National Aboriginal Community
Controlled Health Organisation
Vv
National Disability
Insurance Scheme
Amendment (Integrity
and Safeguarding) Bill
2025
Submission to the Community Affairs
Legislation Committee
February 2026
About NACCHO
NACCHO is the national peak body representing 149 Aboriginal Community Controlled Health Organisations (ACCHOs). We also assist a number of other community-controlled organisations.
The first Aboriginal medical service was established at Redfern in 1971 as a response to the urgent need to provide decent, accessible health services for the largely medically uninsured Aboriginal population of Redfern. The mainstream was not working. So it was, that over fifty years ago, Aboriginal people took control and designed and delivered their own model of health care. Similar Aboriginal medical services quickly sprung up around the country. In 1974, a national representative body was formed to represent these Aboriginal medical services at the national level. This has grown into what NACCHO is today. All this predated Medibank in 1975.
NACCHO liaises with its membership, and the eight state/territory affiliates, governments, and other organisations on Aboriginal and Torres Strait Islander health and wellbeing policy and planning issues and advocacy relating to health service delivery, health information, research, public health, health financing and health programs.
ACCHOs range from large multi-functional services employing several medical practitioners and providing a wide range of services, to small services which rely on Aboriginal health practitioners and/or nurses to provide the bulk of primary health care services. Our 149 members provide services from about 550 clinics. Our sector provides over 3.1 million episodes of care per year for over 410,000 people across Australia, which includes about one million episodes of care in very remote regions.
ACCHOs contribute to improving Aboriginal and Torres Strait Islander health and wellbeing through the provision of comprehensive primary health care, and by integrating and coordinating care and services. Many provide home and site visits; medical, public health and health promotion services; allied health; nursing services; assistance with making appointments and transport; help accessing childcare or dealing with the justice system; drug and alcohol services; and help with income support. Our services build ongoing relationships to give continuity of care so that chronic conditions are managed, and preventative health care is targeted. Through local engagement and a proven service delivery model, our clients ‘stick’. Clearly, the cultural safety in which we provide our services is a key factor of our success.
ACCHOs are also closing the employment gap. Collectively, we employ about 7,000 staff — 54 per cent of whom are Aboriginal or Torres Strait Islanders — which makes us the third largest employer of Aboriginal or Torres Strait people in the country.
Enquiries about this submission should be directed to:
NACCHO
Level 5, 2 Constitution Avenue
Canberra City ACT 2601
Telephone: Email:
Website: naccho.org.au
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Recommendations
NACCHO recommends:
1 any interventions to address integrity and safeguarding in the NDIS align with the National Agreement and its four Priority Reform Areas.
2 acoordinated, whole of government approach to improving access to disability care and supports for Aboriginal and Torres Strait Islander people.
3 Government adopts a ‘heath in all policies’ approach, recognising that health outcomes are influenced by a wide range of social, commercial, political, environmental and cultural determinants.
a. the definition of “unsafe supports or services” be expanded to include culturally unsafe supports and services,
b. that a function of the Commissioner is to ensure cultural safety is embedded in the delivery of the
NDIS,
c. mainstream service providers are held accountable through their funding agreements to demonstrate cultural capabilities required to deliver care in a culturally respectful and appropriate manner.
5 the Commission prioritises funding and support mechanisms for ACCHOs and ACCOs to become NDIS providers and deliver the NDIS services needed in their regions.
6 the Commission includes prioritising workforce development training and pathways for ACCHO and ACCO staff delivered through the existing network of ACCRTOs.
7 The Commission:
a. waives the requirement for ACCHOs and ACCOs to provide information in a period shorter than 14- days, and
b. allows ACCHOs and ACCOs a minimum of 14-days to provide information and documents to the Commissioner for registration purposes when required.
8 the Commission allows ACCHOs and ACCOs flexibility to submit claims in a variety of ways if required, not only via the my NDIS Provider Portal.
9 targeted engagement with the community-controlled sector to ensure Aboriginal and Torres Strait Islander disability needs and priorities are supported and implemented through department initiatives.
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Acknowledgements
NACCHO welcomes the opportunity to provide a submission to the Community Affairs Legislation Committee on the National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Bill 2025 (the Bill).
NACCHO supports the submissions to this consultation made by NACCHO Members and Affiliates.
