Osteopathy Australia
Suite 4, 11 Railway St, Chatswood NSW 2067
PO Box 5044, Chatswood NSW 1515
Ph (61) 02 9410 0099 www.osteopathy.org.a u
Osteopathy Australia’s submission to the Senate inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 .
Introduction
Osteopathy Australia thanks the Committee for the opportunity to provide this
supplementary submission to the Senate inquiry into the National DisabilityInsurance Scheme Amendment (Securing the NDIS for Future Generations) Bill
- We note our previous submission provides more detailed feedback on the Bill . This supplementary submission highlights three priority issues that remain
unresolved and should be addressed before the Committee’s final report is completed.
Recommendations requiring immediate action
Our original submission made 13 recommendations . This supplementarysubmission focuses on the most immediate issues that remain unresolved and are most directly relevant to participant access, Scheme design and allied health
workforce capacity. W ith the C ommittee's final report now due on 14 August
2026, we ask that the following recommendations be addressed before thatreport is finalised :
- It is clear that transparent provider access and equity processes have failed to be developed by either the NDIA or Government. We recommend r esolv ing
participant access and equity inconsistenc ies in NDIS recognition of osteopathy by establishing a clear pricing and claiming pathway for osteopathic services, including a dedicated support item or line item in the
relevant NDIS Pricing Arrangements and Price Limits and Support Catalogue,
where servic es are disability -related, functional, goal -linked, evidence -
informed, and delivered by an Ahpra -registered osteopath. This lack ofbenchmarking is an outcome of many years of Government and NDIA planning, process and/or data documentation failures. We continue to see provider blame for government failure in data management and analysis.
2. Clarify that musculoskeletal disability, pain -related functional limitation andsecondary musculoskeletal complications can be genuine disability -related support needs where they arise from, or are functionally connected to, a participant’s eligible impairment.
- The NDIA should accept clinical evidence on treating humans for a range of conditions, regardless of disability status, when disability may or may not impact such conditions, physiological or musculoskeletal processes.
About Osteopathy and Osteopathy Australia
Osteopaths in Australia are university -qualified allied health practitioners registered with the Australian Health Practitioner Regulation Agency (Ahpra). Only practitioners registered with the Osteopathy Board of Australia may use the protected title “osteopath”.
Osteopaths complete either a dual bachelor’s degree, or a bachelor’s and master’s qualification with education and training in anatomy, biomechanics, human movement, the musculoskeletal and neurological systems, clinical intervention approaches and biomedi cal science including pharmacology. Osteopathic practice is underpinned by a biopsychosocial management
approach and includes assessment, diagnosis, manual and movement -basedtherapy, exercise advice, education, self -management support and functional rehabilitation within an osteopath’s individual scope of practise.
Osteopathy Australia is the peak body representing the interests of osteopaths, osteopathy as a profession, and consumers’ access to osteopathic services. Our core work includes liaison with state and federal government, statutory agencies, professional bodies, and private industry regarding professional, educational, legislative, and regulatory issues. Most registered osteopaths are me mbers of Osteopathy Australia.
Our concerns about the Bill in its current formIn our view the interim report and recommendations do not adequately capture the feedback provided by the disability community, including the allied health
sector. They also do not address the scale and significance of the concerns raised.The interim report fails to recommend any amendments to the Bill itself before it passes.
O steopathy Australi a is concerned the interim report does not adequately address the practical implementation risks raised in our original submission. These risks are not limited to osteopathy as a profession. They relate to participant access, continuity of care, allied heal th workforce capacity, market stewardship and the way disability -related functional needs will be recognised under the reformed Scheme.
We urge the C ommittee to address at a minimum the priority recommendationshighlighted in this supplementary submission.
Recommendation 1
It is clear that transparent provider access and equity processes have failed to be developed by either the NDIA or Government. We recommend resolving participant access and equity inconsistencies in NDIS recognition of osteopathy by establishing a clear p ricing and claiming pathway for osteopathic services, including a dedicated support item or line item in the
relevant NDIS Pricing Arrangements and Price Limits and Support Catalogue,
where services are disability -related, functional, goal -linked, evidence -informed, and delivered by an Ahpra -registered osteopath. This lack of benchmarking is an outcome of many years of Government and NDIA planning, process and/or data documentation failures. We continue to see provider blame for government failure in data m anagement and analysis. What the Bill does The Bill is framed as a reform to improve sustainability, quality, integrity and market stewardship. The Explanatory Memorandum states that the Bill seeks to improve quality of supports, place the Scheme on a more sustainable footing,
address fraud and str engthen regulation. However, these objectives may beundermined if NDIS pricing and claiming arrangements do not accurately recognise the full range of Ahpra -registered allied health practitioners who can deliver clinically appropriate disability -related supports.
