Submission 4256 — Across the Coast Abilities — NDIS Future Generations Bill

To: Mrs Melissa McIntosh MP

Member for Lindsay

Shadow Minister for the National Disability Insurance Scheme

Shadow Minister for Families and Social Services

From: Lennon Andrew Paturzo (Andrew)

Managing Director, Across the Coast Abilities Pty Ltd - Registered NDIS Provider

Specialist Support Coordinator

Positive Behaviour Support Practitioner

1. Who I Am and My Professional Background My name is Lennon Andrew Paturzo. I am a 39-year-old man from Adelaide, South Australia, I now live on the Gold Coast in Queensland and have raised my family here for the past 12 years now.

I have worked in disability support and related community services since 2009. My experience has developed through frontline disability support, youth work, mental health, psychosocial disability, complex support coordination, NDIS National Contact Centre work, NDIS service support, NDIS planning, PACE, provider operations and now as I’m operating a registered provider, Specialist Support Coordination and Positive Behaviour Support.

My early work included the Young Minds Matter project and the Ten to Men project, focusing on mental health and men’s health through Roy Morgan Research through the Department of Ageing-related contracts. This gave me early experience in mental health related projects, men’s health, government-funded research and how national programs connect with real people and families.

I completed my first Certificate IV in Youth Work 2010 and later completed a Certificate IV in Mental Health around 2014. I also later in my career worked toward completing a Bachelor of Social Work. I eventually deferred from my social work studies due to the requirement to complete more than 600 hours of unpaid placement, became impossible while I was working for DHS / Services Australia - Disability Services SA, raising young children and paying a mortgage. I could not realistically work unpaid for that period while maintaining my family and financial responsibilities and it was becoming clear the Social Work Degree has also become redundant and an uneconomical pathway into disability or community services.

In my early years in Disability Support I worked with many companies one being Anglicare SA in the Exceptional Needs Program. This work was based around a psychosocial model of support. Many of the people supported through that program had mental health diagnoses as well as physical or intellectual disabilities. The service operated under what was a “no retreat” model, where the support provided was often one of the final attempts to rehabilitate a person safely back into the community or for a person to be until their final days. This role gave me direct experience with complex support needs, mental health, disability, risk and community reintegration.

I moved to Queensland in 2015 and worked for again many companies one being FSG. During my time there, I contested many practices and I saw the company decline and ultimately fail. I also made formal complaints to the NDIS quality safeguards commission regarding the treatment of participants I supported as it declined.

I then worked for many years with House with No Steps, which later merged with The Tipping Foundation and is now known as Aruma Disability Services. During this time, I completed a Diploma of Community Services through the organisation’s internal RTO scholarship program. I also spent three years as a board member on the Human Rights Committee. My focus in the committee role was policy improvement and human-rights focused matters connected to the people we supported including the continuous review of restrictive practices used within the SIL support services.

I returned to Adelaide for a short period after this and commenced worked for the Department of Human Services as an NDIS Support Coordinator. In that role, I carried a caseload of 34 NDIS & Disability Support for Older Australians. These participants were all streamed as complex or super-intensive with multiple risks and behaviours of concern present. This role gave me direct experience coordinating supports for people with high needs, navigating complex government systems, multiple providers collaboration, family pressures, safeguarding risks and significant functional support requirements. On my case load I also coordinated participants who were on end-of-life arrangements.

As Disability Services SA transitioned from their “In Kind” funding model to becoming a NDIS registered provider, I was seconded to the Gold Coast for a role in the NDIS National Contact Centre office at Robina. I was part of the very first group of staff to work in the newly created Robina Gold Coast call centre. I trained with early leadership including Team Leader Kerri Wells and the first executive director for the Gold Coast call centre, Trevor Coleman. At the National Contact Centre, I helped train many new recruits on the phones. I provided daily support to staff and helped team leaders understand disability support areas where I had extensive practical knowledge. I also helped train members of my team who later moved into other successful roles.

I was there when the Robina office grew from approximately 30 staff to around 90, then 150, and then to the point where the office became so full that original staff could no longer work there full time and were moved into full time work-from-home arrangements with one or two office days per week.

After working in the NCC, I was seconded again as a Service Support Officer. This was before the highly anticipated PACE rollout. In that role, I worked with NDIS systems and helped with internal PACE-related knowledge processes, including knowledge material connected to PACE. Because of this experience, and because I have worked across the NCC, service support, planning and provider-facing roles, I was considered a PACE super user.