National Agreement on Closing the Gap
Advocating for and securing the National Agreement on Closing the Gap was an historically significant act of Aboriginal and Torres Strait Islander self-determination. The National Agreement is evidence of a new era of engagement by and with Aboriginal and Torres Strait Islander people. It commits Australia to a new direction and is a pledge from all governments to fundamentally change the way they work with Aboriginal and Torres Strait Islander communities and organisations — to support self-determination and build the capacity of the community-control sector.
The reforms and targets outlined in the National Agreement seek to overcome the inequality experienced by Aboriginal and Torres Strait Islander people, and achieve life outcomes equal to all Australians. Governments at all levels have committed to the implementation of the National Agreement’s four Priority Reform Areas, which offer a roadmap to meaningfully impact structural drivers of poor health and social outcomes for Aboriginal and Torres Strait Islander people:
Priority Reform Area 1 — Formal partnerships and shared decision-making
This Priority Reform commits to building and strengthening structures that empower Aboriginal and Torres Strait Islander people to share decision-making authority with governments, and to accelerate policy making that centres Aboriginal and Torres Strait Islander voices.
Priority Reform Area 2 — Building the community-controlled sector
Recognising that community-controlled services achieve better outcomes, employ more Aboriginal and Torres Strait Islander people and are often preferred over mainstream services, this Priority Reform commits to building Aboriginal and Torres Strait Islander community-controlled sectors to deliver services to support Closing the Gap.
Priority Reform Area 3 — Transformation of mainstream institutions
This Priority Reform commits to systemic and structural transformation of government organisations to identify and eliminate racism, embed and practice cultural safety, deliver services in partnership with Aboriginal and Torres Strait Islander people, support truth telling about agencies’ history with Aboriginal and Torres Strait Islander people, and engage fully and transparently with Aboriginal and Torres Strait Islander people when programs are being changed.
Priority Reform Area 4 — Sharing data and information to support decision making
This Priority Reform commits to shared access to regional data and information to inform local-decision making and support achievement of the first three Priority Reforms. This Priority Reform supports principles of Indigenous Data Sovereignty.
Despite some progress, the need for fundamental systemic reform remains evident. In its first review of the National Agreement on Closing the Gap, the Productivity Commission found that governments are not adequately delivering on their commitments. Despite support for the Priority Reforms and some good practice, progress has been slow, uncoordinated, and piecemeal.
The Commission noted that to enable better outcomes, governments need to relinquish some control, share decision making and acknowledge that Aboriginal and Torres Strait Islander people know what is best for
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their communities. Aboriginal Community Controlled Organisations, must be treated as critical partners rather than passive funding recipients, and trusted to design, deliver and measure government services in ways that are culturally safe and meaningful for their communities.
‘Too many government agencies are implementing versions of shared decision-making that involve consulting with Aboriginal and Torres Strait Islander people on a pre-determined solution, rather than collaborating on the problem and co-designing a solution’!
This inquiry into the Bill provides the Department of Health, Disability and Ageing with an opportunity to ensure that legislation is in alignment with the National Agreement and the needs and aspirations of all Aboriginal and Torres Strait Islander people, especially those with a disability.
Nevertheless, it is disappointing that the Department who had led the National Agreement on Closing the Gap have not identified how the priority reforms will be integrated and how it will align with the Department’s Closing the Gap disability cross-cutting outcome,? and the Disability Sector Strengthening Plan.?
NACCHO recommends any interventions to address integrity and safeguarding in the NDIS align with the National Agreement and its four Priority Reform Areas.
Coordination within key national disability policy
Based on the NDIS Review’s final report in December 2023, National Cabinet agreed that “the Commonwealth would work with state and territory governments to implement legislative and other changes to return the NDIS to its original intent of supporting people with permanent and significant disability as part of the larger landscape of supports outside of the NDIS”.
The Department of Health, Disability and Ageing’s (DOHDA) work should therefore reflect whole-of-system solutions and better coordination between government departments and agencies at the federal, state, territory and local level.
Acoordinated approach within the Department, and between State and Territory governments is needed for improved efficiency. There have been several recent and upcoming government reviews — all within the last two months — into the NDIS and disability initiatives that intersect with the objectives of this review. These include, but are not limited to, the Parliamentary /nquiry into the Thriving Kids initiative, NDIA’s consultations on Building culturally safe services for First Nations participants and the 2025-26 Annual Pricing Review, and DoHDA’s Disability Safeguards Consultation, and a new Commonwealth individual disability advocacy reform.
