprises three integrated elements:

• Language Service Provider (LSP) Endorsement, building on NAATI’s existing endorsement model, would require all government-contracted LSPs, including those delivering NDIS-funded interpreting services, to comply with the Workforce Code as a condition of procurement. This would establish a level playing field and prevent undercutting and phoenixing behaviour that currently undermines workforce stability and quality.
• Language Services Workforce Code would establish enforceable minimum standards across the sector, including minimum pay rates indexed by credential level, minimum booking periods, penalty rates, travel allowances, cancellation protections, paid professional development, support for NAATI certification and recertification, insurance coverage, and workplace health and safety protections including trauma debriefing and access to support services. Compliance would be overseen by a Code Compliance Panel comprising Professionals Australia and relevant professional associations, with powers to investigate breaches and require remediation.

• A Professionally Endorsed Translator and Interpreter status would create a clear professional benchmark for interpreters who meet enhanced standards, including current NAATI credentials, additional professional development, ethics training, probity checks, and insurance. This designation would support quality assurance, strengthen safeguarding, and address the ongoing deprofessionalisation of the workforce.

10.2 Relevance to the Bill

Professionals Australia submits that this reform proposal aligns directly with the objectives of the National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Bill 2025. Effective safeguarding is not achieved solely through expanded enforcement powers. It requires stable, regulated, and professionally supported workforces capable of delivering safe communication, informed consent, and early identification of risk.

A compliance-heavy approach that treats interpreters as a cost or administrative risk, rather than as regulated safeguarding professionals, would undermine both integrity and participant safety. By contrast, a workforce-based integrity model strengthens quality, reduces downstream risk, and ensures that Deaf and CALD participants can exercise their rights on an equal basis with others, consistent with Australia’s obligations under the Convention on the Rights of Persons with Disabilities (United Nations, 2006).

Case Study: Interpreter Access as a Safeguarding Requirement

A CALD family attending an NDIS plan review without access to a qualified interpreter was unable to fully understand proposed changes to supports, including reductions affecting behaviour support. Subsequent disengagement delayed intervention and increased family stress. When interpreter access was restored, concerns were raised and addressed. This case demonstrates that interpreter availability is a safeguarding prerequisite, not an administrative convenience, and that integrity settings must support, rather than constrain, interpreter access (NDIS Review, 2023; United Nations, 2006).

 11.  Risks of a compliance-heavy regulatory model

There are significant risks to people with disability if the expanded powers conferred by the Bill are implemented within a regulatory model that is resourced predominantly for provider compliance activity rather than participant safeguarding. Evidence from national inquiries and regulatory reviews indicates that compliance-driven approaches tend to prioritise registration status, documentation, and procedural adherence, which may fail to detect relational, cumulative, or situational harms experienced by participants, particularly those who are socially isolated, non- verbal, or reliant on informal or unregistered supports (Disability Royal Commission, 2023; NDIS Review, 2023).

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Differentiated Pricing and Perverse Incentives

Risks of Poorly Designed Differentiated Pricing Models

Professionals Australia acknowledges ongoing policy discussions regarding differentiated pricing models within the NDIS, particularly proposals to vary prices according to participant complexity. While the intent of such models is often to better reflect clinical effort and resource intensity, delegate feedback provided to Professionals Australia raises significant concerns about unintended and harmful consequences if differentiated pricing is poorly designed or implemented.

A central risk is that price differentiation may create perverse incentives that distort service provision rather than improving equity or access. If higher prices are attached to participants assessed as more complex, providers may be financially incentivised to preferentially seek out higher-priced participants, regardless of whether they possess the clinical skills, experience, or infrastructure required to deliver safe and effective care. This creates safeguarding risks for high-

Differentiated Pricing Models in Allied Health Services

need participants, who may receive services from inadequately skilled providers motivated primarily by pricing signals rather than competence.

Conversely, differentiated pricing models that introduce lower prices for participants assessed as having lower needs risk reducing access for those cohorts altogether. Delegate feedback highlights that there have previously been policy discussions about setting prices below current levels for participants with lower assessed complexity. Such an approach would likely make service delivery financially unviable for these participants, particularly where fixed costs, travel time, non-face-to-face work, and compliance obligations remain unchanged. The result would be service withdrawal, longer waitlists, and unmet need for people who may still require skilled allied health intervention to prevent deterioration.

