National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 445
28 May 2026
Submission to the Senate Standing Committee on Community Affairs National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
- Executive summary 1
- About Attain Healthtech 2
- Recommendations 3
- Attain as an exemplar of NDIS best practice 3
- Conflicts of interest management in care 4
- Managing conflicts of interest 4
- Divestment & Sovereign Risk 5
- Appendix 1 – Largest Plan Managers in Australia 7
- Appendix 2 - Proposed Elements of the Act to be amended 12
1. Executive summary
● Attain Healthtech operates two NDIS businesses at scale Mable and Leap In! Through more than $300 million in investment Attain has grown to become a major employer in Australia, and now has six hundred employees and provides work for tens of thousands of sole traders through its brands. ● Attain supports in principle the notion of commissioning plan managers, however, a plain text reading of this legislation might see responsible, scaled plan managers like Leap In ineligible to be commissioned as plan managers. ● Across the top twenty largest plan managers, 75 per cent provide another NDIS service in addition to plan management. ● However, plan managers of scale like Leap In are the exact businesses the Government should want to commission. Leap in! declined $67.78 million in claims in the financial year, while receiving $17.5 million in fees from the taxpayer, meaning it returned the taxpayer’s investment four times over by preventing inappropriate, fraudulent or ineligible claims. ● Leap In has conflict of interest controls, disclosure obligations and policies in place. Notably 98.7 per cent of all funded supports used by Leap In participants are spent at providers other than Mable. ● Attain Group companies operate robust conflict of interest management policies including but not limited to maintaining: separation of operational entities, separation of management and boards, disclosure of relationship externally, and providing consumers with options. ● Conflicts of interest in care are extremely common and most major providers of care – whether for-profit or not-for-profit, participate in multiple markets – major, responsible companies operating in the care economy can manage conflicts of interest through
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 445
appropriate mechanisms which fall short of divestment, which might be the end result of this legislative proposal. ● Market sources have established a valuation for plan management businesses at approximately $2,000 per participant. Plan management has a total market value of approximately $1 billion. ● The Government has proposed to launch an intervention into this market and to choose via a procurement process which businesses will be permitted to operate. It is likely a large percentage of the 1,462 existing plan managers will no longer be permitted to operate in the market. ● The Senate must carefully consider the implications of the deleterious effect of these decisions on shareholder value and whether this move could be perceived to comprise the acquisition of property by the Federal Government. ● The Senate should consider the risk associated with potentially triggering the Just Terms guarantees for acquisition of property under the Australian constitution. ● Given that a number of major players in the space have offshore investors, the Parliament must also consider the extent to which some investors may have protections under Bilateral Investment Treaties. ● The Senate should inquire how the Government intends to remunerate investors in unsuccessful, non-commissioned plan managers for their lost property.
2. About Attain Healthtech
Attain Healthtech is a leading health technology group that comprises Mable Technologies Pty Ltd, aged care registered provider Self Managed Support Pty Ltd (trading as HomeMade) and leading plan manager Leap In!
Mable is a health tech platform that offers a complementary approach to traditional aged care at home and disability support models. Mable gives older persons and people with disabilities more choice, control and flexibility to shape the care and support they receive in their own homes and communities. This choice is made possible by over 21,000 independent contractors providing valuable and necessary care and support services via the platform. Founded in 2014, Mable now operates at some scale with support providers on the platform providing care and support services to over 28,000 people with disability and older Australians.
HomeMade is a registered aged care provider that enables older people to self-manage their home care packages. Founded in 2021, HomeMade now operates at scale, with 5,400 older people choosing HomeMade as their registered provider to access services and supports at home. HomeMade recognises the importance of effective systems and processes to provide customers with freedom and control to access services and support on their terms, combined with effective safeguards to ensure high-quality care and compliance with support at home guidelines and requirements.
Leap in! is Australia’s leading NDIS plan manager. Established in Queensland, Leap in! now supports more than 15,000 participants across Australia. Leap in! is a business driven by purpose
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 445
and believes in people. Leap in! exists to help people with a disability live their best life by getting the most out of their NDIS Plans.
3. Recommendations
Recommendation 1 – That the Senate amends items 91 through 93 of Schedule 2 to require appropriate conflict of interest management policies be put in place in integrated businesses. See Appendix 2.
Recommendation 2 – The Committee recommends the Government require integrated groups that include both a registered plan manager and another registered NDIS provider to comply with appropriate conflict of interest policies, in line with other parts of the care economy, including aged care.
