Submission 362 Hireup ti
Committee Secretary 1 June 2026
Senate Standing Committee on Community Affairs
Parliament House
Canberra ACT 2600
Dear Committee Members
Hireup submission: Inquiry into the National Disability Insurance Scheme
Amendment (Securing the NDIS for Future Generations) Bill 2026
The NDIS is one of Australia’s most important social reforms. It has transformed what is possible for people with disability by enabling greater independence, participation and control over everyday life. However, the Scheme has also grown into a large and complex provider market without the structural settings needed to govern it consistently or adequately.
The issues now before the Parliament are not new. Concerns about the Scheme’s design, sustainability, provider visibility, pricing, regulation and safeguarding have been raised across multiple reviews, inquiries, audits and public debates over many years. While those processes have given these issues formal expression, some of the underlying design risks were visible from the Scheme’s inception.
Reading Dr Simon Duffy’s1 2012 critique of the NDIS today feels uncomfortably close to looking into a crystal ball. He warned that a highly centralised scheme, where the individual plan became the main mechanism for control, where fiscal responsibility sat heavily with the Commonwealth, and where responsibility was not sufficiently shared across states, communities, services, families and citizens, would be vulnerable to exactly the pressures now being addressed through legislation. His concern was that this design would generate cost pressure and, once that pressure became politically unavoidable, governments would reach for blunt controls such as tighter eligibility, caps, clawbacks and administrative rationing.
More than a decade later, the Bill now before the Parliament is dealing with many of those pressures in legislative form. While public attention has often focused on fraud, rorting and individual misconduct, the deeper issue is the way the market has been allowed to develop. Planning, pricing, regulation and oversight have evolved alongside each other, but not always in a coordinated way. The result is a system where comparable supports can be delivered under very different levels of oversight, and where providers with materially different obligations and overheads can access the same level of public funding.
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Submission 362
The Bill is an important legislative step in responding to long-standing pressures in the Scheme. It establishes mechanisms to strengthen provider visibility, pricing governance, plan management, compliance powers and broader market regulation.
Hireup recognises that the Bill introduces significant structural changes to the NDIS. If the legislation progresses, it will be critical that implementation is carefully designed to avoid unintended consequences for people with disability and to preserve access to the supports they rely on. The practical impact of the reforms will depend heavily on the rules, instruments, guidance and systems that follow. These should be developed through genuine consultation with people with disability, families, carers, providers, workers and the broader sector.
This submission focuses on the provider and market integrity settings where Hireup has direct operational experience. In doing so, we recognise that these issues are not separate from participant outcomes. A sustainable NDIS depends not only on managing expenditure, but on building a provider market that is visible, accountable, properly regulated and sustainably priced.
Impacts on people with disability
Hireup recognises that the Bill will have significant consequences for people with disability, families and carers, because it affects the legal and practical architecture through which people enter the NDIS, have their needs assessed, receive funding, maintain supports and seek changes when their circumstances shift.
Although the reforms are directed toward sustainability, consistency and integrity, their real-world effect will be experienced through the everyday questions that matter most: whether participants will remain eligible, whether their plan reflects the reality of their disability-related needs, whether trusted support relationships can continue, whether community participation remains possible, and whether there is a clear and fair pathway to support when life changes.
The scale of change should be carefully understood, particularly because the measures will not operate in isolation. A limited reassessment pathway may reduce participants ability to update a plan when their needs or circumstances change. This creates a risk that funding decisions remain in place even where they no longer reflect a participant’s support needs. A tighter link between funded supports and eligible impairments may create particular challenges for people with multiple or interacting disabilities, where day-to-day support needs often arise from the combined impact of several conditions rather than one impairment alone. A clearer boundary between the NDIS and other service systems may be necessary, but it will only work if those systems are ready to respond. Where health, mental health, community services or other mainstream supports are unavailable, under-resourced or difficult to access, participants may be left without practical support even if the legislative boundary is clear.
