Submission 3156 — Approved by Frankie — NDIS Future Generations Bill

APPROVED BY FRANKIE PTY LTD

Provider Registration Number: 4050059677

Email: mgt@approvedbyfrankie.com.au Phone: 1300 481 181

ABN: 79 633 055

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: Approved by Frankie

Contact: Rachael Henderson, Director and Founder

Location: New South Wales

Date: 9 July 2026

1. Introduction and position on the Bill Approved by Frankie welcomes the opportunity to provide a submission to the Senate

Community Affairs Legislation Committee inquiry into the National Disability Insurance

Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

The Bill was introduced into Parliament on 14 May 2026 and is intended to amend the National Disability Insurance Scheme Act 2013 to protect the NDIS, with changes focused on clarifying eligibility and funded supports, addressing fraud, and updating governance and administrative arrangements. The Senate referred the Bill to the Community Affairs Legislation Committee for inquiry.

Approved by Frankie supports the objective of securing the NDIS for future generations. The Scheme must be sustainable, protected from fraud, clearer in its administration, and centred on the rights, safety and outcomes of people with disability.

Our concern is that the Bill and surrounding reform agenda may unintentionally weaken the very providers and practice models that help achieve those aims.

The central question we ask the Committee is simple:

Does Government want to preserve independent, clinically informed, fairly employed Support Coordination at scale, or does it want the future market left to large multi-service providers and not-for-profit systems with multiple layers of management, competing service interests and far less independence?

2. About Approved by Frankie Approved by Frankie is a large, independent Support Coordination provider operating across NSW. We have been an NDIS registered provider since 2019 and have spent more than seven years building a specialist model of Support Coordination for people with complex disability and high-risk support needs.

We support approximately 1,600 participants, many of whom experience complex psychosocial disability, acquired brain injury, intellectual disability, trauma, hospital interface, justice interface, public guardianship, substitute decision-making, family violence, homelessness, thin markets, provider breakdown, and limited or no informal supports.

We understand ourselves to sit within the top seven Support Coordination providers nationally by size and scale, while operating only in NSW. That position matters because we have not reached scale through SIL capture, downstream service revenue, internal referrals, accommodation pathways, therapy, core supports or plan management.

Support Coordination is all we do.

We are independent. We are non-conflicted. We are not vertically integrated.

Approved by Frankie has scaled by professionalising the Support Coordination workforce. We directly employ our staff under proper employment and Fair Work conditions. We invest in supervision, including a bespoke clinical supervision model built for the specific needs of Support Coordinators, practice governance, escalation systems, documentation, workforce development and clinical understanding.

Our workforce includes people with experience across social work, health, psychosocial disability, hospital discharge, safeguarding, justice interface, housing, guardianship, family violence and complex service systems. Our founder is a Social Worker. Approved by Frankie was built from frontline experience, business discipline and a belief that people with complex disability deserve skilled, independent support around them, not conflicted referral pathways, unmanaged provider markets or systems that speak over them.

There is also a personal history behind this work. Our founder is the daughter of a particle physicist from Bankstown who was given an opportunity through the expansion of public education under the Whitlam era. His career was dedicated to the research, testing and design of safe work practices that have significantly contributed to equity and improved worker safety and conditions for working Australians.

That story matters because the NDIS is also part of the Australian promise that people should not be limited by class, disability, gender, geography or the system they were born

into. Approved by Frankie was built with that same belief in a fair go: that people without voice, informal supports or system power deserve skilled people beside them, and that frontline workers, many in highly gendered caring professions, should be able to build quality, professional and fairly paid work around that purpose.

This is not accidental scale. It is the result of eight years of building a professional, independent Support Coordination model in one of the most complex parts of the NDIS market. It has required personal risk, financial risk, workforce investment and a commitment to staying in a pricing environment that has become increasingly hostile to providers who directly employ skilled staff and invest in quality.

Approved by Frankie reflects the kind of model Government says it wants: accountable, skilled, independent, participant-centred and able to work with complexity. It is a model grounded in Fair Work, professional practice and a justice-based approach to disability.

The question for this inquiry is whether current pricing and future commissioning reforms will preserve this capability, or whether they will unintentionally price out the very providers that have driven quality, market stewardship and independent support for some of the most vulnerable people in the Scheme.

