NDIA Accountability Project

Provider design: avoiding a two-tier market that erodes investment and choice

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BCA Business Council of Australia

29 May 2026

Committee Secretary Senate Standing Committees on Community Affairs PO Box 6100 Parliament House Canberra ACT 2600 Community.affairs.sen@aph.gov.au

Dear Committee Secretary

The Business Council of Australia (BCA) writes on behalf of our members in response to the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026, introduced on 14 May. A quarter of our members are directly invested in the health, disability and aged care sectors - operators, insurers, technology providers, professional services firms and research institutions that employ a substantial share of the national care workforce and underwrite significant private investment into the system the Bill seeks to reform.

The BCA supports the Government’s reform agenda and the shift to stronger governance, integrity and management of the NDIS. We also support the Government’s objective of placing the NDIS ona fiscally sustainable footing and share the policy intent behind the Bill’s integrity, fraud and quality provisions. The suggestions that follow are offered constructively, in the spirit of helping implementation succeed.

The NDIS cannot deliver for Australians if growth continues unchecked or fraudulent quality providers operate in the market. However, the speed and breadth of the reforms, particularly those reshaping the provider market and workforce, risk unintended consequences across the broader health and care economy if not carefully sequenced, including provisions that may inadvertently limit private sector participation.

This letter outlines three areas where further engagement with industry is needed before key provisions commence.

1. Provider market design: avoid a two-tier market that erodes investment and choice

Schedule 2 of the Bill introduces a strengthened regulatory framework for providers - expansion of mandatory registration and the move to differentiated pricing for unregistered providers will reshape the provider market. Some of our members operate across the NDIS, private health, primary care and aged care interface. These organisations are the providers most able to manage tighter integrity, audit and digital-payment obligations. They have already invested to support this.

Structural Separation Reforms

Risk Assessment

The risk, however, is that structural separation reforms could consolidate plan management into a single model, limiting investment, innovation, and critical functions like fraud detection and informed choice, which are counter to achieving a sustainable scheme.

In addition, the new settings could also inadvertently displace specialised allied health, capacity-building and home-living providers who are commercially viable today but may struggle to meet the requirements and complexity of registration.

We recommend that the Government:

  • Engage with the segment of the market to ensure care settings align with the policy intent;
  • Position mandatory registration as a quality lever, with the objective of increasing the number of high-quality providers - not reducing overall provider supply.

Workforce: sequencing the reforms to support the care workforce

The care workforce is a growing segment of Australian employment and is forecast to require an additional 110,000 workers by 2035 across disability, aged care and health.

The combined effect of moving 160,000 participants off the NDIS, managing plan inflation, ending plan rollovers and introducing support determinations is expected to affect the disability sector at the time that major reforms - including the Support at Home program, Thriving Kids, and the Strengthened Aged Care Quality Standards - are being implemented, placing additional pressure on a shared workforce.

Workforce planning for the next two financial years is now exposed to policy risk. Providers operating across the care sector may need to shift staff between systems with diverging pricing, scope, and registration settings on different timelines. At the same time, universities and research members face pipeline issues - as training places for key roles - such as allied health, nursing, behaviour support and assistive technology specialists - are committed years ahead of demand.

We recommend the Government release a workforce impact assessment alongside the Bill. Without this, there is a risk the reforms could shift costs to other parts of the system rather than deliver structural savings to the scheme and the Commonwealth budget.

Spillover into the broader health and care sector

The Bill does not sit in isolation. The transfer of pricing decisions to the Minister (Schedule 3, part 1), the new powers around automated decision making, and the changes to claiming timeframes will have flow-on effects to private health insurers, hospital operators, pharmaceutical suppliers, medical technology firms and digital health providers within our membership. These organisations provide the essential foundation for the reformed NDIS, with effective sequencing being central to unlocking a successful and sustainable reform.

Governance arrangements should reflect this interdependence across the care sector. We recommend that the Government:

  • Establish a time-limited Industry Implementation Advisory Group, to inform the design of these governance arrangements;
  • Require public consultation and a published regulator impact statement for new ministerial pricing powers and automated decision-making tools before they take effect.

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Next Steps

The BCA and our members would welcome the opportunity to meet with you and the Department of Health, Disability and Ageing to discuss these issues. We support a fiscally sustainable NDIS - one that supports participants, attracts ongoing private investment, and underpins a productive, well-supplied care economy.

This Bill represents an important step forward, and realising its full potential will depend on continued collaboration between government, industry and the disability community.

The BCA strongly supports the Government’s objectives to improve the NDIS’ fiscal sustainability and governance, and our recommendations are intended to help deliver on these goals.

Yours sincerely

Bran Black Chief Executive Business Council of Australia

BCA

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