Submission 2519

Submission to the Senate Community Affairs Legislation Committee on

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

Prepared by Carer Solutions July 2026

Carer Solutions Payroll Pty Ltd ABN: 19 655 854 907 trading as Carer Solutions Head Office: Level 1, 2 Macquarie St, Prahran, Vic 3181 Website: CarerSolutions.com.au

Contents

Executive Summary ……………………………………………………………………………….. 3
About Carer Solutions ……………………………………………………………………………. 4
Key Terminology…………………………………………………………………………………………. 5
Submission Points…….…………………………………………………….………………………..………………….6
Recommendations………………………………………….…………………………………………………………..9

Submission 2519

Executive summary

By way of introduction, Carer Solutions provides a unique Direct Employ service for NDIS Participants and Nominees who have chosen to self-direct their supports. Our service supports them to directly employ trusted Support Workers they have chosen themselves. We provide the payroll, employment compliance and safeguarding infrastructure behind those arrangements, while the Participant or Nominee remains the employer.

Carer Solutions supports the Government’s objective of securing a sustainable and safe NDIS for future generations. We recognise the need to strengthen safeguards, improve integrity and ensure the Scheme can continue to support people with disability over the long term.

However, Minister Butler’s reform announcement has created significant uncertainty, fear and frustration across the disability community. People are being asked to prepare for major changes to their supports and arrangements without enough operational detail to understand what will change, when it will change or how they will be affected.

Our submission focuses on three areas:

Self-directed supports must be explicitly recognised, clearly defined and given an appropriate pathway. The reform framework must clearly recognise self-directed supports as a legitimate and safeguarded category of support, provide practical guidance for Participants, Nominees and services, and establish an appropriate regulatory pathway for intermediary services that support these arrangements.
Regulation and pricing must reflect actual risk. Registration status alone does not determine whether a service is safe, compliant or well governed. The Government must assess the safeguards and responsibilities that exist in practice.
Budget resets must not shift responsibility from government onto unpaid carers. Reducing Social, Civic and Community Participation budgets will reduce access to support and leave families to fill the gap. Unpaid care is not a substitute for the individualised support people need to participate in community life.

A sustainable NDIS needs diverse, well-governed support models. It must protect supported self-direction, regulate according to actual risk and avoid reforms that shift responsibility from the Scheme onto Participants, families and unpaid carers.

Submission 2519

About Carer Solutions

Carer Solutions is an intermediary service provider that enables NDIS Participants to directly employ their own disability Support Workers under a compliant employment framework. We provide payroll administration, employer compliance, safeguarding governance and workforce assurance services so that participants can exercise genuine choice and control over who supports them, when and how.

Our service model is distinct from both traditional registered providers and sole-trader Support Workers. We operate as the compliance and governance layer between Participants and their directly employed Support Workers, managing obligations including:

Fair Work and SCHADS Award compliance, including payroll processing, supersannuation, leave entitlements and employment contracts
Screening and onboarding of Support Workers
Ongoing workforce oversight and incident management
Safeguarding controls that protect both Participants and Workers
Investment in systems and technology to monitor and report compliance

Carer Solutions employs dedicated full-time equivalent (FTE) staff specifically for compliance functions, with additional indirect FTEs supporting governance, onboarding, payroll and regulatory engagement.

We deliver services across diverse geographic contexts, including metropolitan areas, regional, remote and very remote communities such as Christmas, Cocos (Keeling) and Norfolk Islands and communities in East Arnhem Land.

While Carer Solutions is not currently registered because the existing framework does not provide an appropriate pathway for our model, we carry significant compliance costs that are comparable to, and in some cases higher than, those of registered providers.

Our model relieves Participants of the substantial administrative and compliance burden of employing their own Support Workers, while preserving the Participant choice and control that is foundational to the NDIS.

Submission 2519

Key terminology

Self-directed supports

Drawing on NDIS guidance, self-directed supports are arrangements where an NDIS Participant, or their Nominee, chooses and manages their own supports rather than receiving them through a traditional provider arrangement.

This can include directly employing Support Workers or engaging independent contractors. The Participant or Nominee retains control over who supports them, how support is delivered and the terms of the arrangement. Providers and Workers delivering NDIS supports remain subject to the NDIS Code of Conduct.

Self-directed intermediary service

For the purpose of this submission, a self-directed intermediary service is an organisation that supports Participants and Nominees to self-direct their supports while managing some of the administrative, compliance and safeguarding responsibilities behind the arrangement.