I left the agency for a break after this role as I had just had another child. However, after a few months I successfully obtained another contract to work for the NDIA and

commenced work within the Assurance Planning Team. In that role, I was trained exclusively on the new NDIA Scheme Sustainability measures and trained how to meet the s34.1 a - f criteria and align it with NDIS funding for participants. Our taskforce focussed on NDIS plans with identified over or under utilisation of funds and it was communicated during these plans were built during covid times by untrained LAC’s and it was evident multiple non R&N decisions was applied to plans for participants incorrectly (For example able bodies and functional participants who could drive with vehicles noted were on level 2 transport etc). I worked on ministerial-level complaint plan reassessments and after a while I was able to complete around five plans per week on average. In comparison, some of my colleagues who came from non-disability sector backgrounds were completing closer to one to two plans per week showing a huge gap in the disability sector understandings. Within three to six months, I had outperformed my team leader in planning service delivery. I received around seven internal compliments for work completed and was one of the higher-performing planners within the Assurance Planning and within the National Core Planning Team.

On the 13th of June 2025 while in my planning role, I was advised of being successful by the NDIS Quality Safeguards Commission with my application to become a registered NDIS provider. I advised the senior leadership team and the executive directors above me and was placed on administrative leave pending a formal written notice of choice to continue working within the NDIS or to go and work as a registered NDIS provider. I chose to follow the provider pathway officially after that date and officially left the agency.

I now work as a registered NDIS provider, where we provide a multitude of supports including Core Support Services (Transport, personal care community access etc), Capacity Building Supports, Home Modifications, Support Coordination & recently I personally obtained my Positive Behaviour Support Practitioner ID and am working towards obtaining the 0110 PBSP NDIS registration for my company Across the Coast Abilities.

My work experience in frontline disability support, psychosocial disability settings, support coordination, NDIS planning, PACE service systems, NDIS provider operations and participant advocacy allow for great insight into some of the more systemic issues currently plaguing the NDIS.

I am not writing to you from theory. I am writing from direct experience across the disability sector, government service systems, the NDIS internal environment and current provider practice views.

I have seen the NDIS from the participant-facing side, the provider side and the internal NDIA side. I have worked with people with complex and super-intensive support needs including Aboriginal and Torres Strait Islanders & Culturally and Linguistically Diverse participants and families and I have supported participants and families through some of the most difficult parts of the system and times of their lives.

I believe some of the information within this report is relevant to support why a reform is necessary, but it must be practical, targeted and informed by people who understand how the scheme actually works. Reform must not be based only on political targets, broad budget

concerns or assumptions about participants and providers. It must include the knowledge of people who have worked inside the scheme and on the ground with participants directly.

2. Why This Report Is Not Just One Provider’s Opinion This report is not written as a complaint from one provider. It is written from the position of someone who has worked across multiple sides of the NDIS: frontline disability support, psychosocial disability support, support coordination, the NDIS National Contact Centre & NDIS planning.

The issues raised in this report are not isolated. They are patterns that appear repeatedly across participant matters & provider operations leading to extensive unpaid support coordination work, high amounts of plan reassessments, extensive complaints, unlimited payment issues, PACE-related communications and the current blowout of ministerial-level escalations that you see day to day. This is also not the first time I have had to personally reach out to your office.

At present Support coordinators are being told their role will reduce over time. But the practical detail is often missing. People are left trying to understand new rules, new systems, funding periods, PACE processes, plan reassessment pathways, consent rules, provider access and payment processes while the NDIA’s own service systems are still failing at basic tasks.

The NDIS National Contact Centre is a major example.

The NCC may answer calls quickly, but fast call answering is not the same as competent service. A call answered quickly but handled poorly still creates cost. If the caller has to ring back three, four or five times, escalate to a team leader, resend evidence, lodge a complaint, contact a ministerial office, or pay a support coordinator to keep chasing the matter for outcomes, then the system has not saved money. It has shifted the cost into participant plans and unpaid provider time & provider stress.

Public reporting has stated that the NDIS has been publicly committed to answering 80% of calls within 60 seconds, and an NDIA spokesperson reportedly stated the National Contact Centre had achieved 92% customer satisfaction and 86% first-point-of-contact resolution. However, the same reporting described serious concerns from call centre workers and NDIA related sources about inadequate training, pressure to meet call-volume targets, and calls being answered quickly without proper resolution. When I worked in the agency, I was measured not by the amount of factual information I provided by mostly by the tone of my voice and willingness to review related resources to find an answer as part of the first call resolution. When I call personally to the NCC this is now not evident at all and I find frustrated at the blowout of the cost involved. We are wasting the time from both sides. A wasted untrained call centre operator and a provider who is charging per hour to complete support coordination tasks both funded by the NDIA budget.

When I call 1800 800 110 the National Contact Centre, I am asked to press 6 if I am a NDIS provider. When I press this the call is answered but still only by a generic and untrained call centre operator. So, if I push 5 for Home and Living I don’t get it. This was implemented

while I worked at the NDIS in the contact centre and feedback was already coming in that it not working. Staff such as myself were advised we would all have some “Specialisation” training in certain areas to take these calls. This has appeared to have failed to roll out in anyway.