3. Relevance to the Bill The Bill is directed toward Scheme sustainability, fraud control, pricing and governance, eligibility, functional capacity, administrative processes and the future structure of NDIS supports. Those issues cannot be considered only through legislation, data or budget settings. They must be tested against the real market the Bill will operate in.

Approved by Frankie’s scale is not a sales point. It is evidence.

It shows that independent Support Coordination can operate at significant scale when it is built around professional practice, fair employment and quality governance.

It shows that participants with complex disability, families, hospitals, guardians and mainstream systems will actively seek independent coordination when the work is complex and the stakes are high.

For complex participants, independence is not a preference. It is a safeguard.

Support Coordination for this cohort is not administration. It is not generic “connection”. It is understanding risk, reading systems, supporting decision-making, testing provider claims, challenging poor practice, escalating safeguarding concerns, identifying plan

waste, supporting hospital discharge, questioning unsafe SIL arrangements and holding the whole picture when no other part of the system does.

That is why the Bill’s objectives — fraud prevention, sustainability, integrity, better administration and value for money — depend on preserving skilled independent coordination.

Fraud is not always visible from invoices.

Plan waste is not always visible from utilisation reports.

Provider capture is not always visible from registration status.

Functional capacity is not always visible from a one-off assessment.

Participant risk is not always visible from administrative contact attempts.

Independent Support Coordination is one of the few functions that can see across the whole ecosystem around a participant.

4. The market risk the Bill must address Much of the public discussion focuses on small poor-quality operators. That risk is real. Poor providers should be regulated, audited and removed where needed.

However, the larger structural risk is provider power.

The most complex participants are often also the participants with the highest value plans. They may require SIL, daily supports, shared living, behaviour support, psychosocial support, hospital discharge coordination, justice interface, guardianship involvement and intensive provider input.

These participants are not only high need. They are commercially significant within the provider market.

Large providers, including large not-for-profit organisations and provider alliances, have a direct financial interest in this cohort because long-term service revenue often sits around daily supports, accommodation-linked services, SIL arrangements and wraparound service models.

That does not make every large provider improper.

But it does mean they are not neutral.

A provider that delivers housing-linked supports, SIL, core supports, therapy or other funded services has a financial interest in the participant’s pathway. That interest is strongest where the participant is complex, has limited informal supports, is under guardianship, is difficult to place, or has few practical alternatives.

Those are precisely the participants who need independent Support Coordination most.

The Committee should be careful not to confuse provider voice with participant voice.

Large provider alliances may speak about quality, sustainability and market stewardship. Those issues matter. But these organisations also have business models, service lines, revenue exposure and market positions to protect.

They are providers.

They are not the participant in a group home who needs someone independent to question the provider controlling the house, roster and daily life.

They are not the person under guardianship trying to express will and preference.

They are not the person with no family advocate and no informal network.

They are not “nothing about us without us”.

For many complex participants, there is no informal support network holding the system to account. There is only the system itself — and often no one in that system understands the whole picture.

That is the gap independent Support Coordination fills.

5. Large provider alliances must not be allowed to treat participants as market share Approved by Frankie asks the Committee to be alert to the way some large provider systems and alliances already operate around complex participants.

This is not about whether an organisation is for-profit or not-for-profit. It is about power, incentives and practice.

Some large not-for-profit and multi-service provider systems have significant influence in the disability market despite sector concerns about quality, safeguarding, management efficiency and participant choice. Some have multiple layers of management, broad service lines, strong government relationships and the ability to shape referral pathways across housing, SIL, daily supports, therapy, community access and accommodation linked services.

Where those organisations form alliances or preferred-provider networks, there is a risk that participants are moved between related or familiar services at scale, not because this is always the best expression of choice and control, but because the provider ecosystem has already decided where the person “fits”.

For participants with high-value plans, no informal supports, guardianship involvement, communication barriers or complex psychosocial disability, this risk is particularly serious.

The participant may not experience the market as a place of genuine choice. They may experience it as a closed system of large organisations referring between themselves, managing vacancies, preserving service relationships and treating the participant’s plan as something to be allocated rather than a life to be built around the person’s will and preference.

That is the opposite of what the NDIS was meant to achieve.

