Submission 588
Submission to the Community Affairs Legislation
Committee
Inquiry into the National Disability Insurance
Scheme Amendment (Securing the NDIS for Future
Generations) Bill 2026
31 May 2026
Submission 588
Kirinari welcomes the opportunity to make a submission to the Senate Community Affairs
Legislation Committee’s Inquiry into the National Disability Insurance Scheme Amendment
(Securing the NDIS for Future Generations) Bill 2026.
We recognise and support the need to moderate growth of the NDIS, and Kirinari supports the intent of this Bill. The NDIS needs to be sustainable, and providers who do the wrong thing should be held to account.
However, sustainability must not come at the cost of the people and communities the Scheme was built to serve.
It is critical that policy made in capital cities does not overlook regional realities. Unless we expect everyone to migrate to urban areas, we need processes and pricing models that appropriately reflect where people live.
Kirinari would be very pleased to provide further information and/or appear before the Committee to discuss our submission and other related matters, particularly as it relates to the experience of Australians living with disability in regional, rural and remote areas.
About Kirinari
Kirinari is Australia’s largest regionally-based provider of human services. We deliver disability, aged care, housing, children and youth, allied health, community nursing, transport, and carer services to more than 15,000 customers across New South Wales, Queensland, South Australia, Tasmania, and Victoria.
We deliver coordinated, integrated and person-centred service models that recognise people achieve the best outcomes when supports are connected and collaborative. Our care is trauma informed, and we work with the people we support to identify the underlying causes of the barriers they face and provide them access to the services and support they need to live a good life.
Kirinari is passionate about regional Australia and has a unique understanding of our regional communities. We believe that everyone deserves access to quality care, no matter where they live.
Submission 588
Reduction of the Statutory Claims Period to 90
Days
Relevant provision: Part 5 – Reducing claim times: Amending item 89 paragraph 45A(5)(a)
The Explanatory Memorandum to the Bill states that claims submitted more than 90 days after service delivery are “disproportionately associated with higher rates of claims that are not payable”.
Kirinari does not dispute this as a general pattern, however, has concerns about the proposed changes to the timeframe in the Bill – from two years to 90 days – as registered providers depend on factors outside of their control to meet this deadline.
A claim can only be submitted when the provider has accurate, complete data to support it. Across the disability sector, technology and systems challenges routinely prevent providers from assembling that data within tight timeframes. For example, Plan details may not be current in Agency systems, or funding categories may be in dispute or under variation.
Kirinari supports the principle that timely claiming supports scheme integrity. However, the reduction from two years to 90 days raises concerns as there is no assurance that providers will be compensated for services already delivered.
For example, for participants whose plan is plan-managed, the provider does not claim directly from the Agency. Rather, the provider invoices the plan manager, who then submits the claim to the NDIA. If the plan manager does not lodge the claim within 90 days, whether due to administrative issues, processing backlogs, or disputes over the invoice, the provider’s revenue is lost.
Under this scenario, the provider has delivered the support and issued the invoice, but then has no control over when the plan manager submits the claim. The proposed 90-day window will penalise providers for potential delays by a third-party intermediary, over whom they have no authority.
Kirinari recognises the Bill’s proposed plan management reforms are intended to improve plan manager conduct. However, the proposed plan management approach will not be implemented until 1 October 2027, yet the new 90-day claims window is proposed to commence on 1 December 2026.
During this 10-month period, providers will be subject to the new claims deadline, while the intermediaries who control the claims process will remain under the existing framework, which will cause significant confusion and puts claims at risk for providers.
Submission 588
Even after the plan management reforms begin, the fundamental problem remains: the provider bears the financial consequence of a plan manager’s failure or delay to claim.
The Explanatory Memorandum notes that the CEO retains discretion to accept late claims where “exceptional circumstances” apply under subsection 45A(6). However, this provision is undefined and unclear in the Bill.
Recommendation: The Committee should recommend that the Bill be amended to:
(a) require NDIS rules made under subsection 45A(6) to define “exceptional circumstances” to expressly include delays attributable to Agency processes, technology and system failures, and plan manager conduct;
(b) provide that the 90-day period for plan-managed claims commences from the date the provider issues the invoice to the plan management provider, not the date of service delivery; and
(c) establish a statutory right for providers to claim directly from the Agency where a plan manager has failed to submit a claim within 60 days of receiving a valid invoice.
Submission 588
Support for Mandatory Registration
Relevant provision: Scheule 2 Part 1: Addition of 10C definition of NDIS provider
Kirinari is a committed registered provider and supports the move toward mandatory registration for all providers. We embrace the compliance obligations that come with registration, which are critical for strong governance and safeguarding.
Our submission to the Department of Health, Disability and Ageing’s Getting It Right: A new definition for NDIS providers consultation in February 2026 stated plainly: “…ultimately, any organisation or person providing one-on-one support to people with disability should be subject to the regulatory oversight that comes with registration”.