4. Attain as an exemplar of NDIS best practice
Attain Healthtech owns two NDIS businesses at scale: Australia’s largest healthtech marketplace Mable, and top ten plan manager Leap In!. In line with its registration requirements, Leap In has an independent board and management structure. Through more than $300 million in investment Attain Healthtech has grown to become a major employer in Australia, and now has six hundred employees and provides work for tens of thousands of sole traders through its brands. Leap In is registered, while Mable is in the process of becoming a registered provider.
To date, Attain has supported the Parliament’s important work to improve NDIS scheme integrity. Attain supports in principle the notion of commissioning plan managers. However, a plain text reading of this legislation – particularly items 91 through 93 of Schedule 21 – might see responsible, scaled plan managers like Leap In ineligible to be commissioned as plan managers. The bill states:
A person may be registered to manage the funding of supports under participants’ plans only if the person is not also registered or applying to be registered, or a related party of a person registered or applying to be registered, to provide other supports or services (and vice versa): see subsection 73E(2B).2
Leap In would not be alone – across the top twenty largest plan managers using Mable, 75 per cent provide another NDIS service in addition to plan management (see Appendix 1 for an overview).
However, it is these plan managers of scale are the exact providers that the Government should want to be commissioned in 2027. In the last financial year, Leap in! paused or declined $67.78 million in claims. This comprised 10.7 per cent of the total claims made by providers through Leap
1 See: Items 91 to 93, Schedule 2, Part 6, National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026, link, p. 81. 2 See: lines 21-25, Schedule 2, Part 6, National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026, link, p. 81.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 445
in!, which amounted to $629.6 million. Bear in mind that in the same period Leap in! received $17.5 million in fees from the taxpayer, which means that plan managers like Leap in! are returning the taxpayer’s investment four times over by preventing inappropriate, fraudulent or ineligible claims.
Leap In and Mable might have the same parent company but they have appropriate controls, disclosure obligations and policies in place and, as a result, 98.7 per cent of all funded supports used by Leap In participants are spent at providers other than Mable.3
5. Conflicts of interest management in care
Conflicts of interest are everywhere in commercial and professional life. They arise wherever expertise meets participation, in for-profit, not-for-profit, and government settings alike. Conflicts of interest are not in and of themselves a problem to be eliminated. The problem is the conflict that goes unmanaged, undisclosed, or uncorrected. With the right governance in place – disclosure, independent oversight, recusal, separation of functions, fiduciary duties, audit, and real consequences for breach – conflicts can be identified, resolved, and often prevented altogether.
None of this is novel. Regulators have spent decades building exactly these tools across every major sector, and have investigated and prosecuted those who failed to manage their conflicts properly – rightly so, because poor governance erodes market integrity and carries serious consequences. Medicine, law, accounting, banking, and public administration all rest on the same principle: conflicts can rarely be removed without removing the expertise that makes the activity valuable, so they are made visible, accountable, and correctable instead. We do not outlaw conflicts in medicine or allied health just because those professionals receive taxpayer funds via Medicare, as we accept that these conflicts are unavoidable, can be well-managed, and would involve people with considerable expertise removing themselves from service delivery.
The idea that the Parliament’s only option is to prohibit conflicts outright sits at odds with that record. Prohibition is a blunt instrument. It cannot tell a well-managed conflict from a corrupt one, it catches the responsible and the reckless in the same net, and in a sector built on integrated expertise it can force divestment, fragmentation, or withdrawal – costs that land on the taxpayer, and in this case, NDIS participants who deserve expertise and experience. Prohibition has its place: where the potential harm is severe, monitoring is impractical, and the expertise at stake is low. None of those conditions holds across the care economy.
Responsible care operators already manage conflicts through mechanisms well short of divestment – disclosure, separation of functions, independent decision-making, conflict registers, third-party review, and enforceable fiduciary duties. Strengthen those mechanisms, lift the standard, and sharpen the regulator’s power to detect and act on failures, and the Government can address the real concerns behind this proposal. A blanket prohibition does the opposite: it displaces capable providers while doing little to stop the conduct that actually causes harm.
3 Note: In Financial Year 2026 (up until April), Mable accounted for 1.31 per cent of claims submitted by Leap In! to the NDIA.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 445
6. Managing conflicts of interest
As three major brands operating across the care economy, Attain group companies are keenly aware of the need to behave ethically. For this reason, the three companies have adopted the following measures to protect consumers.