Each of these consultations presents an opportunity to align national efforts and deliver coordinated, place based solutions that improve outcomes for Aboriginal and Torres Strait Islander people with disabilities.
In addition, the National Skills Agreement plays a critical role in strengthening health and wellbeing outcomes for Aboriginal and Torres Strait Islander people. The Agreement provides an important mechanism for Commonwealth and State collaboration to support seamless transitions between sectors, reduce
structural barriers, and ensure Aboriginal and Torres Strait Islander people with disabilities can
access culturally safe care and supports.
A holistic, whole-of-government approach that brings together multiple departments and agencies to address systemic barriers and expand access to culturally safe disability care and supports is needed. This includes
’ Productivity Commission, Review of the National Agreement on Closing the Gap, Study Report, Canberra, 7 Feb 2024 https://www._pc.qov.au/inquinies/completed/closing-the-gqap-review/report.
2 Department of Social Services. (2024, November 25). Disability cross-cutting outcome. Australian Government. https://www.dss.gov.au/closing-gap/disability-cross-cutting-outcome.
? National Indigenous Australians Agency, Disability. https://www_niaa gov au/2023-commonwealth-closing-gap-implementation plan/cross-cutting-areas/disability.
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embedding Aboriginal and Torres Strait Islander-led strategies across portfolios and ensuring that Aboriginal and Torres Strait Islander organisations and communities are active partners in policy design and implementation.
Acoordinated approach will enable governments to leverage existing investments, avoid duplication, and scale successful models—particularly those led by ACCOs and ACCHOs. It will also strengthen accountability and ensure that Closing the Gap targets are embedded across all relevant disability reforms.
NACCHO urges DoHDA to explicitly align with other policy work and across government agencies, ensuring that Aboriginal and Torres Strait Islander communities are central to program development.
NACCHO recommends a coordinated, whole of government approach to improving access to disability care and supports for Aboriginal and Torres Strait Islander people.
Health in all policies
A broad range of structural and social factors (social determinants) influence health outcomes for Aboriginal and Torres Strait Islander people. Entrenched cycles of poverty, exacerbated by poor education and employment outcomes and increased interaction with the justice system contribute significantly to poorer health outcomes for Aboriginal and Torres Strait Islander people.
The Australian Institute of Health and Welfare (AIHW) notes that the links between socioeconomic disadvantages such as poverty, social dysfunction and exclusion, stress, racism and poor health are well established.4 This is true across urban, regional and remote areas. The consequent disparity in health outcomes between Aboriginal and Torres Strait Islander people and other Australians remains significant — 34 per cent of the health gap between Aboriginal and Torres Strait Islander people and non-Indigenous Australians is attributable to social determinant factors.®
Consideration is therefore needed of the impact of all policy decisions on health outcomes for Aboriginal and Torres Strait Islander people. This allows scope to identify and address those issues around social disadvantage which contribute to higher rates of chronic health conditions such as diabetes, as well as preventable disease.
The World Health Organization defines Health in All Policies as “an approach to public policies across sectors that systematically takes into account the health implications of decisions, seeks synergies, and avoids harmful health impacts in order to improve population health and health equity.”®
A Health in All Policies approach would require consideration of the impact on health outcomes for Aboriginal and Torres Strait Islander people in all policy decisions. Such an approach aligns with the National Agreement on Closing the Gap. It also aligns with the ACCHO holistic model of care which considers factors that contribute to health and wellbeing as well as those that compound the likelihood and/or incidence of health conditions.
This is particularly important in the context of disability, where health outcomes are shaped by intersecting social, cultural, environmental, and systemic factors that extend beyond the health system alone.
- AIHW, 2.09 Index of disadvantage https://www.indigenoushpf.gov.au/measures/2-09-index-disadvantage ® Australian Institute of Health and Welfare. Determinants of health for Indigenous Australians 2022 [Available from: https://www.aihw.gov.au/reports/australias-health/social-determinants-and-indigenous-health.
