Quality care and health services for Victorians depend on a quality workforce (Provider advocacy) | External submission

Submission 345

SUBMISSION: National Disability

Insurance Scheme Amendment

(Securing the NDIS for Future

Generations) Bill 2026

June 2026 For inquiries regarding the contents of this submission, please contact:

Paul Healey, HACSU State Secretary

Rebecca Sprekos, HACSU Assistant State Secretary

Submission 345

Contents

Introduction ……………………………………………………………………………………………………………………….. 2 Executive Summary ……………………………………………………………………………………………………………….3 Recommendations ………………………………………………………………………………………………………. 3 Schedule 1 - Access and Planning Measures ………………………………………………………………………..4 Schedule 2 – Fraud and Integrity Measures ………………………………………………………………………….5 Schedule 3 – Governance Arrangements ……………………………………………………………………………..5 Future Concerns and Opportunities for Review ………………………………………………………………….. 6 Conclusion …………………………………………………………………………………………………………………………. 7

Introduction

The Health and Community Services Union (HACSU) is the Victoria No. 2 Branch of the Health Services Union (HSU). HACSU is one of the fastest growing HSU Branches in Australia, with over 13,000 members working in disability, mental health, and drug and alcohol services across Victoria.

For over a century, HACSU has represented workers who make a real difference to the lives of people living with mental illness, disability, and drug and alcohol addiction. HACSU members are employed in a range of occupations including nurses, health professionals, disability and human service workers, program and support workers, trades and administration.

HACSU’s longstanding position is that quality care and health services for Victorians depend on a quality workforce. This means a workforce that is recognised for its skills, commitment and passion in making sure the most vulnerable and disadvantaged Victorians can live better lives and become active citizens.

The Health Services Union Victoria No 2 Branch (HACSU) welcomes the opportunity to provide a submission to the Senate Standing Committee on Community Affairs Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

Submission 345

Executive Summary

Alongside other Unions representing workers in the National Insurance Disability Scheme (NDIS), HACSU has been involved in fighting for better working conditions and improved outcomes for people from the inception of the NDIS. We have been vocal in demanding improvements to the scheme to better protect workers and participants. We seek to ensure that serious systemic issues which threaten the NDIS’ sustainability, fairness and workforce viability are addressed as a matter of priority.

These safeguards cannot be built upon unstable foundations, the introduction of a risk proportionate provider registration scheme will ensure that the participants can be confident in the quality of the service they will receive, regardless of the provider. We support the proposed amendments at Schedule 2, Part 1 to amend the definition of ‘NDIS provider’ and the recognition of the negative consequences of low registration of NDIS providers.

As a union, we are opposed to limiting spending growth through austerity measures. The expenditure of the NDIS will continue to grow as more Australians with disabilities are accessing supports to fully engage with their community on their own terms. Investment in disability supports delivers social and economic benefits. Australians should be made aware of the value the NDIS provides to the community.

HACSU recognises that there must be changes made to the NDIS to ensure its ongoing viability and to secure this crucial scheme for future generations, however, we must express our deep concerns with the changes proposed in this legislation. Many of the proposed austere measures will negatively impact the lives of our most vulnerable community members and the workers who support them rather than the dodgy providers who are rorting the system, abusing workers and participants alike. We support the Fraud and Integrity Measures outlined in Schedule 2 of this Bill, yet we urge the Federal Government to take further action to stamp out dodgy providers, shore up worker protection within the scheme and introduce a national mandatory worker registration scheme as a priority.

Reforms  of  this  scale  require meaningful  construction,  clear safeguards and  careful

implementation. The period available for stakeholders to engage with the Committee and provide submissions was grossly inadequate, we echo the sentiments of other submissions and call on the Federal Government to extend the period for submissions to ensure proper consultation with the affected community. These submissions respond to three schedules of the Bill which directly affect HACSU members and impacts the support they can provide to people with disability. We urge the Committee to recommend substantial amendments before it passes.

Recommendations

Recommendation: Ensure all relevant Ministerial Powers are subject to

Parliamentary Oversight and Independent Review

Amend the Bill to include a restriction of the Minister’s unilateral power to reduce funding for specific support categories. Include a requirement for any proposed determination under Section 34 to require an independent, public participant

Submission 345

safety impact assessment, and made a disallowable instrument subject to active parliamentary scrutiny.

Recommendation: Expand Mandatory Registration to all High-Risk Disability

Service Providers

HACSU recommends that the Government undertakes further consultation with industry stakeholders to ensure that mandatory, robust regulatory oversight is appropriately applied. This is an opportunity to ensure that the most vulnerable workers and participants receive proper protection.

Recommendation: Introduction of an Independent Pricing Authority HACSU recommends that final price-setting authority should be transferred to a completely independent, external pricing body rather than the Minister. This external body should be provided with a mandate to set pricing limits based upon the cost of high-quality, best practice and safe service delivery.
Recommendation: Establish a Worker Registration Scheme Pilot HACSU recommends that the Bill is amended to mandate the creation of a

comprehensive, individual National Worker Registration Scheme. This Scheme

should be tied to minimum required qualifications, secure employment pathways and professional standards. We strongly recommend that the Commonwealth immediately fund a pilot of a nationwide scheme using the Victorian voluntary worker registration model as a template.