Separation of operational entities – Each portfolio company operates its own workforces, with their own core operational functions. Each are consumer facing brands, with significant interactions with members of the public. IT systems are carefully managed, privacy policies operate to govern data use and storage, and all data is protected.
Separation of management and boards – Each portfolio company has its own management structure, with a separate executive which reports to its own Board. These boards in turn report to the Attain board for matters pertaining to the entire group.
Disclosure of relationship – In those instances where a customer service agent working at one portfolio company might think that a product or service at another company is a good fit for a customer, they will always disclose the nature of the relationship and the principles of choice and informed decision making.
Providing consumers non-aligned options – All businesses across the Attain Group are committed to supporting client choice and control. Since 2020, Leap In! Has offered a free provider directory and support connection service with more than 2,500 different providers outside of the Attain Group. Registered aged care provider HomeMade similarly manages a large provider directory of non-related businesses.
As an end result of these robust protections, the natural product of operating in a market which emphasises choice, and the fact that not all services or products are available from the group, there is large evidence of outsourcing across the group, with clients across the three brands choosing from both Attain and non-Attain brands.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 445
Note: this data relates to the most recent complete month at the time of publication, April 2026.
7. Divestment & Sovereign Risk
As of March 2026, 68 per cent of all NDIS participants utilise a plan manager amounting to 526,376 individuals and 1,462 plan managers operate within this market.4 Presently, where an existing plan manager might seek to exit the market it can sell its assets to other registered plan managers. Market sources have thus established a valuation for these businesses5 at approximately $2,000 per participant.6 At the current size of the NDIS, this creates a total market value of approximately $1 billion. However, the Government has proposed to launch an intervention into this market and to choose via a procurement process which businesses will be permitted to operate from 1 October 2027.7 The end result of this market intervention is that a large percentage of the 1,462 existing plan managers will no longer be permitted to operate in the market.
Given that the bill establishes the ability for the Government to manage this procurement process, the Senate must carefully consider the implications of the deleterious effect of these decisions on shareholder value. Putting aside the ethical implications of this decision, given this move could be perceived to comprise the acquisition of property by the Federal Government, the Senate should consider the risk associated with potentially triggering the Just Terms guarantees for acquisition of property under the Australian constitution.8 Given that a number of major players in the space have offshore investors, the Parliament must also consider the extent to which some investors may have
4 “NDIS Quarterly Report,” March 2026, link, p. 66. 5 Exclusive any other assets that the business might hold. 6 This figure is based on transactions of which Attain Healthtech is aware. 7 “Securing the NDIS for future generations timeline,” Department of Health, Disability and Aged Care, 13 May 2026, link. 8 “Protections from statutory encroachment,” Australian Law Reform Commission (ALRC), 31 July 2015, link.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 445
protections under Bilateral Investment Treaties.9 On this basis, the Senate should determine how the Government intends to remunerate investors in unsuccessful, non-commissioned plan managers for their lost property.
Attain is grateful for the opportunity to provide this input on National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 and welcomes any further opportunities to support the Committee in its important work.
9 “Australia’s bilateral investment treaties,” Department of Foreign Affairs and Trade (DFAT), accessed: 21 May 2026, link.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 445
8. Appendix 1 – Largest Plan Managers in Australia
Rank Name Owner Other Participant Total Size on in NDIS Numbers payment Mable 202610 assets in amount group? ($m) Q2 2025-2611
1 My Plan Gallagher No Approx. $1,12014 1 (MPM) Manager & Bassett12 80,000 and 4 NYSE: AJG. participants1 NDSP (NDSP) 3
2 Plan Partners Established Yes, 42,600 $659.6 2 and 10 & Plan as a joint disability customers16 (Plan venture employme NB: One of Tracker) Tracker between nt and the largest Disability support NDIS Services coordinatio Support Australia n Coordinator (DSA) and s. McMillan Shakespeare Group.15 Part of the “Plan and Support Services” Group within MMS.
3 NIB Thrive & Previously Yes, exited 43,00417 $621.6 3 (NIB Instacare acquired a provider Thrive) number of market but and 7 businesses has a SC (Instacare including business. ) Maple, Connect,
10 Supplement E National 2025-26 Q2, link, Table 102 11 Supplement E National 2025-26 Q2, link, Table 102 12 Thomson, Sarah et al, “NYSE-listed insurance giant swoops on IFM Investors’ My Plan Manager,” 25 September 2023, link. 13 Based on an industry source, not independently verifiable. 14 My Plan Manager and NDSP are listed separately in the data set. 15 See ASX page, link, accessed: 20 May 2026. 16 AGM Papers, McMillan Shakespeare, link, p. 9. 17 See 2025 Annual Report, NIB, link, p. 14.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 445
BudgetNet, Peak Plan, All Disability and Developing Links. In FY25 combined into a single tech platform.