However, in amending the NDIS provider definition, it is critical to consider the purpose of registration to ensure Australians receive safe, high quality, well-regulated disability services.
The evidence shows the current system is not providing this. As noted in the 2026 Report on Government Services1:
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there were 45.7 total complaints per 1,000 active NDIS participants, an increase from 21.2 in 2022-23
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there were 46.1 other reportable incidents (excluding unauthorised use of restrictive practices) per 1,000 NDIS participants, an increase from 29.9 per 1,000 in 2021-22
Contributing to these increases in complaints and incidents is the current lack of regulatory oversight.
This has been noted by Minister for Health and Ageing, the Hon. Mark Butler MP, who said: “15 out of 16 providers are unregistered, leaving far too much scope for poor quality service, sharp practice, conflicts of interest and precious little oversight”2.
Kirinari welcomes the amended NDIS provider definition in section 10C of the Bill, and the Bill’s intention to narrow the definition to genuine providers while enabling mandatory registration.
1 Report on Government Services | Productivity Commission2 Speech from Minister Butler, National Press Club – 20 August 2025
Submission 588
However, we believe the Bill’s approach to mandatory registration remains incomplete, which creates ongoing risk.
The proposed definition captures persons who receive NDIS funding and persons prescribed by NDIS rules who provide supports outside the NDIS. The NDIS’ Category D rules can also carve out classes of persons or entities entirely.
Kirinari appreciates the outcome of the Getting it Right consultation will determine this, however, the exemptions to mandatory registration being legislated depends entirely on NDIS rules that have not yet been made.
Treasury modelling documents tabled in the Senate suggest registration will be mandatory only for high-risk providers3. We believe this would represent a failure to properly reform the market to improve standards, quality of care and governance. Any organisation or person providing one-on one support to people with disability should be subject to the regulatory oversight that comes with registration.
The exemption to this would be, for example, a physiotherapist who provides one-on-one support and is already registered and regulated by the Australian Health Practitioner Regulation Agency. It is logical that they do not need to be defined as a NDIS provider as well.
The NDIS Provider and Workforce Registration Taskforce has recognised this, noting that “practitioners, including allied health practitioners, that hold professional registration may have that registration recognised to avoid duplication and administrative burden”4.
Kirinari is in agreement with the Taskforce, and recommends any support or service provider that is already registered with a health-related regulator should not also be subject to NDIS registration as doing so would create regulatory duplication which would add duplicative costs.
Recommendation: The Committee should recommend that mandatory registration be expanded to anyone who provides one-on-one support to people with disability, unless covered by existing industry registration.
The Committee should also recommend that the Bill includes a timeline for the commencement of mandatory registration for all providers.
3 Tabled documents | Document 165854 NDIS Provider and Workforce Registration Taskforce
Submission 588
Impact of Reduced Funding for Community
Participation in Regional Areas
Relevant provisions: Schedule 1 Part 4 – Support determinations: Addition of 34A determination reducing funding for groups of supports 4 Schedule 1 Part 5 – Plan renewal: Addition of 50A renewal of participant’s old framework plan on end date Schedule 1 Part 6 – Reasonable and necessary supports: Addition of 17B principles relating to scheme sustainability
The proposed section 34A enables “the Minister to determine by legislative instrument: a percentage (Iower that 100 per cent) by which a funding component for specified group of supports is reduced for the duration that the determination is in force”.
The Explanatory Memorandum to the Bill provides examples of Ministerial Determinations for section 34A and other aspects of the Bill, many of which cite reductions of 25 or 50 percent for assistance with social, economic and community participation.
Minister Butler’s speech announcing the NDIS changes suggested community participation is a central focus for reducing growth of the scheme, announcing plans to “reset the total cost of social and community participation back to where it was last year”5, and Treasury modelling tabled in the Senate in May 2026 confirms reduced funding for community participation will be the single biggest source of savings over the forward estimates, at $13.2 billion. 6
This presents significant concerns for the participants Kirinari supports in regional communities across Australia.
In metropolitan areas, a reduction in funded community participation may be partially offset by the density and accessibility of mainstream community infrastructure. This may include public transport, community centres, libraries, sporting clubs, and social networks which are relatively proximate and available.
5 Minister Butler speech at the National Press Club – 22 April 2026
6 Tabled documents | Document 16585Submission 588
However, in regional areas, these alternatives either do not exist or are not accessible to people with disability without funded support. For many of Kirinari’s participants, their community access support worker is their primary connection to social life beyond the walls of their home.
Subsection 17B(2)(c) of the Bill also proposes new considerations relevant to the CEO’s performance of functions and exercise of powers, stating that the NDIS should support “the desirability of supporting communities to respond to the goals and needs of participants”.
However, this assumes a level of community infrastructure that does not exist in many regional towns across Australia.