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The Bill would also give the Minister the power to reduce funding within particular support categories. Social, civic and community participation and capacity building daily activities have been identified as the first areas for adjustment, but the significance of this power extends beyond those categories alone. It creates scope for future reductions to be applied across other areas of participant funding without those changes necessarily being considered through an individual assessment of each participant’s needs and circumstances. Given the central role that funded supports play in people’s independence, safety and participation in community life, the breadth of this power warrants careful scrutiny.
The proposed changes to social, civic and community participation and capacity building daily activities also require careful consideration. For many people, they are the supports that enable routine, connection, confidence, skill development, employment pathways and protection against isolation. The proposed one-size-fits-all, massive reduction of fifty percent to these supports does not adhere to the principle of ensuring that support levels are personalised to each individual; instead, it appears arbitrary. While respecting the need to ensure scheme sustainability, we urge the Government to reconsider the size and blunt nature of these reductions.
Similarly, any move toward functional capacity-based assessment must be capable of recognising disability as people actually experience it, including fluctuating conditions, psychosocial disability, cognitive disability, communication barriers, trauma, limited informal support, co-occurring impairments and multiple disabilities that do not fit neatly within a single assessment category.
For this reason, the rules, assessment tools, guidance, transition arrangements and administrative systems that sit beneath the Bill will be as important as the legislation itself, and these must be developed with people with disability, families, carers and representative organisations, and applied by staff with the disability literacy, training and operational guidance needed to make decisions consistently, respectfully and safely.
The Committee will rightly hear directly from people with disability, families, carers and representative organisations about the lived impact of these reforms, and those voices must remain central to its consideration. Hireup’s submission focuses on the provider and market settings that must be strengthened alongside these changes, because participant safety, continuity and confidence depends not only on planning decisions, but also on the quality, visibility and accountability of the market delivering supports. Schedule 3, Part 1: Pricing determinations and cost differentiation
Hireup supports Schedule 3, Part 1 of the Bill, which gives the Commonwealth Minister clearer authority to set and enforce maximum prices for NDIS supports through a
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formal legislative instrument, informed by NDIA advice following the Annual Pricing Review.
Pricing is one of the most powerful settings in the NDIS. It shapes the provider market. It can produce outcomes as diverse as encouraging high quality, accountable service models, or incentivising a race to the bottom on price, with market distortion and workforce fragmentation as a result.
The current pricing framework has allowed significant market distortion. For disability support worker-delivered supports, NDIS price limits act as a hard ceiling on what an organisation can afford to do — and do well — after the non-negotiable costs of fair working conditions have been met. For years, the cohort of the sector that is registered, responsible, and driven to engage the best possible workforce delivering the highest quality supports, has told the NDIA the current system does not reward this. In fact, at times, pricing incentives punish those providers. Pricing is a critical lever in market stewardship that encourages the quality, safe services models that participants deserve and that governments say they want.
Currently, providers delivering the same support can receive the same maximum price while operating under materially different obligations. A registered provider that employs workers, pays award wages, contributes superannuation, holds workers compensation insurance, screens and onboards workers, manages complaints and incidents, prepares for audits and complies with NDIS Practice Standards can be paid the same maximum price as a provider that does not carry those same responsibilities.
This is why Hireup has consistently argued that pricing reform should be understood as cost differentiation. The issue is not simply whether one provider is paid more than another, but whether the funding received by a provider reflects the real cost of delivering support safely, lawfully and compliantly. Worker screening, onboarding, incident management, complaints handling, employment protections, insurance, supervision, quality assurance and audit readiness are not optional extras. They are part of the infrastructure of safe service delivery.
Hireup supports Ministerial pricing authority where it is exercised within a clear and accountable governance framework. Given the significance of pricing for participants, workers, providers and Scheme sustainability, pricing determinations should be transparent, evidence-based and supported by appropriate safeguards, including clear advice, published reasoning, consultation on material changes and alignment with the objects and principles of the Scheme.
