Submission 2518
Submission to the Senate Community Affairs Legislation Committee
Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future
Generations) Bill 2026
Submitted by
Danae Callaghan
Clinical Director, Therapeutic Healing and Counselling Gippsland
PACFA Registered Clinical Counsellor and Supervisor (Reg. No. 27849)
Full Member, EMDR Association of Australia
Counselling and psychotherapy recognised as allied health through PACFA’s full membership of Allied Health
Professions Australia
Contact details (for the committee, not for publication)
Publication: I consent to this submission being published by the committee.
Submission 2518
THACG Submission: NDIS Future Generations Bill 2026
Summary
I am a clinical counsellor, supervisor and educator, and the Clinical Director of a counselling andpsychotherapy practice in regional Victoria. This submission addresses Schedule 3, Part 1 of the Bill, which makes the Commonwealth Minister the decision maker on NDIS pricing.
I support the objective behind this Bill. The scheme needs to be sustainable, and it needs to stop paying for supports with no evidence base and no qualified practitioner behind them. The government is right to address that.
The 2026-27 pricing does not do it. Counselling was already at the floor of the therapy schedule and remains there. What changed is that the one item above it, which recognised specialised and quality-audited therapeutic practice at a higher rate, was collapsed onto that same floor. There is now no mechanism anywhere in the therapy schedule by which advanced qualification or specialist training in psychosocial therapy can be recognised in price. This Bill would make that permanent and legally enforceable.
The pricing rests on four contradictions with decisions the government has already made, in its own documents.
One: the scheme abolished its own mechanism for recognising specialist practice, on the ground that it could not identify a category its own rules define and its own approved auditors gate.
Two: it pays a psychology trainee in their fifth year of study $252.99 an hour, and pays behaviour support the same rate in a category where it sets no minimum qualification at all, while paying a clinical registrant with postgraduate qualifications and fifteen years of practice $156.16.
Three: it recognises PACFA registered clinical counsellors as allied health, in the same alliance and under the same self-regulating model as speech pathology, then prices them $37.83 an hour below it.
Four: the identification it says is impossible already operates elsewhere in government. The Minister
endorsed National Standards defining this profession in October 2025. The Commonwealth issuespractitioner identifiers to members of non-AHPRA professional bodies. WorkSafe Victoria registers and prices counsellors by peak body membership level.
If the government cannot reconcile its own standards, its own identifier infrastructure and its own state schemes with its own NDIS pricing, that is the strongest reason to build safeguards into this Bill before the power to set enforceable prices is conferred.
Who I am
I am a PACFA Registered Clinical Counsellor and Supervisor. I hold multiple postgraduate qualifications and more than fifteen years of experience with high-risk clinical presentations. I supervise other practitioners, and I am an educator who has taught into a Masters of Counselling and Psychotherapy. As a PACFA registrant I must maintain ongoing clinical supervision and continuing professional development. My profession is recognised as allied health through PACFA’s full membership of Allied Health Professions Australia.
My practice is in the Latrobe Valley, in the Gippsland region of Victoria, an area roughly the size of Switzerland. We work with the participants other services do not have the experience to manage: psychosis, chronic suicidality, aggression, severe self-harm, complex mental health and forensic presentations. This work is defined by intersectionality. Participants rarely present with a single diagnosis or a single form of disadvantage. They present with co-occurring psychosocial and physical disability, neurodivergence, substance use, statutory involvement, cultural safety needs, and the compounding effects of regional isolation. Each factor shapes the others, and none can be treated in isolation. Our waitlist is around eight months.
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Submission 2518
THACG Submission: NDIS Future Generations Bill 2026
What actually changed
Therapy line item 2025-26 2026-27 ChangePsychologist (incl. provisional psychologists
$232.99 $252.99 up $20.00under supervision)
Speech pathologist, occupational therapist,
$193.99 $193.99 heldsocial worker
Other Professional (incl. specialist therapy
$193.99 $156.16 down $37.83work)
Counsellor $156.16 $156.16 held, at the floorContradiction one: the scheme abolished its own mechanism for recognising specialist practice.
