NDIA Accountability Project

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Systemic misuse of supports and diagnostic inflation (Individual advocacy)

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Submission: Securing the NDIS for Future Generations Bill 2026

To: Committee Secretary (Confidential) Subject: Systemic Misuse, Diagnostic Inflation, and Structural Reform

Executive Summary

The NDIS is being undermined by a combination of:

  • Weak eligibility controls
  • Provider overbilling and low accountability
  • Diagnostic inflation driven by funding incentives
  • Cost-shifting from mainstream systems
  • Misuse of supports beyond disability-related needs At the same time, public funds are being diverted into legal disputes by the National Disability Insurance Agency rather than frontline support. If left unaddressed, these failures will:
  • Erode public trust
  • Divert funding from participants with genuine, significant disability
  • Create long-term fiscal instability This submission proposes targeted, enforceable reforms to restore integrity without disadvantaging those with legitimate needs.

Core Problem: A System That Rewards Gaming Over Need

The current design of the NDIS has created perverse incentives:

  • Diagnosis unlocks funding, creating pressure to secure labels rather than demonstrate functional impairment
  • Providers are financially rewarded for maximising billable hours, not outcomes
  • Vague rules enable reinterpretation of supports as “disability-related”
  • Participants face reduced supports without formal diagnoses, encouraging escalation This is not an isolated misuse. It is system-enabled behaviour.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission 1784

Diagnostic Inflation and Autism Access Pressures

There has been a significant rise in autism diagnoses since the introduction of the NDIS. While increased awareness plays a role, the scheme has also created clear structural incentives:

  • Long-term funding tied to diagnosis
  • Limited supports available without formal eligibility
  • Abrupt withdrawal of early intervention supports This has contributed to:
  • Over-reliance on single-discipline assessments
  • Pressure on clinicians to diagnose
  • Expansion of diagnostic thresholds in practice

Key Position This is not a critique of autism.It is a critique of a system that rewards diagnosis over demonstrated functional need.

Misuse of Supports and Cost-Shifting ### Support WorkersSupport workers are increasingly used for: - Babysitting and passive supervision - School drop-offs and pick-ups - Daytime care during school hours>This represents a shift of parenting and education responsibilities into the NDIS..### ConsumablesConsumablesfundinghasexpandedbeyondintenttoinclude:- Everyday household items- Non-disability-related purchases

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1784

• High-risk recreational equipment (e.g., trampolines, swing sets , monkey bars)

This is a failure of enforcement* t>not policy ambiguity.

Provider Billing Practices Common patterns include:

  • Excessive charging for case notes and session planning - Inflated travel claims High-frequency low-value billing This results in systemic financial leakage at scale..### Misclassification of Parental Responsibilities as Funded Supports A further significant concern includes inclusion of ordinary parental responsibilites within children’s NDIS plans There have been increasing instances where funding has been used:
  • Lawn maintenace & gardening - General householld cleaing Swimming lessons presented as therapy These aren’t disability supports They’re ordinar family resposibilities#### Household Tasks No child’s NDIS plan should incluude: • Law maintenance • Gardening • Genral domestic cleaning These are responsibilities household shouldn’t funded under scheme unless direct, evidenced link to functional impairment cannot reasonably be managed through informal support.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1784

Swimming Lessons vs Therapy

There is also a growing misuse of therapeutic supports, particularly:

  • Hydrotherapy
  • Physiotherapy as a pathway to fund effective swimming lessons. While hydrotherapy and physiotherapy have legitimate clinical purposes, they are increasingly being used to:
  • Circumvent funding restrictions
  • Reclassify recreational or developmental activities as therapy This undermines the integrity of therapeutic support.

Key Distinction

  • Therapy must be clinically prescribed, outcome-focused, and directly linked to functional goals* Swimming lessons are a general developmental activity and parental responsibility.# Commercialisation of Disability Through High-Cost ProgramsA growing concern is the expansion of high-cost non-evidence-based programs marketed to NDIS participants—particularly children—under the guise of therapy or skill development.These include:*School holiday programs run by occupational therapists at extremely high hourly ratesActivities such as:Learning to ride a bikeSurfingFishingArt classes

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1784

While these activities may have general developmental value, they are being: • Rebranded as therapeutic interventions, and Charged at specialist therapy rates In many cases, these same activities could be: • Safely and effectively facilitated by a support worker at a fraction of the cost, or Undertaken as part of normal family and community participation## Profit-Driven Programs Targeting Disability There is also a noticeable increase in companies developing NDIS-targetedprograms including: • Camps • Fishing trips • Boat charters • Group activity programs marketed specifically to autistic participants These programs are often: • Packaged as “capacity building” • Delivered at premium prices • Poorly defined in terms of measurable outcomes### Key Concern The Scheme is increasingly being used as a funding stream for commercial ventures rather than a targeted support system This raises a fundamental question Where is the evidence base?#### Evidence Gap and Lack of Accountability Many of these programs lack peer-reviewed or clinically validated evidence do not demonstrate measurable functional outcomes

National Disability Insurance Scheme Amendment Bill 2026

Submission 1784

  • Are not subject to consistent evaluation Yet they continue to attract significant funding. This creates:
  • A market incentive for programs designed with profit, rather than needs Reduced availability of essential support funds due to reduced funding allocation.

National Disability Insurance Scheme Amendment Bill

Submission 1784

Purpose: prevent escalation without granting long-term access inappropriately

Diagnostic Integrity Controls

  • Mandatory multidisciplinary assessment for autism
  • Independent review of inconsistent reports
  • Monitoring of high-diagnosis providers

Funding alignment:

Funding must align with functional impact, not diagnostic labels.

Provider Regulation

  • Mandatory registration(tieredbyrisk)
  • Uniqueprovideridentifiers
  • Publicperformanceandcompliancerecords

BillingControls

  • Captopnon-facetofacebilling(e.g.casenotes)
  • Restricssessionplanningcharges
  • Enforcetravellimitsandverification
  • Requirerecitemisetime-stampedinvoices

ConsumableRestrictions

Consumableslimitedto: Disabilityspecificsupports Adaptiveandasistivitems Exclusions: Everydayitems Householdgoods High-riskrecreationalequipment

SupportWorkerLimits(Children)

Supportworkersmustnotbeused:

  • During school hours for children capable of attending school
  • For parenting or supervision roles
  • For school transport (unless disability-specific or ineligible Assisted School Travel Program) Exception: • Homeschooling or documented inability to attend school

Clarification of Parental Responsibility (Children’s Supports)

Legislation or Rules must explicitly state: NDIS funding for children must not include: • Lawn maintenance or gardening • General household cleaning • Recreational or developmental activities ordinarily expected of families, including swimming lessons

Therapeutic Support Integrity To prevent misuse of therapy funding:- Hydrotherapy and physiotherapy must:

o Be prescribed by a qualified clinician do Demonstrate clear functional outcomes o Not duplicate or substitute recreational activities- Claims that resemble structured lessons(e.g.swimming instruction)mustnotbefunded unless:oDeliveredaspartofaclinicallydocumenteddreatmentplandoSupportedbymeasurabletherapeuticalgoals

Evidence-Based Funding Requirement LegislationorRulesmustrequirethat:

All fundedsupports: •Demonstratclearevidencebase, or

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission 1784 • Show documented, measurable functional benefit to the participant

Restriction on High-Cost Recreational Programs

NDIS funding must not be used for:

  • Recreationa l-or lifestyle programs delivered at therapy-level pricing
  • Activities that can reasonably be delivered by: o Support workers do Families co Community organisations unless:A qualified clinician provides justification that:o The activity is necessary due to the participant’s disability;ando It cannot be delivered in a lower-cost, non-clinical setting### Prohibition on Reclassification of Activities as TherapyInsert provision:

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission 1784

Fraud Detection and Enforcement

  • Real-time analytics to detect abnormal billing
  • Payment suspension for flagged providers
  • Financial recovery and banning powers
  • Criminal referral for serious fraud

Participant Safeguards

  • No liability for provider fraud unless complicit
  • Ability to change providers easily
  • Protection from service withdrawal during investigations

Outcome

These reforms will:

  • Reduce fraud and overbilling
  • Eliminate incentives for diagnostic inflation
  • Restore fairness and consistency
  • Protect funding for participants with genuine need
Final Position

The Scheme must draw a clear and enforceable line: NDIS funding is for disability—not for replacing ordinary parenting, household responsibilities, or recreational activities rebranded as therapy. The NDIS must not become a marketplace where ordinary activities are repackaged as therapy and sold at inflated prices. Disability support is not a business model—it is a public responsibility grounded in evidence, necessity, and fairness. The NDIS is at risk not because it supports people with disability—but because it has became too easy to extract funding without sufficient accountability. A system that:

  • Rewards diagnosis over need
  • Allows providers to inflate billing • Funds supports outside its intended scope **Will not remain sustainable.Reformmustbedecisive.Notbroader.Notharsher.Sharpers.
  • Becauseeverydollarislosttothesystem,gamingisdollartakenfromsomeonewho genuineleyneedsupportorisanabletousecessthethescheduedtotighteningeligibility.