Submission 3414 — Ms Katrina Bourne — NDIS Future Generations Bill

Submission to the Senate Community

Affairs Legislation Committee

National Disability Insurance Scheme Amendment

Bill 2026

Submitted by:

Katrina Bourne

NDIS Plan Manager

Date: 8 July 2026

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Executive Summary

The National Disability Insurance Scheme Amendment Bill 2026 seeks to strengthen the sustainability and integrity of the NDIS. While these objectives are strongly supported, the Bill remains heavily weighted toward participant administration, post

payment enforcement, and  structural reform,  rather than addressing the most

significant driver of inefficiency within the Scheme: small-scale fraud, weak pre payment verification, and inconsistent application of existing pricing rules.

A key challenge in public understanding of the NDIS is that many stakeholders, including some policymakers and members of the public, do not fully appreciate how the Scheme operates at ground level. This has contributed to a reform environment shaped by perception and pressure rather than the operational realities experienced by frontline Plan Managers.

Based on  daily  operational  experience, a  substantial  proportion  of avoidable

expenditure arises from small-scale but repeated issues, including incorrect claiming, inflated or unsupported charges, and invoices that do not reflect verified service

delivery. While estimates have suggested  small-scale  fraud may account  for

approximately 8.3% of Scheme expenditure, our experience indicates the actual figure may be higher due to under-detection in largely automated or lightly supervised payment pathways.

A core systemic weakness is the absence of consistent pre-payment verification across all management types. In many cases, payments are processed with limited confirmation that the support was actually delivered. This creates an environment where incorrect or inappropriate claims may be paid without timely detection.

A recent example illustrates this risk: an invoice was received from a physiotherapist claiming services delivered on 11/05/2026 for a participant who had passed away on 03/05/2026. In a fully automated payment environment, there is a strong likelihood this invoice would have been processed without human intervention, highlighting the limitations of current safeguards when real-time verification is absent.

In contrast, smaller Plan Management businesses often apply higher levels of manual scrutiny and are able to identify anomalies that automated systems may miss. This includes recognising inconsistencies in participant status, service patterns, and provider behaviour.

Transport and travel claiming is another area of systemic inconsistency. While the NDIS Pricing Arrangements and Price Limits (PAPL) set a benchmark of up to $0.99 per kilometre for provider vehicle use, there is inconsistent interpretation across the Scheme. In practice, some providers charge $1.00 per kilometre as standard, while others charge as high as $1.50 per kilometre, significantly exceeding both the intended benchmark and comparable ATO rates ($0.88 per kilometre for 2025–26). This variation reflects a broader lack of clarity and enforcement consistency, contributing to avoidable overspend.

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As Plan Managers, consistent application of the $0.99 per kilometre benchmark alone has resulted in measurable savings. Over a recent ten-month period, this approach generated savings of $4,128.24, equating to approximately $13.90 per participant. Scaled nationally, this represents an estimated potential saving of approximately $10.76 million annually without reducing participant supports.

These findings demonstrate that meaningful efficiency gains can be achieved through better enforcement of existing rules, rather than reductions in participant funding.

The most effective mechanism for reducing fraud and inappropriate claiming is real time verification that supports have actually been delivered. Similar to workplace clock-on and clock-off systems, providers and support workers should be required to verify attendance and service delivery before invoices are submitted for payment. This requirement should apply consistently across registered, unregistered, plan-managed, and agency-managed pathways.

While provider registration reforms are a positive step, they do not address the

ongoing  risk of small-scale, opportunistic fraud, which  is often fragmented and

therefore difficult to detect through post-payment review alone.

Finally, there are additional opportunities for targeted cost containment without reducing participant plans. In particular, greater scrutiny of high-use household support items (such as cleaning and yard maintenance) may be warranted where functional need is not clearly demonstrated, ensuring that funding remains focused on disability-related support needs.

In summary, the Bill represents an important governance reform package, but it does not sufficiently address the core issue of payment integrity at the point of transaction. Strengthening pre-payment verification, enforcing existing pricing rules consistently, and introducing real-time service validation would significantly improve sustainability while protecting participant outcomes.

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Senate Community Affairs Legislation

Committee

Submission on the National Disability Insurance

Scheme Amendment Bill 2026

Submitted by:

Katrina Bourne

NDIS Plan Manager

Introduction

I welcome the opportunity to provide this submission to the Senate Community Affairs

Legislation Committee  regarding  the  National  Disability Insurance Scheme

Amendment Bill 2026.

