Multiple sclerosis participant struggling to access NDIS funding (Participant experience)

Submission 2581

Submission to the Senate Community Affairs

Legislation Committee

National Disability Insurance Scheme Amendment (Securing the

NDIS for Future Generations) Bill 2026

Submitted by: Jarrod Hamilton AI-Assisted Role: Self-managed NDIS participant, independent researcher Date: May 2026 Position on the Bill: Serious concerns

This submission is made at a critical juncture. The Bill before the committee presents as a sustainability and integrity measure. What it actually is is a cost-containment exercise conducted on a scheme whose structural problems have never been correctly named, let alone fixed. The difference matters enormously, because cost-containment applied to a structurally broken system does not fix the structure. It concentrates the damage on the people least able to absorb it.

The stakes are not abstract. For participants like me, they are immediate, material, and compounding. This submission names the structural problems, proposes a specific mechanism to address the pricing architecture failure at the scheme’s core, and asks the committee to hold both dimensions clearly: the scheme must be sustainable, and it must actually work for the people it exists to serve. Those are not competing objectives unless the governance architecture is broken. This submission argues it is, and explains why.

1. Introduction I have thousands of dollars in NDIS funding I am structurally unable to spend. Not because my needs are not real. Because the system has no mechanism to tell me what I am allowed to buy, at what price, from whom, or why. That is not a participant failing to navigate the scheme. That is the scheme failing to be navigable.

I am a self-managed participant living with Multiple Sclerosis, with foot drop, heat-induced muscle spasms, chronic fatigue, brain fog, and short-term memory impairment. The last of those makes navigating a system that is deliberately complex not a bureaucratic inconvenience but a clinical barrier. I barely use my plan’s funding. Not from lack of need. From fear of getting a call up and having to pay something back.

The NDIS was designed as insurance for two things simultaneously: having a disability, and supporting the workforce that serves those who do. Both purposes were legitimate. Both remain legitimate. What the scheme is in practice is something the name never captured and the

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governance architecture was never built to handle: a national disability support infrastructure, underwriting not just individual participants but an entire care economy, on the pricing assumptions of a tightly bounded insurance product. The name was never updated. The governance was never updated. The cost trajectory was the predictable result.

The Bill before this committee is the latest attempt to address that trajectory. It does so by tightening compliance, restricting eligibility pathways, and adding administrative requirements to participant interactions with the scheme. Some of those measures are necessary. None of them address the fundamental pricing architecture failure that makes the scheme simultaneously expensive and unusable for a significant proportion of its participants.

This submission is that experience made structural, and a proposal for the specific mechanism the Bill requires but does not include.

What I find genuinely staggering is that a system incapable of funding a tennis court hire, only the support worker to watch me watch other people play, has simultaneously managed to become one of the most fraud-ridden public programs in Australian history. That contradiction is indicative of structural problems resulting from a pricing architecture with no floor on what can be extracted and no ceiling on what can be obscured. The structural problems elaborated in this submission are the product of an investigation I would never have undertaken had the government not proposed these changes. So I suppose I should say thank you. What I found was a neglected and fully outsourced workforce worse than Uber Eats.

2. Lived Experience Personally, as a self-managed participant I struggle to know what I can even purchase. I’d gotten Kmart workout equipment and gotten a call up over it. When I got on the scheme, which is really super confusing how to access to start off, then even more confusing to know what I can actually buy, I was under the impression it was for things related to my disability. So I got cooling blankets and things for my multiple sclerosis since heat is a problem for me, with really sweaty nights and insomnia with heat related muscle spasms, from Big W, and they told me on the phone that I needed to buy these RRP items from a NDIS equipment provider.

Considering also my symptoms, I suffer with foot drop, muscle spasms, fatigue, brain fog, and short term memory issues. That last one makes it really hard to get everything I need in order to say “I need to update my plan so I can buy heat related things due to aspects not recorded about my condition, or things I’d forgotten I have problems with.”

I also had my plan approved for inner city living, then moved to a rural town that requires a much bigger focus on transport since allied health is far more difficult to access. It took a little over a year to organise an OT to finally reassess my plan, but I’m still lacking memory assistives, if I can even get them, because I don’t know what I can and cannot get.

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Self managed was sold to me as “you can buy outside of NDIS exclusive providers” but the NDIS was also sold to me as “you can update your plan as you need,” not “you need to get an OT to approve any need changes.” The person who approved my plan did so in lieu of reassessing it again, as my plan was approved literally the week I’d moved due to cost of living pressures and black mould.

Truly, if a managed plan is “the provider decides what you need” then that’s very scary, considering the Nicolaitan properties of enforcing a class of people who can understand the system and those who do not. Not just cannot in terms of cognitive capacity, but also those who simply don’t know the confusing rules of the system.

I’m just glad they didn’t try to claw money back from me after my purchases for my disability, including my vaporiser for my spasms.

It truly doesn’t make any sense that they give me such a high cap for spending in some cases. I have $10,474.95 in core supports, $7,211.24 in capacity building support coordination psychosocial coaches, $35,390.28 in capacity building improved daily living skills. First up, what is that actually meant to mean? My cannabis medicine costs $5,268 per year. Without it I require upwards of 100mg of baclofen per day for my muscle spasms. With it I manage on approximately 50mg. The medicine is not recreational. It is the difference between a functional dose of a standard spasticity drug and one that would be clinically concerning at sustained use. They make these figures incredibly precise, but so vague that you can’t spend any of it.

The entire point of the NDIS was, I thought, the realisation that pensioners and disabled people end up just acting as a poor funnel of government money, spending their pension on their medicine and bills and unforeseen-predictable medical requirements to keep them out of the public health system, so hospitals and GPs have less workload.

So me spending my pension on my medicine, taking $439 out of my monthly $1,810.40 pension, is structurally the same as the government paying for and ordering my medicine directly.

In the categories I still don’t know exactly what I can use them for. I know what I bill my support worker as and I’ve thoroughly researched and understood it at some point, but I’ve forgotten, and the system is ever-changing and just confusing to begin with. So I barely use my plan’s funding in fear of getting a call up and having to pay something back.

The “daily living skills” category apparently covers some aspects of outings, like paying for a support worker to go with you, but not for the outing or anything related to it. Like, say I want to go out and do tennis, but after medicine, bills, and rent I’m drawing a deficit in savings or scraping by week to week. I can only pay for a support worker to take me to watch people play tennis, because I can’t afford equipment, court hire, or membership. Yet I have thousands of dollars I structurally cannot use. Sports and activities that fulfil genuine needs, in this case social

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and physical, should be budgeted for separately. If you want to do a sport or activity for psychosocial recovery the phrase “NDIS covers sports” is a complete misnomer.

It seems insanely counterproductive that there can be funding I’m not meant to be touching or using, in relation to my disability, where the prerequisite of “disability needs sorted” must be met before any outing, event or daily interaction occurs in disabled life.

I truly wish we could put in an order for something, get the money for it, and have it purchased by the NDIA, instead of me spending my money first then being reimbursed. Or even something more general like “I have this condition and this need, what can I buy?” and being given a list of things to order.

This experience was the inspiration behind the relative price list proposal, and the system of value physics I’m working on with the help of AI. https://zenodo.org/records/19354391

Through this I’d also realised that support workers get paid by participants, so workers are effectively government paid, just indirectly. Raising this with my support provider led them to the admission that they don’t know how they can continue operating with all these changes, having to cut support coordination, cut workers who’ve been there for years, who know the community.

I mean, there’s no reason the ndis cannot be seen as a dynamic sliding scale of payment or benefit allowance per need, functionally a mutation UBI + civic credit government/economic system I’m working on for fun with AI that I call PREF Because the pensioner is spending and redistributing a gov stipend the gov could easily cover cost of living related disability things like medicine to allow the person to buy equipment for personal use stuff

So all things related to disability gets covered by ndis

And the government gets to both get a chunk of the population to engage in society and in the economy, where any pensioner paying for services is an indirect and moral subsidy to that business where they would not have made a purchase otherwise, where support workers get paid acting as second order redistributors too as they functionally fund a lot of volunteer workers​ ​ I rely heavily on AI to keep my thoughts in track, I can, will and do forget what I’m talking about as I’m talking about it in person, this document and submission is the result of meticulous direction and review to the best of my holey brain(because of all the holes in it from MS).

3. What the Bill Gets Right and Where It Falls Short The Bill’s integrity and compliance measures are directionally correct. Tightening audit requirements, strengthening enforcement powers, and restricting unregistered provider access

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to scheme funds are all necessary responses to documented exploitation. The committee’s attention to these mechanisms is appropriate.

However, the Bill addresses the symptoms of a pricing architecture failure without fixing the architecture itself.

The current scheme operates on broad billing categories with flat maximum caps. A provider billing under “Assistive Technology” or “Daily Activities” can bill anything up to the cap regardless of what is actually being delivered, to whom, at what real-world cost, or with what justification. The NDIS Quality and Safeguards Commission has documented the direct consequences: shower chairs sold at ten times retail price, shoes at five times, mattress protectors at fifty percent above standard retail, all billed legitimately under valid category codes because the system has no mechanism to evaluate the relationship between what is charged and what it actually costs to deliver.

Tightening enforcement within this architecture catches the most egregious and careless actors. It does not structurally prevent the pricing behaviour that produces the NDIS tax, the systematic premium charged to participants simply for being in the scheme, because that behaviour operates within the rules as written.

What the Bill gets right

Before addressing the Future Generations Bill specifically, it is worth noting what the preceding legislation already achieved. The National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026, which received Royal Assent on 8 April 2026, significantly expanded the NDIS Quality and Safeguards Commission’s enforcement powers. Serious contraventions now carry civil penalties of up to $3.3 million. Code of Conduct breaches causing death or serious injury now carry penalties up to $16.5 million, up from $412,500. Criminal penalties of up to five years imprisonment now apply to operating without registration and to ignoring banning orders. These are substantive and overdue improvements to the enforcement architecture, though as this submission will argue, they remain weapons without a targeting system.