Participants are not commodities.

High-value plans are not market share.

SIL vacancies are not participant choice.

Provider alliances are not participant voice.

A charity brand is not proof of independence.

Scale is not proof of quality.

The Committee should be especially cautious where large provider alliances present themselves as the natural answer to market failure. In some cases, those same organisations may benefit from the market conditions that make independent challenge difficult: thin provider choice, housing scarcity, discharge pressure, family exhaustion, participant isolation and the absence of strong informal advocacy.

Independent Support Coordination is one of the few safeguards that can sit outside those networks and ask whether the arrangement is actually in the participant’s interest.

A skilled independent coordinator can ask:

Is this provider arrangement safe?

Is the participant being given real options?

Is the person’s will and preference being heard?

Is the plan being used to improve the participant’s life?

Is the provider benefiting more than the participant?

Is the participant being moved through a provider ecosystem because it is convenient for the system?

Is there an alternative that has not been explored because it sits outside the provider network?

If future commissioning strengthens large provider alliances while pricing out independent Support Coordination, the NDIS may become less of a participant-led market and more of an administered welfare supply chain.

That would be a profound failure of Scheme design.

The Bill should not allow reform to replace poor small-provider practice with large-scale provider capture. Both are risks. Both must be addressed.

The Committee should require Government to build safeguards that prevent participants, particularly those with high-value plans and limited informal supports, from being channelled through provider alliances as revenue opportunities.

Quality must be measured by independence, participant outcomes, safeguarding practice, workforce capability, supported decision-making and the ability to challenge poor practice — not by organisational size, charitable status, alliance membership or tender capacity.

6. Do not replace independent coordination with large welfare bureaucracy The Bill sits within a broader reform direction that includes changes to intermediary services, including Support Coordination and plan management. Public commentary and sector analysis have identified that the Bill proposes moving Support Coordination and plan management toward a commissioned provider panel model.

Approved by Frankie is concerned that future reform may unintentionally replace independent, professional Support Coordination with a smaller market dominated by large multi-service organisations and not-for-profit welfare systems.

That would not necessarily improve quality.

A smaller market is not automatically a safer market.

A national panel is not automatically more accountable.

A not-for-profit structure is not automatically independent.

A charity brand is not proof of quality.

A large organisation with many service lines may have more reasons to protect its own revenue.

Thirty layers of management do not equal frontline skill.

The NDIS is a rights-based, market-based scheme. It should not drift into a model where participant choice is managed through large welfare institutions because they are easier for Government to contract with.

That may look administratively clean. It may look like control. It may even look like reform.

But for complex participants, it risks removing independent power from the person and giving more control to the provider systems around them.

The Committee should therefore test what “quality” means before the market is narrowed.

Approved by Frankie asks the Committee to consider whether Government really wants to lose a resource like ours: a large-scale, independent, clinically informed Support Coordination provider that directly employs its workforce, operates under Fair Work conditions, understands complex disability, and is prepared to call out poor practice without a downstream service line to protect.

If the answer is no, pricing and commissioning must reflect that.

7. Pricing is now a quality and safeguarding issue Support Coordination pricing is not only a commercial issue. It is now a quality, workforce and safeguarding issue.

Approved by Frankie directly employs staff because complex participants need continuity, supervision, accountability and professional practice.

Fair Work conditions matter. Stable employment matters. Clinical understanding matters. Supervision matters. Documentation matters. Escalation matters.

The current pricing model does not properly recognise the cost of delivering Support Coordination in this way.

If pricing rewards the thinnest possible model, the market will move toward thin practice. If pricing ignores supervision, governance, fair employment and complexity, the providers most committed to those things will be placed at risk.

If a top-tier, NSW-only, independent Support Coordination provider that directly employs its workforce is concerned about viability, the issue is not poor business capability.

The issue is market design.

8. Pricing cannot be based on the cheapest workforce model The Committee should also consider what workforce model current Support Coordination pricing is actually testing.

A significant part of the Support Coordination market now relies on subcontractor, sole trader or very low-overhead delivery models. Some individual practitioners in those models are skilled and committed. However, those models are not the same as a directly employed, supervised, practice-governed Support Coordination workforce.