® World Health Organization, What you need to know about Health in All Policies, WHO website, 2015
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‘… an approach that incorporates Health in All Policies is the only way to achieve the health-related goals governments are pursuing. Otherwise, health systems will remain locked in a never-ending struggle as they respond to the ill health that often arises from weaknesses in other sectors’.’
NACCHO recommends Government adopts a ‘heath in all policies’ approach, recognising that health outcomes are influenced by a wide range of social, commercial, political, environmental and cultural determinants.
Accountability within the NDIS
NACCHO agrees that there is a need to “address current concerns of safety” and “resolve existing structural issues that minimise the effectiveness of regulatory action to combat abuse, neglect and exploitation that continue to cause significant harm to participants in the NDIS”. Anumber of our member services have provided feedback on the challenges they have had with reporting incidents to the Commission. Often this has resulted in no consequences for the providers reported, and no feedback from the Commission on outcomes, it is clear that local level accountability is needed.
Some amendments, however, as they are currently drafted pose significant risks for ACCHOs and ACCOs, and the communities they support, who are already experiencing funding constraints, an overstretched workforce, and limited NDIS service access.
Prioritising cultural safety
The NDIA’s First Nations Strategy 2025-30, co-designed with Aboriginal and Torres Strait Islander community members, recognises that “the rights of First Nations people with disability cannot be separated from First Nations concepts of holistic physical, cultural, social, emotional, and spiritual health and wellbeing.”® This understanding extends beyond service delivery models to encompass ways of being, knowing, and doing, including culturally distinct understandings of disability that differ from Western, deficit based definitions.
Despite this recognition, the ongoing absence of culturally safe services — identified by the Disability Royal Commission as a “time-sensitive national crisis” — has left Aboriginal and Torres Strait Islander participants particularly vulnerable within the NDIS.° In this context, Aboriginal and Torres Strait Islander disability markets are often dominated or exploited by mainstream providers who reportedly negate, suppress, or ignore the cultural rights and lived realities of Aboriginal and Torres Strait Islander people with disability. ’° The consequences of these failures are reflected in persistent experiences of inequity, lack of safety, trauma, and disengagement from services, including instances of service refusal by participants. We have heard from the sector that some parents of children with diagnosed disability have chosen not to engage with the NDIS due to these shortcomings of service quality.
Evidence further indicates that inadequate safeguarding of cultural safety contributes to poorer health outcomes, lifelong harm, and, in some cases, preventable deaths within Aboriginal and Torres Strait Islander
7 Greer S_L., Falkenback M, Siciliani L, Mckee M, Wismar M, Figueras J. From Health in All Policies to Health for All Policies. Viewpoint, Vol 7, 8, E718-E720, August 2022, doi: https://doi.org/10_1016/S2468-266 7(22)001554
® NDIS (2025). First Nations Strategy | NDIS. [online] Ndis.gov.au. Available at: https:/Awww.ndis.gov.au/strategies/first-nations-strategy.
® Deloitte. (2023). Research report — Options to improve service availability and accessibility for First Nations people with disability. Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability.
https://disability royalcommission.gov.au/system/files/2023-09/Research%20Repornt%20 %200ptions%20to%20improve%20service% 20availability¥% 20and%20accessibility%20for%20First%20Nations%20people%20with%20
disability pdf *° Ibid.
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communities. ‘’ These outcomes underscore that cultural safety is not an optional or supplementary consideration, but a fundamental safeguard.
‘Cultural safety is about overcoming the power imbalances of places, people and policies that occur between the majority non-Indigenous position and the minority Aboriginal and Torres Strait Islander person so that there is no assault, challenge or denial of the Aboriginal and Torres Strait Islander person’s identity, of who they are and what they need. Cultural safety is met through actions from the majority position…’ ’2
Explicitly safeguarding cultural safety is central to protecting the rights of Aboriginal and Torres Strait Islander people with disability to be free from harm, abuse, and neglect, and to uphold their right not only to life, but to a life of quality, dignity, and self-determination. Embedding Aboriginal and Torres Strait Islander ways of knowing, being, and doing — across physical, cultural, social, emotional, and spiritual domains — must be integral to safeguarding frameworks if these foundational rights are to be meaningfully realised in practice.
ACCHOs hold a well-established reputation for culturally safe service delivery and maintain strong relationships with the communities they serve. Their inherent structural and governance mechanisms, seen in the ACCHO model of care, place their quality and safeguarding frameworks as markers of best practice. Their expertise is critical to the development of meaningful and credible quality and safeguarding mechanisms.