A low wait time does not mean the issue is resolved. A quick answer does not mean the person on the phone understands their role as a delegate of the CEO, disability in general, PACE systems, consent, plan implementation, provider access, home and living, home modifications, assistive technology, complex supports let alone the unique and complex queries.

In my recent 12 months of experience, the quality of NCC calls has become extremely poor compared with other government services. With Services Australia, a person may wait a long time to speak to someone, but the call is more likely to end with a factual answer, a clear direction or an actual resolution. With the NDIS NCC, the call may be answered quickly, but too often the person answering is unable to meaningfully assist.

For complex disability matters, I would estimate that only a small minority of calls result in a competent response or practical resolution. When NCC staff cannot locate consent, cannot understand PACE, cannot find the correct notes, cannot understand a provider’s question, cannot action a basic request, or simply act as message-takers, the cost does not disappear. It is transferred to support coordination funding, provider administration time, complaints pathways and provider stress.

The NCC has also grown from what I saw in the early Robina office into a large call centre operation, including outsourced call centre arrangements with SERCO continuing. Public reporting has described Serco’s NDIA contract as beginning in September 2024 for a three year term, worth more than $248 million, with Serco stating at the time it had a 1,200-strong contact centre team additional to NDIA employed NCC call centre staff and the average salary being:

APS4 NCC / Planner / Service Support style roles: roughly $75,000 – $85,000 plus super.

APS5 NCC / Team Leader / higher operational roles: roughly $85,000 – $96,000 plus super.

That scale matters. If the contact centre workforce is large, expensive and central to participant and provider access but not actually providing the quality responses we as providers need, then its quality must be measured by more than speed-to-answer statistics. It must be measured by whether calls are resolved correctly with factual information provided & whether participants & providers have received accurate and factual advice.

From a provider and support coordinator perspective, the NCC often feels like a “seat-filling” model rather than a specialist disability service. People answer the phone, but many do not appear to have the disability knowledge, PACE knowledge, delegation confidence or

practical training in systems usage required to resolve the matter. That creates avoidable work for everyone else and the NDIA pay for it.

This is why the NDIS cost blowout cannot be understood only by looking at participant plan values. The scheme also needs to examine the cost of its own operating model. Although it is noted there is also room for improvement on the planning side also.

With support coordinators now expected to build the participant capacity without having access to capacity building funding, and with too much of their time being spent compensating for NDIA system failures.

This is not sustainable. As a result, Across the Coast Abilities has already commenced winding down all NDIS support coordination supports and referring all participants onto other companies. Many of which don’t respond and or are also not taking on any further participants.

This report is written to provide feedback from the provider and participant-facing side of the scheme. It identifies areas where money is being wasted, where fraud risk is increased, where NDIA service quality is creating cost, and where reform could occur without harming participants who genuinely require support.

3. Transport Funding Need Immediate Reform Transport funding must be reviewed as its own reform area.

It should not be hidden inside broader Core funding discussions, and it should not be lumped together with consumables as if they carry the same risk, urgency or purpose.

Consumables can include disability-related items such as continence products, wound care items, nutrition-related items, low-cost assistive technology and other supports connected to health, hygiene, dignity and safety. Some participants cannot safely live without these supports. Transport funding is different.

Transport is important, and some participants absolutely need it. Some people cannot drive, cannot use public transport, cannot travel independently, or need funded transport to access work, study, appointments, day programs, community activities and social participation.

However, recurring transport funding is often paid directly into a participant’s nominated bank account. In practice, this makes it impossible to know whether the money is being used for disability-related transport at all and this is the first area needing tightening and or removing NDIS is giving out cash. The NDIS public guidance confirms that recurring transport is the only recurring support category, Level 1 is $1,784 per year, Level 2 is $2,676 per year and Level 3 is $3,456 per year, and that eligible recurring transport supports are paid regularly to a participant’s nominated bank account without needing to be claimed through the participant portal or my NDIS app.

Important to note the current distinction: $888m = actual payments over 12 months, while $547m = annualised committed supports in current plans. Were already way over budget and its nearly a billion alone. If we change this to only pay the funds if you provide a taxi receipt, you will see many people not be using anymore as they don’t use taxis and don’t need it. Its not gone wont hurt the ones who need it and use it. But gets rid of the unwanted expenditure.

When I worked in the NDIS National Contact Centre, I regularly received calls from participants asking where their transport money was and why it had not gone into their bank account and that they had run out of cigarettes and really needed the money. Participants clearly made comments that suggested the payment was being relied upon for ordinary living expenses, including things like cigarettes, rather than transport.

I have also seen situations where parents or nominees controlled the transport funding of young adult participants as its paid in the plan nominee’s or participants-controlled bank account, while actual transport for the participant had in reality reduced, stopped completely or was passed onto the support workers via the $1 per km charge billed through the participants support funding. In those situations, the transport funding did not appear to be improving the participant’s access to transport in any way and only caused budget blowout and created areas for abuse and exploitation of funding.

