National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 167 - Supplementary Submission
Submission on Proposed NDIA/NDIS Reforms Regarding Provider Registration and Participant Access
I am writing to express concern regarding proposed reforms that may expand mandatory registration requirements and progressively restrict access to unregistered providers within the National Disability Insurance Scheme.
While participant safety is essential, I strongly urge that the NDIS not move toward a blanket registered-only provider model. Doing so risks unintended harm to participant choice, access, flexibility and continuity of care, particularly for participants who are self-managed or plan- managed. The NDIS was established on principles of participant choice and control, and reforms must remain consistent with these foundational objectives.
I acknowledge that the Government has stated that mandatory registration is initially intended to apply to certain higher-risk supports and specific provider categories. However, there remains significant uncertainty within the disability sector regarding how broadly these requirements may later expand and what impact they may have on participant choice, workforce availability and regional access to supports.
There is a persistent assumption that provider registration is equivalent to quality or safety. However, real-world evidence across disability and other care systems demonstrates that serious incidents of neglect, abuse, medication errors and poor outcomes can and do occur within registered and regulated services. Public reporting and findings from the Disability Royal Commission highlighted multiple cases involving harm within regulated care environments, reinforcing that registration alone does not guarantee safe or high-quality care.
Conversely, many unregistered providers deliver highly responsive, ethical and individualised supports that participants actively choose because they better meet their needs. This is particularly important for participants seeking culturally appropriate supports, continuity of relationships, flexibility or providers willing to service regional and remote areas.
Unregistered providers also play a critical role in service accessibility. They often include sole traders, small organisations, peer workers and culturally specific supports, many of whom would be unreasonably affected by increased administrative and financial burdens associated with registration. These providers already carry significant overheads, including insurance, taxation, training, compliance obligations and operational costs.
However, there remains limited clarity regarding the full scope, cost, administrative burden and ongoing compliance obligations associated with future registration requirements, particularly for smaller and regional providers. Without careful design and adequate safeguards, there is a real risk that a broader shift toward mandatory registration could force many smaller providers to exit the system, reducing workforce diversity and limiting participant choice.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 167 - Supplementary Submission
I strongly support appropriate safeguarding measures for all disability support workers, regardless of registration status. Reasonable protections such as NDIS Worker Screening Checks, criminal history checks, mandatory safeguarding and worker orientation training and enforceable codes of conduct can help protect participants without requiring every small provider, sole trader, or privately engaged worker to become fully registered providers.
For many families, particularly those supporting participants with high personal care needs within the family home, flexibility, trust, and continuity of care are essential. As a parent and legal guardian employing support workers to assist with intimate personal care for my sons within our home environment, I believe families should retain the ability to engage trusted workers who meet appropriate safety and screening requirements without imposing excessive administrative burdens that may reduce service availability or participant support hours.
I also have extensive professional experience working within government and community systems, including almost 30 years in education across teaching, leadership, and support roles, as well as experience working alongside child protection and safeguarding frameworks. This background has given me a strong understanding of professional standards, duty of care, appropriate boundaries and participant safety. In training and supervising support workers, I already place significant emphasis on professionalism, safeguarding practices, and respectful participant support.
My concern is that increasingly complex registration, reporting, and administrative requirements may unintentionally redirect time, funding and workforce capacity away from direct participant support and toward compliance processes. In practice, excessive administrative burden can ultimately reduce the number of hours and supports participants actually receive. This impact is likely to be felt most heavily by small providers, family-managed arrangements and regional participants who already experience workforce shortages and limited service availability – especially, high quality support workers, speech therapists with specific skill sets, physiotherapists and Occupational Therapists who know how to write a strong functional capacity report.
As an unregistered provider, and as the carer of my husband and two adult sons, I am making this submission to highlight the real-world impact that proposed changes to the National Disability Insurance Scheme may have on participants and families already experiencing significant barriers to access.
We are located in Goolwa, over an hour from the Adelaide CBD. In our area, we are already experiencing a significant reduction in available providers, long waitlists, and reduced willingness of services to travel outside metropolitan Adelaide. This has resulted in diminished choice, delayed access to essential supports, and increasing pressure on families to coordinate and fill gaps in care.
While the proposed amendments do not explicitly restrict regional service delivery, several changes may indirectly worsen these existing access issues. These include stronger Ministerial
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 167 - Supplementary Submission
control over pricing, more paperwork and administrative requirements for providers, as well as stricter rules about who can receive support. In practice, this may mean supports are more tightly linked to specific diagnosed conditions rather than a person’s overall functional needs and daily reality. It may also mean that before funding supports, planners are required to consider whether those needs could be met through other systems such as health, education, or community services.
In reality, these “other systems” are often not available in practice, not specialised enough, or already at capacity. This creates a risk that people may be told to seek support elsewhere, even when there is no realistic or accessible alternative. For participants and families, this could result in reduced access to essential supports, increased administrative burden to justify needs, and more time spent navigating systems rather than receiving care.