The plan renewal mechanism (section 50A of the BIll) compounds this risk. Unspent community participation funding will no longer roll over, meaning participants who were unable to access community activities during part of a plan period will lose that funding permanently rather than having it available in the next period.
This is a particular disadvantage for regional participants whose access patterns are inherently uneven due to seasonal isolation, carer unavailability, or the limited frequency of activities in small towns.
Participants in Dubbo, for example, should not receive materially less support than participants in Sydney for the same assessed need, simply because the cost of delivery in their community is higher or there are fewer options available to them.
Recommendation: The Committee should recommend:
(a) that any support determination made under section 34A that applies to community participation support categories must include an assessment of its differential impact on participants in regional and remote areas; and
(b) that the plan renewal mechanism under section 50A include provision for the carryover of a proportion of unused community participation funding for participants in regional and remote areas where access is constrained by geography.
Submission 588
The Case for Regional Loading in NDIS Pricing
Relevant provision: Schedule 3 Part 1 Decision making on pricing: Addition of 45C Maximum amounts payable under the National Disability 1 Insurance Scheme—funding not managed by participants
The Bill allows for differentiated pricing by “remoteness” (section 45C(9)(a)), which Kirinari welcomes in principle and proposes that this principle is given effect through expanded regional loading.
The NDIS currently applies price loadings of 40 per cent and 50 per cent for remote and very remote areas (MM6 and MM7 under the Modified Monash Model), which covers approximately 1.4 per cent of NDIS participants.
However, no loading exists for inner regional (MM2–MM3) and outer regional (MM4–MM5) areas, despite the 239,769 participants in these areas representing approximately 31 per cent of all NDIS participants.
The cost realities of care delivery across regional Australia are well documented.
In metropolitan areas, a support worker may see five participants in a day with two hours of travel; in regional areas, it can take over an hour to drive between two participants alone.
Kirinari’s own data shows that large metropolitan providers average EBITDA margins of 4.62 per cent on average annual revenue of $660.8 million. This compares to large regional providers which average just 1.69 percent on $112.6 million. This is not a function of inefficiency; it is a function of geography.
Kirinari proposes a loading model that would add 5 to 10 per cent for MM2–MM3 areas and 10 to 20 per cent for MM4–MM5 areas. We estimate the total cost of this loading at $0.6 to $1.2 billion per annum, equating to 1.4 to 2.8 per cent of current NDIS spend.
This cost could be partially or fully offset by modest reductions (1 to 3 per cent) to overhead rates within the Disability Support Worker cost model for metropolitan providers, which benefit from significantly greater scale efficiencies.
Submission 588
Recommendation: The Committee should recommend that the Bill be amended to require the Minister, when making the first pricing determination under section 45C, to include a regional loading for supports delivered in MM2–MM5 areas, reflecting the actual cost differential between metropolitan and regional service delivery.
Submission 588
The Missing Middle
Relevant provision: Schedule 1 Part 1 Defining functional capacity: Addition of 9B
NDIS providers are already delivering unfunded mental health work because participants with psychosocial disability fall between the NDIS and mainstream mental health systems.
Kirinari is concerned that the Bill only widens the gap for Australians with psychosocial disabilities whose support needs do not fit neatly into either system.
These are Australians whose care needs are too complex for primary care, too episodic or insufficiently “permanent” for the NDIS’s disability framework, and too functional on assessment days to trigger the crisis thresholds of state and territory mental health services.
Currently, NDIS providers in regional areas fill this gap because the person is in front of them and they need support then and there. That work is unfunded, and the Bill does not acknowledge it.
Kirinari’s concern about the missing middle is compounded by the Bill’s consolidation of pricing and funding authority in the Minister – the NDIS Review recommended that pricing functions be placed with an independent body, however the proposed changes under the Bill departs from that pathway.
For participants with psychosocial disability in regional areas, where Kirinari may be the only provider with capability and expertise to support complex presentations, reduced funding and reduced prices do not result in the participant choosing a more efficient alternative.
Instead, they result in the participant receiving less support, or no support at all.
Recommendation: The Committee should recommend the Bill require a formal transitional support pathway, developed with state and territory governments, for participants who lose NDIS eligibility as a result of these changes.
Submission 588
Conclusion
Kirinari supports the intent of this Bill and agrees that the NDIS needs to be reformed so it delivers on its promise and purpose. However, striving for sustainability must not come at the cost of the people and communities the Scheme was built to serve:
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The claims framework must not penalise providers for potential failures in third-party systems they do not control;
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Registration must apply to everyone delivering one-on-one support, not just those already in the system;
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Funding reductions to community participation must account for the reality that regional participants have nowhere else to turn;
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Pricing must reflect where services are actually delivered; and
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Australians with psychosocial disability must not be pushed out of one system without a pathway into another. These are not competing priorities, they are the minimum conditions for a NDIS that supports people to live a good life, no matter where they live.