This creates a dual risk:

• people with higher needs may be serviced by providers without appropriate skills, drawn by higher prices; and
• people with lower or moderate needs may struggle to access any services at all, as providers exit that segment of the market.

Both outcomes undermine safeguarding, workforce integrity, and the principles of the NDIS Act.

Professionals Australia submits that the lowest price point in any differentiated pricing model must, at a minimum, be aligned with current pricing levels, which already reflect constrained margins for allied health providers. Any differentiation should operate upward only, recognising additional complexity, risk, and professional input, rather than downward in a way that destabilises baseline service provision.

Further, pricing signals alone cannot be relied upon to ensure appropriate matching between participant need and provider capability. Without parallel safeguards, including clear scope-of-practice guidance, skill and credential recognition, and active market stewardship, differentiated pricing risks encouraging providers to operate beyond their competence, increasing the likelihood of harm and regulatory intervention.

Delegate feedback strongly indicates that pricing reform must be accompanied by safeguards that prioritise clinical competence, ethical practice, and continuity of care, rather than creating a quasi-market where participant access is shaped by financial incentives rather than need.

Professionals Australia therefore cautions against any differentiated pricing framework that:

• reduces prices below current levels for participants assessed as having lower needs,
• relies on pricing alone to signal complexity without clinical governance safeguards, or
• creates incentives for providers to service populations beyond their skills.

Properly Designed Pricing Reform

Properly designed pricing reform must support workforce sustainability across the full spectrum of need, ensure safe matching of providers to participants, and avoid shifting risk onto participants through market knowing or unintended exclusion.

Recommendations

Professionals Australia recommends that the Committee, and the Parliament, consider amendments and implementation safeguards to ensure that integrity and safeguarding reforms improve safety outcomes without collapsing provider markets or undermining lawful, individualised supports. In particular, Professionals Australia recommends that:

• Participant-facing safeguarding resourcing be embedded as a core implementation requirement, including strengthened complaints pathways, outreach to self-managed participants, proactive monitoring in thin markets, and timely, trauma-informed support for families navigating safeguarding concerns, rather than relying predominantly on post-hoc compliance enforcement (NDIS Quality and Safeguards Commission, 2024; NDIS Review, 2023).
• Any expanded integrity and compliance powers be exercised subject to clear statutory thresholds, written reasons, and accessible internal review pathways, including enforceable time limits and proportionality requirements for payment holds, registration actions, banning orders, and provider interventions, to ensure lawful decision-making and reduce systemic risk (Amato v Commonwealth of Australia [2019] FCA 1133; Australian National Audit Office, 2025a).
• Reforms explicitly recognise and protect the role of allied health professionals as clinically regulated providers, including clear differentiation between evidence-based clinical practice and exploitative conduct, and avoid blunt compliance settings that penalise ethical practitioners, discourage early risk escalation, or reduce service availability in high-need cohorts (Disability Royal Commission, 2023; NDIS Review, 2023).
• Ensure that any differentiated pricing model sets the minimum price at or above current pricing levels, applies upward adjustment only for additional complexity, and is accompanied by safeguards to prevent perverse incentives, inappropriate service provision, and exclusion of participants with lower or moderate needs.
• Access and autonomy for self-managed and plan-managed participants be protected by a genuinely risk-based approach that supports informed choice, transparent information, and targeted intervention where harm or exploitation is evidenced, consistent with self-determination principles (NDIS Review, 2023; Productivity Commission, 2011).
• Specific safeguards for First Nations children and families be implemented, including co-designed and community-controlled escalation pathways, culturally safe decision-making and review processes, and market stewardship measures that support continuity of allied health and therapeutic services in regional and remote settings, consistent with the National Agreement on Closing the Gap (Commonwealth of Australia, 2020; NDIA, 2025a; AIHW, 2025).

Specific Safeguards for Culturally and Linguistically Diverse Children and Families

Recommendations

Recommendation 7:

Specific safeguards for culturally and linguistically diverse (CALD) children and families be implemented, including guaranteed access to qualified interpreters across planning, review, safeguarding, complaints, and incident response processes, and explicit recognition that interpreter access is a safeguarding prerequisite rather than an optional administrative support (NDIA, 2024a; NDIS Quality and Safeguards Commission, 2025).

