Submission 534
Submission to:
Senate Community Affairs Legislation Committee
Inquiry:
National Disability Insurance Scheme Amendment (Securing the NDIS for Future
Generations) Bill 2026
Submitted by: Awesome A & S Pty Ltd t/a Awesome Plan Management
Position: Support reform in principle, but recommend amendments and safeguards.
26 May 2026
Awesome A & S Pty Ltd t/a
Awesome Plan Management
ABN: 62 647 322 021
Website: www.awesomeplanmanagement.com
Address: Office 4070, Ground Level,
470 St Kilda Road, Melbourne VIC 3004
Phone: 1300 848 105
Submission 534
- Executive summary Awesome Plan Management supports the broad objectives of the National Disability
Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill
2026, particularly measures aimed at reducing fraud, misuse of NDIS funds, conflicts of interest, and improving the long-term sustainability of the Scheme.
Our submission focuses on Schedule 2, Part 6 of the Bill, which proposes significant changes for registered plan management providers, including a deed of arrangement with the Agency, new integrity and governance requirements, claims handling and verification obligations, ICT and systems requirements, reporting obligations, and related-party conflict controls.
We support stronger integrity and governance measures. However, we are concerned that the proposed reforms are progressing quickly despite limited detail about how the new plan management model, deed of arrangement, panel process and transition arrangements will operate in practice.
In our experience, previous NDIA system and policy changes, including the PACE rollout, funding periods and endorsement processes, demonstrate the importance of practical testing and clear implementation planning before reforms commence. Without this, there is a risk of confusion, unclear implementation, increased administrative burden, market consolidation, reduced participant choice, and higher costs to the Scheme and taxpayers.
A key concern is that the deed of arrangement and any panel process should not become a blunt market access tool or shift the focus away from actual service quality. Good plan managers already perform significant daily work to support Scheme integrity, including invoice review, budget monitoring, identifying irregularities, maintaining audit trails, supporting participants and communicating with providers.
Awesome Plan Management recommends that the new plan management model be transparent, operationally tested and focused on quality. The reform should strengthen fraud prevention and Scheme sustainability while preserving participant choice, service continuity and the practical integrity work already being performed by effective plan managers.
- About Awesome Plan Management Awesome Plan Management is an independent SME provider of NDIS plan management services, with practical, ground-level experience supporting participants, providers and families across the Scheme.
Through our day-to-day work, we have direct experience with participant budgets, provider payments, claims processes, PACE, NDIA administrative requirements, and the practical impact that system and policy changes can have on participants, providers and service continuity.
Submission 534
We support the objective of strengthening Scheme integrity and believe experienced plan managers play an important role in supporting that objective. This includes identifying administrative issues, supporting clear and accurate payment processes, maintaining practical oversight of claims, and helping ensure NDIS funds are used appropriately.
- Our position on the Bill Awesome Plan Management supports the broad objectives of the Bill, particularly measures aimed at reducing fraud, misuse of NDIS funds, conflicts of interest, and strengthening the long-term sustainability of the Scheme.
Our focus is on Schedule 2, Part 6, which introduces significant changes for registered plan management providers. These changes include the requirement for a deed of arrangement with the Agency, new standards relating to integrity, governance, staff, claims handling, ICT systems, reporting, and the management of related-party conflicts.
We support the intent of stronger integrity and governance settings. However, we are concerned that reforms of this scale are being progressed through a very short inquiry process, without sufficient time for detailed sector consultation, operational testing, or practical input from providers who work with the Scheme’s payment and administrative systems every day.
If the reforms are rushed or implemented without clear criteria and realistic transition arrangements, there is a risk of unintended consequences. These may include disruption to participants, reduced participant choice, uncertainty for providers, unclear implementation, increased administrative burden, and higher implementation costs for both the sector and taxpayers.
In our view, sustainability should be achieved through targeted integrity measures that improve quality, reduce misuse and strengthen participant outcomes. The objective should be a stronger, more sustainable NDIS that protects participants, improves integrity, preserves choice and ensures plan management reform remains focused on service quality in practice.
- Key concerns Concern 1 - The reform is progressing quickly despite limited detail about how the new model will operate
Awesome Plan Management is concerned about the speed at which the proposed plan management reforms are progressing, particularly given the limited detail currently available about how the new model will operate in practice.