This does not mean all transport funding should be removed. It means the current model needs proper review.

A fair transport reform campaign should focus on the section 34 reasonable and necessary criteria and ask practical functional questions and not just state were going to cut NDIS funding. We need to state clearly what the eligibility is and what is not.

 Does the participant hold a driver licence?

 Does the participant own a car, or have regular access to a car?

 Has the participant demonstrated the functional capacity to obtain and maintain a driver’s licence? – Can we support them in another area to build capacity.

 Can the participant safely use public transport? Or can they develop the capacity to through intensive supports?

 Is public transport available and accessible in the participant’s area is another key consideration.

 Is cost actually the barrier, or is disability-related functional capacity the barrier?

 Is the participant already receiving community access support through Core funding, is provider travel already being claimed?

 Is the participant using taxis, rideshare or other paid transport & are invoices or records available to prove actual transport use? – This is the mostly likely scenario where the funding is actually benefiting any participants.

 Is the recurring transport payment improving the participant’s life, what is it being used for? What goals have been achieved and are the goals disability related?

 Is the money being used for disability-related transport, or is it being absorbed into ordinary household income? – This is where the scheme loss is huge more than is actually used. I predict it will be maybe after it settles 250 million costing and NDIA will have the invoices to show and predict growth.

The focus should not be the participant’s financial position. The focus should be whether there is an actual disability-related transport need that the NDIS should fund.

If a participant has a drivers licence, owns or accesses a car, can safely catch public transport, or already has transport needs met through other supports, then recurring transport funding may not be reasonable and necessary in the same way it is for someone who cannot travel independently.

For some participants, losing recurring transport funding would not be detrimental to day-to day support because their transport is already covered through other means. They may need to pay some ordinary transport costs themselves, while the NDIS continues to fund disability related provider travel, taxis or other transport where it is actually required and invoices are provided as proof of actual travel with no exceptions.

NDIS should move away from poorly evidenced recurring transport cash payments and toward actual usage-based transport support, including invoices, taxi use, provider travel where appropriate, and clear evidence of disability-related needs. This could create significant savings without cutting essential disability supports.

The current public reporting also needs to improve. Transport should be reported separately from consumables. If public reports combine consumables and transport, they hide the true transport-only cost and prevent honest reform discussion its already nearly a billion dollars itself.

Transport reform should therefore include:

1. A transport-only cost breakdown – with a new billing system with only transport services allowed to have access to and with tight invoicing protocol.

2. A national review of recurring transport payments to all NDIS participants and the new rules explained clearly.

3. Functional transport questions at reassessment and included as mandatory in the functional capacity assessments as it’s easy to omit from using certain wording that allows the data to reflect the need for transport where it is not.

4. Ongoing recurring transport changed to an agency managed style of service transport providers (It could also for only registered transport & Taxi providers) where payment is claimed through the payment system, invoice-based or usage-based funding where appropriate.

5. Protection for participants who genuinely cannot travel without funded support. When it hits the media its clearly articulated. Do you have a licence and or vehicle? you may no longer be eligible etc.

6. Removal or reduction of transport funding where there is no disability-related transport need for example when I worked in planning, we saw many plans for participants with psychosocial diagnosis and no physical impairment and they had level 1-2 and some even level 3 transport.

This highlights the change needed is real and this is one of the clearest areas where the NDIS can save money without cutting supports that are essential to health, safety or daily living and or having negative media attention with participants who don’t agree.

4. Plan Management, Payment Integrity and Fraud Reform Plan management is another major area requiring reform. Participants are often told that plan management is about choice and control. In practice, plan management is often just a service where someone processes invoices. It is not at all in anyway therapeutic. It is not a personal service. For many participants, it is simply a third-party invoice payment function.

The question needs to be asked clearly: why is the NDIS paying external businesses to process invoices when the NDIA already has an agency-managed payment system?

Participants often change plan managers because one invoice is paid late, because the plan manager is slow where invoice errors are present, because communication is poor, or because another provider promises faster processing. This gets framed as choice and control, but it also exposes the problem.

If the service is invoice processing, there should not be any major differences between plan managers. There should not be inconsistent payment timeframes, inconsistent practices, inconsistent checks or inconsistent provider experiences. This is not the case, and the plan managers are advertising they are quicker than others etc. The simple fact that participants move left and right between plan managers shows that plan managers do not all operate the same way. It shows that there are gaps and inconsistencies in the system and this is annually a half a billion-dollar area to reform. We can make a system for less with a team of staff who monitor it and continue with endorsement process to safeguard who can bill and have this fixed.

Choice and control should mean choice over meaningful supports, providers and life outcomes. It should not mean endless variation in who pays an invoice.

The main reform option would be to bring payment processing back under stronger NDIA control through a streamlined internal system. In simple terms, the NDIS should seriously consider putting everyone through an agency-managed or centralised payment gateway model, while preserving participant choice over providers and supports not who pays the invoices. This closes the gap on experiences.