4 Kismet Acquired a Yes. 40,00018 Unknown - 9 (Moira), large number constituent 15 (My of smaller plan Autonomy plan managers ) and 19 managers are listed (Onboard between separately. Supports) 2022 and 2026.
5 MyIntegra Subsidiary of Yes, owns 19,000 $248.3 6 APM Human Mobility (industry Services platform source) International and Ltd. In 2024, support Also has APM delisted coordinatio 2,000 from ASX n support and returned business. coordination to private Operates clients. ownership allied under PE firm health APM also Madison business. owns Dearborn.19 Commissi Mobility. oned LAC and Inclusive Employme nt Australia provider.
18 Note: Based on an industry source. 19 “APM,” Madison Dearborn, accessed: 20 May 2026, link.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 445
6 Provider Private No $175.7 8 Choice company. WA based.
7 Leap In! Acquired by Yes, part 14,670 $162.7 5 Attain of the participants Healthtech same May 2026. on 1 July group as 2024. Mable and SC business.
8 Moira Acquired by Yes. <10,000 $140.5 9 Financial Kismet in participants Plan March Manager 2026.20
Plan Tracker Acquired by Yes, <10,000 10 McMillan disability participants Shakespeare employme in 2021.21 nt and support coordinatio n.
First2Care Constellation Yes also <10,000 11 Plan Software provides participants Management (Canada) assistive acquired in tech.23 2024. Constellation operates other NDIS software businesses.22
Bright Plan Private No. <10,000 12 Management company participants Victoria based in Melbourne.
20 See Kismet branding on Moira Financial Plan Management page, link. 21 “About us,” Plan Tracker, accessed: 19 May 2026, link. 22 Based on an industry source. 23 NDIS Registration, accessed: 19 May 2026, link.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 445
IDEAL Plan Private Unclear, <10,000 13 Management company also an participants based in accounting Canberra. business.24
Sunshine Private No. <10,000 14 Coast Plan company participants Manager based in Queensland
My Autonomy Owned by Yes <10,000 15 Kismet25 participants
Capital Private Unclear <10,000 16 Guardians business also participants (NDIS) based in provides Victoria. payment solutions26
Leisure Registered Yes, also <10,000 17 Networks charity.27 provides participants SC, ILO, employme nt support and supports.28
Manage Private No <10,000 18 Mode Pty Ltd business participants based in Perth.
Onboard Owned by Yes. <10,000 19 Supports Pty Kismet29 participants Ltd
Plan Manage Private Yes, <10,000 20 Assist business support participants based in coordinatio
24 ABN information,accessed: 19 May 2026, link. 25 See Kismet branding on MyAutonomy webpage here. 26 See home page, accessed: 19 May 2026, link. 27 ACNC Registration, accessed: 19 May 2026, link. 28 See “Disability services,” accessed: 19 May 2026, link. 29 See home page for branding, accessed: 19 May 2026, link.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 445
North n Sydney. business.30
30 ABN listing, accessed: 19 May 2026, link.
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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 445
9. Appendix 2 - Proposed Elements of the Act to be amended
In the view of Attain, the following provisions should be removed from National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 and a more reasonable approach to conflict of interest management established through the commissioning process.
THE ITEMS INCLUDED BELOW THIS LINE SHOULD BE REMOVED FROM THE BILL:
91 Section 9
Insert:
related party: a person is a related party of another person in any of the following circumstances: (a) the person is a relative of the other person (within the meaning of section 9 of the Corporations Act 2001); (b) either person is an associated entity of the other person (within the meaning of section 50AAA of the Corporations Act 2001); (c) circumstances prescribed by the National Disability Insurance Scheme Rules for the purposes of this paragraph.
92 Subsection 73C(1) (note)
Omit “Note”, substitute “Note 1”.
93 At the end of subsection 73C(1)
Add:
Note 2: A person may be registered to manage the funding of supports under participants’ plans only if the person is not also registered or applying to be registered, or a related party of a person registered or applying to be registered, to provide other supports or services (and vice versa): see subsection 73E(2B).31
31 See: lines 21-25, Schedule 2, Part 6, National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026, link, p. 81.
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