A strong understanding of cultural safety must be part of the organisational mindset at all levels in order to align with Priority Reform 3 (the government’s commitment to systemic and structural transformation of mainstream government organisations to embed and practice cultural safety and deliver services in partnership with Aboriginal and Torres Strait Islander people). Focus should be on cultural capabilities, and developing skills, knowledge and behaviours required to plan, support, improve and deliver services in
a culturally respectful and appropriate manner. ’? This requires comprehensive, cultural capabilities training and greater engagement by listening to Aboriginal and Torres Strait Islander people about their experiences and taking those learnings on board across the organisation. Without cultural respect and understanding as a core component of the NDIS, we are unlikely to see the benefits for Aboriginal and Torres Strait Islander people. The AIHW Cultural safety in health care for Indigenous Australians: monitoring framework’4 may offer insights on how best to evidence the provision of culturally safe care. Consideration should be given to the development of mandated, specific guidance on delivering cultural safe disability care and supports
for Aboriginal and Torres Strait Islander people.
NACCHO recommends:
a) the definition of “unsafe supports or services” be expanded to include culturally unsafe supports and services, and
b) that a function of the Commissioner is to ensure cultural safety is embedded in the delivery of the
NDIS,
“ Elvidge, E., & Haddock, R. (2025). Measuring what really matters for Aboriginal and Torres Strait Islander peoples — Racism and cultural safety i in healthcare (Deeble Issues Brief No. 60). Australian Healthcare and Hospitals Association. https://ahha.asn.au/wp content/uploads/2024/09/Deeble-Issues-Brief-No_-60-Racism-and-cultural-safety-in-healthcare.
“2 Closing the Gap: In Partnership (2022). https://www.closingthegap gov au/sites/default/files/2022-09/ctg-nationalagreement_apr-21 comm-infra-targets-updated-24-auqust-2022_0_pdf.
“3 Mohamed J, Stacey K, Chamberlain C and Priest N. (2024), Cultural safety in Australia, Discussion paper, Lowitja Institute, Melbourne. https://www _lowitja.org_au/resource/cultural-safety-in-australia/. “4 Australian Institute of Health and Welfare, Cultural Safety in health care for Indigenous Australians: monitoring framework,
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c) mainstream service providers are held accountable through their funding agreements to demonstrate cultural capabilities required to deliver care in a culturally respectful and appropriate manner.
The need for localised, community-controlled NDIS providers
The ACCHO model of community-controlled comprehensive primary healthcare is a holistic system grounded in truth, lived realities, culture, law, and Country, bringing these elements together and drawing on evolving structures and relationships to design culturally informed health models and programs that meet community needs, with practice led from the ground up to inform effective policy, advocacy, and legislation. ’°
For many Aboriginal and Torres Strait Islander people, health is deeply connected to land, sea, language, culture, and community relationships. These connections manifest differently from one individual or community to another. The Aboriginal and Torres Strait Islander community-controlled comprehensive primary healthcare model seeks to translate these unique and intrinsic values into a framework for delivering health services and programs.
The model is built around four core domains that ensure healthcare services are locally defined and culturally responsive. These include governance, clinical services, policy direction and partnership, and community health promotion and empowerment.
Research shows that ACCHOs deliver better results for Aboriginal and Torres Strait Islander people than mainstream services, ’® and at a lower cost. 7:18 ACCHOs achieve this through delivering a holistic model of care, which:
e Underscores the importance of connecting the physical, mental, social, emotional and spiritual dimensions of health and wellbeing to promote preventive and comprehensive care, with a strong focus on prevention not solely through focusing on treatment.
e Prioritises the values of community, culture and the deep connection to the land as integral elements of overall wellness.
e Recognises the significance of traditional healing methods, cultural protocols and community-driven initiatives in fostering the wellbeing of Aboriginal and/or Torres Strait Islander communities.
e Integrates the concept of ‘joined up services’, to ensure that healthcare services are coordinated and work together seamlessly to provide comprehensive support for individuals and communities.
A critical supportive factor, and key cultural determinant of health, is the provision of health care by staff and services that know the lived reality of Aboriginal and Torres Strait Islander people. ACCHOs have provided culturally safe primary healthcare by and for Aboriginal people since the 1970s. They are innovators in the development of comprehensive primary health care in Australia. ACCHOs are best placed to respond to local health needs as they position their model of care within a framework of family and cultural safety.