The Future Generations Bill builds on that foundation. Its core provisions are: a formal legal definition of substantially reduced functional capacity as the basis for eligibility, replacing the previous reliance on diagnosis; expanded mandatory registration requirements for providers delivering support to participants most at risk of abuse and exploitation; new NDIA civil penalties for non-compliance with information-gathering requirements; and changes to the budget method enabling funding caps for particular types or classes of supports. The shift to functional capacity assessment is correct in principle and removes the pay-to-play inequity of the previous medicalized model.

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Where it falls short

The Bill’s integrity measures will improve the NDIA’s ability to detect and prosecute fraud after it occurs. They will not prevent extractive pricing before it occurs, because they do not address the absence of a pricing benchmark against which extraction can be identified. A provider who sells a shower chair at ten times retail is potentially in breach of the Code of Conduct. But the NDIA has no systematic mechanism to identify that the shower chair cost ten times retail, because there is no government-held registry of what specific products cost versus what they are being billed at. The weapons have been sharpened. The targeting system has not been built.

The Bill’s increased administrative and communication requirements for participants are appropriately directed at improving accountability and responsiveness. The problem is that they apply without distinction between participants who are administratively capable and those who are not. For a participant with acquired brain injury, severe fatigue, or significant cognitive impairment, a tighter timeframe for responding to the NDIA is not an administrative nudge. It is a clinical barrier. More critically, the Bill’s non-contact suspension provision grants an NDIA officer the power to begin a 90-day countdown to plan revocation with no mandated obligation to exhaust reasonable contact methods first. There is no requirement to try multiple channels, contact known providers or support workers, reach emergency contacts, or initiate a welfare check before the clock starts. The officer’s judgement of what constitutes reasonable attempts is entirely unconstrained.

Ninety days without contact from a person with a permanent and significant disability is a signal of escalating concern, not a basis for removing support. Treating it as the latter is structurally indistinguishable from assuming the person is deceased, except that death at least triggers a welfare response. The full detail of what a correct escalation protocol should look like is in section 6 of this submission.

The 90 day rule is like the Mitch Hedberg Dufresnes joke of neglect; of going to dinner, or a handout in this case, to a really busy restaurant with a waiting list. They start calling out names. They say, like, “Disabled, party of two. Table ready for Disabled, party of two.” And if no one answers, they’ll say the name again: “Disabled, party of two.” But then if no one answers, they’ll just go right on to the next name. “Government, party of three.” ​ Yeah, but what happened to the Disabled? No one seems to care. Who can spend on spectacles at a time like this? People are missing cover! You people are selfish. The Disabled Participant has a severe cognitive impairment right now, with a clinical inability to navigate the portal. And they’ve lost their support workers! That’s a triple whammy. Government, search party of three! You can spend once you fund the Disabled.

The foundational supports framework proceeds from a structural assumption this submission contests directly. The assumption is that the correct response to the scheme absorbing too broad a population is to exclude lower-needs participants into separate state-funded programs. The alternative argument is that the correct response is to tier them within the same framework, on the same pricing rules, with appropriately calibrated funding envelopes.

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Every Australian with a disability or functional impairment has some legitimate claim on public support infrastructure. The question is not whether they belong in the system but at what tier and with what entitlement. A child with mild developmental delay and a person with acquired quadriplegia both belong in a coherent national framework. What differs is the funding level, the support obligations, and the administrative pathway, not whether they need funding.

The foundational supports approach reconstructs exactly what the NDIS was built to replace: a patchwork of state-funded programs with their own eligibility rules, their own compliance overhead, their own geographic variation, and their own capacity constraints. A participant whose needs are assessed as lower does not need to leave the framework. They need a different tier within it. The pricing discipline and funding integrity are maintained through the tier structure and the RSP-OOD pricing architecture, not through exclusion. Redirecting lower-needs participants to underfunded and not yet operational external programs does not reduce the underlying need. It relocates it off the federal ledger, onto families, emergency departments, and state systems already under strain, while reconstructing the postcode lottery the NDIS was designed to end.

Finally, and most significantly: the Bill does not address the information architecture failure that causes a substantial proportion of participants to systematically underspend their plans not from lack of need but from lack of knowledge of what they are entitled to purchase. That failure is documented at scale, it is well-researched, and it functions as a structural savings mechanism at the direct expense of participants. It does not appear in the Bill.

There is a structural logic problem underlying all of the above. The plan budget is the NDIA’s own calculated ceiling for what a participant needs. A participant cannot exceed it. The plan is capped by design. Which means a participant is structurally incapable of being the source of cost blowout in the scheme. They cannot overspend. Only a provider can extract more than a service is worth. Only a provider can bill for services that did not occur. The fraud and abuse vector is entirely on the supply side. A Bill that responds to scheme cost pressures by increasing compliance obligations on participants is not targeting the problem. It is targeting the party who is structurally incapable of producing it.

4. The Structural Proposal: RSP-OOD and Registered Price

Spectrums

The mechanism the Bill requires but does not include is a mandatory provider price registry anchored to a Recommended Service Price based on Observational Operational Data, an RSP-OOD.

The RSP-OOD is not a new concept. It is the NDIS equivalent of a Recommended Retail Price. Its function is not to set a hard floor or force a single national rate. It is to give participants,

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planners, and regulators an observable, data-derived benchmark against which any registered provider price can be evaluated. What the RRP does in a retail market, orienting buyers and flagging anomalies, the RSP-OOD does in the NDIS context.

This matters because NDIS funding is not a personal budget in any meaningful sense. It is a participant’s allocated share of pooled public money, the accumulated contributions of every taxpayer in the country, entrusted to them to spend on their disability-related needs. A participant has both a right and a practical need to know whether the price their provider is charging is reasonable relative to what that product or service actually costs to deliver. Currently they have no basis for that judgement. The RSP-OOD gives them one.

The proposal is straightforward. Before any service or product is billed against a participant’s plan, the provider must register the specific item or service, its real-world cost basis, and its geographic context in a public government-managed registry. That registered price is then evaluated against an objectively derived spectrum of difficulty and cost, built from the aggregated data of all registered providers nationally. A shower chair sourced from a general retailer sits at the low-difficulty end and must align with its observable retail cost. A custom-engineered mobility aid delivered to a remote community sits at the high-difficulty end and may justifiably cost more, with that difference documented and visible.

Critically, the enforcement infrastructure to act on extractive pricing already exists. Under the NDIS Amendment (Integrity and Safeguarding) Act 2026, serious contraventions now carry civil penalties of up to $3.3 million, and Code of Conduct breaches causing death or serious injury carry penalties up to $16.5 million. Providers who charge higher prices to NDIS participants than to other customers without justification may already be in breach of the Code of Conduct. The ACCC chairs a taskforce specifically targeting the NDIS tax in collaboration with the Commission and the NDIA. The government has the weapons. What it does not have is a systematic way to identify the targets. An RSP-OOD registry solves that problem. It does not ask the government to build new enforcement powers. It asks the government to give the powers it already has something precise to aim at.

This proposal is a direct application of the relative value physics pricing framework published at https://zenodo.org/records/19354391. The difficulty-floor spectrum, mapping price against observable operational reality from lowest-complexity retail transactions to highest-complexity remote clinical delivery, is the Universal Price Equation applied to the NDIS context. Price is not a flat cap. It is a function of physical constraints on value, extraction ratio, and transactional mass relative to the social price. The RSP-OOD is what makes that function governable in practice.

This produces several structural outcomes the current architecture cannot achieve.

The price spectrum replaces the flat cap. Instead of a single maximum for a broad category, the system maps every registered price against a spectrum from lowest-difficulty to

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highest-difficulty service delivery. The spectrum makes the distinction between retail price-gouging and genuinely complex service delivery visible and objective.

The burden of proof shifts before payment. Under the current architecture, the government pays first and investigates after. Under an RSP-OOD registry, the provider must justify any price above the spectrum baseline before the claim is processed. Fraud becomes structurally harder because unjustified prices are rejected at the point of claim, not discovered months later through audit.

Participants gain legible purchasing power. A condition-linked product registry, where a participant can query their diagnosis or functional limitation and receive a list of eligible, pre-registered products with their validated prices, would transform the experience of self-management from a compliance minefield into a functional tool. The participant knows what they can buy. The price they pay is already validated. The fear of retrospective clawback is removed because the purchase was registered and approved before the transaction occurred. A platform for participant purchase requests, modelled on the self-managed pathway but replacing the reimbursement model with direct pre-approved requests, would eliminate the structural barrier of participants spending their own money first and waiting for reimbursement that may never come, or worse, repayment.

The scale of the category becomes governable. The current broad categories are not pricing mechanisms. They are billing taxonomies. They tell the system which bucket to draw from but say nothing about whether the amount drawn is justified. An RSP-OOD registry converts those buckets into structured markets, each with observable price floors, ceilings, and a spectrum of legitimate variation between them.

5. I Don’t Know What Support I Need Because I Don’t Know What

Support I Can Get

This is not a personal failing. It is a documented structural failure of welfare system design, replicated across every comparable country, across sixty years of research, and apparently across every reform cycle the NDIS has undergone. The experiential and epistemic point runs deeper than navigation difficulty: a participant cannot identify an unmet need they do not know the scheme can address. The information gap does not just make the system hard to use. It makes it impossible to know what you are missing.