Recommendation 8:

Interpreting and translation services, including AUSLAN interpreting, be formally recognised as regulated safeguarding functions, with integrity settings that support timely payment, clear claiming rules, recognition of travel and non-face-to-face work, and active market stewardship to maintain interpreter availability, rather than administrative settings that further destabilise already thin interpreting markets (NAATI, 2023; Disability RoyalCommission, 2023; United Nations, 2006).

Recommendation 9:

A procurement-based workforce integrity approach be adopted for language services, requiring government-contracted Language Service Providers to comply with enforceable workforce standards as a condition of contract, to prevent undercutting, phoenixing, and workforce erosion that directly undermine participant safety and access.

Recommendation 10:

Information-sharing powers be strengthened in a manner consistent with privacy, procedural fairness, and cultural safety, including clear governance arrangements, auditability of information flows, limits on automated risk-flagging, and accessible mechanisms for participants and providers to correct, challenge, and review inaccurate or harmful records (Australian National Audit Office, 2025b; NDIS Review, 2023).

Recommendation 11:

Data governance and transparency be improved by requiring the NDIA and the NDIS Quality and Safeguards Commission to publish meaningful safeguarding and integrity performance indicators, including time to resolve complaints, incident response timeliness, outcomes for children, continuity of supports, provider exit rates, interpreter access, and market thinness impacts (Australian National Audit Office, 2024; Australian National Audit Office, 2025c).

Recommendation 12:

Safeguards against automated or template-driven decision-making be maintained and strengthened, including requirements for genuine consideration of evidence, transparency around risk-scoring and data-matching tools, and the availability of effective, timely independent review, to reduce systemic legal, financial, and human harm (Amato v Commonwealth of Australia [2019] FCA 1133; Australian National Audit Office, 2025a; Sweeney, 2026; Australian Neurodivergent Parents Association, 2026).

Recommendation 13:

Market stewardship be treated as a core safeguarding function, with early warning systems and intervention mechanisms to prevent unplanned provider withdrawal, particularly in allied health, interpreting, and therapeutic services where workforce collapse would directly increase participant risk (NDIS Review, 2023; Productivity Commission, 2011).

Conclusion

Recommendation 14:

The implementation of the Bill be explicitly assessed against Australia’s obligations under the Convention on the Rights of Persons with Disabilities, ensuring that integrity and safeguarding mechanisms are accessible, proportionate, culturally appropriate, and responsive to lived experience, rather than focused solely on procedural compliance (United Nations, 2006).

Professionals Australia

Professionals Australia supports robust safeguarding and integrity settings that protect people with disability, particularly children, from harm. However, safeguarding will not be strengthened by expanding compliance powers without adequate participant-facing functions, procedural fairness safeguards, and market stewardship that protects access to clinically necessary supports.

Allied health professionals are indispensable to delivering safe, individualised, evidence-based supports under the NDIS. The Scheme’s capacity to prevent harm and to respond early to risk depends on a viable, ethically regulated workforce that can provide continuity, supervision, collaboration, and culturally safe practice. Reforms that destabilise allied health and interpreting markets, or that treat professional clinical practice as a compliance problem, will undermine safeguarding outcomes and increase downstream costs.

Professionals Australia urges the Committee to recommend amendments and implementation safeguards that embed proportionality, transparency, culturally safe practice, and genuine engagement with evidence. Professionals Australia welcomes the opportunity to assist further and to provide supplementary evidence from members, including sole traders and small-to-medium practices who deliver essential supports across Australia (NDIS Review, 2023; Disability Royal Commission, 2023).

References

Amato v Commonwealth of Australia. (2019). Federal Court of Australia [2019] FCA 1133. hhttps://www.judgments.fedcourt.gov.au

Australian Broadcasting Corporation. (2024). Auslan interpreter shortages raise concerns for Deaf Australians. ABC News. hhttps://www.abc.net.au

Australian Federation of Disability Organisations. (2026). Submission to the Senate Community Affairs Legislation Committee inquiry into the National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Bill 2025. Parliament of Australia. hhttps://www.aph.gov.au

Australian Institute of Health and Welfare. (2020). Australia’s children. AIHW. hhttps://www.aihw.gov.au

Australian Institute of Health and Welfare. (2022). People with disability in Australia. AIHW. hhttps://www.aihw.gov.au

Australian Institute of Health and Welfare

(AIHWA) (2023). Australia’s children: Developmental vulnerability and disability. AIHW. h[ttps://www.aihw.gov.au]

