Submission 520
Dear NDIA / NDIS Reform Team,
Thank you for the opportunity to provide feedback regarding the proposed changes to NDIS Plan Management arrangements.
As a registered Plan Management provider currently supporting approximately 1,500 NDIS participants, Rise and Shine Plan Management welcomes reform that strengthens quality, consistency, transparency and long-term sustainability across the Scheme.
However, the proposed changes raise significant operational and transitional questions for existing providers and the participants who rely on us. We respectfully seek further clarification to ensure we can plan responsibly, maintain continuity of support, and communicate clearly with the participants, nominees, families and providers we support.
Plan Management plays a critical role within the NDIS. It is not simply an administrative payment function. Plan Managers are often the first point of contact for participants, nominees and providers when navigating budgets, PACE, service agreements, invoices, funding risks and the practical day-to-day use of NDIS plans.
Before claims are submitted to the NDIA, our team undertakes substantial administrative and compliance checks, including reviewing invoices against the NDIS Pricing Arrangements and Price Limits, checking line items, confirming service dates, reviewing GST where relevant, identifying duplicate claims, monitoring available funding, checking participant authority or service agreement documentation where required, and resolving discrepancies directly with providers before submission.
Where invoices are incorrect, incomplete, duplicated, inconsistent with NDIS requirements, or raise concerns, we regularly stop claims from progressing until the matter is reviewed and resolved. This process protects participant funding, reduces errors, assists with early identification of non-compliance, and prevents issues from reaching the NDIA unnecessarily.
In practice, Plan Managers are a significant first line of defence in preventing incorrect, duplicate, inappropriate or potentially fraudulent claims from being submitted to the Scheme. This safeguarding role should be recognised and preserved in any future Plan Management model.
With this in mind, I respectfully seek clarification on the following matters:
- Proposed provider panel and Deed of Agreement arrangements Can the NDIA confirm whether Plan Management services are proposed to move to a provider panel, commissioned model, or similar arrangement?
Submission 520
If providers will be required to enter into a formal Deed of Agreement with the NDIA, please clarify:
-
the intended scope and purpose of the agreement
-
whether it would replace or operate alongside existing NDIS registration requirements
-
the obligations providers would be required to meet
-
performance, reporting or compliance requirements
-
contract duration and renewal processes
-
how pricing arrangements would be determined under the agreement
- Transition pathway for existing registered Plan Managers Can the NDIA clarify how currently registered Plan Management providers will transition into any new model?
Specifically, we seek clarification on whether:
- existing registration status will be recognised
- current providers will be able to transition directly into the new arrangement
- a new application, tender or approval process will be required
- grandfathering arrangements will apply for established providers
- additional evidence or documentation will be required
- anticipated onboarding and approval timeframes will be provided Clear transition arrangements are essential to avoid disruption for participants and providers.
- Recognition of the Plan Manager compliance and safeguarding role How will the NDIA formally recognise the compliance, administrative and safeguarding role Plan Managers currently perform before claims are submitted?
This includes:
- invoice compliance review
- pricing arrangement checks
- identification of duplicate or incorrect claims
- budget monitoring and risk identification
- provider follow-up and discrepancy management
- protection of participant funding
Submission 520
- early identification of concerns before they progress to the NDIA This preventative function contributes significantly to Scheme integrity and reduces administrative burden downstream. It should be considered a core function of Plan Management, not an incidental task.
- Participant choice, control and continuity How will participant choice and control be maintained under any future panel or commissioned model?
Participants often choose their Plan Manager based on trust, responsiveness, established relationships, communication style, and confidence in the provider’s compliance practices.
We seek reassurance that:
-
participants will retain meaningful choice of Plan Manager
-
participants will be able to remain with their existing provider where both parties wish to continue
-
there will be no unnecessary disruption to supports during transition
-
participants will not be forced into a provider arrangement that does not meet their needs
Participant choice and continuity must remain central to any reform.
- Eligibility criteria and provider access Can the NDIA clarify the eligibility criteria for providers wishing to participate in any future model?
In particular, please confirm:
- whether all registered Plan Managers will be eligible to apply
- whether minimum participant numbers or scale requirements will apply
- how small, regional and relationship-based providers will be considered
- whether provider performance history, compliance practices and participant outcomes will be taken into account
It is important that reform does not unintentionally reduce provider diversity, limit participant choice, or exclude smaller providers who deliver high-quality, relationship-based and compliance-focused services.
- Consultation and implementation Will there be further direct consultation with Plan Management providers before implementation?
Submission 520
We strongly encourage continued engagement with Plan Managers of varying sizes, locations and service models. Existing providers hold practical operational knowledge about the realities of invoice review, provider behaviour, participant communication, funding risk, PACE processes and compliance pressures.
This insight will be critical in designing a model that is workable in practice, protects participants, supports Scheme integrity, and avoids unintended consequences.
Rise and Shine Plan Management supports reform that strengthens participant outcomes, improves consistency, and protects the sustainability of the NDIS. However, any future model must also preserve participant choice, recognise the important safeguarding role Plan Managers already perform, and provide a clear, fair and practical transition pathway for established providers.
Thank you for considering this submission. I welcome the opportunity to participate in further consultation as reforms progress.
Kind regards,