This would also allow the NDIS to:

 reduce external administrative cost;

 standardise payment timeframes;

 reduce fraud risk;

 create consistent claim rules;

 require providers to be endorsed, registered, approved or verified before accessing payment systems;

 improve audit capacity;

 allow a budget to build a specialised payment resolution team;

 stop participants from being bounced between plan managers unnecessarily;

 protect participants from poor plan management practices;

 redirect savings into essential participant supports and decrease the national NDIA budget.

This reform would not remove participant choice over supports. Participants would still choose their providers and supports. What would change is the unnecessary duplication of invoice-processing businesses sitting between the participant, the provider and the NDIA.

The money saved from reducing plan management could be redirected into a specialised NDIA payment team staffed by trained public servants, similar to payment teams in other government systems such as Centrelink. This team could resolve payment issues, assist providers, manage claims integrity and prevent the endless delays and inconsistencies currently seen across plan managers.

Plan management reform should also connect directly to provider integrity reform with mandatory registration for anyone working in the NDIS sector. Fraud reform cannot be limited to blaming providers for errors (They were legally allowed to operate unregistered and untrained) or cutting participant plans to reduce the budget. The cutting plans is a scary sentence for NDIS participants often with limited capacity to fully understand how it will work. There are bad providers, and they should be removed from the scheme. There are also fraudulent claims, false invoices, inflated supports, supports not delivered, identity misuse, cash incentives and poor practices that need strong action. The NDIS must also look at the system design flaws that allowed this to occur.

Public reporting has identified serious NDIS fraud concerns, including alleged organised crime involvement, cash kickbacks, false or exaggerated documentation, claims for services not delivered and weaknesses in provider suitability and screening. The current system has too many weak points.

A provider may claim through one pathway, a plan manager may apply a different standard through another pathway, a self-managed participant may face different checks again, and

agency-managed processes may operate differently again. This creates inconsistency. It also creates space for poor practice and areas of exploitation.

If claims are processed through a stronger centralised system, the NDIS can build better fraud prevention into the payment process through a more holistic reviewing process being established.

For example, when a provider submits a payment claim for personal domestic supports, the system could require a declaration that clearly defines what personal domestic supports include and that they confirm they have done this category of supports?

Something simple like the provider could be required to declare that the support was actually delivered, that it matched the participant’s plan, that it was connected to disability-related need, and that records are available if audited.

The system could clearly state that if the NDIA audits the claim and finds that the provider did not deliver the claimed support, the payment can be recovered.

This could be done through creating a Provider Integrity and Claims Responsibility Policy attached to the new payment system.

This would be clearer and fairer than the current system, where different plan managers may have different checks, different standards and different levels of oversight.

Some plan managers are also in on the dodgy practices so this would help to close an area of major exploitation.

The NDIS should create claim categories that require providers to acknowledge what they are claiming for before payment is released.

Examples could include:

 Personal domestic supports.

 Community access.

 Support coordination.

 Psychosocial recovery coaching.

 Provider travel.

 Capacity building supports.

 Behaviour support.

 Therapy supports.

 Consumables.

 Transport.

Each claim type should include a clear declaration and audit warning of the funding can be clawed back if this was found to be fraudulently claimed.

This would reduce fraud and poor practice without punishing ethical providers and or genuine claims.

5. Support Coordination, NCC and PACE Failure Support coordination is being slowly reduced year after year, with the expectation that participants and families will build capacity and need less support over time. In some cases, capacity building can happen. But for many participants, this expectation does not match reality, and the consensus is that this role has become so unsustainable I myself have been extensively affected by these funding limitations. I wanted to explain below one small example below.

When I previously reached out to your office advising of a participant, I supported needing an urgent plan reassessment and having depleted all consumables & support coordination funding. Roza Sage was able to help me escalate this and get the outcome the participant needed.

However, during this time I noted that there is ZERO support coordination funding available and that the plan manager has rejected capacity building invoices in place. During this time I had to remain as the direct contact regarding the plan reassessment, I had to continue to provide the support coordination to the family and I had to support coordinate all allied health supports with zero funding in place and there were some clinical support needs as the participant was accessing home enteral feeding and was nil by mouth, mum needs a lot of help to manage the budgets access supports and would often contact me daily or on alternate days.

During the reassessment process I told NDIA we don’t have any support coordination funding and or consumable funding and I am at present working without any coordination funding. No acknowledgment of the lack of coordination funding was provided despite this being highlighted maybe 4-5 times there is just nothing they can do and its bad luck to me as a provider who maintains the responsibility of continuity of supports. The consumable budget had some funding that was able to be released and resolve the consumable funding issues until a plan reassessment could be completed but I had to continue working for nothing.