Australian Institute of Health and Welfare

(AIHWA) (2024). Disability support services: Workforce and access. AIHW. h[ttps://www.aihw.gov.au]

Australian Institute of Health and Welfare

(AIHWA) (2025). Aboriginal and Torres Strait Islander people with disability. AIHW. h[ttps://www.aihw.gov.au]

Australian National Audit Office

(ANAO) (2024). Audits of the financial statements of Australian Government entities for the period ended 30 June 2024 (Auditor-General Report No. 22 2024–25). Commonwealth of Australia. h[ttps://www.anao.gov.au]

Australian National Audit Office

(ANAO) (2025a). National Disability Insurance Agency’s management of claimant compliance with National Disability Insurance Scheme claim requirements (Auditor-General Report No. 48 2024–25). Commonwealth of Australia. h[ttps://www.anao.gov.au]

Australian National Audit Office

(ANAO) (2025b). Interim report on key financial controls of major entities (Auditor-General Report No. 39 2024–25). Commonwealth of Australia. h[ttps://www.anao.gov.au]

Australian National Audit Office

(ANAO) (2025c). Performance statements auditing in the Commonwealth: Outcomes from the 2023–24 audit program (Auditor-General Report No. 25 2024–25). Commonwealth of Australia. h[ttps://www.anao.gov.au]

Australian National Audit Office

(ANAO) (2026). Effectiveness of the NDIS Quality and Safeguards Commission’s regulatory functions (Auditor-General Report No. 2 2025–26). Commonwealth of Australia. h[ttps://www.anao.gov.au]

Australian Neurodivergent Parents Association

(ANPAA) (2026). Submission to the Joint Committee of Public Accounts and Audit inquiry into the administration of the National Disability Insurance Scheme. Parliament of Australia. h[ttps://www.aph.gov.au]

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(COA) (2013). National Disability Insurance Scheme Act 2013 (Cth). h[ttps://www.legislation.gov.au]

Address: 152 Miller St, West Melbourne VIC 3003 | Phone: 1300 273 762 | Email: info@ProfessionalsAustralia.org.au

Commonwealth of Australia

(2020). National Agreement on Closing the Gap. https://www.closingthegap.gov.au

Commonwealth of Australia

(2025). National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Bill 2025. https://www.legislation.gov.au

Department of Health and Aged Care

(2025). National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Bill 2025: Consultation and information materials. Commonwealth of Australia. https://www.health.gov.au

Deloitte Access Economics

(2025). Sustainability of the language services workforce in Australia. Deloitte. https://www2.deloitte.com

National Accreditation Authority for Translators and Interpreters

(2023). Annual report 2022–23. NAATI. https://www.naati.com.au

National Disability Insurance Agency

(2023). NDIS pricing arrangements and price limits. NDIA. https://www.ndis.gov.au

National Disability Insurance Agency

(2024a). NDIS Cultural and Linguistic Diversity (CALD) Strategy and Action Plan 2024–2028. NDIA. https://www.ndis.gov.au

####### National Disability Insurance Agency (2025). NDIS First Nations Strategy 2025–2030. NDIA. https://www.ndis.gov.au

######## National Disability Insurance Scheme Quality and Safeguards Commission (2023–2024). Annual report. Commonwealth of Australia. https://www.ndiscommission.gov.au

######### National Disability Insurance Scheme Quality and Safegards Commission (2024). Regulatory approach to protecting NDIS participants. Commonwealth of Australia. https://www.ndiscommission.gov.au

########## National Disability Insurance Scheme Quality and Safeguarding Commission (2025). Guidance on integrity and safeguarding reforms. Commonwealth of Australia. https://www.ndiscommission.gov.au

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National Disability Insurance Scheme Review

(2023). Working together to deliver the NDIS: Final report. Commonwealth of Australia. https://www.ndisreview.gov.au

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Productivity Commission. (2011). Disability care and support (Inquiry Report No. 54). Commonwealth of Australia. https://www.pc.gov.au

Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability. (2023). Final report. Commonwealth of Australia. https://disability.royalcommission.gov.au

Sweeney, M. (2026). Submission to the Joint Committee of Public Accounts and Audit inquiry into the administration of the National Disability Insurance Scheme. Parliament of Australia. https://www.aph.gov.au

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World Health Organization. (2022). Global report on health equity for persons with disabilities. WHO. https://www.who.int

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