The Other Professional item was not a residual bin for the unqualified. It was the only place in the therapy schedule where advanced or specialised practice attracted a higher rate than entry-level therapy.
The NDIA cut it on the basis that the category aggregates disciplines that cannot be reliably identified or benchmarked. Its own pricing rules say otherwise. The NDIS Pricing Arrangements and Price Limits provide that therapists claiming under that item are those accepted by an approved quality auditor of the NDIS Commission as having the relevant qualifications, expertise and experience. Entry is conditional on a quality audit. The NDIA’s Therapy Supports guidance goes further, confirming that therapies without a dedicated line item may be claimed under Other Professional where they meet the funding criteria, and requiring that any therapy claimed be evidence based and improve or maintain functional capacity.
The timeline compounds this. The NDIA published revised Other Professional guidance on 14 October 2025, effective 24 November 2025, setting out who may claim under each therapy item. It has been enforced. Plan managers have required providers to demonstrate how a support fits the category before approving payment and are able to request evidence that a practitioner holds the qualifications set out in the pricing arrangements. A verification process was already operating and the burden of proof already sat with the practitioner. Eight months later the Annual Pricing Review reduced the rate on the ground that the NDIA lacks visibility over who claims under the item.
The Agency created this category, gated entry behind a quality audit, required the therapy within it to be evidence based, directed practitioners into it, enforced that direction through plan managers, and then reduced its price on the basis that it does not know who is in it.
The counselling rate itself did not fall. It has sat at the floor throughout. What changed is that the tier above it was removed. There is now no line item anywhere in the NDIS therapy schedule through which advanced qualification, specialist training, or a higher level of professional registration in psychosocial therapy can be recognised in price. The ceiling has been taken away, and this Bill would make the floor permanent and legally enforceable.
Contradiction two: the pricing tracks professional title, not competence.
The pricing rules allow a provisionally registered psychologist working under supervision to be claimed at the full psychologist rate of $252.99 per hour. Under the Psychology Board of Australia registration standard, the minimum qualification to apply for provisional registration is a four-year accredited sequence of study. A provisional psychologist therefore attracts the highest therapy rate in the schedule from the commencement of their fifth year, before any postgraduate qualification is completed.
By contrast, PACFA clinical registration cannot be held until a practitioner has completed their qualification, accumulated 750 hours of post-qualification client contact and 75 hours of professional supervision, and it
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Submission 2518
THACG Submission: NDIS Future Generations Bill 2026
remains conditional on ongoing supervision and continuing professional development. I hold multiple postgraduate qualifications representing more than five years of formal tertiary study, I meet the PACFA clinical standard, and I have more than fifteen years of practice with high-risk presentations. I am claimed at $156.16 per hour.
The same pattern appears in behaviour support. Specialist Behavioural Intervention Support is priced at $252.99 per hour. Yet the NDIS Quality and Safeguards Commission’s own Positive Behaviour Support Capability Framework states that it does not outline minimum years of practice, qualifications, training, or professional development required to be a behaviour support practitioner, and the Commission operates an entry level pathway for applicants with less than six months of experience. The Framework describes four capability levels. The price schedule applies a single rate across all of them.
This is not a criticism of provisional psychologists or of behaviour support practitioners. Supervised practice is how clinicians learn, and behaviour support is demanding, high risk and necessary work. The criticism is of the model.
The scheme pays $252.99 per hour to a practitioner in their fifth year of study, $252.99 per hour for a support category in which it sets no minimum qualification at all, and $156.16 per hour to a clinical registrant whose national standards, endorsed by the responsible Minister, require a bachelor to masters qualification and more than 750 hours of supervised client contact. That is not measuring capability. It is reading a label.
Contradiction three: the government recognises counsellors as allied health, then prices them below it.