Recommendation: A Formal, Structured Consultation Framework HACSU recommends that the Federal Government establishes a formal, structured framework for consultation with HACSU and other relevant unions. This consultation framework must be backed by a fully funded NDIS Workforce Plan focused on secure employment, wage growth, and mandatory training.

Schedule 1 - Access and Planning Measures

The Bill introduces Section 34A, granting the Minister unilateral power to reduce funding for support categories. In its current form, this power is largely unrestricted, requiring only that the Minister consider participant safety. HACSU is concerned that reductions in one category may create unintended consequences across others. For example, reduced funding for social and community participation may increase demand in other support areas to maintain adequate care. HACSU does not believe that any wholesale reduction in spending will aid this Bill in achieving its goals in securing the NDIS for future generations.

Recommendation: Ensure all relevant Ministerial Powers are subject to

Parliamentary Oversight and Independent Review

Submission 345

Schedule 2 – Fraud and Integrity Measures

HACSU is in staunch agreement with the Government’s decision to mandate registration for providers involved in the delivery of Daily Activities and Personal Care supports. A large proportion of our members are represented in these supports and recognise that these are the most intimate and high-risk interactions in a participant’s life. It is without doubt that these services should be subject to mandatory, robust regulatory oversight. We welcome this long-overdue step to remove bad-faith actors and introduce further professionalisation of the sector.

HACSU recommends that the Government takes further steps to mandate registration for all high-risk service environments. The current structure of the Bill risks leaving workers and participants exposed without oversight in a transitioning sector which urgently requires further regulation.

Recommendation: Expand Mandatory Registration to all High-Risk Disability

Service Providers

Schedule 3 – Governance Arrangements

HACSU is opposed to the proposal to transfer final pricing authority directly to the Minister, with minimal oversight. The Explanatory Memorandum of the Bill incorrectly asserts that the Independent NDIS Review recommended for the Government to take an active role in price setting within the NDIS. This is incorrect. The Review rightly addressed the conflict of interest which is inherent when the NDIA holds responsibility for both the overall sustainability of the scheme and the pricing caps. It is concerning that the proposed model ignores this recommendation. To ensure the sustainability of the NDIS for future generations HACSU proposes the following recommendation.

Recommendation: Introduction of an Independent Pricing Authority

HACSU recommends that final price-setting authority should be transferred to a completely independent, external pricing body rather than the Minister. This external body should be provided with a mandate to set pricing limits based upon the cost of high-quality, best practice and safe service delivery.

Submission 345

Future Concerns and Opportunities for Review

A National Worker Registration Scheme

HACSU has consistently advocated for the creation of a mandatory Worker Registration Scheme which is linked to minimum qualifications, continual professional development and secure employment pathways. It is our view that this is essential to improving the quality of disability service and providing better protections from abuse for participants.

Victoria currently runs a voluntary registration scheme through the Victorian Disability Worker Commission. It is our belief that the Federal Government should look to this scheme to model a pilot project federally. This presents an opportunity to professionalise this workforce, create a centralised register that reduces the turnover rate of staff, recognise the skills involved in providing disability care and ensure that only screened and qualified workers are a part of the NDIS.

Recommendation: Establish a Worker Registration Scheme Pilot

HACSU recommends that the Bill is amended to mandate the creation of a

comprehensive, individual National Worker Registration Scheme. This Scheme should

be tied to minimum required qualifications, secure employment pathways and professional standards. We strongly recommend that the Commonwealth immediately fund a pilot of a nationwide scheme using the Victorian voluntary worker registration model as a template.

The Impact of Austerity on the Quality-of-Service Delivery

HACSU members have spent decades advocating for improved funding to ensure that the participants they support receive the highest possible level of care. When funding in the NDIS is reduced, private providers immediately respond by reducing the outlay on their direct-care workforce as they aim to maintain their operating margins. In an already hyper casualised workforce we hold concerns that reductions to support categories will incentivise providers to move away from a permanent workforce.

This will have a direct negative impact on participants who reside in long-term supported accommodation. The workers who provide this support are also key members of these participants social networks and safety systems. High turnover of staff in these high-risk situations leads to an increase in the risk of abuse, neglect and exploitation of participants.

The austerity measures in the Bill are a clear departure from the values-based not-for-profit foundations of the NDIS and we encourage the Committee to advocate for a return to these values. We echo the call of the HSU to use this Bill to redirect funds towards non-profit, public and cooperative models of care that ethically prioritise any surpluses to workers and participants.

Submission 345

Ongoing Consultation

The Explanatory Memorandum of the Bill contains an intention for further consultation with relevant stakeholders; however, the structure and formation of this consultation goes unmentioned. To ensure that proper consultation occurs we wish to encourage the inclusion of a formal, structured consultation framework within the Bill.

Recommendation: A Formal, Structured Consultation Framework

HACSU recommends that the Federal Government establishes a formal, structured framework for consultation with HACSU and other relevant unions. This consultation framework must be backed by a fully funded NDIS Workforce Plan focused on secure employment, wage growth, and mandatory training.

Conclusion

HACSU welcomes the opportunity to contribute to reforms that ensure the long-term sustainability of the NDIS. A strong, well-supported workforce must remain central to these reforms.

Measures such as workforce professionalisation and mandatory registration will help ensure the NDIS continues to deliver high-quality support.

HACSU urges the Committee to recommend amendments that strengthen consultation, oversight, and participant outcomes.