In OECD countries, non-take-up rates for eligible social assistance sit between 40 and 80 per cent. Across European means-tested benefits the figure is around 50 per cent. In the UK, £19 billion of support goes unclaimed annually by people who are entitled to it. The research is consistent going back to the 1960s: non-take-up is not evidence that recipients do not need or want the help. The barriers are administrative complexity, lack of information about entitlements, high claiming costs, and fear of retrospective consequences. Those most in need are

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consistently the least likely to participate. The system design produces the gap. The individual absorbs it.

In the NDIS context this dynamic is compounded by the specific cognitive profile of a large proportion of participants. Acquired brain injury, MS, psychosocial disability, developmental delay, chronic fatigue conditions, these are not peripheral cases. They are central to the scheme’s participant population. A system that requires continuous, current knowledge of an ever-changing eligibility framework across three budget categories, dozens of support types, and thousands of billing line items to access funding is not a system designed for the people it ostensibly serves. It is a system designed for people who can hire someone else to navigate it, which is what plan management and support coordination exist to do, adding overhead cost while solving a problem that should not exist.

I have $53,076.47 in allocated NDIS funding across three categories whose practical boundaries I cannot reliably map. I have a condition that causes brain fog and short-term memory impairment. I am the exact participant profile for whom an ever-changing eligibility framework across thousands of billing line items is not merely inconvenient but clinically inaccessible. I do not know whether cooling blankets for MS-related heat sensitivity are eligible. I do not know whether memory assistives are covered under my current plan. I do not know what I could ask for that I have not yet asked for, because the scheme has no mechanism to tell me what is available relative to my condition and functional needs. So I do not ask. My funding goes unspent. It rolls over within the plan period, but at renewal that underspend becomes evidence my previous allocation was too high, and my next plan gets cut.

There is a contradiction worth naming directly. The NDIA provides plan allocations to the cent. My plan carries $10,474.95, $7,211.24, and $35,390.28. That precision is not decorative. It represents the NDIA’s own calculation of what my disability-related needs require. Some of those categories may be over-estimated. Others are almost certainly under-estimated relative to what I actually need but cannot identify or access. Both of those problems exist simultaneously and neither is visible in underspend data.

What is not acceptable is using aggregate underspend as evidence that the allocation was too high, when the NDIA set the allocation figure itself to the cent, and when the scheme has no mechanism to tell a participant what they can actually purchase with it. If the funding is precisely calculated and then structurally inaccessible, the correct response is to fix the access architecture, not reduce the funding on the basis that it went unused.

That same precision raises a harder question. If the NDIA can calculate a participant’s needs to the cent, the plan budget is already the NDIA’s own ceiling for what that participant requires. A participant cannot exceed it. Which means a participant is structurally incapable of being the source of cost blowout in the scheme. They cannot overspend. The fraud and abuse vector is entirely on the supply side, where providers extract more than a service is worth or bill for services that did not occur. The scheme’s cost pressures and the participant’s inability to spend

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their own plan allocation are both downstream of the same absent pricing architecture. They are the same problem at opposite ends of the same ledger.

Under the October 2024 reforms, aggregate underspend figures are now analysed alongside participant outcomes, with large unspent pools creating pressure toward plan reductions on the basis that previous funding exceeded the participant’s needs. The information gap generates underspend. Underspend generates plan cuts. Plan cuts deepen the information gap. The government has built a compounding loop that reduces entitlements for the participants least able to navigate the system to claim them.

This is not an obscure flaw. The NDIA received over 7,000 submissions during the August 2024 consultation on the draft support lists alone. The government has access to its own underspend data. It has access to sixty years of international research on welfare non-take-up. Peer-reviewed literature identifies the administrative functioning and communications strategy of the administering institution as the primary determinant of take-up rates, more significant than any individual claimant characteristic. A government administering a scheme whose participant population is defined by the impairments that most impede system navigation, and which has not built a plain-language condition-linked eligibility tool in over a decade of operation, has no available defence of ignorance.

Whether this gap persists by design or by neglect is structurally irrelevant. A known problem that produces measurable harm, that has documented solutions, and that remains unaddressed across multiple reform cycles, is indistinguishable from an intentional one. The underspend is used as evidence against the participant at the next plan review. The participant goes without. The reform cycle continues without addressing it.

I ask the committee to consider a mandatory condition-linked eligibility tool as part of this Bill’s scope: a searchable registry where a participant can enter their diagnosis or functional limitation and receive a validated list of eligible supports, pre-registered prices, and approved providers. This is not a novel technical challenge. It is a political choice about whether participants are entitled to understand what they have been allocated.

Research references for this section: OECD non-take-up rates (Cambridge Journal of Social Policy, Barcelona B-MINCOME study): https://www.cambridge.org/core/journals/journal-of-social-policy/article/why-do-poor-people-not-t ake-up-benefits-evidence-from-the-barcelonas-bmincome-experiment/D8D53581D21A5223AC1 4A9380099A9E9 — UK £19 billion unclaimed: Policy in Practice 2024: https://policyinpractice.co.uk/wp-content/uploads/2024/10/Report_Missing-out-19-billion-of-supp ort-1.pdf — NDIS unspent funds rollover and plan renewal mechanics: https://www.disabilitysupportguide.com.au/talking-disability/what-happens-if-you-overspend-or-u nderspend-your-ndis-plan-budget — NDIS October 2024 consultation: https://www.ndis.gov.au/changes-ndis-legislation

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6. The Participant as Vehicle There is a structural dimension to the scheme’s design that this Bill does not address and that the committee should understand. It is not a criticism of the scheme’s intent. It is a description of how the money actually moves, and what that means for accountability.

Every dollar in every participant’s plan originates in consolidated government revenue. It is allocated through an individual plan, flows through a provider, into worker wages, and partially returns to government through income tax, GST, and superannuation. The participant is not the financial beneficiary of that circulation in any meaningful economic sense. They are the vehicle through which public money enters the private care economy at arm’s length from the government that issued it.

This architecture has practical consequences that the Bill compounds rather than addresses. A participant plan is not a bank account. It is a voucher with strict categorical restrictions. Money allocated to capacity building cannot fund a support worker’s travel. Money in core supports cannot purchase a piece of assistive technology that falls under a different line item. If a participant’s needs change mid-plan, accessing additional funding or recategorising existing funding requires a plan review, which requires an OT assessment, which requires a waiting list, a referral, and often significant out-of-pocket cost to initiate.

I moved from inner-city Sydney to a rural town mid-plan. My transport needs changed fundamentally overnight. Allied health is hours away. Everything that was walkable is now inaccessible. It took over a year to get an OT reassessment and update the plan to reflect that reality. During that year, I had funding I could not spend on what I actually needed, and no funding for what I did need. That is not a system responding to need. That is a system responding to paperwork.

The voucher structure also means that consistent underspend is used at plan renewal to justify reducing future allocations. A participant who cannot find a provider in their area, cannot navigate the administrative requirements, or is too symptomatic to engage with the process does not receive the equivalent value in any other form. The entitlement is compressed over successive plan cycles. From a budget management perspective this functions as a structural savings mechanism. From a participant perspective it is a penalty for being disabled in a way that makes administrative engagement difficult.

This is the population the scheme exists to serve. Schedule 2 of the Bill provides that the CEO may suspend a participant’s plan if they are not contactable after reasonable attempts, with full revocation of participant status if the participant remains suspended for 90 days. There is no hearing. No formal decision. No tribunal. Gone.

The Bill does not define reasonable attempts. The NDIA officer making the call sets their own standard. There is no minimum number of contact attempts specified, no requirement to try different communication channels, no requirement to contact known providers or support

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workers who might be able to reach the participant, no obligation to attempt contact with emergency contacts or plan nominees before suspension begins, and no welfare check obligation attached to the process at all. A participant could have lost their phone, changed numbers, forgotten a password, or be in a period of acute symptoms. The NDIA officer has no mandated pathway to establish which of those is true before the clock starts.

This administrative gap is highly dangerous, it actively enables coercive control and provider abuse—dynamics extensively documented by the Disability Royal Commission. The non-contact suspension provision provides an ultimate, frictionless dumping mechanism for abusive providers. If a provider controls a participant’s communication or wishes to dispose of a complex client, they can simply intercept or ignore the NDIA’s contact attempts. This weaponizes the administrative architecture, allowing the provider to use the NDIA to formally revoke the participant’s plan and jettison the client, thereby aiding in administrative neglect and coercion. Furthermore, the rule’s justification as an integrity measure against fraud on deceased or non-contactable participant accounts is questionable, as a determined bad actor would simply fake the necessary documentation (such as forms or signatures) to continue billing, rendering the non-contact suspension ineffective against the primary fraud vector on the supply side.

Ninety days is not an inherently unreasonable window. What is unreasonable is what happens at the end of it. The correct response to three months of failed contact with a cognitively impaired, chronically ill, or psychosocially vulnerable person is a mandated welfare escalation protocol: contact across multiple channels, then contact with known providers and support workers, then contact with emergency contacts or nominated representatives, then referral to a welfare check through the appropriate state agency. Ejection should come only after that protocol is exhausted and it has been positively established that the person has voluntarily disengaged or has otherwise been made ineligible for welfare, either getting better or death, not simply failing to respond, since overseas travel is tracked by DHS in ‘portability’ rules.

Non-contact is not an administrative non-compliance event for this population. It is a welfare signal. The Bill treats it as the former. For the people this scheme exists to support, silence is far more likely to mean crisis than choice.

If the NDIA cannot contact you, they stop your support. If your support stops, the reason they could not contact you gets worse. That is not a safeguard, that’s structural neglect

I ask the committee to consider whether the Bill’s compliance architecture, which is appropriately directed at providers and bad actors, has been adequately separated from its administrative burden on participants, many of whom already underuse their plans not from lack of need but from lack of capacity to navigate the system safely.

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7. Summary of Asks I ask the committee to consider the following in its report:

That the Bill’s integrity measures be accompanied by a legislative mandate to develop and implement a granular provider price registry anchored to an RSP-OOD, as the structural mechanism without which cap enforcement alone cannot prevent the NDIS tax.