These changes risk making regional service delivery less financially viable. Providers already face increased travel time, smaller caseloads, and workforce shortages when servicing regional areas. Without adequate recognition of these factors in pricing and system design, there is a real risk that providers will further concentrate services in metropolitan Adelaide, leaving regional participants with fewer options and longer wait times.
Unregistered providers play a critical and often overlooked role in maintaining access to supports. Unregistered providers, including local therapists, support workers and community- based services, often fill urgent gaps where registered providers are unavailable or have long waiting lists. They are particularly important in regional areas where choice is already limited. Maintaining access to unregistered providers is therefore essential for continuity of care, flexibility and timely support.
It is also important that Parliament understands the practical reality for families in regional South Australia. My family is located over an hour from the Adelaide CBD, and we do not qualify for the Patient Assistance Transport Scheme (PATS). This leaves us without any transport or travel support to access essential allied health and disability services concentrated in the metropolitan area.
We are already managing significant barriers to access, including reduced provider availability, long waitlists and limited choice of supports. In this context, even small reductions in provider willingness to travel, or increased administrative or cost pressures on services, have a unbalanced impact on regional participants and their carers. Access is not a matter of convenience, but of basic service availability and continuity of care.
We have already experienced reductions in practical supports within the current system. In my son’s most recent plan, the fortnightly travel allowance was completely removed. This has further increased the out-of-pocket and burden on our family in managing access to services located in Adelaide.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 167 - Supplementary Submission
When combined with our regional location and lack of eligibility for PATS, the removal of this allowance significantly reduces our capacity to access required supports. It effectively shifts more of the cost and responsibility of access onto families, rather than recognising travel as an unavoidable component of equitable service delivery in regional areas.
It is also important to recognise that telehealth is not an appropriate substitute for many participants with complex needs, particularly in regional and rural areas where face-to-face services are already limited. While telehealth can be valuable in some circumstances, it is not suitable for many participants who require hands-on assessment, behavioural observation, physical support, communication assistance, relationship-based therapy or complex care coordination.
For my participants, sons and husband, the level and complexity of their support needs often require in-person services and trusted relationships with workers and clinicians who understand their individual communication styles, behaviours, routines and care requirements. This is also true for many other participants living in regional Australia. Telehealth should not be treated as an equivalent replacement for accessible face-to-face services, particularly where participants already experience significant barriers to care.
There is also growing concern regarding what practical alternatives remain available to participants and families when NDIS supports become more restricted or difficult to access. Prior to the introduction of the NDIS, many smaller local programs, community-based services and disability supports existed within communities. Over time, many of these services either closed, lost funding or were absorbed by larger organisations during the transition to the NDIS system.
As a result, participants are increasingly being told to rely on “mainstream” or alternative services that, in reality, may no longer exist locally, may already be overstretched or may not have the specialist disability knowledge required to appropriately support people with complex needs. Any reforms that further restrict access to providers or supports must genuinely consider what accessible alternatives are practically available for participants and families, particularly in regional and rural communities.
Any reforms to the National Disability Insurance Scheme must ensure that efforts to improve efficiency, compliance and pricing consistency do not unintentionally deepen the existing inequity between metropolitan and regional participants. Without explicit safeguards for regional access, there is a real risk that families like ours and the ones I support, will face further reductions in service availability and increased barriers to essential supports.
I strongly support improvements to system integrity, safety and accountability. However, these reforms must be balanced with a clear commitment to equitable access for regional and rural participants, including recognition of travel costs, provider viability outside metropolitan areas and the ongoing importance of unregistered providers in filling critical service gaps (which in no way diminishes their vital services).
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 167 - Supplementary Submission
For regional families, maintaining access is not optional, it is essential to wellbeing, development, daily functioning and quality of life.
It is also important to consider the broader economic and workforce implications of these reforms, particularly for regional South Australia. The disability and aged care sectors are significant employers in many regional communities and changes that increase administrative burden, compliance costs or reduce the viability of small providers may unintentionally contribute to service contraction and job losses in already fragile regional labour markets.
In areas such as regional South Australia, where service delivery is already limited and workforce shortages are well documented, any reduction in provider viability or willingness to operate outside metropolitan centres risks further concentrating employment opportunities in cities. This may have flow-on effects for local unemployment rates, reduced skilled employment pathways, and fewer opportunities for carers, support workers, allied health professionals and community-based providers to remain working within their own regions.
A system that unintentionally drives providers out of regional areas does not only reduce participant choice, it also weakens local economies that rely on these services as a key employment sector.
I would welcome the opportunity to contribute directly to the development and oversight of these reforms, for example through participation on a committee or advisory group. My goal would be to help ensure that any amendments to the NDIS do not unintentionally harm participants, reduce choice or create worse outcomes.
It is my observation that, too often, carers and participants are invited to provide feedback after key decisions have already been made. I hope there can be genuine engagement where lived experience and professional expertise are considered meaningfully, and where the voices of families and participants help shape legislation in ways that truly support safety, access and participant-centred care.
Yours sincerely
Parent, Carer, Regional South Australian Resident and Unregistered NDIS Provider