In 2022, Allied Health Professions Australia, the peak body the Commonwealth turns to for the allied health view, admitted PACFA as a full member, placing PACFA registered clinical counsellors inside the same allied health alliance as speech pathology. The comparison is exact. Speech pathology is not registered through AHPRA. It is self-governing, regulated by its own peak body through membership standards, supervision requirements and continuing professional development. Counselling under PACFA is governed the same way. The only material difference for pricing purposes is the line item they occupy. The speech pathologist is paid $193.99 per hour. The PACFA registered clinical counsellor is paid $156.16.
Only PACFA holds that full allied health membership. The Australian Counselling Association does not. Yet a single flat Counsellor rate is applied across the entire spectrum, from a diploma-level entrant through to an allied-health-recognised clinical registrant. The answer is to tier the rate against the levelling the government has already published, not to hold the whole profession at the floor.
Contradiction four: this profession is already defined and identified by government.
In October 2025 the Minister for Health, Disability and Ageing endorsed the National Standards for Counsellors and Psychotherapists. That document defines counselling as a competent, career-staged profession, and makes identifying and managing suicidal risk, self harm and trauma a core competency. This Bill is advanced by the same Minister, in the same portfolio, yet the pricing it would entrench treats counselling as a floor-rate activity in a category the NDIA says it cannot identify.
The Commonwealth operates the Healthcare Identifiers Service under the Healthcare Identifiers Act 2010. Under that Act, healthcare providers registered under national, state or territory laws, and members of a professional association that meets the legislative criteria, are eligible for a unique Healthcare Provider Identifier. Eligibility is not confined to practitioners registered through AHPRA. The Australian Digital Health Agency’s National Healthcare Identifiers Roadmap 2023 to 2028 lists non-AHPRA professional bodies among its delivery partners, states that broader adoption of these identifiers will link the health system to the National Disability Insurance Scheme, and names the improvement of funding models as an intended use.
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Submission 2518
THACG Submission: NDIS Future Generations Bill 2026
At state level, WorkSafe Victoria requires a practitioner to provide evidence of current PACFA Clinical membership or ACA Level 3 or 4 to register as a counselling provider and invoice at the counselling fee schedule, and to maintain that level of membership to continue providing services. WorkSafe describes counsellors as skilled healthcare professionals delivering psychological interventions. A Victorian government scheme already identifies counsellors by peak body, differentiates them by registration level, and ties payment to that level.
These are not my characterisations. They are the government’s own documents, published within twelve months of each other, saying opposite things. The NDIA cannot maintain that this workforce is unidentifiable while the Commonwealth issues practitioner identifiers to members of professional associations, a state government prices counsellors by their registration tier, and its own plan managers require providers to evidence their category before payment. This is not a limitation of data. It is a decision not to use identification infrastructure that already exists.
The consequence: complexity is pushed out of the services that hold it
Counselling under the NDIS is not one clean hour of therapy. The participants I see carry very high clinical risk, and much of the work is unscheduled and unfunded: risk assessment, safety planning, crisis contact outside business hours, and consultation with support coordinators, general practitioners, police and child protection. There is no after hours loading, though risk does not observe business hours. These participants also fall between systems. State mental health services treat them as an NDIS responsibility, the NDIS treats their acute needs as a state responsibility, and the person lands with whoever holds the relationship and answers the phone. In a regional community with severe workforce shortages, that clinician holds the complexity alone.
Distance compounds this. Provider travel between clients is capped at 50 per cent of the hourly rate, with travel time limits calibrated to metropolitan distances. Remote loadings apply only to postcodes effectively unreachable by road. Gippsland is roughly the size of Switzerland and attracts no remote loading at all, yet is expected to absorb travel rules written for a city. Under those rules home visiting became financially unviable and I have had to stop it. The participants most affected are those with severe mental illness who cannot travel to an office and hold no transport funding. For them, this is not a reduced service. It is no service.
This produces an outcome that should concern the committee more than any provider’s income. Ethical practice requires that we do not begin treatment we cannot safely complete. Commencing therapeutic work with a participant and then withdrawing because the funding cannot sustain the clinical hours the work requires is not neutral. It causes harm. Where funding does not permit safe and adequate treatment, the responsible clinical decision is not to commence. That is the decision experienced clinicians across regional Australia are now being forced to make, and the participants excluded by it are the most complex, the highest risk, and the least able to find an alternative.