The Government has indicated that a new plan management approach will commence from 1 October 2027, with a 6-month transition period. At the same time, the Bill introduces significant changes for registered plan management
Submission 534
providers, including the requirement for a deed of arrangement with the Agency, new integrity and governance standards, claims handling requirements, ICT and systems requirements, reporting obligations, and conflict of interest controls.
These are substantial operational changes. However, there is currently limited detail about what the new plan management model will look like, how providers will be assessed, what criteria will apply, what the deed of arrangement will require, and how existing providers will transition.
A 6-month transition period may be insufficient if plan managers are required to enter into new arrangements, update systems, change internal processes, train staff, satisfy new reporting requirements, communicate with participants and providers, and manage any transition into a panel or commissioning framework.
Without clear detail and proper consultation before implementation begins, there is a risk of confusion, participant uncertainty, increased provider and participant enquiries, increased administrative burden, and higher costs to the Scheme and taxpayers.
Concern 2 - Previous NDIA reforms demonstrate the need for full operational testing before commencement
Awesome Plan Management is concerned that the proposed plan management reforms may repeat issues seen in previous major NDIA system and policy changes, where implementation proceeded before systems and processes were fully tested and ready.
We have previously participated in NDIA consultation processes, including consultation relating to the PACE rollout. During that process, we raised practical concerns that the system was not ready for full implementation. Despite this feedback, implementation proceeded, and a number of issues later required amendment, clarification or operational correction after commencement.
Similar issues have occurred with other NDIA changes, including funding periods, endorsement processes and administrative changes. In our experience, the key issue is not simply that reforms are difficult, but that systems are sometimes implemented before practical issues have been fully identified, tested and resolved.
A common expression within the NDIS sector is that the Scheme is often “building the plane while it is already in the air”. After more than a decade of the NDIS operating, this should not continue to be the default approach for major reform.
This concern is not raised in opposition to reform. Awesome Plan Management supports stronger integrity, governance and fraud prevention measures. However, reforms of this scale should be designed, tested, refined and confirmed as operationally ready before commencement.
Plan managers operate at the point where participant budgets, provider invoices, claims, payments, PACE and NDIA administrative processes intersect. This gives
Submission 534
plan managers direct visibility of how system and policy changes work in practice, where issues arise, and what needs to be resolved before implementation.
Given the proposed changes to plan management, the NDIA should undertake full operational testing before finalising the model, deed of arrangement, claims verification requirements, ICT obligations, reporting expectations, transition arrangements and participant communication.
This testing should identify practical issues before the reforms commence, not after the sector is already required to comply. Without this level of testing and issue resolution, there is a real risk that avoidable problems will emerge after implementation, resulting in participant disruption, provider uncertainty, increased enquiries, greater administrative burden and higher costs to the Scheme and taxpayers.
Concern 3 - Cost savings may not be achieved without a well-designed implementation model
Awesome Plan Management is concerned that the proposed plan management reforms appear to be directed, at least in part, toward improving Scheme sustainability and reducing costs. However, there is currently limited detail about how the reforms will be implemented in practice or how the expected savings will be achieved.
We support the objective of ensuring taxpayer funds are used appropriately and that the NDIS remains sustainable. However, sustainability cannot be assumed simply because a new model is introduced. If the reform is not carefully designed, properly consulted on and operationally tested, it may create additional costs for the Scheme rather than reduce them.
A poorly implemented reform could result in significant disruption across the sector, including participant confusion, provider uncertainty, increased complaints, additional provider and participant enquiries, greater administrative burden, additional NDIA workload, system remediation costs, legal and review processes, and the need for further corrective policy changes after commencement.
There is also likely to be significant concern across the plan management sector if the new model, panel process, deed of arrangement and eligibility criteria are not clearly explained early. Without meaningful consultation, the reform may create uncertainty for providers and participants well before implementation begins.
For this reason, it is important that the Government clearly explains how the proposed plan management reforms are expected to deliver savings, what implementation costs have been considered, and how the risk of unintended costs will be managed.
In our view, reform that is designed with the sector is more likely to achieve savings. Reform that is rushed, unclear or poorly implemented may ultimately cost taxpayers more.
Submission 534
Concern 4 - The proposed panel may shift sector focus away from service quality and toward consolidation
Awesome Plan Management is concerned that the proposed move toward a panel of plan management providers may unintentionally shift the sector’s focus away from service quality and toward market consolidation.