Carer Solutions is an example. Through its Direct Employ service, it supports Participants or Nominees to directly employ Support Workers they have already chosen and manages payroll, employment compliance, worker screening, WorkCover insurance and safeguarding governance.

Carer Solutions does not employ, recruit, match, recommend, supply or directly deliver Support Workers. It should not be confused with a traditional provider, labour-hire service, marketplace or digital platform.

Why the distinction matters

Self-directed intermediary services have a different role, risk profile and set of responsibilities from traditional service providers, Support Coordinators and Plan Managers. The reform framework needs to recognise that distinction and provide clear regulatory settings that reflect how these services operate in practice.

Submission 2519

Self-directed supports must be explicitly recognised, clearly defined and given an appropriate pathway.

The Government’s Securing the NDIS for Future Generations reforms place a strong emphasis on improving safeguards, strengthening integrity and ensuring the Scheme remains sustainable. Carer Solutions supports these objectives. However, the new regulatory settings must recognise that self-direction, when supported by appropriate payroll, compliance and safeguarding infrastructure, is itself a legitimate and safeguarded model of support.

This is not a niche issue. Carer Solutions has supported 1,532 Australians to directly employ 2,636 Support Workers from within their own local communities. Thirty-three per cent live in MMM5–7 areas, including small rural towns, remote and very remote communities, where traditional provider models are often limited, unavailable or unable to offer the consistency people need.

As the Government develops new provider definitions, registration settings and integrity measures, it must not assume that safety can only be achieved through traditional provider arrangements or broad registration categories.

People who self-direct need clear guidance and certainty. For many people, particularly in thin markets, self-direction is not about avoiding safeguards. It is how they access support safely in the first place. It enables people to maintain trusted Support Worker arrangements and retain control over who supports them, how support is delivered and the terms of the arrangement.

Yet Participants and Nominees are being left to work out how new registration settings apply to their existing arrangements. They need practical guidance on what self-direction means under the reforms, and what obligations apply. Without this clarity, people cannot make long-term employment decisions or maintain stable support arrangements with confidence.

Organisations that support self-direction, such as Carer Solutions, also need an appropriate pathway. Some Participants and Nominees choose to use an intermediary service to manage the payroll, employment, insurance and compliance obligations behind direct employment.

Carer Solutions has spent the past 18 months engaging extensively with the Department, the Commission, Government and the office of Minister McAllister to explain how Direct Employ operates and to understand where it fits within the developing risk-proportionate registration framework. Despite this sustained engagement, there remains no clear or appropriate pathway for a model such as ours, nor clear, coordinated advice on how Direct Employ should be treated under the developing framework.

Without clear recognition, intermediary services supporting self-directed arrangements risk being misclassified, regulated against requirements designed for direct support delivery, or left without an appropriate regulatory pathway altogether. Carer Solutions has had to seek external legal advice to navigate the developing framework because our model sits outside existing categories. Organisations should not need to incur legal costs simply to understand how a legitimate, established model of support will be treated. This uncertainty also leaves Participants and Nominees unsure about the future of arrangements they rely on.

More broadly, this would undermine the Government’s broader objective of creating a more sustainable NDIS. The Government’s Care and Support Economy State of Play highlights the importance of adopting innovative models across the care and support sector. Supported self-direction is one such model. It can respond to local workforce shortages and provide practical access to support where other provider models do not work. In thin markets, the alternative may be no support at all.

Submission 2519

Risk-proportionate regulation and pricing must reflect actual safeguards

The Government’s reforms propose a risk-proportionate approach to regulation. Carer Solutions supports this. However, regulation and pricing cannot be genuinely risk-proportionate if they are based on the assumption that registered services are inherently lower risk or that unregistered services are inherently higher risk.

Risk must be assessed according to what a service actually does, where responsibility sits and what safeguards are in place. Some services carry substantial governance, compliance and safeguarding responsibilities but do not fit neatly within existing regulatory categories.

Carer Solutions is one example. Although Direct Employ does not employ, recruit, match, supply or directly deliver Support Workers, it carries significant responsibility for payroll, employment compliance, worker screening, WorkCover administration, incident management and safeguarding governance.

This is not simply an administrative function. Carer Solutions employs two dedicated compliance FTEs, supported by staff across payroll, onboarding, incident management and regulatory engagement. Our annual compliance costs are approximately $654,000, or around $1,382 for each Participant we support. These costs include worker screening, SCHADS Award compliance, payroll governance, WorkCover purchase and administration, staff training and investment in systems including Salesforce, NetSuite and specialist payroll software.