Why this matters for participants The NDIS does not operate in a separate workforce universe. It draws on the same allied health workforce that supports primary care, rehabilitation, aged care, compensable injury schemes, private practice, community health and disability services. Australian evidence also shows that osteopaths are already integrated within multidisciplinary primary care, including established referral relationships with general practitioners and other health professionals. 1
If the NDIS selectively recognises some Ahpra -registered allied health professions’ while leaving others uncertain or administratively sidelined, it creates artificial workforce constraints. Participants experience this as reduced provider choice, longer w ait times, disrupted continuity, greater travel burden and reduced access to locally available care.
This is especially important in regional, rural and thin -market areas, where the available allied health workforce may not neatly match the NDIS pricing, claiming and support catalogue arrangements.
Provider recognition is therefore not simply an administrative issue. It is a participant access, continuity of care, workforce and market stewardship issue.
Why this matters for osteopathy and the wider allied health workforce
Osteopathy is the immediate issue for this submission, but it is also an example of
a broader system -design problem. O steopaths are Ahpra -regulated, primary1 Vaughan, B., Fleischmann, M., Grace, S., Engel, R., Fitzgerald, K., Steel, A., Peng, W., & Adams, J. (2024). Osteopathy referrals to and from general practitioners: Secondary
analysis of practitioner characteristics from an Australian practice -based resear chnetwork. Healthcare, 12(1), 48. https://doi.org/10.3390/healthcare12010048
contact allied health practitioners who assess, diagnose, manage and refer
people with neuro -musculoskeletal, conditions across the lifespan. They alreadyparticipate in multiple publicly funded systems, including Medicare, Department of Veterans’ Affairs, workers’ compensation, motor accident compensation and aged care, where their role and clinical contribution are clearly recognised.
Despite this, osteopathy remains inconsistently recognised within NDIS pricing, claiming and support catalogue arrangements. Rather than having a profession specific claiming pathway, osteopathic services are generally claimed under a generic “other profes sional” category. This reduces transparency, limits benchmarking of utilisation and pricing, and creates uncertainty for participants, providers and planners.
The issue extends beyond osteopathy. Where clinically appropriate, excluding or inconsistently recognising Ahpra -regulated allied health professions reduces participant choice and underutilises an existing regulated workforce. This is
particularly importan t in regional, rural and thin -market settings where provideravailability is already constrained.
Recognising osteopathy appropriately would improve consistency across Australian health systems, strengthen participant access to appropriate care, better utilise the existing allied health workforce and support the Bill’s stated objectives of sustainabili ty, quality and market stewardship.
The current generic “other professional” claiming category also creates practical pricing problems. Because osteopathy is grouped with multiple unrelated professions, the NDIS Annual Pricing Review has acknowledged that meaningful benchmarking is difficult . This contributes to pricing that does not reflect comparable government -funded schemes or the costs of delivering osteopathic
services. This benchmarking difficulty is an outcome of many years ofGovernment and NDIA planning, process and/or data documentation failures. We continue to see provider blame for government failure in data management and analysis.
We recommend the annual pricing review ( APR ) aligns with other schemes likethe following:
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The average fee charged data recorded by Medicare is billed at the Medicare Benefits Schedule (MBS) MBS $61.80 rate. 2 This fee is charged for
a minimum of a 20 -minute session as well as a gap fee is charged.
Therefore, the rate would be approximately $180 plus a gap fee per hour, which is much higher than the NDIS rate.
2 Australian Government Department of Health and Aged Care. Medicare Benefits
Schedule item 10966 [Internet]. Canberra: Australian Government Department of Health and Aged Care; 2004 Jul 1 [updated 2026 Jul 1; cited 2026 Jul 2]. Available from: https://www9. health.gov.au/mbs/fullDisplay.cfm?type=item&q=10966
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Aged care: Support at Home $159.91 weekdays, $179.18 weekdays outside of normal business hours, $224.13 weekends, $352.58 public holidays 3. This is
an indicative price range and not price caps for the profession .