That a condition-linked eligible product and service registry be developed, allowing participants to query their diagnosis or functional need and receive a validated list of purchasable items with pre-registered prices, with a platform for participant requests similar to the self-funded pathway by submitting requests for purchase instead of reimbursements, removing the compliance uncertainty that causes systematic underspend among self-managed and plan-managed participants.

That the Bill’s increased administrative and communication requirements on participants be reviewed specifically for their impact on participants with cognitive, fatigue-related, and communication disabilities, with adjustments made to ensure compliance burden falls on providers rather than on the people the scheme exists to support.

That the committee consider a tiered access model within the NDIS framework as an alternative to the foundational supports offloading approach. Rather than creating separate state-funded programs with their own eligibility rules and compliance overhead, the scheme should establish distinct tiers calibrated to need, all governed by the same national pricing architecture and eligibility tools. The distinction between a participant with mild developmental delay and one with severe acquired disability is a funding level and support obligation question, not an inclusion question. A unified tiered framework maintains pricing discipline, ends the postcode lottery, and makes entitlements portable without requiring a separate program infrastructure to be built and funded from scratch.

That the committee acknowledge in its report that support workers are structurally government-funded employees operating under a private employment fiction, and that the ongoing viability of the support workforce cannot be separated from the pricing decisions the government makes through the annual Pricing Arrangements and Price Limits, as those decisions are wages policy in effect regardless of how they are framed.

8. Closing Statement The NDIS was and remains a necessary and legitimate public institution. It is insurance for having a disability, and for the system that supports those who do. The problems documented in this submission and in the structural analysis linked below are not arguments against the

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scheme. They are arguments for governing it honestly, pricing it correctly, and building the administrative architecture that makes it legible to the people it exists to serve.

The scheme is not failing because disabled Australians cost too much. It is failing because the rules governing what can be charged, by whom, at what price, and with what justification were never defined with enough precision to hold. Every reform cycle that does not address that foundational problem is rearranging the architecture of a building whose price is unbounded and whose inhabitants cannot read the floor plan.

The government is projecting savings of $37.8 billion over four years from this Bill. That figure appears only on the NDIS line of the federal budget. There is no whole-of-government accounting for what Centrelink, Medicare, state mental health services, public hospitals, and housing systems will spend absorbing the needs the scheme stops meeting. The Productivity Commission built the original case for the NDIS on precisely that whole-of-government cost modelling: invest here, save there. This Bill reverses the logic. Cut here, costs flow somewhere else, call it a saving. That is not fiscal discipline. It is cost transfer, or debt thermodynamics, because someone has to pay. The cost does not disappear from the system when it leaves the NDIS line item. It reappears in a hospital bed, a carer’s breakdown, a housing crisis, a Centrelink payment. The government is not reducing cost. It is changing which ledger it appears on.

The five asks in this submission are not aspirational. They are specific, technically achievable, and directly responsive to documented failures the government already knows about. A granular provider price registry that aims to make fraud nigh impossible. A condition-linked eligibility tool. A compliance framework that distinguishes between participants and providers. An honest acknowledgement that support workers are de facto government employees and that pricing decisions are wages policy. None of these require new legislation beyond the mandate to build them. They require political will to treat the scheme as the public infrastructure it actually is, rather than the arms-length market it was always only nominally pretending to be.

I ask the committee to consider my lived experience and the structural proposal presented here when reviewing this Bill. The NDIS has the potential to be what it was always supposed to be. That potential is not served by reforms that trim the visible cost while leaving the structural failures intact. It is served by building the architecture that was never built the first time.

Jarrod Hamilton May 2026

The government is not 226 people in Canberra. It is the collective institutional expression of the will of Australians and their residents. I’m fully aware of what the government’s idea is doing, and we need one that takes care of its constituents and advances all Australia fairly.

Supporting material: A Structural Analysis of the National Disability Insurance Scheme: Failures, Mechanics, and Systems Governance(Appended below) Research publication: https://zenodo.org/records/19354391

Submission 2581

A Structural Analysis of the National Disability

Insurance Scheme: Failures, Mechanics, and

Systems Governance

Executive Summary

The National Disability Insurance Scheme was built on a sound premise: pool national risk to provide insurance for Australians with permanent and significant disability, and for the workforce and systems that support them. That premise has not failed. The structure built around it has.

What this document traces is not a story of bad intentions but of predictable systemic collapse across multiple compounding layers. A scheme designed as the top tier of a layered support network became the only tier. A funding model that lacked any anchor to real-world pricing handed the market a blank cheque. A verification architecture that paid first and asked questions later created one of the most accessible fraud environments in Australian public administration. A market model premised on economies of scale produced the opposite, rewarding micro-operators and penalising every provider that tried to grow. And a name that said insurance was carrying, silently and without the governance structures required, the full operational function of a national support scheme.

The reforms underway address the symptoms. This document addresses the structure. It identifies the RSP-OOD that was never built, the price spectrum that was never mapped, and the burden of proof that was never correctly assigned. It names the information gap that structurally suppresses legitimate demand: a participant cannot identify support they do not know the scheme can provide, their plan underreads their actual need, the funding goes unspent and rolls over within the plan period, but consistent underspend is then used at plan renewal to justify reducing future allocations while the government records a neutral outcome. Non-take-up rates for eligible welfare support sit between 40 and 80 per cent across OECD countries. The research on why has existed since the 1960s. A government administering a scheme whose participants are defined by the impairments that most impede system navigation, and which has not built a plain-language eligibility tool in over a decade of operation, has no available defence of ignorance. It names the employer fiction at the centre of the scheme: a government workforce operating under a private payroll structure, with the participant as the vehicle through which public money circulates into the private economy and blame is laundered back onto providers, workers, and the market. It traces that fiction to its origin in 1967, when the government first chose to fund a disability workforce without employing one, and maps how every subsequent policy layer, from block grants to HACC to the NDIS itself, inherited that architecture without questioning it.

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The argument here is not that the NDIS should be smaller. Insurance for having a disability, and for the system that provides for those who do, is a legitimate and necessary public function. The argument is that a scheme of this scale, simultaneously a disability safety net, a support infrastructure, and the primary financial engine of an entire care workforce, requires governance architecture honest enough to name what it actually is. What follows is a structural diagnosis of why it was never built that way, and a set of engineering principles for what that architecture should look like.

Table of Contents

1.​ The Core Functional Breakdown of the Existing Scheme

2.​ Legislative Trajectory and Attempted Fixes

3.​ The Mechanics of Leakage: How the Money is Extracted 4.​ The Interface Layer and the Absence of Definition Integrity

5.​ The Information Gap: Not Knowing What You Need Because You Don’t Know What You

Can Get

6.​ The Matrix of Contextual Difficulty and Price Spectrums

7.​ Bounded Fraud and Statistical Governance

8.​ The Dual-Function Engine: Insurance and Labor Subsidy

9.​ The Employer Fiction

10.​The Definitional Drift

11.​The Inverted Scale Discount

12.​The Pension Suppression Mechanism

13.​The Historical Chain

14.​The Three Shields

15.​Deficit-Driven Value and the Topology of Obligation 16.​References

1. The Core Functional Breakdown of the Existing Scheme The breakdown of the National Disability Insurance Scheme (NDIS) stems from a deep mismatch between what the law originally intended and how it actually runs in practice. Over the past decade, the system has grown into an unsustainable structure due to several compounding basic design flaws.

The “Lifeboat in the Desert” Effect

The NDIS was designed to support Australians with severe, permanent disabilities. It was meant to be the top tier of a highly functioning broader support network. However, because state

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governments and community programs severely underfunded everyday disability services over the last decade, the NDIS became the only real option for receiving care [1]. This caused the scheme to expand far beyond its original purpose. Families with children presenting low-to-moderate developmental delays or autism entered the scheme because early intervention supports simply did not exist outside of it. The scheme became a lifeboat in a desert. That is not evidence the population was wrong. It is evidence that the support infrastructure outside the scheme had been allowed to collapse, and that the governance architecture inside the scheme was never built to handle the scope it was always going to carry.

The Unsustainable Cost Trajectory

Driven directly by the lifeboat effect and a critical lack of internal cost controls, participant numbers grew from approximately 400,000 in 2020 to 739,414 as at June 2025, representing 85 per cent growth in five years and approaching a doubling of the scheme’s population [1, 30]. Without major intervention, the scheme was projected to cost $64 billion annually by 2029 [1]. This trajectory threatened the viability of the entire federal budget, shifting the scheme from a carefully managed insurance pool to an unconstrained drain on public funds.

Inequitable and Medicalized Planning

Historically, getting access and funding heavily relied on medical diagnoses and the sheer volume of specialist reports a person could provide. This created a deeply unfair system. People with the financial means and the know-how to buy multiple expensive health reports secured larger funding packages. Conversely, those who could not afford the upfront costs of paperwork received substantially less.

This structural inequity was heavily documented in the 2023 Independent Review of the NDIS [1]. The review found that the reliance on medicalized evidence, such as comprehensive functional assessments or diagnostic reports that frequently cost between $1,500 and $3,000 out-of-pocket, created a system that inherently favored higher-socioeconomic participants [2]. Those with financial means and high health literacy could privately fund multiple reports, providing the exact language required by the National Disability Insurance Agency (NDIA) to justify expansive, highly funded plans. This effectively allowed them to buy better plans.

Conversely, individuals without the upfront capital, those in regional areas lacking private specialists, or those without the literacy to navigate the complex bureaucracy were forced to rely on underfunded public health systems with years-long waiting lists. Operating strictly on the paper evidence provided, the NDIA consistently granted these individuals significantly smaller plans or rejected them entirely, despite their actual functional needs potentially being higher [3]. This dynamic fundamentally shifted the scheme from needs-based funding to evidence-based funding, directly tying the size of a participant’s support package to their financial capacity to procure paperwork.