A subcontractor model does not carry the same cost base as a registered provider that directly employs staff under proper employment conditions. It does not necessarily carry the same obligations for paid leave, supervision, training, practice leadership, performance management, risk escalation, documentation systems, audit preparation, compliance, insurance, continuity planning, incident review, clinical consultation or organisational accountability.

Government should therefore be very careful about using current market pricing as evidence of what Support Coordination “should” cost.

The current price does not appear to be based on a true and tested quality model of Support Coordination. It appears to reflect a market where much of the work can only remain viable through thin overheads, subcontracting, low supervision and reduced organisational accountability.

That is not the model complex participants need.

Approved by Frankie has deliberately taken a different path.

We directly employ Support Coordinators. We use a tested Fair Work employment model. We provide supervision, practice leadership, escalation pathways, documentation standards, workforce development and management accountability. We do this because participants with complex disability need continuity, skilled judgement and organisational responsibility around them.

That is particularly important for participants with complex psychosocial disability, acquired brain injury, cognitive disability, guardianship involvement, family violence risk,

hospital interface, justice interface, homelessness, provider breakdown or no informal supports. These participants need practitioners who are supported to stay, think, document, escalate, challenge poor practice and hold the system around the person.

That cannot be safely priced as though Support Coordination is a low-overhead contracting task.

Approved by Frankie has shown that a directly employed, independent Support Coordination workforce can reach scale.

But only just.

We have reached scale despite the pricing model, not because of it.

If a large, NSW-only, independent Support Coordination provider that directly employs its workforce under Fair Work conditions is saying the model is becoming unsustainable, the issue is not poor business capability. The issue is that pricing is not recognising the real cost of quality.

The Committee should ask:

What kind of workforce does Government want around the most complex participants in the NDIS?

If Government wants a low-overhead, subcontracted market, current pricing may produce that.

If Government wants accountable, supervised, independent, clinically informed Support Coordination, pricing must fund the employment model required to deliver it.

The NDIS cannot be secured for future generations by benchmarking quality against the cheapest version of the work.

It must price the service based on the workforce participants need.

9. Legislative reform will change provider behaviour — and the Bill must anticipate that

Approved by Frankie also asks the Committee to consider how providers will respond once legislation and future commissioning arrangements change.

Provider markets do not stand still. When Government signals that Support Coordination and intermediary services will be redesigned, providers will adapt before the future model formally begins.

That adaptation is already predictable.

Large providers, including large not-for-profit organisations and provider alliances, will seek to preserve their position by forming referral partnerships, preferred-provider relationships, informal alliances and closed service ecosystems. Where they do not have in-house Support Coordination, they may still influence participant pathways through housing, SIL vacancies, daily supports, family communication, discharge pathways, provider relationships, tender positioning and control of information.

This is particularly important in relation to participants with high-value plans.

The most complex participants often require the most intensive supports. They may have SIL, shared living, daily supports, behaviour support, psychosocial support, health interface, justice interface, guardianship involvement, family violence risk, homelessness, provider breakdown and limited or no informal supports. These participants are also commercially significant in the provider market because long-term service revenue often sits around them.

That creates a risk.

Large providers and alliances may present themselves as quality market stewards while also having a direct interest in controlling referral pathways and preserving revenue around high-value participants.

That does not mean every large provider is acting improperly.

But it does mean Government must not treat provider alliances as neutral.

The NDIS is a market-based scheme, but anti-market behaviour can still occur inside it. It may not look like open collusion. It may look like preferred-provider arrangements, referral partnerships, selective cooperation, closed networks, brand-based dominance, tender capture, or large organisations using scale to make themselves the easiest option for Government.

These practices can reduce real participant choice.

They can also make it harder for independent Support Coordinators to challenge poor practice, question value for money, raise safeguarding concerns or support a participant to move away from an unsuitable provider.

This is why future reform must include explicit anti-capture safeguards.

The Committee should require Government to show how the Bill, future rules and commissioning arrangements will prevent:

• large provider alliances from shaping the future model around their own interests;
• preferred-provider networks replacing genuine participant choice;
• vertically integrated providers indirectly controlling coordination pathways;
• not-for-profit status being treated as a substitute for independence;
• organisational size being mistaken for quality;
• tender capacity being mistaken for participant outcomes;
• participants with high-value plans becoming locked into provider ecosystems;
• independent state-based providers being priced out before commissioning begins. This issue is central to the Bill.