- Department of Veterans ’ Affairs ( DVA ): $75.10 for a minimum 20 -minute
appointment. 4 Recent proposed budget increases have recognised that this is well below market value.
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Workers compensation schemes: Rates are per consultation of at least 30 minutes and are as follows:
o NSW $148.90 5
o VIC $84.18 6
o QLD $132 initial consultation, $104 subsequent consultation 7
o ACT $175.64 initial consultation (30 -65 minutes), $117.66 (consultation
up to 30 minutes), $135.74 (consultation between 31 -50 minutes) 8
o SA $156.80 initial consultation, $115.79 subsequent consultation 9
o WA $133.50 initial consultation, $111.90 subsequent consultation 10
Collectively, these examples demonstrate that recognising osteopathy through profession -specific funding and claiming arrangements is already standard practice across Australian health and compensation systems. Aligning NDIS arrangements with these existin g schemes would improve consistency across government -funded healthcare rather than introduce a new policy approach.
3 Independent Health and Aged Care Pricing Authority (IHACPA). Support at Home
Pricing Advice 2026 –27 [Internet]. Sydney: IHACPA; 2025 Nov [cited 2026 Jul 2]. Available from: https://www.ihacpa.gov.au/sites/default/files/2026
05/support_at_home_pricing_advi ce_2026 -27.pdf4 Department of Veterans’ Affairs (DVA). Osteopaths schedule of fees effective 1 July 2025 [Internet]. Canberra: DVA; 2025 Jul 1 [cited 2026 Jul 2]. Available from:
https://www.dva.gov.au/sites/default/files/2025 -07/osteopathfees -1-jul -2025.pdf5 State Insurance Regulatory Authority NSW (SIRA). Physiotherapy, chiropractic and osteopathy fees and practice requirements [Internet]. Sydney: SIRA; 2026 Feb 1 [cited 2026 Jul 2]. Available from:
https://www.sira.nsw.gov.au/__data/assets/pdf_file/0008/1398 068/2026 -Physiotherapy, -
chiropractic -and -osteopathy -fees -and -practice -requirements.pdf6 Transport Accident Commission (TAC). Osteopathy fees [Internet]. Geelong: TAC; updated 2026 Jun 13 [cited 2026 Jul 2]. Available from:
https://www.tac.vic.gov.au/providers/invoicing -and -fees/fee -schedule/osteopathy -services7 WorkCover Queensland. Osteopathy services table of costs [Internet]. Brisbane: WorkCover Queensland; 2025 Aug 1 [cited 2026 Jul 2]. Available from:
https://www.worksafe.qld.gov.au/__data/assets/pdf_file/0031/147892/Osteopathy -Services -Table -of-Costs -1-Augu st -2025.pdf 8 Comcare. Rates for medical and allied health treatment [Internet]. Canberra: Comcare;
[cited 2026 Jul 2]. Available from: https://www.comcare.gov.au/service -providers/medical -allied -health/treatment -rates 9 ReturnToWorkSA (RTWSA). Osteopathy fee schedule and policy [Internet]. Adelaide: RTWSA; 2026 Jul 1 [cited 2026 Jul 2]. Available from:
https://www.rtwsa.com/media/documents/fee -schedules/Osteopathy -Fee -Schedule -1-July -2026.pdf 10 WorkCover WA. Rates, fees and payments [Internet]. Perth: WorkCover WA; updated 2026 Jun 16 [cited 2026 Jul 2]. Available from: https://www.workcover.wa.gov.au/resources/rates -fees -payments/
Recommendation
The Committee should recommend that provider recognition be considered as part of NDIS workforce and market stewardship , consistent with the Bill’s stated objectives of improving participant choice, quality, sustainability and market stewardship.
Recommendation s 2 and 3 Recognise that musculoskeletal disability, pain -related functional limitation and secondary musculoskeletal complications can be genuine disability related support needs where they arise from, or are functionally connected to, a participant’s eligibility .
The NDIA should accept clinical evidence on treating humans for a range of conditions, regardless of disability status, when disability may or may not impact such conditions, physiological or musculoskeletal processes.