These are the safeguards that make direct employment safe and compliant. They are not optional overheads.

The current uncertainty surrounding registration pathways exposes a gap in the regulatory framework. Models that do not employ, recruit, match, supply or directly deliver Support Workers should not be assessed against requirements designed for organisations that do. They require regulatory settings that reflect their actual role and responsibilities.

The proposed 10 per cent reduction in maximum price limits for Social, Civic and Community Participation supports delivered by unregistered providers compounds this problem. It creates a financial disadvantage based on registration status, without considering the safeguards, governance and compliance costs a service carries.

A blanket reduction does not distinguish between a low-overhead service with limited safeguards and an intermediary model that invests heavily in payroll compliance, insurance, worker screening and safeguarding. It penalises services that have built the infrastructure needed to support safe self-direction, while providing no mechanism for that investment to be recognised.

This is not risk-proportionate regulation or pricing. It is a blunt measure that risks undermining the compliance, workforce assurance and safeguarding infrastructure the reforms are intended to strengthen.

Submission 2519

The proposed budget resets must not shift responsibility onto Participants and carers

As part of the Government’s reform agenda, budgets for Social, Civic and Community Participation supports will be reset from 1 October 2026, with spending intended to return on average to 2023 levels.

These are substantial reductions for people who rely on this funding to participate in everyday life. These supports are not discretionary. They enable people to get out into their community, maintain relationships and live life on their terms.

Since the announcement, Carer Solutions has heard from Participants and family members who are terrified about what these changes will mean. Some have called in tears, worried about losing the support that allows them to leave the house. For people who have spent years building stable arrangements with Support Workers they know and trust, this is not an abstract policy change. It threatens the routines and relationships that make everyday life possible.

A budget reset does not reduce a person’s need for support. Where funding no longer meets that need, people will be forced to reduce support hours, give up activities that matter to them or turn to family members to fill the gap. This shifts costs and responsibilities from the Government back onto unpaid carers.

That is particularly concerning given carers are reported to experience poorer health, wellbeing and financial wellbeing than other Australians. When paid support is reduced, family members may be forced to reduce their hours, leave work altogether or absorb additional costs to fill the gap. This is not only harmful for families but also economically short-sighted. It reduces workforce participation, increases financial pressure on households and can lead to greater reliance on health, income-support and other public systems. The Government should not treat unpaid family care as a substitute for individualised support.

Minister Butler has also announced a $200 million Inclusive Communities Fund. This investment is welcome, but it cannot be treated as an alternative. It is unclear how the fund will replace the support people stand to lose through the budget resets, particularly in thin markets. A national fund may support worthwhile local initiatives, but it cannot be assumed to reach every community, provide support at the right time or replace the 1:1 support people currently rely on.

These changes also raise serious human rights concerns. Australia has committed through the United Nations Convention on the Rights of Persons with Disabilities to support the right of people with disability to live independently and be included in the community. Reducing the funding people use to participate in community life, without ensuring an accessible alternative is available, moves in the opposite direction.

Submission 2519

Recommendations

Carer Solutions recommends that the Government:

1. Recognize self-directed supports, provide clear guidance and establish appropriate regulatory settings. Explicitly recognize self-directed supports as a legitimate and safeguarded category within the NDIS regulatory framework. Provide clear guidance for Participants and Nominees about how the reforms apply to their arrangements and establish regulatory settings that reflect the actual role and responsibilities of intermediary services that support self-direction.
1. Assess actual risk, not registration status alone. Assess risk according to a service’s actual functions, rather than registration status alone.
1. Remove the pricing penalty for unregistered services that sit outside existing regulatory categories. The proposed 10 per cent reduction in maximum price limits for unregistered providers delivering Social, Civic and Community Participation supports is separate from the October 2026 budget resets. It should not apply to services that carry substantial governance, compliance and safeguarding obligations but remain unregistered because no appropriate category or pathway currently exists for their model.
1. Do not proceed with the budget resets. The proposed reductions to Social, Civic and Community Participation budgets risk undermining the right of people with disability to live independently and be included in the community. They will reduce access to individualised support and shift responsibility from government onto families and unpaid carers.
1. Do not treat the Inclusive Communities Fund as a replacement for individualised support. Ensure the $200 million Inclusive Communities Fund complements, rather than replaces, direct and individualised support, particularly in regional, remote and very remote communities.