If pricing removes independent providers and future commissioning favours large alliances, the Scheme may reduce the number of providers while increasing provider power.

That is not reform.

That is consolidation.

Approved by Frankie submits that the future model should not be built around whoever is easiest for Government to contract with. It should be built around participant safety, independence, supported decision-making, workforce quality and the ability to challenge provider markets when they fail.

For participants with no informal supports, no family advocate, guardianship involvement or communication barriers, independent Support Coordination may be the only function able to stand outside the provider ecosystem and ask whether the person is being heard.

That is what must be protected.

10. Non-contactable participants: a critical safeguarding risk Approved by Frankie is particularly concerned about the Bill’s provisions relating to participants who are “not contactable”.

The Bill creates a pathway where a participant being unable to be contacted can lead to plan suspension and, over time, potential revocation of participant status. We understand the administrative purpose of this provision. The Agency must be able to manage inactive plans and make reasonable attempts to confirm participant circumstances.

However, for people with complex disability, being “not contactable” is often not an administrative issue.

It is often a safeguarding signal.

Approved by Frankie sees this frequently. A participant may appear not to be engaging when the reality is that they are critically unsafe, unwell, homeless, hospitalised, incarcerated, traumatised, without a phone, under coercive control, avoiding services because of previous harm, cognitively impaired, under guardianship, or unsupported to communicate.

This is a high-risk scenario. It cannot be safely managed as a standard contact process.

For many participants with complex psychosocial disability, acquired brain injury, intellectual disability, trauma histories, no informal supports or substitute decision-making arrangements, engagement is slow, staged and relational. It may require weeks or months of careful outreach. It may require knowledge of the person’s history, triggers, communication style, previous harms, provider relationships, housing instability, family dynamics, hospital presentations, justice involvement and risk profile.

That work takes expertise.

It is not simply calling five times and sending a letter.

It requires clinical judgement, supported decision-making capability, trauma-informed practice, system knowledge and the ability to understand when “no response” means “the person is at risk”.

In many cases, the Support Coordinator may be the only person who knows enough to flag that non-contact is dangerous. There may be no active family member. There may be no reliable nominee. The person may be under guardianship, but the guardian may not have day-to-day visibility. The person may have moved, lost their phone, disengaged from services, left hospital, entered crisis accommodation or be in contact only with a provider who has limited interest in escalating concerns.

The Bill includes some recognition that contact attempts should not count where the Agency becomes aware the person was in hospital, another institution or experiencing homelessness. That is important, but it is not enough.

The practical question is: who checks?

Who confirms whether the participant is homeless, hospitalised, incarcerated, unsafe, under coercive control or unable to communicate?

Who contacts the Support Coordinator before suspension?

Who contacts the guardian, nominee, hospital social worker, housing service, mental health team, advocate or known provider?

Who understands whether the person’s apparent non-engagement is actually a symptom of disability, trauma or crisis?

Who holds the picture together where no single service does?

For complex participants, this cannot be left to an administrative assumption.

Before any plan suspension, funding consequence or revocation pathway is triggered because a participant is not contactable, there must be a mandatory human safeguard. That safeguard should require the NDIA to actively check with known formal supports, including the participant’s Support Coordinator, Recovery Coach, guardian, nominee, advocate, health team, housing provider or other relevant service.

Where a Support Coordinator is involved, they should be treated as a critical safeguarding contact before any adverse action is taken.

This is not about protecting a provider role. It is about protecting participants who may have no one else close enough to understand what non-contact actually means.

For the cohort Approved by Frankie supports, non-contact is often the moment when the system should lean in, not step back.

The Bill should make that clear.

11. Functional capacity and progressive disability Approved by Frankie is also concerned that the Bill’s focus on functional capacity must be applied with particular care to people with progressive disability.

Functional capacity is not fixed. It can change over time, sometimes slowly and sometimes rapidly. For people with progressive conditions such as multiple sclerosis, Huntington’s disease, motor neurone disease, Parkinson’s disease, younger onset dementia and other neurological or degenerative conditions, capacity is not simply a snapshot of what the person can do on one day.