I have worked on the frontline of the NDIS for many years as an independent Plan Manager alongside my twin sister, Amanda. Through our daily work, we process participant claims, identify non-compliant invoices, educate providers, and observe firsthand how Scheme funds are being utilised.

This practical experience provides a perspective that is often underrepresented in

policy development: the operational  reality  of how NDIS funding moves from

participant plans, through service delivery, to payment.

The Government has stated that the purpose of this Bill is to improve the sustainability and integrity of the NDIS while ensuring participants continue to receive high-quality supports.

While these objectives are essential, the Bill does not adequately address one of the most significant challenges facing Scheme sustainability: ensuring that every payment made by the NDIS represents a genuine disability support that was actually delivered.

Fraud, waste, inappropriate claiming, weak financial controls and limited mechanisms to verify service delivery prior to payment continue to create significant integrity risks.

Many  of  the proposed  reforms  increase  controls and  obligations  relating  to

participants, budgets and planning processes, while  significant weaknesses  in

provider accountability and payment verification remain largely unresolved.

This submission responds to the Committee’s Terms of Reference and provides recommendations to strengthen the Bill while protecting participants and ensuring public funds are directed towards genuine disability supports.

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Whether the Bill improves the sustainability of the NDIS

The long-term sustainability of the NDIS will depend not only on managing participant expenditure, but equally on ensuring that every claim paid by the Scheme represents a genuine disability support that was actually delivered.

Strengthening pre-payment verification and provider accountability would protect participants, reduce fraud and inappropriate claiming, and preserve Scheme funding for those who rely upon it.

Current reform discussions focus heavily on:

• participant budgets
• planning processes
• assessment pathways
• administrative powers However, there remains limited focus on preventing invalid payments before they occur.

From a Plan Manager’s perspective, Scheme expenditure continues to be impacted by:

• duplicate invoicing
• inflated service hours
• unsupported transport claims
• incorrect support item claiming
• over-servicing
• claims inconsistent with participant circumstances
• missing mandatory invoice information
• potentially fraudulent claims These issues demonstrate the need for stronger payment integrity measures across all payment pathways.

Transport and travel claiming integrity

The NDIS Pricing Arrangements and Price Limits (PAPL) establish clear parameters for provider travel claims, including:

• up to $0.99 per kilometre for provider or worker-owned vehicles 5

• up to $2.76 per kilometre for accessible vehicles or buses under Activity-Based

Transport

• reimbursement of actual costs such as tolls, parking and public transport fares The $0.99 per kilometre rate is intended to represent a reasonable contribution towards vehicle operating costs and is already higher than the Australian Taxation Office (ATO) rate of $0.88 per kilometre for the 2025–26 financial year.

Despite this framework, inconsistent application continues to occur.

Examples include:

• providers routinely charging $1.00 per kilometre as a standard practice
• providers charging up to $1.50 per kilometre, often citing increased fuel costs These practices demonstrate inconsistent interpretation of pricing rules and contribute to avoidable Scheme expenditure within a high-volume claiming category.

Stronger national guidance, provider education and compliance enforcement would improve consistency without restricting access to legitimate participant supports.

Understanding the Scheme and addressing small-scale fraud

A significant challenge facing the NDIS is that many policymakers and members of the public do not fully understand how the Scheme operates in practice.

While  estimates suggest  fraud and  non-compliant  claiming may account  for

approximately 8.3% of Scheme expenditure, frontline experience indicates the impact may be higher due to the difficulty of detecting smaller-scale inappropriate claiming.

Many payment systems rely heavily on automated invoice processing, with limited real-time verification that a service was actually delivered.

At the centre of Scheme integrity is a simple but fundamental question:

Did the support actually occur?

Recently, we received an invoice from a physiotherapist claiming services delivered on 11/05/2026 for a participant who had passed away on 03/05/2026.

Under a fully automated payment model, there is a significant risk that this type of claim could be processed without appropriate review.

As a small boutique Plan Management provider, we are often able to identify

anomalies  quickly  because we  have  direct  knowledge  of  participants,  their

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circumstances and their providers. This contextual oversight is difficult to replicate in large-scale automated systems without appropriate safeguards.

The most effective way to reduce fraud and inappropriate claiming is to verify that supports have actually been delivered.

The technology required  to achieve  this already  exists. Electronic attendance

verification systems are widely used across healthcare, aged care and workforce management sectors. Similar principles could be applied within NDIS payment pathways to confirm service delivery before public funds are released.

Importantly, legislation should establish minimum service verification standards rather than mandate a single technology platform.