Since the announcement of a proposed panel approach, there has been increasing concern across the plan management sector about how providers will be selected, what criteria will apply, what level of scale may be expected, and whether providers of different sizes and operating models will have a realistic pathway to participate. This may create pressure for providers to consolidate, merge, acquire, or become larger in order to improve their perceived chances of being considered for the panel.
This creates a risk that the reform may reward size rather than service quality. The focus should not be on which providers can become the largest before implementation. The focus should be on which providers deliver high-quality, compliant, participant-focused and reliable plan management services.
If the panel process is not carefully designed, it may unintentionally encourage a race for scale rather than a race for better service, stronger governance, improved integrity controls and better participant outcomes.
Participant choice and service quality should remain central to any new plan management model. A provider’s size should not be treated as evidence of quality, integrity or capability. Providers of different sizes and operating models should be assessed on objective criteria, including compliance history, governance, payment integrity controls, participant service standards, systems capability, responsiveness, complaints handling and demonstrated operational performance.
The Government should ensure that any panel or commissioning model does not create unnecessary market concentration or reduce the diversity of providers available to participants. The purpose of reform should be to strengthen quality and integrity across the sector, not to create a system where providers feel forced to consolidate simply to remain viable.
Concern 5 - The deed of arrangement may become a compliance gatekeeper without sufficient focus on actual service quality
Awesome Plan Management supports the intent behind the proposed deed of arrangement. We agree that stronger integrity, governance, reporting, claims handling, ICT, verification and conflict management standards can play an important role in reducing fraud and misuse of NDIS funds.
However, our concern is that the Bill gives the deed of arrangement a central role in determining whether a plan manager can continue operating, without providing enough detail about how the deed will work in practice, how providers will be assessed, or how service quality will be measured.
We support the objectives of stronger governance and integrity. In practice, good plan managers already perform significant work in the background to support
Submission 534
Scheme integrity. This work often includes reviewing invoices, identifying irregularities, querying unclear claims, supporting participants to understand budgets, communicating with providers, maintaining audit trails, monitoring funding use, and helping ensure claims are consistent with plan funding and NDIS requirements.
Much of this work is not visible in headline data, public reporting or simple provider registration status. It is daily operational work that helps prevent errors, misuse and inappropriate claiming before they become larger problems.
Our concern is that a deed-based model, particularly if linked to a limited panel of providers, may shift the focus away from the actual quality of plan management work and toward whether a provider satisfies a centralised administrative process. Simply requiring a deed, or limiting plan management to a panel of providers, does not automatically mean that high-quality fraud prevention work will continue.
A provider may be large enough or resourced enough to satisfy a deed process, but that does not necessarily mean it delivers better participant service, stronger invoice review, better budget oversight, or more effective fraud prevention at the practical level.
The purpose of the Bill is to strengthen fraud measures. For that reason, the assessment of plan managers should focus on the actual integrity work performed by providers, not merely whether they fit within a new administrative structure.
Any deed of arrangement should therefore include clear and transparent criteria that assess:
- the quality of invoice and claim review processes
- how providers identify and escalate irregularities
- participant service and communication standards
- provider payment accuracy and timeliness
- internal audit trails and record keeping
- staff training and supervision
- complaints handling
- budget monitoring practices
- systems capability
- governance and conflict management
- demonstrated history of supporting Scheme integrity The deed should not become a blunt market access tool. It should be designed to recognise and preserve the work that effective plan managers already do to protect participants and support the integrity of the Scheme.
Submission 534
In our view, the Bill should ensure that the deed of arrangement process strengthens quality and integrity in practice, rather than simply creating a new administrative threshold or shifting the sector’s focus away from service quality.
- Recommendations Awesome Plan Management recommends that the Committee consider the following amendments, safeguards and implementation requirements.
Recommendation 1 - Release detailed implementation information before the reform commences
The Government should publish detailed information about the proposed plan management model well before implementation begins.
This should include:
- how the new model will operate
- how providers will be assessed
- what criteria will apply
- how the deed of arrangement will be developed and approved
- how existing providers will transition
- what systems, reporting and governance requirements will apply
- how participant choice and continuity will be protected Plan managers, participants and providers should not be expected to prepare for a major reform without clear operational detail.