Furthermore, this reliance on medical diagnoses rather than functional capacity frequently led to “sympathy planning.” Certain specific diagnoses automatically triggered large funding blocks,

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even if the individual’s actual day-to-day functional impairment was relatively low. The resulting budgets were incredibly rigid. Because funding was tied tightly to specific medical recommendations, the NDIA built plans line-by-line based on those reports, locking funds into specific categories. The budget reflected the paperwork, not the person [4].

Systemic Fraud and Exploitation

The rapid growth of the scheme, combined with its highly complex and poorly defined billing rules, created a lucrative environment for bad actors. The system lacked the rigorous checking processes required to prevent aggressive marketers, unregistered providers, and opportunistic operators from overcharging, price-gouging, or billing for services that never happened.

2. Legislative Trajectory and Attempted Fixes In response to these massive threats to the scheme, federal and state governments introduced a wave of law changes aiming to shift the NDIS from a diagnosis-based payout to a tightly managed framework based on practical needs [5].

Shifting from Medical Diagnosis to Functional Capacity

The fundamental eligibility test is being altered. Instead of relying heavily on a medical diagnosis, the scheme shifts to a strict assessment of practical daily abilities. Eligibility is based on what a person can do without assistance from others, specialized equipment, or home modifications. An impairment is only considered permanent if the applicant can prove they have exhausted all reasonable treatments and that further treatment is unlikely to fix the condition.

The Foundational Supports Response

The government’s proposed response to the lifeboat effect is to offload lower-needs participants into separate state-funded programs outside the NDIS, reserving the scheme for those with the highest and most permanent support needs. Children aged 0 to 8 with low-to-moderate support needs will no longer automatically enter the NDIS. They will be routed to external state and community programs [5].

This proceeds from a structural assumption worth contesting directly. The assumption is that the correct response to the scheme absorbing too broad a population is exclusion. The alternative argument is that the correct response is tiered inclusion within the same framework, on the same pricing rules, with appropriately calibrated funding envelopes.

Every Australian with a disability or functional impairment has some legitimate claim on public support infrastructure. The question is not whether they belong in a national framework but at what tier and with what entitlement. A child with mild developmental delay and a person with

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acquired quadriplegia both belong in a coherent national structure. What differs is the funding level, the support obligations, and the administrative pathway, not the whether.

The foundational supports approach reconstructs exactly what the NDIS was built to replace: a patchwork of state-funded programs with their own eligibility rules, their own compliance overhead, and their own geographic variation. A participant whose needs are assessed as lower does not need to leave the framework. They need a different tier within it. The pricing discipline and funding integrity are maintained through the tier structure and the RSP-OOD pricing architecture, not through exclusion. Redirecting lower-needs participants to programs that are underfunded and not yet operational does not reduce the underlying need. It relocates it off the federal ledger onto families, emergency departments, and state systems already under strain, while reconstructing the postcode lottery the NDIS was designed to end.

Standardized Assessments and Flexible Budgets

The legislation aims to phase out the reliance on multiple external medical reports to build a plan. Instead, standard, structured needs assessments will determine funding, shifting the cost of evidence-gathering away from the participant [4]. This aims to generate a holistic, single flexible budget that people can spend across various needs, rather than navigating rigid restrictions on individual items.

Aggressive Integrity and Fraud Crackdowns

New legislation arms the regulatory bodies with severe penalties to clean up the provider market. This includes making it a criminal offense to ignore banning orders, multiplying fines for code of conduct breaches, and granting new powers to demand evidence before a bill is paid, effectively targeting the “pay first, ask questions later” loopholes.

3. The Mechanics of Leakage: How the Money is Extracted

How Unregistered Providers Access Funds

An unregistered provider cannot directly draw money from the government. They depend on how a participant’s funding is managed. While Agency-managed funding requires registered providers, Self-managed and Plan-managed funding structures historically operated on an honor system.

In Plan-managed setups, an unregistered provider emails a bill to a third-party accountant. In Self-managed setups, the participant claims the money and pays the provider directly. Because the automated systems often paid claims before any human verified if the service actually happened, bad actors could generate fake bills for unregistered services, or collude with participants to split the cash. The system lacked real-time verification [10].

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The Registered Business Sale Scam

Becoming a registered NDIS provider requires strict background checks and expensive independent audits. However, this high barrier to entry created a black market for pre-registered companies. An NDIS registration is tied to a specific company’s Australian Business Number (ABN).

Instead of passing an audit, bad actors purchase a company that is already registered. By buying the shares and taking over the ABN, they instantly acquire the ability to bill the NDIA as a registered provider, including accessing high-value funding [9, 11]. While buyers are supposed to update key personnel, the business does not automatically trigger an immediate, ground-up re-audit.

The Umbrella Franchise Scam

Legitimate operators who achieve full registration sometimes sell franchise or sub-contracting rights to entirely unqualified, unregistered individuals. A registered company approved for specialized support allows unqualified workers to operate under their ABN. The unqualified worker performs the job, the umbrella company bills the NDIA at the maximum premium rate, and the owner takes a massive cut. The system assumes a highly qualified professional delivered the care, while the reality on the ground is fundamentally different [11].

4. The Interface Layer and the Absence of Definition Integrity The most critical design flaw of the NDIS is the lack of a highly organized, government-managed digital marketplace anchored by a concrete price book. More specifically, the government outsourced the delivery of care to the market, but fundamentally failed to own and strictly define the rules connecting funding and delivery, the “interface layer,” by establishing a Recommended Service Price based on Observational Operational Data (RSP-OOD).

The RSP-OOD is not a novel regulatory concept. It is the NDIS equivalent of a Recommended Retail Price. Its function is not to impose a single national rate or eliminate legitimate price variation. It is to give participants, planners, and regulators an observable, data-derived benchmark against which any registered provider price can be evaluated. What the RRP does in a retail market, orienting buyers and flagging anomalies, the RSP-OOD does in the NDIS context.

This matters because NDIS funding is not a personal budget in any meaningful sense. It is a participant’s allocated share of pooled public money, the accumulated tax contributions of the entire country, entrusted to them to spend on their disability-related needs. A participant has both a right and a practical need to know whether the price their provider is charging is reasonable relative to what that product or service actually costs to deliver. Currently they have no basis for that judgement. The RSP-OOD gives them one.

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Without an RSP-OOD, the system is entirely blind to the natural spectrum of price. It cannot differentiate between a high-difficulty service and basic retail price-gouging, leaving a massive structural gap for bad actors to exploit.

The “NDIS Tax” and the Rejection of the Price Spectrum

Currently, providers do not register specific products with fixed prices. The scheme relies on broad, abstract categories and maximum price limits, completely ignoring the reality that prices exist on a spectrum relative to how hard the job actually is.

This is not a theoretical vulnerability; it is a heavily documented failure.

-​ The $1,200 Shower Chair: The NDIS Quality and Safeguards Commission has explicitly published findings of severe price markups, documenting cases where a provider sold a shower chair to an NDIS participant for $1,200, while identical chairs were sold to non-NDIS customers for $120 [6]. -​ The $690 Shoes: Similarly, the Commission highlighted complaints of retail markups where a provider charged an NDIS participant $690 for a pair of shoes that retailed for $130 outside the scheme [7].

-​ The $130 Mattress Protector: The Australian Competition and Consumer Commission

(ACCC) has also noted deliberate “twin pricing” strategies, observing providers charging participants $130 for a waterproof mattress protector that is sold to non-participants for $90 [8].

Definition Integrity as State Responsibility

If the state is the sole funder and ultimate risk bearer, it is entirely responsible for ensuring the rules of the system are clear and unbreakable. Pricing, eligibility, service definition, and verification must not leave room for exploitation.

When the rules are vague and disconnected from real-world data, businesses will naturally and predictably optimize for profit within those grey areas. This is not a moral failing of the market; it is a predictable reaction to a weak structure. The state must retain financial responsibility by removing the guesswork.

Operationalizing the Interface: The Equipment Example

In a well-designed system grounded in an RSP-OOD, the provider must proactively register the specific item, along with their exact geographic price. This price is locked into the public spectrum and subject to checks based on objective reasonability. The registered price must map directly to wholesale unit costs, standard assembly labor, and documented shipping costs. If a provider in a major city registers the chair at $3,000, but a provider in a remote region registers it at $3,800, the $800 difference is instantly isolated, visible, and mapped on the difficulty matrix.

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5. The Information Gap: Not Knowing What You Need Because

You Don’t Know What You Can Get

A participant cannot request support they do not know exists. This observation is trivial only until you examine what it produces at scale.

Non-take-up of eligible welfare support is one of the most extensively documented failures in social policy research. In OECD countries, non-take-up rates for social assistance programmes range between 40 and 80 per cent [14]. Across European means-tested benefits the figure sits around 50 per cent [14]. In the UK, £19 billion of eligible support goes unclaimed every year [15]. The research literature going back to the 1960s is consistent on two points: non-take-up is not evidence that recipients do not need or want the help, and those most in need are consistently the least likely to participate [16]. The barriers are not personal failings. They are administrative complexity, lack of information about entitlements, high claiming costs, and fear of retrospective consequences. The system design produces the gap. The individual absorbs it.

In the NDIS context this dynamic is structural and compounding. A participant with cognitive fatigue, brain fog, or short-term memory impairment, the exact profile of a significant portion of the scheme’s participants, cannot maintain current knowledge of an ever-changing eligibility framework across three budget categories, dozens of support types, and a billing taxonomy of thousands of line items. They cannot identify unmet needs they do not know the scheme can address. Their plan underreads their actual support requirement. Their funding goes unspent. Unspent funds roll over within the plan period, but at plan renewal consistent underspend is used as evidence that the previous allocation exceeded the participant’s needs, and the new plan budget is reduced accordingly [17, 27]. The government records an underspend. The information gap generates underspend. Underspend generates plan cuts. Plan cuts deepen the information gap. The loop compounds.

