Submission to the Inquiry into NDIS Reform and the Future Sustainability of the NDIS
Introduction
I welcome the opportunity to provide a submission regarding the future of the National Disability Insurance Scheme (NDIS) and proposed reforms intended to secure its long-term sustainability.
The NDIS has transformed the lives of hundreds of thousands of Australians by providing supports that enable independence, participation, education, employment, community inclusion and dignity. Any reforms to the Scheme must preserve these outcomes while ensuring the NDIS remains financially sustainable for future generations.
While I recognise the need to strengthen governance, address fraud and improve public confidence in the Scheme, many current reform discussions focus heavily on reducing expenditure without adequately examining the structural issues that are driving costs and limiting participant outcomes.
My perspective comes from living in a rural community of approximately 1,000 people. Our town has a general store, post office, cafés, a GP clinic and a small number of local businesses. There are no local speech pathologists, occupational therapists, psychologists or other allied health professionals. The nearest services are approximately 40 minutes away.
Many of the challenges facing participants in regional and rural Australia are not caused by participants receiving excessive support. They are often the result of market failure, pricing distortions and service delivery models that do not reflect the realities of rural communities. In our case, it has taken nearly a year to put supports in place.
- Tightened Eligibility Criteria The proposed move toward functional capacity assessments and stricter definitions of permanent disability may unintentionally exclude people who experience significant disability-related impacts but whose conditions fluctuate or do not fit narrow assessment frameworks.
Particular concerns include:
People with psychosocial disability whose functional capacity varies over time.
Individuals with neurological or degenerative conditions.
People with autism who require ongoing support but may not meet revised thresholds.
Existing participants facing reassessment and uncertainty regarding continued access.
No participant should lose essential supports before alternative services are fully established, funded and operational. Any new system must also preserve genuine choice and control. Participants and families should not be forced to move from service to service, repeatedly retell their stories, or hand over medical notes again and again simply to access basic support.
Choice and control means being able to engage people who know, understand and care for the participant. In many cases, small independent providers and local workers offer more consistent, personal and effective support than large organisations with multiple layers of management and rotating staff.
It would be a serious mistake to move to a model where supports are effectively decided by schools, principals or other mainstream systems without meaningful participant and family control. In our experience, school-based disability funding does not always translate into direct support for the child. Families may have little say in how funding is used, and disability funding can be absorbed into broader staffing or administrative needs.
Participants should not have other systems become their decision makers. Carer Gateway and similar programs may provide information, but families need practical, hands-on workers on the ground, not more websites, referrals and layers of administration.
- Risks of Cost Shifting Reducing access to the NDIS without simultaneously strengthening foundational and mainstream supports risks shifting costs to:
Families and informal carers.
State health systems.
Mental health services.
Education systems.
Community organisations.
Many families already provide significant unpaid care. Reductions in formal support may increase carer burnout, workforce withdrawal and financial hardship.
Any reduction in NDIS-funded supports must be accompanied by guaranteed and adequately funded alternatives. Those alternatives must include genuine choice and control. Families do not need more organisations, websites or information portals. They need practical, hands-on workers who can provide real support in the community.
- The NDIS Has Fundamentally Changed the Allied Health Market Prior to the introduction of the NDIS, many allied health services were available through hospitals, schools, community organisations and private practices at significantly lower costs.
Speech pathology and similar therapy services could often be accessed for approximately $80 per hour, with preparation, administration and reporting costs absorbed into the overall fee.
Following the introduction of NDIS pricing arrangements, many providers now charge at or near NDIS price limits, currently approximately $193.99 per hour for many allied health services.
This has had broader consequences beyond NDIS participants.
People who do not qualify for NDIS funding often face higher costs and reduced access to services because many providers have shifted toward NDIS-funded work where pricing is more favourable.
The inquiry should examine whether current pricing structures have unintentionally reduced service availability within mainstream health, education and community settings.
- Current Pricing Does Not Reflect Experience or Complexity The current pricing model makes little distinction between clinician experience or participant complexity.
For example:
A newly graduated occupational therapist can charge the same rate as a clinician with decades of experience.
Straightforward cases can attract the same rates as highly complex cases requiring specialist expertise.
Many participants understood higher NDIS rates to reflect advanced expertise and complex clinical work. Instead, the highest rates have effectively become standard rates.
This creates limited incentive for professional development, fails to recognise specialist expertise and places unnecessary pressure on participant budgets.
A regulated tiered pricing model based on clinician experience and participant complexity should be considered, supported by independent auditing and oversight mechanisms to prevent misuse.
- Billing Practices Are Consuming Participant Funding A significant concern relates to the way providers are permitted to bill for non-face-to-face activities.
Participants are frequently charged for:
Preparation.
Administration.
Report writing.
Cleaning.
Travel.
File management.
For example, a therapist may bill:
30 minutes preparation.
60 minutes face-to-face support.
10 minutes cleaning.
20 minutes notes and reporting.
The participant receives one hour of therapy but is charged for two hours of funding.