This would allow providers and participants to select compliant solutions capable of recording:

• attendance
• service delivery
• participant acknowledgement while encouraging innovation and minimising implementation costs.

Embedding technology-enabled verification into payment processes would shift the NDIS from a predominantly post-payment compliance model towards a preventative integrity model.

This approach would reduce:

• fraud investigations
• debt recovery activity
• administrative burden
• disputes between participants and providers while ensuring more funding is directed towards genuine participant supports.

Mandatory provider registration is an important safeguard; however, registration alone does not verify that an individual service occurred.

A  registered  provider can   still submit  inaccurate  or  fraudulent  claims where

independent verification mechanisms do not exist.

Effective Scheme integrity requires both provider regulation and robust payment verification.

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System integrity concerns

The Bill strengthens post-payment enforcement measures, including debt recovery and compliance action.

While these measures are necessary, they do not replace effective pre-payment verification.

Preventing incorrect payments before they occur is significantly more efficient than attempting to recover funds after payment has already been made.

In our experience, concerns regarding inappropriate claiming are often reported but may remain unresolved while providers continue submitting invoices.

In one instance, a provider we had reported for suspected fraudulent activity was subsequently registered under the Scheme, raising concerns regarding oversight and information-sharing processes.

Where concerns are identified, timely intervention is essential to protect participants and public funds.

Recommendation: Technology-enabled

service verification

The Committee should consider  introducing  legislated minimum standards  for

electronic service verification prior to payment for higher-risk supports.

These standards should require evidence that a support was delivered before a claim is paid, while allowing providers and participants to select any compliant technology platform capable of recording:

• attendance
• service delivery
• participant acknowledgement Cleaning and yard maintenance supports

Consideration should be given to reviewing the following support categories:

• 01_020_0120_1_1 – House Cleaning and Other Household Activities 8

• 01_019_0120_1_1 – Lawn and Garden Maintenance Access to these supports should remain focused on participants with a demonstrated disability-related functional need.

Concerns observed in practice include:

• participants receiving supports despite apparent capacity to undertake tasks independently

• providers billing minimum service blocks regardless of actual need

• duplication between informal and funded supports NDIS funding should remain targeted towards disability-related support needs rather than routine household activities where functional capacity exists.

Fraud, waste and abuse

The Explanatory Memorandum outlines a commitment to Scheme integrity; however, many proposed mechanisms remain weighted towards identifying and recovering funds after payment has occurred.

As a Plan Manager, I routinely identify invoices containing:

• impossible service hours
• incorrect support codes
• duplicate claims
• mathematical errors
• unsupported travel charges
• services inconsistent with participant plans
• potentially fraudulent claims These issues are frequently identified through manual review before payment occurs.

Other payment pathways do not consistently apply equivalent scrutiny.

We have also received invoices for services claimed after a participant had passed away, highlighting significant gaps in real-time verification.

Without stronger safeguards, even digital payment systems risk processing invalid claims.

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Recommendation: Minimum invoice

verification standards

Introduce minimum invoice verification requirements prior to payment across all management types:

• Agency Managed
• Plan Managed
• Self Managed Impact on participants

Participants deserve both flexibility and protection.

Many participants reasonably assume that invoices paid through the NDIS have been appropriately verified.

In practice, payments may occur with limited validation.

Risks include:

• financial exploitation
• incorrect or inappropriate charging
• reduced funding available for legitimate supports
• loss of confidence in the Scheme Strengthening payment integrity ensures funding is directed towards genuine

disability-related supports.

Provider accountability

Provider accountability remains significantly weaker than participant accountability.

Providers are not consistently required to provide evidence at the point of claim, including:

• attendance records
• service verification
• contemporaneous documentation
• participant acknowledgement
• supporting evidence for amounts claimed 10

Instead, this information is often requested only after payment has occurred.

This creates an environment where inappropriate claiming can continue undetected for extended periods.

Conclusion

The NDIS Amendment Bill 2026 contains important measures aimed at improving Scheme governance and sustainability. However, its focus remains heavily weighted towards participant administration and expenditure management rather than payment integrity.

As a frontline Plan Manager, I believe the greatest opportunity to strengthen the Scheme lies in preventing invalid payments before they occur.

Every dollar lost through fraud, poor claiming practices or administrative inefficiency is a dollar unavailable to support Australians living with disability.

The Committee has an opportunity to strengthen this legislation by introducing preventative integrity measures that improve accountability, protect participants and ensure the long-term sustainability of the NDIS.

A sustainable NDIS must not only manage demand; it must ensure that every dollar spent represents a genuine disability support delivered to a person with disability.

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