I had to facilitate all supports and consumable orders until NDIS made a new plan and this included multiple requests for information from plan nominee – mum, NDIA staff, phone calls from schedulers and planners to complete the planning meeting and then to complete a planning implementation meeting along with liaising with the LAC & work with the allied health supports to manage continuity of care and setup all the new service agreements for the new plan.

By the end of it I had nearly completed more unpaid work than the participants whole annual NDIS plan could afford from support coordination being 20 hours per year. In the end we

advised we would be stepping away from NDIS support coordination and would be moving towards other more sustainable support areas.

Many participants and families are not using support coordination because they are lazy or unwilling to learn. They are using support coordination because the NDIS system is too complex, inconsistent to understand as my understanding can vary from yours and more difficult to navigate than it should be for regular people.

Support coordination is often required because:

 the NCC does not resolve issues;

 planners are unable to be or too hard to contact;

 consent is not found or applied correctly, even coordinators have trouble with this;

 funding is extensively unclear;

 service bookings or claims fail and invoices for services go unpaid;

 plan reassessments are delayed so long it can lead to breakdown of supports;

 home and living matters are too hard to understand;

 assistive technology wording causes purchases to be rejected;

 participants receive inconsistent information from many sources;

 families cannot manage complex systems alone;

 providers need coordination across multiple services;

 high-risk participants need safeguarding oversight;

 hospital, housing, justice and mental health systems intersect with NDIS.

Reducing support coordination without fixing the NDIA systems that create the need for support coordination is not reform. It is cost shifting and will hurt the reform more than support it. It shifts the burden onto participants, families and providers.

Families are already exhausted. Participants with complex disability may never be able to self-navigate the system without support. Some people have no informal supports. Some have families who are part of the risk environment. Some have psychosocial disability and are fully functionally able, cognitive impairment, trauma, behavioural escalation or communication barriers.

For complex and super-intensive participants, support coordination is not just “help to understand the plan.” It is a safeguarding function. It is a systems navigation function. It is crisis prevention. It is provider coordination. It is risk management. It is often the difference between a participant remaining stable in community or falling into crisis.

One of the biggest hidden costs in the NDIS is the amount of support coordination funding wasted because the NCC and NDIA systems do not work properly. As a support coordinator,

I often have to bill a participant’s plan while attempting to resolve problems that should be simple NDIA administrative tasks.

It can take three to five calls on average to get someone who can provide meaningful assistance. Often, the first operators simply take notes and take 15 minutes looking for consent unsuccessfully then terminate the call. SERCO staff in particular often appear to act like messengers. They can take a message, but they often cannot complete a meaningful task or access PACE or navigate profiles even with consent acknowledged.

This wastes participant funding. If a support coordinator spends one to two hours per week dealing with wasted NCC calls at approximately $100 per hour, that cost comes directly from participant plans. Across the entire NDIS, this is likely a major hidden cost not acknowledged as a critical area of support.

This is not just frustrating. It is a structural waste problem.

The NCC often cannot:

 locate consent properly;

 understand PACE records;

 locate the right case note;

 understand planner or consultant notes;

 apply their level of delegation correctly;

 answer basic NDIS questions;

 understand home and living issues;

 understand home modifications;

 understand plan reassessment pathways;

 understand assistive technology wording issues;

 understand why a provider is calling;

 resolve matters at first contact.

When the NCC introduced menu options where callers could press a number for areas such as home and living, home modifications or other specialist matters, this should have meant that callers were triaged to properly trained specialist staff.

In practice, from my direct and ongoing experience, this does not appear to occur. The caller may press an option for a specialist area but still reach a generic operator without the specialist knowledge or delegation confidence to resolve the issue.

This is a major failure.

I understand the need to employ people with disability and to maintain an inclusive workforce. I support that. But inclusion cannot replace competence, training, supervision and service quality.

NCC staff need proper training in disability, PACE, consent, delegation, planning, escalation, and the practical consequences of giving poor advice.

When the NCC does not work, support coordinators become the system’s trainers while participants pay the bill through their plans.

I have significantly reduced how often I call the NCC because the service is so ineffective. I am tired of arguing with operators and team leaders and then having to escalate matters to complaints or ministerial pathways just to get basic action.

PACE is now central to the NDIS, but many NCC staff do not appear to understand how to use it properly. I have worked in the NCC, worked as a Service Support Officer, worked in planning and supported PACE-related knowledge processes. I understand where information should be located and how staff should search for it.

When I call and explain where information should be found, I still encounter staff who cannot follow the request or do not understand the relevance of what I am asking.

This creates an extensively unnecessary delay.

Consent is a major example. NCC staff often say they cannot find consent, or they treat consent as missing when it has been provided or should be visible. This blocks providers and support coordinators from resolving issues and forces repeated calls.

PACE and consent failures create unnecessary costs in support coordination. They also create risk because urgent issues may not be resolved.