What the Bill does The Bill strengthens the link between supports and impairments that meet the disability or early intervention requirements. The Explanatory Memorandum states that supports must arise directly from impairments for which the participant meets access requirem ents and that needs relating to impairments that do not meet those requirements should not be funded. This is intended to improve consistency and sustainability across the Scheme.
Osteopathy Australia understands the policy intent of ensuring NDIS supports are linked to eligible disability -related needs. However, the practical application of this requirement will need to be carefully managed where participants have interacting impai rments, comorbidities, secondary complications or functional consequences arising from their primary disability.
Why this matters for participants Participants do not experience their impairments in neat legislative boxes.
A person with cerebral palsy, spinal cord injury, acquired brain injury, limb difference, multiple sclerosis, developmental disability, wheelchair dependence or lower -limb impairment may develop secondary musculoskeletal complications
affecting mobility, t ransfers, self -care, pain, participation, work, education orcommunity access.
If the Scheme treats these secondary functional consequences as separate or unrelated, participants may lose access to supports necessary to maintain
function and reduce future support escalation .This is particularly important where the secondary complication affects the participant’s ability to use other disability -related supports. For example, pain, reduced mobility, compensatory movement patterns or upper -limb overuse may affect wheelchair use, transfers, personal care, domestic activities, employment, education or community participation.
Why this matters for osteopathy Osteopaths support participants with disability -related presentations including chronic pain arising from neurological or musculoskeletal disability, postural and movement difficulties, secondary musculoskeletal complications arising from primary disabilit y, non -pharmacological pain management needs, and functional goals related to daily living, community participation and capacity building. These are not necessarily “extra” health concerns sitting outside disability support. For many participants, they are part of how disability affects daily function.
Where these needs are connected to a participant’s eligible impairment and affect functional capacity, they should be considered as part of the participant’s disability -related support needs. The key issue is not diagnosis alone, but whether the support ad dresses functional consequences directly relevant to the participant’s disability, safety, independence and participation.
Recognising these secondary functional impacts would not expand Scheme eligibility. Rather, it would support more consistent implementation of the Bill by ensuring disability -related support needs are assessed in the context of the
participant’s overall fu nctional capacity and the real -world consequences of theireligible impairment.
Recommendation
The Committee should recommend that the Bill and associated Rules clarify how secondary musculoskeletal complications, pain -related functional limitations and interacting impairments will be considered where they a rise from, or are functionally connected to, a participant’s eligible impairment and affect mobility,
self -care, safety, participation or the ability to use other disability -related supports.This clarification should ensure that legitimate disability -related functional needs are not excluded simply because they present as musculoskeletal pain,
compensatory movement, overuse injuries, fatigue, mobility limitation or
secondary functional consequences of an eligible impairment .Conclusion
Osteopathy Australia supports reform that strengthens the NDIS for future generations. However, the Bill must not create a narrower, more administratively controlled Scheme that loses sight of real -world function, participant choice and
the clinical expert ise needed to understand disability -related support needs.Osteopathy is not the only issue, but it is a clear example of a broader design problem. The Scheme is tightening access, planning and funding controls while unresolved provider -recognition gaps remain. Unless those gaps are fixed,
participants with muscul oskeletal, mobility, pain -related and complex functionalneeds may face reduced access to appropriate supports, especially in regional and thin -market areas.
The Committee should recommend amendments and implementation safeguards that preserve participant choice, require clinically informed
assessment, clarify how secondary musculoskeletal and pain -related functionalneeds will be considered where they arise from, or are functionally connected to, a participant’s eligible impairment.
The Committee should also recommend that NDIS pricing, claiming and support catalogue arrangements reflect the availability and role of clinically appropriate Ahpra -registered osteopaths, alongside other regulated allied health providers , to support participant access and effective market stewardship.
Ultimately, the issues raised in this submission are not simply about provider recognition or funding arrangements. They are about ensuring the reformed Scheme preserves participant choice, recognises legitimate disability -related functional needs, and mak es effective use of Australia’s regulated allied health workforce.
These recommendations are not about expanding the Scheme. They are about ensuring implementation of the reforms supports participant access, clinically informed decision -making and effective market stewardship.
If you require more information or wish to discuss further, please contact us on
(02) 9410 0099 or via email at policy@osteopathy.org.au .