Because of this, ACCHOs are more effective than other health services at improving Aboriginal and Torres Strait Islander health. ’9
In NACCHO’s consultations with its Affiliates and members, we have heard reports that many participants underutilise their NDIS plans due to the limited availability of culturally safe services. Strengthening the
‘® National Aboriginal Community Controlled Health Organisation (2024). Aboriginal community-controlled health organisations. [online] NACCHO. Available at: https://www.naccho_org.au/aboriginal-community-controlled-health/.
*® NACCHO, Core Services and Outcomes Framework, June 2021, https://csof naccho org_au/wp-content/uploads/2022/10/Core Services-Outcomes-Framework-full-document pdf.
7 Vos et al., Assessing Cost-Effectiveness in Prevention, September 2010, https://public-health ug edu au/files/57 1/ACE
Prevention final_report.pdf.
18 Ong et al., Differences in primary health care delivery to Australia’s Indigenous population: a template for use in economic evaluations, September 2012, https://bmchealthservres biomedcentral.com/articles/10.1186/1472-6963-12-307.
® Campbell, M.A. et al. Contribution of the Aboriginal Community-Controlled Health Services to Improving Aboriginal Health: an Evidence Review, Australian Health Review (http://www_publish_csiro_au/ahr).
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ACCHO sector to provide NDIS services embeds accountability and safeguarding through strong governance, with community representation on boards ensuring services are responsive, safe, and culturally grounded.
In locations where Aboriginal community-controlled services are not available, mainstream providers often operate without sufficient cultural safeguards.2° This can compromise participant safety, trust, and engagement. ACCHOs system of quality safeguarding is managed by reputational standards held by its community and the users of service that sit on their respective boards. Services that have long-standing reputations for cultural safety within their communities, allow for greater engagement due to transparent, culturally safe, and independent communication pathways where the quality of service is shared among community. This results in avoidance of unsafe service and attraction to culturally safe services.
Localised, multidisciplinary teams allow for continuity of care, a deep understanding of the needs and priorities of their clients, and knowledge of the services and supports available in the region that their clients can access. However, from our consultations with member services, we know that a number of ACCHOs do not receive sufficient funding in their areas to be NDIS providers and must use alternative funding and support mechanisms to provide high-quality care for clients effectively at a financial loss. Funding models also favour bigger, mainstream services, ACCHOs. In order to “support the safety of NDIS participants in the NDIS/Scheme’”, localised, community-controlled NDIS providers are needed.
NACCHO recommends the Commission prioritises funding and support mechanisms for ACCHOs and ACCOs to become NDIS providers and deliver the NDIS services needed in their regions.
Strengthening the Aboriginal and Torres Strait Islander disability workforce
ACCHOs are a critical part of the disability service eco-system and must therefore be considered an
essential service, with support to scale up and work in partnership with other organisations. Aboriginal and Torres Strait Islander people are underrepresented in the care workforce across the country, particularly in remote communities.2’ There needs to be workforce development opportunities to upskill existing workers.
We know that in the health sector, the identified lack of Aboriginal and Torres Strait Islander health and care workers contributes to reduced access to health and care services for Aboriginal and Torres Strait Islander people in ACCHOs, and in mainstream primary and allied health sectors more broadly.22 ACCHOs — particularly those in in remote and very remote areas — have existing issues with staff recruitment and retention. This has meant they have become increasingly reliant on a fly-in-fly-out workforce, which requires additional housing that is often not available. Burnout is common, and the workforce is stretched.
In order to carry out the additional services provided through NDIS, local people must be upskilled.
The First Nations Health Worker Traineeship Program (FNHWTP), coordinated though NACCHO, provides a template for how capacity and capability building could occur. The program supports Aboriginal and Torres Strait Islander trainees to become Aboriginal Health Workers or Health Practitioners. Training local
people capitalises on their existing local knowledge and connections, while also providing meaningful local career opportunities. 24
Through the FNHW’TP, trainees undertake Certificate III or Certificate IV qualifications in the Aboriginal and Torres Strait Islander Primary Health Care training package. ACCRTOs deliver wrap-around cultural and
2° Deloitte. (2023). Research report — Options to improve service availability and accessibility for First Nations people with disability. Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability. https://apo_org_au/node/323259.