This is not an obscure design flaw. The NDIA received over 7,000 submissions during the August 2024 consultation on the draft support lists [28], the volume of which signals that confusion about eligibility is not marginal but scheme-wide. The government has access to its own underspend data. It has access to sixty years of international welfare research on non-take-up. It knows the cognitive profile of its participant population. The administrative functioning and communications strategy of public institutions have been identified in peer-reviewed research as the primary determinants of take-up rates, more significant than individual claimant characteristics [14, 16]. A government in possession of that evidence, administering a scheme whose participant population is defined by the very impairments that most impede system navigation, and which has nonetheless failed to build a plain-language condition-linked eligibility tool, has no available defence of ignorance.

Whether the information gap is maintained by design or by neglect is, structurally, irrelevant. A known problem that produces measurable harm, that has documented solutions, and that

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remains unaddressed across decades of reform cycles, functions identically to an intentional one. The effect is the same. The underspend is used as evidence against the participant at the next plan review [17, 27]. The participant goes without.

6. The Matrix of Contextual Difficulty and Price Spectrums The upfront registration of a price book does not merely create a static, flat list of numbers blindly applied across an entire continent. When properly implemented, the data naturally generates a clear spectrum of fair prices mapped directly against how hard the job actually is.

The Misunderstanding of the Flat Rate

A common mistake in opposing structured price books is the assumption that a price book enforces a single, unyielding rate that ignores geographic realities or complex clinical needs. A price book is not a national flat rate; it is a public registry.

Establishing the High-Difficulty Floor and the Low-Difficulty Ceiling

By gathering the registered pricing data from thousands of providers, the system naturally plots a curve on a spectrum of difficulty. The system identifies the minimum fee required for the most difficult service provided by any operator. Relative to this, the system maps the lowest price for the easiest service.

The Ideal Provider Baseline

By connecting the low-difficulty ceiling to the high-difficulty floor, the system generates a theoretical “Ideal Provider” baseline for any given point on the difficulty matrix. Every single registered provider in the country can now be plotted on this graph and objectively judged against this ideal provider in their specific difficulty zone.

Shifting the Burden of Proof

If a provider is registering a price that sits far above the RRP for a transaction that the system maps as zero difficulty, that provider is instantly flagged as drifting away from the ideal contextual provider. Unless that provider can instantly supply documented evidence that the product is a specialty, heavily customized item, the price is rejected. The burden of proof shifts entirely from the government trying to detect fraud after the fact, to the provider having to mathematically justify their higher price before the money is ever paid out.

Participant Legible Purchasing Power

The same registry that anchors provider pricing also resolves the information architecture failure on the participant side. A condition-linked product registry, where a participant can query their diagnosis or functional limitation and receive a list of eligible, pre-registered products with their

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validated prices, converts the current compliance minefield into a functional tool. The participant knows what they can buy. The price is already validated. The fear of retrospective clawback is removed because the purchase was registered and approved before the transaction occurred.

A platform for participant purchase requests, modelled on the self-managed pathway but replacing the reimbursement model with direct pre-approved requests, eliminates the structural barrier of participants spending their own money first and waiting for reimbursement. The participant submits a request against the validated registry. The NDIA approves against the pre-registered price. The purchase is fulfilled. No personal outlay. No retrospective risk. The participant does not need to know the billing taxonomy. They need to know their condition and their need.

7. Bounded Fraud and Statistical Governance Attempting to build massive bureaucratic walls that prevent absolutely all fraud is a recognized failure in system design. Heavy-handed prevention systems harm legitimate users, increase administrative costs, create service delays, and paradoxically advantage sophisticated scammers who know how to navigate the complex rules.

Tracking Patterns and Anomaly Detection

Instead of trying to make fraud impossible, the system must permit minor rule-breaking to expose patterns. By strictly capping the prices of small events, the system limits the maximum damage a bad actor can inflict in a single transaction.

Because the system logs timestamps, route types, and persistent provider identities, repeated fraudulent attempts create an undeniable, highly visible data pattern. The system turns fraudulent behavior into clear digital footprints. Every attempted exploit trains the anomaly detection software [12].

Operationalizing Statistical Governance: The Transport Example

Under a data-driven price registry, the transport provider must register their specific operational variables, including base call-out fees, per-kilometer rates, and hourly driver costs. The bill must reflect the objective physical reality of the event. If a provider submits bills claiming a vehicle drove 500 kilometers in a single day entirely within a dense city grid, the mathematical anomaly instantly flags the behavior [12].

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The Governance Philosophy

The correct model is not zero fraud. It is bounded fraud with guaranteed detection. A well-structured price registry and transaction logging architecture structurally limits how much can be taken before the pattern becomes mathematically visible. Small fraud is tolerated not out of negligence but because it functions as a data-generating mechanism. The expected penalty, recovery plus prosecution plus banning, accumulates faster than the expected gain. The system does not need to prevent every bad actor. It needs to ensure that at scale, fraud is more expensive than compliance.

This is the inverse of the current architecture, which has no structural ceiling on how much can be extracted before detection, and therefore rewards the most sophisticated and patient exploiters while catching only the clumsy ones. A bounded system flips that dynamic entirely. The state grants broad operational freedom to providers and participants, locally expansive but globally constrained by real-time data rules, and continuously checks behaviour against those constraints rather than attempting to pre-approve every transaction. It provides the flexibility of an open market with the accountability of a tightly governed public utility.

Critically, the enforcement infrastructure to act on extractive pricing already exists. Under the NDIS Amendment (Integrity and Safeguarding) Act 2026, serious contraventions now carry civil penalties of up to $3.3 million, and Code of Conduct breaches causing death or serious injury carry penalties up to $16.5 million [21]. Providers charging higher prices to NDIS participants than to other customers without justification are already potentially in breach of the Code of Conduct. The ACCC chairs a taskforce specifically targeting the NDIS tax in collaboration with the Commission and the NDIA [11]. The government has the weapons. What it does not have is a systematic way to identify the targets. An RSP-OOD registry solves that problem precisely. It does not require new enforcement powers. It gives the powers that already exist something precise to aim at.

8. The Dual-Function Engine: Insurance and Labor Subsidy

A Safety Net for Major Life Impacts

Structurally, the NDIS acts as a collective buffer against disability-related support costs. It spreads the unpredictable, catastrophic costs of having a disability across the population, preventing individuals and their families from falling into total financial and physical ruin.

Each participant’s plan is not a personal budget in any meaningful economic sense. It is an allocated share of pooled public money, the accumulated tax contributions of the entire country, entrusted to an individual to spend on their disability-related needs. That framing matters for governance. It means every dollar extracted above a justifiable price is not a transaction

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between a provider and a consumer. It is extraction from a national commons, made possible by the absence of the price transparency mechanisms that any well-governed commons requires.

A Massive Job Creator

Simultaneously, the NDIS is a massive, publicly funded care sector employment engine. Support worker income is overwhelmingly derived from government revenue, routed through the participant’s budget. The scheme functions as a decentralized job subsidy, keeping hundreds of thousands of support workers in jobs [13]. Recognizing this dual function is critical. The NDIS is not merely charity expenditure. It is distributed funding for human well-being and a vital pillar of regional economies [3, 13].

9. The Employer Fiction The NDIS is described in policy language as a market. Providers are described as private businesses. Support workers are described as private sector employees. None of these descriptions survive contact with the funding structure.

The scheme is entirely publicly funded. Every dollar flowing to every provider originates in consolidated government revenue, allocated through a participant’s plan, and disbursed against government-set price caps. The provider layer does not introduce private capital. It introduces administration, compliance overhead, and employment liability, while the revenue source remains singular and public.

This is not a theoretical claim. It is visible in the financial statements of the sector’s largest operators. Northcott, one of Australia’s largest not-for-profit disability organisations with over $224 million in annual revenue, reported in a parliamentary submission that 94% of that revenue came from government funding, grants, and the NDIS [18]. Life Without Barriers, with revenue exceeding $863 million, derives the majority of its income from government funding across its disability, aged care, and family services divisions [20]. Aruma, Breakthru, Yooralla, and Multicap follow the same pattern. Their listed funding sources are NDIS plans, state government programs like iCare, and Department of Social Services grants. The self-funded component is negligible. There is no private market underneath the provider layer. There is only a government workforce operating under a private payroll fiction.

The intermediary structure does not change the employment relationship in any substantive economic sense. It changes who signs the contract and who absorbs the liability. The government sets the wage floor through the SCHADS Award. The government sets the price ceiling through the annual Pricing Arrangements and Price Limits. The government controls participant eligibility, plan budgets, and the total volume of work available. The provider administers the paperwork and carries the compliance exposure. When the government froze core support price caps in the November 2025 v1.1 Pricing Arrangements update, the first cap

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freeze of its kind in years, it locked in a structural margin squeeze [29]. The July 2025 update had increased caps by 3.95% against a 3.5% SCHADS wage increase, but the superannuation guarantee had also risen from 11% to 12% simultaneously, meaning total employer cost increases outpaced the cap rise. The November freeze locked that gap permanently into the operating model of every provider in the sector. The government was making a wages policy decision about its own de facto workforce. It simply does not have to call it that.

This is what makes the current reform narrative structurally dishonest. Price cap freezes, tightened compliance overhead, participant number restrictions, and offloading to foundational supports are not market corrections. They are workforce reductions and pay cuts, administered by the actual employer, communicated through the intermediary layer, and framed publicly as scheme integrity and sustainability measures. Northcott’s 2023-24 annual report named this directly, posting a significant operating loss and attributing it explicitly to fundamental issues with NDIS funding and pricing [19]. The providers are not failing. They are being underfunded by the entity that controls every variable in their revenue model, while that entity retains the political cover of not being their employer of record.