Historically, many of these costs were absorbed within standard business overheads. Participants have little ability to verify whether the time claimed accurately reflects the work completed.
The NDIS should review whether routine administration and overhead costs should continue to be separately billable.
This does not require another large governance structure. It requires clear rules, transparency and access to an independent complaints or ombudsman process that can investigate billing concerns.
- Participants Are Not Receiving the Supports Their Plans Appear to Fund
The practical consequence of current billing arrangements is that participants often receive substantially less support than their plans suggest.
For example, a participant funded for twelve therapy sessions may ultimately receive only six sessions once preparation, travel, administration and reporting are deducted from the budget.
On paper, the participant appears fully funded.
In practice, they receive significantly less support than has been assessed as necessary.
This problem is particularly acute in regional and rural communities where provider choice is already limited.
- Rural Participants Face Significant Disadvantages The NDIS is built upon the principles of choice and control.
In many rural communities, there is no meaningful choice.
Where only one provider services a region and the nearest therapist is 40 minutes away, participants cannot compare providers, negotiate arrangements or select services that best meet their needs.
The Scheme currently assumes a functioning market exists.
In many regional communities, there is no market at all.
Participants are expected to achieve the same outcomes as metropolitan participants while having access to only a fraction of the available services.
Rural participants need funding that reflects the real cost of access, including travel and community participation. They also need investment in local services and local businesses that can provide disability supports. Supporting local providers may appear to cost more initially, but it may reduce travel costs, build community capacity and enable participants to form genuine local connections.
At present, many rural families cannot build those connections. In our situation, my child is often at home because providers will not travel for occupational therapy and speech therapy, and there are no real local activity options that are inclusive and suited to my child’s needs.
- Removal and Reduction of Travel Funding Changes to travel funding have had significant impacts on rural and regional participants.
Occupational therapists, speech pathologists and psychologists are increasingly unwilling to travel because travel time is no longer financially viable.
For many rural participants, access has not simply been reduced — it has disappeared entirely.
This creates situations where funding exists on paper but services cannot be purchased.
A participant in Melbourne may have access to dozens of providers within a short distance. A participant in a small rural town may have access to none.
This is fundamentally inequitable.
Online speech therapy and occupational therapy are not always appropriate, particularly for children with complex needs. Telehealth can be useful in some circumstances, but it should not be treated as a complete replacement for face-to-face support.
- Social and Community Participation Supports There has been considerable discussion regarding reducing expenditure on social and community participation supports.
These supports are often critical for:
Preventing social isolation.
Supporting mental health.
Building independent living skills.
Maintaining employment and educational participation.
Reducing long-term support needs.
Community participation is not discretionary. It is a core component of inclusion, wellbeing and quality of life.
Restricting these supports may create greater costs elsewhere across health and social service systems.
- Support Worker Availability Does Not Match Participant Needs A further issue is the mismatch between participant needs and provider business models.
In our situation, support was required for approximately two hours in the morning and three hours at night.
However, no support worker was willing to accept a two-hour shift.
As a result, supports had to be redesigned around provider requirements rather than participant needs.
This led to fewer support days and less effective use of participant funding.
The NDIS often assumes funding equals access.
In rural Australia, this assumption is frequently incorrect.
The NDIS should consider specific workforce measures for rural and regional participants, including funding arrangements that support viable shifts, local workforce development and continuity of care.
- Independent Support Workers Must Be Protected Independent support workers are often the only reason participants in regional communities can access support.
They frequently provide:
Greater flexibility.
Better continuity of care.
More personalised support.
Improved scheduling options.
Stronger local community knowledge.
Any reforms that restrict participants’ ability to engage independent support workers risk reducing access and undermining the principle of choice and control.
- Consultation, Co-Design and Integrity Measures People with disability must remain active partners in the design of reforms.
The principle of “Nothing About Us Without Us” should guide all future NDIS reform processes.
Recommended measures include:
Extended consultation periods.
Accessible consultation formats.
Greater involvement of people with lived experience.
Publication of impact assessments before major legislative changes.
There is broad support for measures that strengthen scheme integrity and reduce fraud. However, integrity measures should focus on:
Provider accountability.
Stronger registration requirements.
Improved auditing systems.
Better whistleblower protections.
Faster responses to complaints and safeguarding concerns.
Participants should not bear the consequences of failures in regulatory oversight.
- Alternative Models for Areas of Market Failure The NDIS should recognise that market-based approaches do not work equally well in all locations.
Alternative approaches should be explored, including:
Community-based allied health hubs.
Regional outreach programs.
Shared therapy facilities.
Multi-disciplinary rural teams.
Block-funded services in areas of market failure.
Hybrid telehealth and outreach models.
Where no functioning market exists, government should not rely solely on market solutions.
However, alternative models must not remove choice and control. Participants should still be able to engage independent support workers and choose allied health providers who are appropriate for their circumstances.
- Funding Periods and Plan Certainty Funding periods should allow participants and families to plan with confidence. In practice, the first year or two of a plan can be spent finding suitable providers, trialling supports, learning how the plan works and establishing routines.