The NDIA should audit how often calls fail because of:

 consent not being located;

 staff not understanding PACE;

 staff not understanding delegation;

 staff not understanding which team should action a request;

 staff providing incorrect advice;

 callers needing to call back multiple times. Often with different results.

This should be treated as a financial sustainability issue, not just a customer service issue. If the government is serious about reducing support coordination funding, it must first fix the NCC. Otherwise, support coordination reductions will simply punish participants for NDIA operational failure by way of less funding for actual support coordination needs.

6. Planning Quality, Workforce Capability and Internal NDIA Cost A major issue that is not being properly discussed is why some NDIS plans were built incorrectly in the first place.

From my experience inside the NDIS, including planning and assurance work, as staff we were told previously starting from 2019 there were periods where the scheme had a severe shortage of planners and time of low onboarding for areas like planning. During these periods, NDIA delegated Local Area Coordinators heavily in planning processes, despite not having any planning training, disability experience or financial decision-making capability at all they made the plans participants are using at present and as they are heavily over funded and now rolled over for many years participants have become accustomed to this level of funding. This contributed to inconsistent and heavily overfunded plans, poorly justified funding decisions, incorrect assumptions and funding decisions that became embedded over long periods of time.

Once funding is in a plan, it becomes difficult to remove politically and practically, even if the original decision was not properly supported. Families and participants understandably build routines around what was funded. Providers build services around what is funded. Then, when the NDIA later tries to correct poor planning, it is experienced as a cut. When more accurate s34.1 R&N rules were applied to and measured against your actual functional ability as everyone is different.

But the real issue is that the plan has been built incorrectly in the first place. Setting a false standard. Why is NDIA not taking responsibility for this and announcing it to the participants affected. At least an explanation and not just budget blowout and reform is needed. This needs to be discussed honestly.

NDIS sustainability problems are not only caused by participants and providers. Internal planning quality, workforce shortages, inconsistent training, delegation confusion and poor assurance also contributed to scheme growth.

Reform should examine:

 Who was previously making planning recommendations vs current practices?

 What training did they have vs current training being implemented?

 What disability experience did they have and has this been verified?

 What evidence was required previously vs what is being used now?

 How many plans were influenced by LAC recommendations without sufficient planner oversight vs how many have been corrected already by the assurance planning team?

 How often did planners approve supports without understanding the participant’s real functional need TAPIB or technical advisory branch can take up 4 weeks to get an answer for really complex support request?

 How much of the current cost pressure comes from poor internal design rather than participant misuse and what that reduction will look like?

There also needs to be a serious discussion about NDIA internal staffing, role duplication and capability.

When I worked in the Assurance Planning Team, I observed multiple layers of executive and senior roles above the frontline planning work. At my recollection, there were six executive director-level roles above me for my specific assurance planning team with multiple teams Australia wide, each paid at 125k starting Executive Director Levels. At the same time, actual planning output varied dramatically depending on staff capability and disability sector experience and I got paid the same as a planner doing one plan per week despite my workload being more than 5-6 times the workload.

I was completing around five - six plans per week on average. Some colleagues from non disability or unrelated backgrounds were completing closer to one plan per week.

This is not just about me being productive. It shows that disability experience matters. System knowledge matters. Practical understanding matters. I had 15 years in disability support knowledge. It helped me immensely.

The NDIA needs to examine whether it is investing in the right capability frameworks.

It should ask:

 How many planners have direct disability sector experience? It’s not just about how good they can do administrative tasks.

 How many NCC staff have disability sector experience? Core Disability Support Experience.

 How many service support staff understand PACE properly?

 How many staff understand psychosocial disability?

 How many understand intellectual disability and complex behaviours?

 How many understand safeguarding risk?

 How many understand dignity vs risk?

 How many understand support coordination?

 How many understand provider operations?

 How many understand the real cost of poor internal decisions?

 How many calls are not resolved at first contact and the barriers?

 How many matters require repeat calls?

 How many complaints are caused by poor internal knowledge?

 How much participant funding is wasted because providers and support coordinators have to compensate for NDIA staff capability gaps?

This also connects to the disability workforce more broadly. The sector now often treats Certificate III in Disability Support as a broad national standard for disability support work.

In my view, this is completely inadequate for the level of complexity many workers are expected to manage and opens the door to the risk we are currently experiencing.

Many disability support workers are now expected to work with participants who have psychosocial disability, trauma histories, intellectual disability, physical disability, complex behaviours, communication barriers, restrictive practice concerns, family conflict, housing instability, justice involvement, mental health risks and high safeguarding needs without any understanding of these complex issues and factors.

This work requires more than a basic entry-level qualification. It requires practical training, supervision, ethical decision-making, human rights knowledge, trauma-informed practice, mental health awareness, behavioural support understanding and clear escalation pathways.