There is a second function the intermediary structure performs that is less visible than the payroll fiction. The government allocates public money into individual participant plans. The participant is the vehicle. That money moves through the plan into provider revenue, into worker wages, and back into income tax, GST on services, and superannuation held in financial markets. The government is circulating its own expenditure through a population of individual accounts to generate private sector economic activity, recovering a portion through taxation, while the transaction appears on the surface to be a private individual purchasing a private service. The participant is not the financial beneficiary of that circulation. They are the conduit through which public money enters the private economy at arm’s length from the government that issued it.

This architecture does not just obscure the employment relationship. It obscures accountability for every outcome the scheme produces. When prices get gouged, it is a bad provider. When workers cannot stay viable, it is a market problem. When costs blow out, it is scheme abuse. When participants lose support through eligibility tightening, it is a necessary correction to an unsustainable insurance scheme. The government designed, funded, and governed every one of those outcomes. The structural looseness is what allows each one to be attributed elsewhere. A tightly governed scheme with honest scope definition and real-time price verification would leave accountability with nowhere to hide. The ambiguity is not a design failure. It is blame laundering. The smoke is the scheme’s own complexity, a provider layer, a participant vehicle, a market fiction, thick enough that responsibility genuinely cannot be located. The mirrors are what that complexity makes possible: every outcome the government produced reflected back as someone else’s fault. Bad provider. Market failure. Scheme abuse. Unsustainable insurance. The government remains clean at the centre of a structure it designed, funded, and controlled at every point.

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10. The Definitional Drift The NDIS had two purposes baked into its original design, even if only one made it into the name. The first was to fund individuals against the costs of permanent and significant disability, keeping them out of hospitals, emergency systems, and the kind of downstream crisis that costs the public system far more than early support ever would. The second was to provision the support workforce itself, because without a centralised funding mechanism, support workers had no viable revenue source except extracting from participants’ own pension and welfare payments. Both purposes were real. Both were always present. The scheme was insurance for having a disability, and insurance for the system that provides for those who do.

What it was called was an insurance scheme. What it was run as was an insurance scheme. The funding model, the cost projections, the eligibility framework, the governance architecture, all of it calibrated to insurance assumptions. Defined risk. Bounded liability. Calculable ceiling.

But what it structurally became in practice is the National Disability Insurance and Support Scheme. One word never added to the name. That single omission is where every problem in this document was born. An insurance scheme has a calculable liability. A support scheme has a scope of obligation. They are not the same thing and they cannot be governed the same way. The NDIS absorbed early intervention, psychosocial disability, developmental delay, and the functions of state community services that were defunded before the scheme existed. It did not just insure against the costs of disability. It became the operational infrastructure of disability support in Australia, while being governed, funded, and politically defended as though it were still just writing cheques against a defined risk pool.

The $64 billion projection is not a blowout. It is the honest cost of a support scheme finally becoming too large to be obscured by insurance language.

11. The Inverted Scale Discount The market model was chosen over direct public provision on a specific economic premise: competition and scale would drive costs down without the government having to manage a workforce. The foundational promise of any market is that mass production makes things cheaper. A provider serving thousands of participants would develop bulk purchasing power, centralised administration, and streamlined logistics. Unit costs would fall. Quality would rise. The government would get more support delivered for less money than it could ever achieve running the system itself.

It ran directly backwards.

The compliance architecture imposed on registered providers scales geometrically, not linearly. Audit costs, workforce scheduling obligations under the SCHADS Award, incident reporting requirements, restrictive practice authorisations, and worker screening checks do not get cheaper per person as an organisation grows. They multiply. A sole trader working under an

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ABN with a handful of self-managed clients carries essentially none of this overhead. Northcott, running more than 123 disability homes and employing over 3,000 staff, carries it entirely [19]. Both bill at the same government-set price cap.

The result is that growth destroys margin. Every additional participant a large provider takes on adds compliance cost that the flat price cap cannot absorb. Northcott posted a significant operating loss in 2023-24 and named NDIS pricing directly as the cause [19]. Meanwhile micro-enterprises and gig economy platforms like Mable and Hireup flourished precisely because they carried none of the infrastructure burden. The sector did not consolidate as a functioning market would. It fragmented [25]. The compliance architecture designed to protect participants from underqualified providers ended up systematically rewarding the operators least subject to it.

The economies of scale that justified the market model never arrived. The government got the worst of both worlds: the administrative complexity of a regulated market without the cost efficiency a genuine market was supposed to produce.

The downstream effect extends beyond the NDIS itself. Because the scheme historically lacked strict price limits and allowed unregistered providers to operate with minimal compliance overhead, it created a comparatively lucrative environment for care workers. Support work under the NDIS paid more, or offered more flexible hours, than equivalent roles in aged care, early childhood education, and public hospitals, all of which are more tightly regulated and lower-margin. Workers migrated toward NDIS work not because the pay was generous in absolute terms but because the structural looseness of the scheme made it more financially viable for providers to offer better conditions than sectors operating under stricter governance. The result was a gravitational pull on the broader care workforce, starving adjacent sectors of staff they could not afford to lose, while the NDIS absorbed workers into a system that was itself structurally unsustainable.

12. The Pension Suppression Mechanism The NDIS did not emerge in a vacuum. It was dropped onto a welfare architecture that had spent decades deliberately suppressing its baseline income support payments. The Disability Support Pension had been made progressively harder to access, with strict impairment tables and Program of Support rules functioning as active gatekeeping mechanisms rather than eligibility assessments. The cash rate was held below the real cost of living with a disability. This was not accidental. A permanently indexed, liveable cash pension represents an open-ended, compounding liability on the federal balance sheet. Vouchers do not.

An NDIS plan is structurally a voucher. Money is legally locked into specific line items and funding categories. It cannot be redirected to rent, food, or transport outside approved support categories. If a participant cannot find a provider or cannot navigate the administrative complexity of their plan, their funding goes unspent. Unspent funds roll over within the plan period, but at renewal consistent underspend is used to justify reducing the next plan allocation

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[17, 27]. The compression is gradual and invisible. A pension payment, once made, cannot be clawed back in the same way.

This architecture served a precise fiscal purpose. By routing support through a corporate pipeline of providers, intermediaries, plan managers, and compliance bodies, the government kept billions of dollars enclosed within a closed-loop system it controlled at every point, while keeping the direct cash transfer of pensions as suppressed as possible on the public ledger. The participant is not just a vehicle for labour market circulation. They are a vehicle for pension avoidance. The billions in overhead consumed by plan managers, compliance auditors, corporate administration, and scheduling platforms represent money that could have gone directly to individuals as income, purchasing power, and genuine financial autonomy. It did not, because genuine financial autonomy for disabled Australians was never the design objective. Containment was.

None of this negates the legitimate purpose the scheme was built to serve. Insurance for having a disability, and for the system that supports those who do, is a genuine and necessary public function. The costs of permanent and significant disability are real, variable, and often catastrophic at the individual level. Pooling that risk nationally is the correct structural response. The failure is not the insurance model. It is that the insurance model was used as a replacement for adequate baseline income support rather than a complement to it. A properly indexed pension and a well-governed insurance scheme are not alternatives. Running one as a covert substitute for the other is what produced the architecture this document describes.

13. The Historical Chain The employer fiction did not begin with the NDIS. It was the founding architecture of Australian disability support and every model that followed inherited it without question.

In 1908 the Commonwealth introduced the Invalid and Old-Age Pensions Act [24]. The cash rate was set below the real cost of survival and assumed that care would be absorbed by family or by the walls of state-run institutions. No support workforce existed because no support workforce was funded. The government paid for segregation, not support.

By the 1950s families were refusing institutionalisation and building their own day spaces and informal workshops. The government saw an opportunity. Rather than build a public care workforce, it formalised the charity model through the Sheltered Employment Assistance Act 1967 [22, 23] and the Handicapped Persons Assistance Act 1974 [22], providing capital grants and recurrent subsidies directly to NGOs to employ the first recognisable iteration of support workers. The structural decision made at that point has never been reversed. The government would fund the workforce. It would not employ them. The NGO layer absorbed the wage liabilities, the industrial award obligations, and the reputational cost of rationing scarce resources. The treasury stayed clean.

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This boundary was inherited by every subsequent model. The Home and Community Care Act 1985 devolved operational responsibility to the states while the Commonwealth retained funding control. The Disability Services Act 1986 formalised community-based support but refused to attach an entitlement-based financial model to it [22], producing the postcode lottery where access depended entirely on which state you lived in and what grants its charities had managed to secure. For thirty years support worker organisations survived by stitching together funding from multiple short-term state-based program buckets, each with its own compliance rules and arbitrary caps.

When the NDIS arrived it changed how the money moved. It did not change the employment architecture. The government converted block grants into individual plans, introduced a price guide, and called it a market. But the price guide it built bore no resemblance to how a real market prices goods. Instead of granular, product-isomorphic pricing anchored to observable real-world costs, the scheme created broad vague categories with flat maximum caps. The equivalent in a supermarket would be a single price ceiling for everything in the aisle labelled fruit and adjacent products, another for meat and dairy, with no distinction between a bag of apples and an imported truffle, between mince and wagyu. Every provider, regardless of what they were actually delivering, billed to the ceiling of whichever broad bucket their service fell under. The price guide was not a pricing mechanism. It was a billing taxonomy with a cap. The support worker remained employed by a private intermediary, funded by the government, governed by the government, paid within limits set by the government, and entirely excluded from the protections and security of public sector employment. What began as a 1967 administrative convenience to avoid public sector wage liabilities became, sixty years later, a $40 billion annual workforce that the government can reshape, underpay, and restructure without ever having to sit across a bargaining table from the people doing the work.