We note there have been criticisms that this change vests too much power in the Minister, or that somehow this is less accountable. We would invite anyone to engage with the current NDIA annual pricing review process for consecutive years and then decide if that represents accountability. From our experience, it does not. People put in great time and effort to explain to the NDIA the dire state of pricing settings that do not reflect the full cost of quality supports, and this information seems to disappear into a black hole, for months. When the result emerges, it is often unreasonable, detrimental,
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delivered with scant evidence, and totally unchallengeable. It is regularly delivered with a mere few business days before the changes are expected to be enforced.
The Bill would make an elected representative the final decision-maker for NDIS pricing settings, and that is a step in the right, accountable, direction.
The Bill also provides a sensible starting point for bringing NDIS pricing governance closer to arrangements used in other publicly funded care markets. In aged care, the Independent Health and Aged Care Pricing Authority (IHACPA) provides independent pricing and costing advice for Support at Home services, while the Minister remains responsible for determining the final price caps that shape the market. Over time, the NDIS should move toward a similarly disciplined model, particularly as disability and aged care increasingly rely on similar workforces, in-home support models and safeguarding expectations. It would be sensible for NDIS pricing advice to be delivered independently by IHACPA instead of the NDIA, which runs into potential conflicts given they are also tasked with administering the funds.
We welcome the proposed consultation on price differentiation, should the Bill be successful. We have long argued that differentiation based on the real costs of service delivery is the only responsible, fair way to steward a market such as the NDIS and remove the distorting incentives for some providers to strip back overheads, avoid regulatory obligations and working conditions, but charge the highest possible price. Schedule 2, Part 1: NDIS provider definition and registration architecture
Hireup supports Schedule 2, Part 1 of the Bill, which updates the definition of “NDIS provider” and creates the legal foundation for expanded provider registration.
This amendment is important because the next stage of registration reform depends on the Scheme having a clearer understanding of who is operating in the provider market, who should be visible to the regulator, and who should be brought within registration and compliance obligations. Without that foundation, mandatory registration risks being applied inconsistently, with some providers that carry real responsibility remaining outside meaningful oversight while other entities that are not genuinely providing disability supports are unnecessarily captured.
There has historically been a misconception that mandatory provider registration necessarily comes at the expense of participant choice and control. In practice, these objectives can and should coexist. Registration does not prevent participants from choosing who supports them, including workers they already know and trust, nor does it prevent registered providers from offering participants meaningful choice over their support arrangements. Participants can bring their preferred workers into a registered model. Hireup’s experience shows that this balance is achievable. Registration reform should preserve flexibility for participants while ensuring that appropriate safeguards are consistently in place.
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For too long, the NDIS has permitted providers to ‘opt-in’ to regulatory oversight, in a highly unusual state for publicly funded care systems. Accountability should not be opt-in. Providers delivering comparable supports can currently operate under very different obligations, with some subject to registration, audit, safeguarding, complaints, incident management and worker screening requirements, while others deliver similar supports with far less visibility and accountability.
Hireup has always been registered and supported stronger provider registration, because participant safety, service quality and Scheme integrity depend on more than individual choice in the market. Participants should not be expected to identify provider risk in circumstances where the Scheme itself does not have a clear view of all providers delivering supports. While the current registration system is not perfect, we know that ultimately it makes us a better provider.
The revised provider definition should draw a careful boundary around the market. Ordinary mainstream suppliers should not be regulated as NDIS providers simply because a participant uses NDIS funding to purchase goods or services, but entities that deliver supports, organise or facilitate support arrangements, connect participants with workers, or derive revenue from NDIS-funded supports should be visible to the Scheme and subject to obligations that reflect their role and risk.
Hireup understands that the Government intends to begin expanded mandatory registration with higher-risk supports, and we support that sequencing. The Rules and implementation settings should ensure those categories are defined clearly and applied consistently, including for sole traders and small providers, so that comparable risks do not sit outside visibility simply because the support is delivered by an individual rather than an organisation.