The qualification pathway has not kept pace with the reality of the work. At the same time, higher qualifications such as social work can be difficult to complete because unpaid placements create barriers for workers with families, mortgages and existing work responsibilities and I myself was able to obtain high level clinical roles like positive behaviour support without a bachelor’s degree and instead real-world experience.

This should be part of reform. If the NDIS expects workers and providers to manage complex disability, behaviour, psychosocial risk, safeguarding and human rights matters, then workforce standards and training pathways need to match that reality.

Reform cannot only look outward at providers and participants. It must also look inward at NDIA operations and the broader disability workforce.

7. What I Am Asking the Minister to Consider I am asking for NDIS reform that is practical, targeted and informed by people who actually understand the system. By people with disabilities and advocates but also by providers who are experienced and who have good and insightful input to be involved in reform processes.

When I was asked to leave the agency as a planner, I felt a sharp disconnect from NDIS and it was noted it is a conflict of interest to be involved on both sides of NDIA and work as a provider, however I felt this was a complete contradiction as the knowledge I hold is helping me to be a more diligent and compliant provider on top of many others who are also struggling to navigate all of the legislation and compliance requirements.

The scheme needs to stop wasting money on poorly evidenced recurring transport payments, unnecessary plan management duplication, fragmented payment pathways, poor NCC

performance, repeated calls, weak PACE knowledge, poor consent handling, inconsistent planning and internal capability gaps.

At the same time, the scheme must protect essential supports.

Participants should not lose critical supports because the system refuses to deal with the real sources of waste.

I ask that your office consider advocating for:

1. A national transport-only funding review.

2. Clear separation of transport from essential consumables in public reporting.

3. A reassessment campaign using section 34 reasonable and necessary criteria for recurring transport.

4. Stronger evidence requirements for transport funding, including actual usage where appropriate.

5. Protection of transport supports for participants who genuinely cannot travel independently.

6. Reform of plan management as an external invoice-processing industry.

7. A move toward centralised NDIA-managed payment processing or a single national payment gateway.

8. A specialised NDIA payment resolution team staffed by trained public servants.

9. Provider claim declarations built into the payment system.

10. A Provider Integrity and Claims Responsibility Policy.

11. Stronger audit and clawback powers for unsupported provider claims.

12. A full review of NCC performance and first-call resolution rates.

13. Measurement of how much support coordination funding is wasted dealing with NCC and NDIA failures and how core supports can be used in replacement.

14. Proper specialist training for NCC staff instead of generic call routing.

15. A PACE and consent capability audit for all NCC staff.

16. Protection of some kind for specialist support coordination for complex and super- intensive participants where core supports aren’t used and SC is retained.

17. Recognition that some participants will never be able to self-navigate the NDIS without ongoing coordination and how this can be absorbed by core supports. (Support worker assistance)

18. A review of planning quality and how historical planning decisions contributed to current scheme cost with media advising NDIS has made some mistakes and it’s not the participant’s fault.

19. A capability audit of NDIA planning, service support, NCC and complaints staff to ensure the complaints are not coming in for simple administrative or trivial non disability related issues.

20. Greater involvement of experienced providers, former planners, support coordinators and frontline workers in reform design as we deliver the support NDIA just fund it.

21. A workforce reform discussion that recognises the complexity of modern disability support work and the inadequacy of relying on basic qualifications for complex roles where mental health diagnosis is evident, and behaviour of concern are present.

The NDIS does not need blunt budget cuts. It needs intelligent reform with community discussion. It needs reform that protects participants, removes waste, improves accountability, fixes internal systems, reduces fraud and listens to people who actually understand how the scheme works in real life.

I have worked in this sector since 2009. I have worked with participants directly. I have worked in psychosocial support. I have worked on human-rights-focused matters. I have worked in the NCC. I have worked in service support. I have worked in planning. I have worked on complaints and ministerial-level matters. I have worked with the PACE rollout. I now work as a provider, Specialist Support Coordinator and Positive Behaviour Support Practitioner.

I know where the system fails because I have seen it from the inside and the outside.

The NDIS needs reform, but reform must target the right problems.

Cutting participant plans without fixing transport misuse, plan management duplication, payment integrity, NCC failure, PACE confusion and planning quality will not fix the scheme. It will only shift more pressure onto participants, families and providers.

I do have many more issues we could discuss including how the current psychosocial disability affects NDIA and plan reassessments that go to AAT and how they are supported from the provider side as we often hold the evidence required to make the correct decision but are excluded from the process.

I would like to request to be apart of reform discussions as body that sits alongside the NDIA to allow that greater level insight into these complex issues as they arise.

Experienced providers should be part of reform design, but they should not be forced to absorb the cost of failed system design and the bare the pressures associated.

I am ready to contribute to that discussion.

Yours sincerely,

Lennon Andrew Paturzo

Managing Director

Specialist Support Coordinator

Positive Behaviour Support Practitioner

Across the Coast Abilities Pty Ltd