Supports music therapy quality and safety nationally (Provider advocacy) | External submission

Submission 685

Senate Standing Committees on Community Affairs Inquiry: National Disability

Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Australian Music Therapy Association (AMTA) submission

26 May 2026

Senate Standing Committees on Community Affairs Inquiry: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 – Australian Music Therapy Association submission 1

Submission 685

Australian Music Therapy Association submission to

Senate Standing Committees on Community Affairs Inquiry: National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026

26 May 2026

About Australian Music Therapy Association and the NDIS

The Australian Music Therapy Association (AMTA) is Australia’s peak body for music therapy. AMTA is the only government-recognised certifying body responsible for registering music therapists, accrediting music therapy courses, and maintaining professional standards, conduct and ethics. AMTA is a member of Allied Health Professions Australia and the National Alliance of Self-Regulating Health Professions (NASRHP). AMTA-certified registered music therapists (RMTs) are required to comply with strict regulatory standards established by NASRHP to ensure consumer safety. AMTA has clearly defined membership criteria, national professional standards and assessment processes and a clearly defined scope of practice.

AMTA plays a vital role in assuring music therapy quality and safety nationally, to promote the health, wellbeing, and functioning of Australians across the lifespan. We are committed to ensuring that all NDIS participants can access safe, effective and evidenced therapeutic supports and services to assist them in achieving their goals.

AMTA notes and endorses the Allied Health Professions Australia (AHPA) submission to this inquiry.

Response

AMTA strongly supports the need for a sustainable and effective NDIS, and welcomes the opportunity to provide feedback to the Senate Community Affairs Legislation Committee on the National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Bill 2026 (‘the Bill’).

AMTA notes that the proposed changes are the most significant to be proposed in the history of the NDIS and expresses its deep concern that these changes are being introduced with limited time for scrutiny and oversight. AMTA also acknowledges the significant distress that the timeframe and process surrounding the proposed changes has caused participants and providers alike. AMTA endorses the submission made by AHPA, and supports calls from other allied health peak bodies, disability representative organisations, providers and participant

Submission 685

advocates for the changes to be paused, additional time given to review the Bill in detail to enable people to understand the overall impact, and for meaningful consultation to occur.

Key Concerns

AMTA raises six key concerns in relation to the National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Bill 2026.

Increased Ministerial Powers (Schedule 1, Part 4 – Support Determination) AMTA is deeply concerned by the proposal to give the Minister and Government powers to reduce funding to areas in the Scheme with limited consultation, oversight or safeguards. AMTA joins AHPA in highlighting that this will undermine the very premise that the NDIS set out to achieve, as this will bestow power to the Minister to overturn decisions that have been deemed reasonable and necessary. AMTA has experienced first-hand the costly effects of decisions that are made at an agency level without oversight. The 2024 decision to remove art and music therapy as therapy supports from the NDIS was made without due process, resulting in a lengthy and costly independent review, workforce disruption, and most importantly, caused significant distress and harm to participants. AMTA strongly recommends that any proposed changes to funding access for broad groups should be developed based on evidence and is subject to genuine, meaningful stakeholder consultation and oversight.
Effective and Beneficial Considerations (Schedule 1, Part 6 – Reasonable and Necessary) AMTA joins AHPA in rejecting the proposed removal of principles detailed in Section 31 (as proposed in item 66). These principles are the foundation of the scheme and are essential in determining what is reasonable and necessary.

AMTA notes our concern at the proposed changes to the evidence hierarchy, which determines how the CEO can deem supports to be effective and beneficial. These changes place disproportionate reliance on ‘published, peer-reviewed and generalisable’ evidence. As already highlighted, AMTA has previously experienced the consequences of poorly defined reviews of evidence, and notes the significant risk of having decision makers who are not familiar with the principles of research and data analysis. Our concerns around this proposed hierarchy change include:

i. Inappropriate reliance on ‘generalisable’ evidence, unclear definition The proposed change dictates a hierarchy of evidence that the CEO must consider when determining if a support will be considered ‘effective and beneficial’, with ‘research and evidence in relation to the support that is published, peer reviewed and generalisable’ considered the most important form of evidence.