It is a moving picture.

A participant may appear capable at assessment but be losing function in ways that are predictable, clinically significant and difficult to reverse once supports are withdrawn or

delayed. They may be able to complete a task occasionally, but not safely, repeatedly or without exhausting themselves. They may still be working, parenting, volunteering or contributing economically, while also needing support to maintain that role and prevent isolation, deterioration or crisis.

This matters because the NDIS should not wait until a person has fully lost function before recognising support need.

The Scheme should support people to maintain independence, connection, work, relationships and community participation for as long as possible.

Approved by Frankie has direct insight into this. One of our valued Support Coordinators lives with multiple sclerosis. He is skilled, deeply knowledgeable and brings lived experience that strengthens our organisation. His work keeps him connected and supports a major NDIS goal: economic contribution and participation.

He is also a single man living in a regional town without informal supports.

Despite having the knowledge of the system, despite being surrounded by colleagues who understand the NDIS, and despite reasonable workplace adjustments, the way his own plan has been developed means he is now struggling to leave his house.

That should trouble the Committee.

If a skilled Support Coordinator living with progressive disability, backed by a whole organisation of colleagues who understand the Scheme, cannot get timely traction to maintain basic independence and community access, what happens to participants who have no voice, no family advocate, no professional knowledge, no informal supports and no one to challenge the system around them?

This is the point.

Functional capacity must not be reduced to a narrow assessment of what a person can do in a controlled moment. It must consider trajectory, disease progression, fatigue, environmental barriers, regional access, informal support availability, safety, sustainability and the cost of losing function that could have been maintained with earlier support.

For progressive disability, the question should not only be:

What can this person do today?

It should also be:

What support is required to maintain function, prevent avoidable decline, preserve participation and avoid higher long-term Scheme and mainstream system costs?

The Bill should require functional capacity decisions to include evidence from people who understand the participant over time, including treating clinicians, allied health practitioners, Support Coordinators, Recovery Coaches, family or informal supporters where they exist, and the participant themselves.

It should also recognise that people without informal supports are at greater risk. They may have no one to notice functional decline, no one to advocate when supports are inadequate, and no one to help them challenge a decision that does not reflect their lived reality.

For people with progressive disability, late support is often more expensive than early support.

If the Scheme is serious about sustainability, it must not create assessment and planning processes that wait for people to fall further before support is considered reasonable and necessary.

12. Future Support Coordination must be tiered, independent and specialist Approved by Frankie supports reform to improve quality and remove poor practice from the Support Coordination market.

However, the future model must not flatten Support Coordination into generic connection.

For lower-complexity participants, a general connection function may be appropriate.

For complex participants, the Scheme needs specialist independent coordination.

This function should include:

• supported decision-making;
• safeguarding escalation;
• provider-market testing;
• hospital discharge coordination;
• SIL and accommodation challenge;
• conflict-of-interest management;
• fraud and plan waste identification;
• functional capacity context;

• multi-agency coordination;
• crisis prevention;
• plan stewardship;
• continuity of trusted relationships. The future model should be built around the capability required by the most complex participants, not around administrative convenience.

13. Questions the Committee should require Government to answer Before future Support Coordination or connection reforms proceed, the Committee should require Government to answer the following:

14. How will independent Support Coordination providers be preserved before commissioning begins?

15. How will pricing be corrected so providers can directly employ, supervise and retain skilled practitioners under proper employment conditions?

16. How will the future model prevent large provider alliances from consolidating control over participants with high-value plans?

17. How will Government prevent vertically integrated providers from influencing participant pathways through SIL, housing, preferred-provider relationships or service ecosystems?

18. How will participants with no informal supports access independent support to express will and preference?

19. How will existing trusted Support Coordination relationships be protected for complex participants?

20. How will quality be defined beyond organisational size, national footprint, tender capacity or not-for-profit status?

21. How will providers with multiple service lines be prevented from using coordination or connection functions to protect downstream revenue?

22. How will the Bill ensure functional capacity decisions include evidence from practitioners who know the participant over time?

10. How will the Scheme avoid replacing participant choice with provider market management?

11. How will pricing be tested against a true direct-employment model rather than low- overhead subcontracting?

12. How will Government prevent future reform from accelerating referral alliances, preferred-provider networks and anti-market conduct?

