Submission 297
Securing the NDIS for Future Generations
Psychotherapy and Counselling Federation of Australia
29 May 2026
This response is written by the Psychotherapy and Counselling Federation of Australia (PACFA), the leading national peak body for the tertiary-qualified counselling and psychotherapy profession. With more than 12,000 members, PACFA provides registration and quality assurance services for counsellors nationally.
In this response the terms “counsellor” and “psychotherapist” can be used interchangeably to refer to tertiary qualified allied health professionals registered with
PACFA as Certified Practicing Counsellors (entry level), Registered Clinical
Counsellors (full Scope of Practice) and Registered Clinical Psychotherapists
(extended Scope of Practice).
Counselling in the NDIA supports those with functional impairments to navigate complex lives, enabling stability, reducing unnecessary hospital admissions and supporting the effectiveness of other allied health interventions.
Modern neuroscience increasingly shows that therapy works through neuroplasticity by building adaptive responses, while enhancing learning and emotional regulation. Counselling is predominantly solutions-focused - building participant skills to support core relationships or executive functioning within a therapeutic relationship, to enable employment or build daily living skills.
About PACFA registrants
PACFA registration allows employers and funding bodies to recognise verified counsellors who meet high professional standards to support their communities. PACFA maintains rigorous registration criteria and is proud to uphold the highest standards in the sector. All registrants must practise within PACFA’s Scope of Practice and adhere to the Code of Ethics and grievance procedures. To be registered with PACFA, practitioners must meet the following requirements:
- ‘Certified Practising Counsellors’ must have completed an accredited course or equivalent (this mandates that the course must be Bachelor or
Submission 297
postgraduate level, (AQF 7-9) and include a placement and clinical supervision).
-
‘Registered Clinical Counsellors’ must have completed the above plus an additional 750 hours of client contact and 75 hours of clinical supervision over more than two years. This recognises the experience of senior counsellors.
-
’Registered Clinical Psychotherapists’ must be a clinical member of PACFA as above and have completed significant specialised psychotherapy training as well as personalised therapy
As with PACFA’s clinical psychotherapists, counsellors can provide specialised counselling across a range of disciplines to provide the right care for a client’s needs. PACFA’s specialist colleges allow for registrants to be recognised as a specialist in
the fields of Psychotherapy, Relationship Counselling, Indigenous Healing Practices,
Creative and Experiential (art) Therapies, and Clinical Supervision for a range of service providers.
➢ Incoming National Standards
Counselling is an underutilised asset in the mental health workforce and can play a significant role in prevention, early intervention and recovery. In October 2025, PACFA welcomed the National Standards for Counsellors and Psychotherapists published by the Australian Department of Health, Ageing and Disability.
The implementation of these standards, over the next three to five years, will promote greater access to registered counsellors in a wide range of clinical settings and will contribute to a more sustainable mental health system. This project will confirm counsellors and psychotherapists as a health and mental health workforce, signifying a turning point for the profession in addressing barriers to workforce utilisation and increasing our capacity to support Australians in distress.
PACFA’s high standards align closely with those established in the National Standards, and we are proud to see the quality and professionalism of our members recognised as the benchmark for the industry. This confirmation of counsellors and psychotherapists as a key part of the mental health workforce will assist in providing flexible and multidisciplinary healthcare that meets the needs of the community.
Submission 297
Recommendations
Expansion of executive power
PACFA recommends that the NDIS:
➢ Limit and safeguard ministerial powers The reliance on delegated instruments under the Act and the corresponding scope of ministerial powers should be reconsidered. In particular, the ability for the Minister to reduce participant plan supports below what is deemed reasonable and necessary to achieve program cost savings, and to cut the funding for a category of supports without consultation.
➢ Strengthen safeguards and review rights It is crucial to maintain access to administrative and merits review, including for decisions made through automated processes. This is particularly important given the expanded use of automation and the well‑documented risks and integrity concerns associated with past government automated decision‑making systems.
➢ Improve access to reassessments It is important to maintain timely reassessment processes and implement appropriate interim safeguards throughout the transition period. Participants should also be able to access supported reassessment requests, including through providers or advocates where appropriate, with clear transparency and conflict‑of‑interest requirements in place.
➢ Introduce independent pricing oversight Transferring pricing determinations from the Agency to the Minister would diminish the level of independent oversight in pricing decisions. Independent pricing mechanisms should be established to ensure transparency, supported by the publication of advice underpinning decisions. It is also essential that pricing accurately reflects the true cost of delivering safe, high‑quality services.
➢ Require transparency in rulemaking All subordinate legislation and instruments should be:
- Transparent
- Evidence-based
- Subject to appropriate scrutiny
Submission 297
Ensuring continuing access to supports
PACFA recommends that the NDIS:
➢ Adopt a holistic definition of functional capacity The decision to remove alignment of functional capacity determinations from the personal and environmental circumstances of a participant should be reconsidered. It is inconsistent with the World Health Organization’s International Classification of Functioning, Disability and Health (ICF), which recognises that a person’s functioning and disability are shaped by their broader context.
➢ Revise the definition of permanence The definition of permanence, and the requirement that all available treatments be explored before determining permanence, should be reconsidered. The proposed changes may disproportionately affect individuals in rural and remote areas who do not have reasonable access to the full range of treatments.
General principle 4(4) of the NDIS Act 2013 states that “people with disability should be supported to exercise choice, including in relation to taking reasonable risks, in the pursuit of their goals and the planning and delivery of their supports”. To align with this objective, participants should be allowed reasonable refusal of treatment and understand the clinical oversight in decisions.
➢ Strengthen system readiness before restricting access Major access or support reductions should be delayed until the proposed mainstream and community supports are available, accessible, and adequately funded
A fit-for-purpose NDIS
PACFA recommends that the NDIS:
➢ Pause and strengthen consultation Reforms of this scale should be subject to extended consultation timelines and ensure meaningful engagement with stakeholders.
➢ Ensure proportionate regulation of providers PACFA’s existing processes could be utilised more effectively by the NDIA for practitioners providing counselling or counselling-aligned services. PACFA members already meet NDIA standards and are well distributed across Australia including in regional and rural areas. And more than ever before, with the establishment of National Standards for Counsellors and Psychotherapists endorsed by the Minister for Health in October 2025 counsellors are a safe, expert, accessible and cost effective workforce.
Submission 297
➢ Adjust administrative and operational changes The 90‑day claim timeframe should be reconsidered, with assurance that NDIA systems are fit‑for‑purpose and capable of supporting timely and reliable claims processing. In addition, any use of automation must be transparent, appropriately limited, and subject to robust human oversight to ensure accountability and safeguard participant outcomes.
➢ Ensure allied health involvement Include allied health professionals in:
- Functional capacity assessment design
- Planning and reassessment processes
- Policy and rule development Further information
Please see our website for further information on PACFA’s work and publications. For further information about how the National Disability Insurance Scheme could utilise PACFA members, or the clinical practice of counselling and psychotherapy, please contact: