Submission 2984 — Carematch Australia — NDIS Future Generations Bill | External submission

202/1385 Gold Coast Highway, Palm Beach QLD 4221

info@carematchaustralia.com.au

____________________________________________________________________________14 June 2026

Submission to the Senate Community Affairs Legislation Committee

Inquiry into the National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026

Submitted by: CareMatch Australia

Specialist Provider of Spinal Cord Injury Supports

Executive Summary

I welcome the opportunity to provide a submission regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

As a provider specialising in the transition of individuals with spinal cord injuries from hospital environments into community-based accommodation and support arrangements, I have significant concerns regarding the long-term sustainability of quality service delivery under the current NDIS framework.

While the objectives of safeguarding the future of the NDIS, reducing fraud and improving accountability are commendable, there remains insufficient recognition of the substantial costs, responsibilities and risks borne by specialist providers who support participants with some of the highest and most complex support needs in Australia.

This submission outlines the realities of supporting spinal cord injury participants, the extensive compliance obligations placed upon providers, the growing issue of workforce poaching and direct private arrangements, and the risk these factors pose to the future viability of quality NDIS services.

The Reality of Supporting Participants with Spinal Cord Injuries

Participants with spinal cord injuries often enter the NDIS at one of the most vulnerable periods of their lives.

Many individuals transition directly from hospital settings after experiencing catastrophic life-changing injuries. They frequently face uncertainty regarding housing, care requirements, equipment needs, funding arrangements and their future independence.

At this point, participants place extraordinary trust in providers.

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Our role extends far beyond simply supplying support workers.

We become responsible for:

Coordinating hospital discharge planning.
Recruiting and screening suitable care staff.
Developing complex support arrangements.
Conducting risk assessments.
Creating clinical protocols.
Developing emergency response procedures.
Coordinating allied health involvement.
Facilitating housing solutions.
Managing workforce rostering.
Providing ongoing oversight and supervision. The reality is that many participants would remain unnecessarily in hospital if specialist providers were not willing to undertake these responsibilities.

The Significant Cost of Delivering Safe and Appropriate Care

There is a common misconception that support worker rates are excessive.

In reality, providers incur substantial costs before a support worker ever enters a participant’s home.

For every worker employed, providers are responsible for:

National Police Checks.
NDIS Worker Screening Checks.
Reference checks.
Recruitment processes.
Induction programs.
Ongoing training.
Manual handling training.
Clinical competency assessments.
Infection control training.
Medication management training.
Rostering and scheduling.
Human resource management.
Payroll administration.
Superannuation.
Workers compensation.
Professional insurance.
Public liability insurance.
Quality and safeguarding compliance.
Incident management systems.
Clinical governance frameworks. pg. 2

For spinal cord injury participants, these requirements are often substantially higher than for standard support arrangements.

Many workers require specialised training relating to:

Pressure injury prevention.
Bowel care.
Catheter management.
Autonomic dysreflexia.
Respiratory complications.
Transfers and hoisting.
Complex personal care. Where suitable workers cannot be sourced, providers frequently absorb the cost of training workers themselves.

In our organisation, we employ clinical nursing staff specifically to educate, supervise and maintain workforce competency.

These costs are substantial and ongoing.

Hospital Discharge and Housing Challenges

One of the most significant challenges facing providers is the transition of participants from hospital into suitable accommodation.

Many participants cannot immediately access Specialist Disability Accommodation (SDA).

The reality is that obtaining SDA can be a lengthy and difficult process.

As a result, providers are often required to:

Identify temporary accommodation.
Establish interim support arrangements.
Coordinate equipment installation.
Recruit and train entire support teams.
Manage significant risks associated with community transition. These activities can take weeks or months.

Without specialist providers willing to undertake this work, participants may remain unnecessarily in hospital environments at enormous cost to governments and health systems.

The financial cost of extended hospital stays far exceeds the cost of properly funding specialist community support.

pg. 3

Workforce Poaching and Private Arrangements

One of the most significant threats facing the sustainability of quality providers is the growing prevalence of direct private arrangements between participants and support workers.

Providers invest significant time and resources into:

Recruiting workers.
Screening workers.
Training workers.
Supervising workers.
Maintaining compliance systems.
Managing workforce performance. However, once workers become established within a participant’s support team, providers are increasingly exposed to situations where:
Workers encourage participants to engage them privately.
Participants approach workers directly.
Workers resign and continue providing supports privately.
Providers lose the workforce they invested in developing. This creates a fundamentally unfair system.

The provider bears all establishment, compliance, governance and training costs, while another party subsequently benefits without contributing to those costs.

The result is a disincentive for providers to invest in workforce development and participant outcomes.

Risks Associated with Private Care Arrangements

The issue extends beyond financial sustainability.

Private arrangements may significantly increase risks for participants.

Many private workers do not operate under the same governance structures that providers are required to maintain.

Participants may lose access to:

Clinical oversight.
Incident management systems.
Workforce supervision. pg. 4

Backup staffing arrangements.
Ongoing competency assessments.
Professional development.
Risk management frameworks. These safeguards exist for a reason. They protect participants, families, workers and public funds.

The NDIS should ensure that incentives support quality and accountability rather than encouraging the erosion of provider-based safeguards.

Recommendation: Review of Pricing and Private Service Arrangements

Consideration should be given to the development of pricing structures that distinguish between:

Individual workers operate independently.
Established providers operating compliant businesses. A support worker billing independently should not necessarily receive the same funding allocation as a provider that maintains:

Compliance systems.
Clinical governance.
Workforce training.
Quality assurance programs.
Human resource functions.
Insurance coverage.
Financial accountability systems. A capped private support worker rate should be considered, with higher rates reserved for providers that can demonstrate compliance, governance and quality systems.

For example, private support arrangements could be subject to a lower maximum hourly rate, while registered and compliant providers remain eligible to claim the full support item value.

Such an approach would better reflect the actual costs associated with delivering safe and sustainable services.

Protecting the Future of the NDIS The future sustainability of the NDIS is not achieved solely through reducing expenditure.

It is achieved by ensuring that funding is spent effectively and that quality providers remain viable.

If specialist providers leave the market because compliance obligations continue to increase while provider sustainability declines, participants with the most complex needs will be the ones who suffer.

The NDIS relies upon providers willing to: pg. 5

Accept significant risk.
Invest in workforce development.
Support complex participants.
Facilitate hospital discharge.
Deliver safe and accountable services. These contributions should be recognised and protected.

Conclusion

The NDIS has transformed the lives of thousands of Australians living with spinal cord injuries and other significant disabilities.

However, its future depends upon maintaining a sustainable ecosystem of high-quality providers capable of delivering complex supports.

As Parliament considers the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026, I encourage the Committee to carefully consider the operational realities faced by specialist providers.

Without recognition of the significant investment required to recruit, train, supervise and retain a skilled workforce, there is a real risk that quality providers will be driven from the sector.

The NDIS must continue to protect participants, safeguard public funds and support the providers who undertake the complex and demanding work of helping Australians with disability live safely and independently in the community.

Thank you for the opportunity to provide this submission.

Henry Bradford

GENERAL MANAGER

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