In our case, it has taken 11 months to get support workers in place for one child. It is also common to attend two or three sessions with an occupational therapist or other provider before realising they are not the right fit. This is not waste by the participant; it is part of finding effective support.
Funding should carry over for up to three years so participants can plan properly and use supports when they are actually available. Participants should not lose funding simply because the market failed to provide services within a shorter timeframe.
Plan certainty is also essential for families who may wish to employ support workers directly. Employing a worker can be more cost effective and provide better continuity, but families cannot confidently do this if plans can be changed or reduced with little notice. No one wants to accept employment where the funding may disappear suddenly, and families cannot take on the legal and financial risks of employing someone without reasonable certainty.
Before reducing or changing funding periods, the government should clearly model and publish the likely financial impact of moving current plans to three-year rollover arrangements. Reform should be based on evidence, not assumptions.
- Review Rights and NDIA Decisions Removing or limiting participants’ ability to challenge decisions would be deeply concerning.
A core purpose of government is transparency, accountability and the right to review decisions. Participants must retain meaningful appeal rights when decisions affect their access to essential disability supports.
The NDIS involves life-changing decisions. Participants and families must not be left without a fair pathway to challenge errors, provide evidence or seek independent review.
- Assessments by External Assessors I am strongly concerned about proposals that would require participants, including children, to be assessed by people who do not know them.
The NDIA has already funded significant reports for many participants, including functional capacity assessments, occupational therapy reports and other specialist evidence. These reports are expensive, time-consuming and stressful for families to obtain.
In our case, the NDIA has already spent significant public money on reports for one child. Discarding those reports and requiring another costly assessment process would be wasteful and distressing.
Families should not be placed back on a merry-go-round of services, websites, referrals and self-help programs. Many families are already exhausted. They need real people on the ground, not more administrative processes and office-based systems.
Government resources should be directed toward practical supports and frontline services rather than duplicated assessments and layers of administration.
- Fraud and Provider Misconduct Scheme integrity is important, and fraud should be addressed as a priority.
The greatest savings are likely to come from preventing fraud, inflated billing and provider misconduct, not from reducing essential supports for participants with genuine disability-related needs.
Reform should focus first on crime, exploitation and poor provider behaviour. Participants should not be treated as the source of the Scheme’s financial problems when many cost pressures arise from pricing structures, market failures and inadequate provider oversight.
Recommendations
Ensure no participant loses essential supports before alternative services are fully operational.
Preserve genuine choice and control in all reforms.
Focus strongly on fraud, provider misconduct and inflated billing.
Protect access for people with psychosocial, fluctuating and complex disabilities.
Maintain meaningful review and appeal rights for NDIA decisions.
Avoid replacing participant choice with decisions made by schools, principals, mainstream services or large organisations.
Fund more practical, hands-on workers in communities rather than more administrative systems and websites.
Review the impact of NDIS pricing on allied health markets and access to non-NDIS services.
Increase transparency and accountability around non-face-to-face billing.
Introduce an independent ombudsman or complaints mechanism to investigate billing practices by providers, including allied health providers.
Review whether routine administration and overhead costs should remain separately billable.
Examine a regulated tiered pricing model based on clinician experience and participant complexity.
Establish independent oversight and dispute resolution mechanisms for billing concerns.
Ensure participants are funded for the actual cost of accessing supports, not merely nominal hours.
Restore or redesign travel funding to improve access in rural and regional communities.
Invest in local disability support businesses and services in areas of market failure.
Protect participant choice, including the use of independent support workers.
Support rural and regional workforce development, including viable shift lengths and continuity of care.
Retain adequate funding for social and community participation supports.
Allow funding to carry over for up to three years so participants can plan and use supports when they become available.
Provide greater plan certainty so families can confidently engage or employ support workers.
Avoid unnecessary duplication of assessments where the NDIA already holds recent, high-quality evidence.
Expand genuine co-design and consultation with people with disability and families.
Strengthen fraud prevention through provider regulation rather than participant restrictions.
Improve whistleblower protections and complaints handling mechanisms.
Conduct independent impact assessments before major eligibility or funding reforms are implemented.
Recognise and address market failure in rural and regional Australia.
Develop alternative community-based service delivery models where traditional markets do not operate effectively, while preserving individual choice and control. If done, this must be built by locals. Not big not for proificts and businesses who don’t live local and are out of touch.
Conclusion
The NDIS is one of Australia’s most significant social reforms. Sustainability is important, but sustainability must not come at the expense of inclusion, independence and quality of life.
Many of the challenges currently facing the Scheme are not the result of participants receiving excessive support. They arise from structural issues within the market, pricing and service delivery framework.
Future reforms should focus on improving transparency, accountability, equity and service accessibility while preserving genuine choice and control.
Participants living in rural and regional Australia should not receive fewer services, less choice and poorer outcomes simply because of where they live.
A sustainable NDIS must work not only in major cities, but also in the small communities where Australians with disability live, learn, work and contribute every day.