Why this matters for the Bill
Schedule 3, Part 1 makes the Minister the decision maker on NDIS pricing. The NDIA retains responsibility for conducting analysis through its Annual Pricing Review in order to inform the pricing advice given to the Minister, and has stated publicly that it anticipates this year’s Review will inform that advice if the Bill is passed. The 2026-27 Annual Pricing Review is therefore not a separate matter from this Bill. It is the evidence base the Bill would convert into a ministerial determination.
I am not opposed to the Minister holding a pricing power. I am telling the committee that the analytical process which would feed that power has reached a conclusion its own government’s documents contradict. If that process is not corrected before the power is conferred, the error is not a guidance document that can be revised next year. It becomes a determination.
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Submission 2518
THACG Submission: NDIS Future Generations Bill 2026
The remedy is inexpensive. The government has committed to a new enrolment system carrying identifiable information on NDIS providers, which concedes that identification is achievable. The National Standards the Minister endorsed already set out competence tiers. Nothing new needs to be invented. One distinction should be preserved. Registration as an NDIS provider is an organisational audit regime; it certifies a business. Professional registration, through bodies such as PACFA or AHPRA, certifies a clinician. Therapy supports have never required NDIS provider registration precisely because the professions delivering them already carry those safeguards through their peak bodies. A pricing determination for therapy supports should be calibrated to professional registration and demonstrated competence, not to provider registration status.
A note on whose voices reach this committee
I am able to write this submission. Most of the participants affected by this pricing are not. The process requires literacy, written expression, executive function, sustained concentration and the confidence to disagree with government in writing. Many of the people I work with have none of those, not because they
lack views, but because their disability affects precisely those capacities. Where participants withpsychosocial and intellectual disability are consulted, acquiescence is well documented: people whose housing, income and supports depend on a system tend to agree with it when asked.
The committee should treat the relative absence of participant voices on therapy pricing not as consent, but as a measure of how far the consultation process sits from the people it most affects.
Recommendations
I ask the committee to recommend that any pricing determination power in the Bill be subject to the following safeguards.
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Require pricing determinations for therapy supports to be based on demonstrated competence, qualification level and registration status, not professional title alone, so that a trainee in one profession cannot be funded above an experienced clinical registrant in another.
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Require any determination affecting counselling to apply the career stages set out in the National Standards for Counsellors and Psychotherapists endorsed by the Minister in October 2025, so that the levelling the government has already published is used to tier the rate.
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Recognise the allied health status conferred through full membership of Allied Health Professions Australia, so that self regulating professions within the same alliance are not priced against one another on the basis of historical category alone.
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Provide a basis for recognising clinical complexity and risk in psychosocial therapy pricing, including funded professional consultation, non face to face work and after hours clinical responsibility.
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Revisit provider travel rules and regional loadings so they reflect the real distances of large regional areas rather than metropolitan assumptions, and preserve home visiting for participants who cannot travel to an office.
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Require that where an Annual Pricing Review recommendation rests on an asserted inability to identify a workforce, the Minister may not rely on it until the NDIA has demonstrated that existing identification mechanisms are insufficient, including its own claiming guidance, the Healthcare Identifiers Service, peak body registration data, and the tiering already applied by schemes such as WorkSafe Victoria.
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Require consultation with affected professions and their peak bodies before a determination affecting them is made, and public reporting on access impacts in regional and thin markets, including provider exit and treatment refusal on safety grounds.
Closing
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Submission 2518
THACG Submission: NDIS Future Generations Bill 2026
I would welcome the opportunity to give evidence, and to provide further detail on any matter raised here if that would assist the committee. Thank you for reading a regional clinician’s submission alongside the larger ones. The view from a small practice in the Latrobe Valley sometimes shows you what the national picture smooths over.