14. The Three Shields The blame laundering identified in The Employer Fiction operates through three distinct and reinforcing mechanisms that have been refined across the full history of Australian disability policy.

The first is the operational shield. By keeping hundreds of thousands of support workers casualised and employed by private organisations, the government has no direct bargaining obligation with the workforce. When frontline workers report burnout, understaffing, and unsustainable pay, the government does not respond as an employer. It adjusts a line item in a price guide and instructs providers to manage their efficiencies. The workforce crisis is framed as a market failure. Yet the entity controlling every variable of that market remains uninvolved.

The second is the financial shield. Because the system is a bureaucratic maze of line items, funding categories, and compliance requirements, billions of dollars go unspent each year as participants fail to find providers, cannot navigate their plans, or encounter thin markets in regional areas. The government treats this underspend as a budget saving and uses it at plan renewal to justify reducing future allocations. The structural cause, its own pricing decisions

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rendering vouchers unusable in large parts of the country, is attributed to administrative friction in the pathway. The underspend is recorded as evidence the participant’s needs were met [17, 27]. The participant is recorded as having had access to support.

The third is the moral shield, and it is the most corrosive. The cover policy architecture from the sheltered workshops forward has always forced the people who care most to become the face of rationing. In the block-funding era, charity directors turned desperate families away because the government had capped their grant. In the NDIS era, support coordinators tell participants their funding has run out. Plan managers reject invoices that fall outside legislative definitions of reasonable and necessary. Providers exit service categories because the economics no longer work. The people closest to the human cost of the system’s failures are the ones delivering the bad news, absorbing the anger, and carrying the moral weight of decisions made in a treasury spreadsheet.

The institutional apparatus remains clean, distant, and perfectly audited. Those with the greatest capacity to fix the system disclaim responsibility for its failures by ensuring that every point of visible failure has a private intermediary standing in front of it.

15. Deficit-Driven Value and the Topology of Obligation The NDIS is routinely framed in cost terms. Billions spent, billions projected, billions at risk of fraud. That framing, while not inaccurate, systematically omits the other side of the ledger.

A person with a significant disability who loses support does not simply stop costing the public system. They cost it differently, and almost always more. The support that keeps someone in their home, managing daily life and maintaining community connection, is the intervention that prevents an emergency hospitalisation, a mental health crisis, a family carer breakdown, a homelessness event, or a residential aged care placement triggered decades before it would otherwise be necessary. Each of those downstream outcomes carries a public cost that dwarfs the support it replaced. The NDIS does not spend money on disability. It spends money to prevent a far more expensive set of outcomes from landing on the health system, the housing system, and the informal care economy simultaneously.

This is the topology of obligation the scheme maps. Functional gaps in a person’s capacity to live independently are not merely absences. They are predictive signals. An unmet need today is a downstream crisis tomorrow, the cost of which is diffuse, delayed, and therefore invisible in annual budget cycles but structurally certain. The scheme draws labour into those gaps not as charity but as load-bearing infrastructure, the thing that keeps other more expensive systems from absorbing the weight.

The funding model and governance architecture must be evaluated against this full cost picture. A scheme that spends $40 billion on support while preventing multiples of that in downstream health, housing, and welfare costs is not a budget problem [26]. It is the cheapest available option, being governed as though it were an extravagance. The reforms that cut eligibility, freeze

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price caps, and reduce participant numbers may reduce the visible NDIS line item. They will not reduce the underlying need. They will redistribute it onto systems with even less capacity to absorb it.

There is also a positive economic case that the deficit-prevention framing understates. The pension acts as a foundational floor, a base disbursement that keeps participants connected to the economy. The NDIS functions as a dynamic supplement calibrated to the additional cost of disability, the delta between what a non-disabled person requires to participate in society and what a disabled person requires to do the same. Government investment at that foundational level does not simply prevent downstream costs. It generates economic activity that would not otherwise exist. Participants spending in the economy are an indirect moral subsidy to businesses that would not have made those sales otherwise. Support workers receiving wages from participant plans are second-order redistributors, their income funding local spending, community participation, and in many cases volunteer infrastructure the government would otherwise need to fund directly. The redistribution chain from a single NDIS payment runs several layers deep before it dissipates. That multiplier effect is not currently captured in any cost-benefit analysis of the scheme, because the accounting stops at the NDIS line item rather than following the money through the economy it activates. This architecture bears structural resemblance to a productive replacement economic framework in which a foundational dividend floors participation and dynamic supplementary allocation calibrates to individual need, a model developed independently as a general theory of equitable economic design.

References

[1] NDIS Independent Review 2023 https://www.ndisreview.gov.au/resources/reports/working-together-deliver-ndis

[2] Tune Review 2019 https://www.dss.gov.au/disability-and-carers-programs-services-for-people-with-disability-nation al-disability-insurance-scheme-2019-review-of-the-ndis-act-and-the-new-ndis-participant-service -guarantee/government-response-to-the-ndis-act-review

[3] Productivity Commission NDIS Costs 2017

https://www.pc.gov.au/inquiries/completed/ndis-costs/report

[4] NDIS Review: Needs-Based Pathway

https://www.ndisreview.gov.au/resources/reports/working-together-deliver-ndis/designing-needs based-pathway

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[5] NDIS Amendment Bill 2024

https://www.aph.gov.au/Parliamentary Business/Committees/Senate/Community Affairs/NDISA

mendment2024

[6] NDIS Commission: Price Differentiation 2025

https://www.ndiscommission.gov.au/sites/default/files/2025-05/Price-differentiation-participants.p df

[7] NDIS Commission: Price Differentiation Summary 2024

https://www.ndiscommission.gov.au/sites/default/files/2024-09/Price Differentiation Summary

Report.pdf

[8] UoW: ACCC NDIS Price Gouging 2024

https://www.uow.edu.au/media/2024/what-can-the-accc-do-to-stop-ndis-price-gouging-and-redu cecosts.php

[9] NDIS Commission: Compliance and Enforcement

https://www.ndiscommission.gov.au/providers/compliance-enforcement

[10] NDIS Review: Building Quality and Safeguards

https://www.ndisreview.gov.au/resources/reports/working-together-deliver-ndis/building-quality-a nd-safeguards

[11] NDIA: Fraud Fusion Taskforce https://www.ndis.gov.au/about-us/improving-integrity-and-preventing-fraud/fraud-fusion-taskforc e

[12] NDIA: Improving Integrity and Preventing Fraud https://www.ndis.gov.au/about-us/improving-integrity-and-preventing-fraud

[13] DSS: NDIS National Workforce Plan 2021-2025 https://www.dss.gov.au/national-disability-insurance-scheme-review-and-reforms/resource/ndis national-workforce-plan-2021-2025

[14] OECD non-take-up rates: Barcelona B-MINCOME study, Journal of Social Policy https://www.cambridge.org/core/journals/journal-of-social-policy/article/why-do-poor-people-not-t ake-up-benefits-evidence-from-the-barcelonas-bmincome-experiment/D8D53581D21A5223AC1

4A9380099A9E9

[15] UK £19 billion unclaimed support: Policy in Practice 2024 https://policyinpractice.co.uk/wp-content/uploads/2024/10/Report Missing-out-19-billion-of-supp ort-1.pdf

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[16] Most in need least likely to participate; administrative functioning as primary determinant:

National Academies Press https://www.nationalacademies.org/read/26874/chapter/11

[17] NDIS unspent funds rollover and plan renewal mechanics: Disability Support Guide https://www.disabilitysupportguide.com.au/talking-disability/what-happens-if-you-overspend-or-u nderspend-your-ndis-plan-budget

[18] Northcott 94% government funding: NSW Parliament submission https://www.parliament.nsw.gov.au/ladocs/submissions/83629/Submission%2017%20-%20The %20Northcott%20Society.pdf

[19] Northcott 2023-24 operating loss attributed to NDIS pricing: Northcott Annual Report https://ourimpact.northcott.com.au/introduction/

[20] Life Without Barriers $863M revenue, majority government funded: LWB Annual Report 2023-24 https://lwbannualreport.org.au/2023-2024/

[21] NDIS Amendment (Integrity and Safeguarding) Act 2026 civil penalties: MinterEllison https://www.minterellison.com/articles/ndis-legislative-amendments

[22] History of Australian Disability Enterprises and legislative timeline: ADE https://ade.org.au/a-brief-history-of-australian-disability-enterprises

[23] Sheltered Employment (Assistance) Act 1967 legislation: https://www.legislation.gov.au/Details/C1967A00022

[24] 1908 Invalid and Old-Age Pensions Act: National Museum of Australia https://www.nma.gov.au/defining-moments/resources/age-and-invalid-pensions

[25] NDS State of the Disability Sector Report 2024: https://www.nds.org.au/news/state-of-the-disability-sector-report-2024

[26] Grattan Institute: Saving the NDIS https://grattan.edu.au/report/saving-the-ndis/

[27] NDIS underspend and plan reduction pressure: https://markets.financialcontent.com/stocks/article/abnewswire-2026-1-20-why-unspent-funds-ar e-becoming-one-of-the-most-sensitive-issues-in-ndis-plans

[28] NDIS October 2024 legislation changes and consultation: https://www.ndis.gov.au/changes-ndis-legislation

[29] NDIS November 2025 PAPL v1.1 cap freeze and SCHADS 3.5% wage increase: Carevo https://carevo.com.au/blog/ndis-support-worker-pay-rates

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[30] NDIS participant numbers June 2025 — 739,414: Department of Finance FOI brief https://www.finance.gov.au/sites/default/files/foi-25-26-146-document-01.pdf