21 Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, The lack of NDIS services for First Nations people with a disability ‘a national crisis’, June 2023, https-//disability. I . ndis-services-first. nations-people-disability-national- crisis.
22 AIHW Indigenous Health Performance Framework 3.22.
3 VACCHO, Alumni Trailblazers: Kayla Harrison on Breaking the Cycle ar and Ceading With Heart, March 2025, |
. i -k
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Schedule 1, Part 6 — Information Gathering
With the proposed changes to strengthen the NDIS Commission’s powers to i) require information from NDS providers in a shorter timeframe than the 14 days the NDIS Act currently allows, and ii) give information and documents to the NDIS Commissioner as part of expanded registration conditions when required, there is a risk that some of our smaller services, and rural and remote services may not have the resources to comply within the specified period.
Some ACCHOs receive funding from more than 70 different departments, agencies, and organisations, each with unique reporting requirements, often for relatively small funding amounts. Assuming each of these funding providers requires annual reporting, this would be an average of 1 unique report per 3.7 working days.*8 ACCHOS are service delivery organisations and are not resourced to manage this level of reporting.
We understand the need to access information quickly to enable the Commission to take regulatory action appropriate to safeguard participants, and all our member services would support this. However, these increased compliance expectations add additional pressure on services already experiencing workforce shortages and a large financial and administrative burden. This would be compounded if noncompliance results in the Agency withholding payments.
NACCHO recommends the Commission:
a) waives the requirement for ACCHOs and ACCO$ to provide information in a period shorter than 14-days, and b) allows ACCHOs and ACCO$ a minimum of 14-days to provide information and documents to the Commissioner for registration purposes when required.
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digital technologies.26 In remote communities and homelands, rates of digital exclusion are even higher.2“ Some of our ACCHOs do not have adequate infrastructure support and reliable connectivity to be able to provide the growing range of digital health and related services. With the additional stipulation of payments being withheld if not submitted via the portal, this is an additional burden on services and the NDIS participants they support. These ACCHOs require additional support to address structural barriers to digital access and greater flexibility around how they can submit claims.
NACCHO recommends the Commission allows ACCHOS and ACCOSS flexibility to submit claims in a variety of ways if required, not only via the my NDIS Provider Portal.
Consultation and stakeholder engagement processes
The consultation and stakeholder engagement processes undertaken by DoHDA can be significantly strengthened. This should include involving Aboriginal and Torres Strait Islander people, communities, and organisations in planning phases of all initiatives, ensuring ongoing communication throughout development, and appropriate timeframes to allow for meaningful feedback. The nature of consultations to date do not reflect a commitment to the Priority Reforms of the National Agreement on Closing the Gap.
NACCHO seeks to reflect the voices of our membership in all our submissions, however, limited timeframes, and limited formats for stakeholder engagement do not allow for sufficient consultation. Given the importance of this work, these short windows restrict our ability to meaningfully engage with our members and Aboriginal and Torres Strait Islander communities, whose voices are essential in shaping policies that affect disability care and supports. Genuine consultation requires adequate time to ensure cultural safety and inclusive engagement.
We are concerned by the lack of flexibility DoHDA demonstrates regarding consultation and stakeholder engagement, which risks excluding many who would otherwise have valuable insights to contribute. We would welcome opportunities to strengthen alternative engagement approaches to ensure the finite resources of our sector are utilised effectively. For example, forums such as the NDIS Policy Project Community of Practice facilitated by NACCHO allows for open discussion, and feedback shared by members. A willingness for DoHDA to engage with members in this format would support respectful dialogue and allow for a broader, more inclusive understanding of sector priorities. We urge DoHDA to provide more accessible opportunities for public consultations to enable broader and more representative participation.
NACCHO supports more proactive stakeholder engagement approaches as this will allow for more meaningful consultation with the community-controlled sector to include their perspectives throughout DoHDAs functions. This would ensure that any NDIS and other initiatives are more effective for Aboriginal and Torres Strait Islander people and organisations.
NACCHO recommends targeted engagement with the community-controlled sector to ensure Aboriginal and Torres Strait Islander disability needs and priorities are supported and implemented through department initiatives.