13. Recommendations Approved by Frankie recommends that the Committee:

14. Recognise independent Support Coordination as a Scheme integrity function.

Independent Support Coordination and Specialist Support Coordination should be

recognised as safeguarding, fraud-prevention and cost-avoidance functions for complex participants.

2. Correct Support Coordination pricing. Pricing should include immediate correction, annual indexation and a specialist complexity rate that reflects the real cost of fair employment, supervision, clinical skill, compliance, risk governance and professional practice.

3. Price Support Coordination against a direct-employment quality model. Government should not use subcontractor, sole trader or low-overhead delivery models as the benchmark for Support Coordination pricing. Pricing should be based on the real cost of direct employment, Fair Work conditions, supervision, governance, documentation, clinical consultation, compliance, audit, risk escalation and continuity for complex participants.

4. Preserve independent providers before commissioning. Government should publish a market preservation strategy before any commissioned Support Coordination or connection model begins.

5. Require a specialist independent stream. Any future model must include specialist independent coordination for participants with complex disability, high-value plans, supported decision-making needs, SIL risk, guardianship, hospital interface, justice interface, homelessness, family violence or limited informal supports.

6. Make independence a core quality measure. Providers delivering SIL, core supports, accommodation, therapy or plan management

should not coordinate supports for participants using those related services, except in exceptional thin-market circumstances with clear safeguards.

7. Protect trusted relationships. Existing Support Coordination relationships for complex participants should be protected unless there is evidence of poor practice, conflict of interest or the participant chooses to change.

8. Assess market concentration and conflict of interest. Government should undertake a market concentration and conflict-of-interest assessment before commissioning, including assessment of large provider alliances, preferred-provider networks and vertically integrated systems.

9. Anticipate provider alliances and anti-market behaviour. Before implementing future commissioning, Government should assess how large providers, not-for-profit alliances, preferred-provider networks and vertically integrated service systems may use legislative change to consolidate referral pathways and preserve market position. Safeguards should prevent anti-market behaviour and protect genuine participant choice.

10. Commission for workforce quality, not organisational size. Commissioning criteria should value direct employment, Fair Work conditions, workforce qualifications, supervision, clinical understanding, supported decision-making capability, audit history, participant outcomes and local systems knowledge above organisational size or tender capacity.

11. Require human review before adverse action. Human review and supported outreach should be required before adverse action is taken where a participant cannot be contacted, particularly for participants with psychosocial disability, cognitive disability, homelessness, guardianship, hospitalisation, justice involvement, family violence risk or limited informal supports.

12. Include longitudinal practice evidence in functional capacity decisions. Functional capacity decisions should consider evidence from Support Coordinators, Recovery Coaches, guardians, health teams, behaviour support practitioners and others who know the participant over time.

13. Create a protected reporting pathway. Independent Support Coordinators should have a protected pathway to report fraud, conflict of interest, provider capture and safeguarding concerns without retaliation.

14. Separate participant voice from provider voice. Government should consult directly with participants, families, guardians, advocates, independent Support Coordinators and complex-cohort practitioners. Provider alliances and large organisations should not define participant voice on behalf of people whose plans they have a financial interest in servicing.

15. Conclusion Approved by Frankie supports the goal of securing the NDIS for future generations.

But the NDIS will not be secured by pricing out the independent functions that prevent crisis, waste, fraud, provider capture and exploitation.

Approved by Frankie is evidence that independent Support Coordination can work at scale. We are large, but not vertically integrated. We are state-based, but nationally significant. We are clinically informed, but not bureaucratic. We directly employ staff under proper conditions, but current pricing does not properly value that workforce. We support complex participants, but we do not have downstream service revenue to protect.

That combination is rare.

The Committee should ask Government directly:

Do you want to lose this resource?

If Government wants independent, accountable, clinically informed and fairly employed Support Coordination, it must design the Bill, pricing and future commissioning model to preserve it.

The NDIS does not need less coordination for complex participants.

It needs better, independent, properly funded coordination, delivered by skilled and appropriately qualified employees who understand disability, systems, risk, rights, supported decision-making and the reality of people with no one else to hold the system around them and to account.