Submission 48 - Supplementary Submission
Submission regarding the proposed creation of NDIS support coordination and connection services
I am a parent of two adult age disabled children. The views provided within this submission are based on lived experience supporting my children, working with providers and my work experience in business analysis and management. Whilst I agree there is a need for NDIS reforms, change implementation must not be rushed. Change should be structured, created through timely and broad consultation, and ensure it maintains the dignity and respect of people with disability.
It is important to note that the NDIS was created, by government, to promote independence, enhance social and economic participation, and ensure people with disability have choice and control. The cornerstone of the legislation is to enhance the standard of living of vulnerable Australian people with disability and reduce the impact on their functional capacity. It is important that these changes should not be based more on financial considerations and result in significant deterioration of the current allied health and support standards currently provided to people with disabilities.
Background - Tabled Support Coordination Change Options:
Currently, support coordinators are responsible for supporting participants to understand and use their NDIS plans and build confidence in navigating the NDIS, including by connecting participants with NDIS providers, community, mainstream and other government services. The potential options considered aim to address lack of oversight and quality control in the support coordination market. How options propose to achieve this varies from light-touch government intervention in the existing market, through to complete market reform and commissioning of a new support coordination and connection service. The potential options include:
3.3.1 Option 1: Status Quo
In this option, the Australian Government would undertake no reform of existing support coordination functions or markets. The market would continue to operate as per current arrangements with participants paying for support coordination services using their NDIS plan funding. As at 31 December 2025, there are 354,114 participants with funding for support coordination in plans. –[110]
Key issues in the current support coordination market, including issues with quality and integrity and increasing service costs, would not be addressed. There were 10,903 active support coordination providers during the December 2025 quarter, and only 4,783 were registered.
3.3.2 Option 2: Light touch reform to existing support coordination market
This option would involve mandating registration for support coordination providers. This would be the extent of government intervention and reform. Other existing arrangements in the support coordination market would continue, including participants paying for support coordination services using their NDIS plan funding. While this would address some quality and integrity issues, it would not address increasing costs to the scheme for the delivery of the support coordination function.
Submission 48 - Supplementary Submission
3.3.3 Option 3: Commission a new support coordination service with capped program expenditure
This option would involve the Australian Government commissioning support coordination functions as a new support coordination and connection service to commence in mid-2028. This could also provide an opportunity to merge duplicative intermediary functions into a single service, pending policy and funding decisions across other intermediary functions. The new service would be subject to capped program funding, which means the service would need to deliver an agreed scope of service within a set amount of funding. Participants would no longer need to use their NDIS plan funding to pay for support coordination services. Instead, they would be able to access the new support coordination and connection service by engaging with providers commissioned to deliver this service according to the participant’s assessed need.
This option would increase government oversight of support coordination and connection services, addressing key quality and integrity issues raised by the NDIS Review and other recent consultations. It also leaves open the possibility of including support coordination and connection functions currently delivered in other programs through a single commissioned service.
This option would also support a transition approach that minimises disruption to participants and the sector during NFP reform. It would maintain existing arrangements through the initial rollout of major reforms including NFP and Thriving Kids. Detailed design and implementation of the new service would draw on existing insights from recent engagement with participants, and the disability community (see section 5.4.3), as well as market readiness testing with the sector and states and territories.
Submission 48 - Supplementary Submission
I propose a hybrid change option for support coordination. This hybrid is based on the combination of options 2 and 3. This hybrid option would deliver a more equitable, financially viable, enhanced service delivery, accountability and integrity while appropriately maintaining dignity and respect to NDIS participants.
The considerations for this proposal are outlined as follows:
Support coordination NDIS funding rates have never increased, including no allowance for cpi or other considerations, the cost of delivery has remained static and have reduced in real terms. This situation combined with non-mandatory registration has contributed to identified support coordination quality and integrity issues. It should be noted that in general integrity issues identified have generally resulted from non-registered support coordination providers falsely billing for reduced or no service delivery. Reference to increasing costs to the scheme for the delivery of the support coordination function is considered inaccurate or appropriate considering NDIS has never increased support coordination rates therefore any increased costs are directly attributable to the increased number participants and the amount of NDIS support coordination hours allocated to participants.
To address current concerns, it would be more appropriate to: o Introduce mandatory registration for all support coordination providers o Mandatory registration will be conditional for providers to maintaining clearly defined agreed service delivery requirements including mandatory skill and knowledge; ongoing NDIS training and development and standards for all support coordinators. o Providers should be registered to solely deliver support coordination services this will minimize potential integrity issues arising from cross delivery of in house supports and ensure participants continue to exercise their choice and control o Mandatory registration will minimize delays and impact to participants choice and control, NDIS and current registered support coordination providers. o Conducting regular provider audits, as is the current regime for registered support coordination providers, will ensure appropriate standards, continuous improvement and accountability are encouraged and maintained. o Identified provider breaches would result in appropriate [existing defined] enforcement action including de-registration.
In its current form, option 3 unfairly disrespects disabled participants removing their true freedom of choice and control. Implementing the proposed hybrid would result in: o minimal impact to the support coordination role and participants. o retain participant freedom of choice and control to select and pay for their preferred support coordination provider. o promotes best coordination standards that could be extended across other current government services.
Submission 48 - Supplementary Submission
The proposed new support coordination and connection service would be subject to capped program funding, meaning the service would deliver an agreed scope of service within a set amount of funding. Participants would no longer use their NDIS plan funding to pay for support coordination services. o This proposal is not considered equitable, considering the support needs of each participant varies. As the amount of support coordination i.e. number of hours varies; setting mandatory capped funding and expectations could negatively impact on the quality and amount of service deliverable to participants. Implementing support coordination and connection controlled by NDIS is considered a negative to the principle of encouraging participant independence, choice and control. o Establishing an amended standard to allocate participant plans with required support coordination funds and participants paying valid invoices for services delivered by registered support coordinators would be considered as more appropriate. This amended process would minimize the logistics and implementation delays to redefine the current standard. o Concern is raised regarding NDIS defining the role and scope of the support coordination and connection services and then setting capped funding particularly considering the funded rate for support coordination has never been reviewed or increased by NDIS. This also raises the question of how and who will define the agreed scope of service and ensure the set amount of funding has realistic expectations and appropriate remuneration to ensure value for the services delivered. o A further concern is who and how the decision will be made regarding which providers are to be commissioned to deliver this new service. If larger national providers are selected the question of skills, local knowledge and accountability could present a barrier to appropriate levels of participant support being delivered. Some participants like or require face-to-face meetings, such, the question of travel, mileage and demographic location of providers and support coordinators presents a potential challenge to the he proposed new support coordination and connection service. o It is considered that implementing the proposed hybrid support coordination model would be more appropriately: address previously identified issues, retain respect and support to participants, deliver oversight of support coordination and connection services to address quality and integrity issues raised by the NDIS Review and other recent consultations.