A sustainable NDIS requires a framework where the market is visible, comparable risks attract comparable safeguards, and accountability follows the support regardless of the business model used to deliver it. Schedule 2, Part 6: Registered plan management providers and conflict-of-interest reform
Hireup supports Schedule 2, Part 6 of the Bill, which establishes a new framework for registered plan management providers and creates a clearer separation between plan management and the delivery of other NDIS supports.
Plan management performs a crucial integrity function within the Scheme. It sits at the point where participant funding, provider payment and public accountability intersect. It helps determine how funding is administered and meets pricing rules, how claims are processed, and how payments move through the NDIS.
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For that reason, independence is essential. Where plan management and service delivery are connected through associated entities, the conflict is built into the structure. In a public scheme of this size, it is not enough assurance to write a short declaration on a website and consider the risk mitigated. Even where individual decisions appear reasonable, the arrangement itself undermines confidence that decisions are being made independently and in the participant’s interests alone.
Plan management should support participants to use their funding with clarity, confidence and independence. It should not become a pathway for self-referral, bundling, preferential treatment or the steering of participants toward related services. The role that helps administer funding should be clearly separated from the role that seeks to receive that funding for services rendered.
Plan managers also act as an integrity layer in the approval of invoices and the interpretation of rules governing those claims. Not only does any conflict of interest act as a potential incentive to bend those rules, but without stronger governance the real-world reality is the rules are often applied inconsistently across different plan managers. This creates financial risk for providers, potential service gaps for participants, and administrative inefficiency to resolve disputes. We welcome the proposal for a tighter, independent, well-governed and more consistent plan management contingent. Implementation and sequencing
The Bill provides an important legislative foundation for reform, but legislation alone will not determine whether these changes strengthen the NDIS in practice. The decisive question will be how the reforms are sequenced, consulted and implemented across a Scheme that participants, workers and providers rely on every day.
Pricing, registration, plan management, participant funding and assessment reforms are deeply connected. If implemented out of sequence, reforms intended to strengthen integrity may instead shift pressure onto participants, workers and responsible providers. A tighter funding environment before provider regulation and pricing settings are corrected may create stronger incentives towards lower-cost supports with fewer safeguards, while expanded registration without pricing that reflects the cost of compliance may weaken the very providers investing in safe, accountable and high-quality service delivery.
The rules, guidance, systems and transition arrangements must be developed with people with disability, families, carers, providers, workers and the broader sector, and communicated with sufficient time for participants and providers to understand what is changing and prepare accordingly.
The legislation provides the mechanisms for necessary reforms to the regulation and stewardship of the market, but timing and sequencing will determine whether those reforms succeed in creating the stronger, more accountable and higher quality market of services that NDIS participants deserve.
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Yours sincerely,
Peter Willis
Chief Executive Officer
Hireupti
About Hireup
Hireup is Australia’s largest NDIS-registered platform provider, supporting people with disability and older Australians to manage their own support workers who fit their needs and share their interests, enabling the principles of choice and control that underpin the NDIS.
As a registered provider, we operate within the full framework of NDIS registration, including safeguarding, worker screening, onboarding, incident management, complaints, compliance and quality assurance. Unlike most platform-based models in the care and support sector, we directly employ our support workers instead of contracting out those obligations to sole traders, with workers receiving full employee entitlements including award wages, superannuation, workers compensation insurance and return-to-work support.
Since starting in 2015, Hireup has worked across the changing NDIS market and seen firsthand how provider settings affect participants, workers and the quality of support. In the past year, Hireup supported more than 11,000 people with disability and employed more than 14,000 support workers. This experience, across both disability and aged care, gives us a practical basis for understanding the issues before the Committee, including provider accountability, workforce protections, regulatory visibility and whether current pricing settings reflect the cost of safe and compliant service delivery.
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