Recommendation 2 - Do not commence the transition until the model has been finalised, tested and clearly communicated
The proposed 6-month transition period should not commence until the full plan management model, deed requirements, assessment criteria, ICT obligations, reporting expectations and transition arrangements have been finalised and clearly communicated to the sector.
Before implementation begins, the NDIA should undertake practical operational testing to ensure the model works in the real Scheme environment. This should include testing how the deed of arrangement, claims verification requirements, participant communication, provider obligations, system requirements and transition process will operate in practice.
This testing should involve a representative group of plan managers, including providers of different sizes and operating models, so that practical issues can be identified before the model affects the entire sector.
Submission 534
The purpose of this process should be to identify implementation risks before commencement, including risks relating to participant confusion, provider uncertainty, increased enquiries, administrative burden and unintended costs.
If the model is not ready, the transition period should be extended or staged. A reform of this scale should not rely on issues being discovered only after commencement. The transition should begin only when the final model is workable, clearly understood and capable of achieving its intended integrity and sustainability objectives.
This approach would reduce the risk of the Scheme again having to “build the plane while it is already in the air”.
Recommendation 3 - Ensure the deed of arrangement assesses quality, not just administrative compliance
The deed of arrangement should not become a blunt market access tool. It should be designed to assess whether a plan manager genuinely contributes to Scheme integrity, participant outcomes and service quality.
The deed criteria should assess:
- invoice and claim review processes
- irregularity detection and escalation
- participant communication and support standards
- provider payment accuracy and timeliness
- audit trails and record keeping
- staff training and supervision
- complaints handling
- budget monitoring practices
- systems capability
- governance and conflict management
- demonstrated history of supporting Scheme integrity The deed should recognise the practical integrity work good plan managers already perform, not simply whether a provider can satisfy a centralised administrative process.
Recommendation 4 - Ensure the panel process does not reward size over quality
Submission 534
Any panel or commissioning model should be based on objective and transparent criteria.
Provider size should not be treated as evidence of quality, integrity or capability. Providers of different sizes and operating models should have a fair pathway to participate where they can demonstrate strong governance, compliance, service standards, systems capability and participant-focused practice.
The Government should ensure the panel process does not unintentionally encourage unnecessary market consolidation or reduce the diversity of providers available to participants. The purpose of the panel should be to improve quality, integrity and participant outcomes, not to create a system that rewards scale over service quality.
Recommendation 5 - Publish the expected savings and implementation cost assumptions
The Government should clearly explain how the proposed plan management reforms are expected to deliver savings, what implementation costs have been considered, and how the risk of unintended costs will be managed.
This should include consideration of:
- NDIA administration costs
- system build and remediation costs
- provider transition costs
- participant and provider communication costs
- complaints and review costs
- legal and dispute resolution costs
- costs caused by uncertainty or poorly sequenced implementation Reform that is designed with the sector is more likely to achieve savings. Reform that is rushed, unclear or poorly implemented may ultimately cost taxpayers more.
Recommendation 6 - Protect participant choice and continuity
Participant choice and continuity should be built into the reform design.
Participants should not be forced to change plan managers unnecessarily because of unclear criteria, delayed approval processes, or market consolidation caused by the panel model.
The Government should ensure there are clear safeguards for participants, including communication requirements, continuity arrangements, transition protections and support where a provider is not approved or chooses to exit the market.
Submission 534
Recommendation 7 - Keep the focus on fraud prevention and service quality
The purpose of the reform should remain clear: reducing fraud, misuse and poor practice while improving Scheme sustainability.
The reform should not become a process that simply restructures the market or rewards providers who are larger, louder or better positioned to satisfy an administrative process.
The Committee should recommend that any new plan management model must preserve the work of effective plan managers who already support Scheme integrity through practical day-to-day work, including invoice review, budget monitoring, participant support, provider communication, audit trails and identification of irregularities.
- Conclusion Awesome Plan Management supports reform that strengthens the integrity, sustainability and long-term operation of the NDIS.
However, reforms to plan management must be implemented carefully, transparently and with sufficient operational testing. The deed of arrangement, panel process and transition arrangements should strengthen quality and fraud prevention in practice, not simply create a new administrative threshold or encourage unnecessary market consolidation.
The Committee should ensure that participant choice, service continuity, provider diversity and practical Scheme integrity remain central to the reform design.