Generalisable evidence is typically defined in medical models of research as evidence that is derived from large scale trials that control for variables1. However, achieving this rigid definition of generalisability in disability research is fraught, due to high levels of heterogeneity (i.e. many

| 3

Submission 685

disabilities are unique, which makes it difficult to control variables), and as many of the traditional research systems and procedures render this type of research inaccessible2 for people with complex disabilities, who are often excluded from research. Many complex disabilities are also rare, which precludes large-scale efficacy trials3.

Furthermore, allied health therapeutic interventions are notoriously difficult to research due to a wide range of variables (including heterogeneity of disability; socio-economic factors; accessibility and the social nature of many allied health interventions), and allied health research receiving significantly less funding than medical research. Research funding in nature, only allows for short-term interventions to be measured. This can result in skewed data on short-term efficacy, and what is an acceptable or appropriate ‘dosage’ for therapeutic interventions. Many RMTs work with people who have multiple disabilities, predominantly cognitive or intellectual, and often have multiple diagnoses, including Autism, psychosocial disabilities (e.g. schizophrenia) and complex trauma backgrounds. It is typical for participants to receive funding for multiple therapies to support them to reach their functional outcomes. Due to the complex nature of their disabilities and the environments in which they live and participate (e.g. specialist disability accommodation; day programs), therapeutic intervention is often required over a period of years and across disciplines, which is rarely captured by short-term controlled research.

Therefore, the ‘gold standard’ of medical research is not the most appropriate measure of evidence for any allied health profession4. In relation to evidence-based practice, it is the responsibility of practitioners to assess the research findings in the context of clinical application, to determine how the research can guide practice1. The National Disability Insurance Agency (NDIA) have previously acknowledged the importance of following best practice in understanding evidence informed practice (NDIS Quality and Safeguards Commission, 2023, Figure 1).

Figure 1. NDIS Commission’s model of evidence-informed practice (adapted from Sackett, et al. 1996 and Hoffman et al., 2016) – taken from NDIS Quality and Safeguards Commission, 2023).

| 4

Submission 685

In AMTA’s communication with the Evidence Advisory Committee (EAC), we have previously been assured that NDIA understands that not all disabilities will be represented equally in the published evidence base for disability research. As such, multiple forms of research and evidence (including qualitative research, grey literature and lived experience) have been included in their review process5,6. AMTA is concerned that the proposed changes create an inappropriate hierarchy of evidence that relies on conventional models of empirical research that may not capture the full range of relevant evidence. These risks excluding important and diverse forms of evidence and disadvantaging diagnostic groups who are unable to be represented by large-scale sample sizes by nature of their disability.

Recommendations:

NDIA should retain the four-pillar model of evidence informed practice; this should be consistent with current best practice, ensuring that lived experience and practice-based evidence are retained as central to evidence-informed practice in the NDIS
The term ‘generalisable’ should be removed to ensure that accepted forms of peer-reviewed research include high-quality qualitative research and case-study evidence
Where disabilities are under-represented in published research, lived experience evidence and practice implementation evidence should be given equal or higher weight in decision-making

ii.Lack of clarity in expertise and process for interpretation of evidence AMTA has previously experienced the consequences of policy change based on substandard interpretation of research, as revealed through AMTA’s FOI request into the ‘rapid review’ that led to the initial decision to remove art and music therapy from the scheme7. AMTA notes that the ‘rapid review’ did not include clear definitions to guide the literature search. It included irrelevant papers that were not genuinely representative of music therapy research and omitted key evidence due to an inadequate search strategy. For example, only three of the thirty papers included in the review related to actual music therapy research).

Evidence reviews and interpretation of research data and findings are highly specialised skills. While the establishment of the EAC has provided some assurance that evidence synthesis will be more rigorous, AMTA are yet to see the outcome of any EAC reviews. In this context, the changes proposed in this legislation appear to confer power on the CEO for interpreting evidence, without clear guardrails to ensure that appropriate processes are undertaken to ensure integrity of research interpretation.

Recommendations:

Decision-making processes should be transparent
Decisions should not be finalised without genuine, meaningful stakeholder consultation with key stakeholders, including participants, providers, researchers, and peak bodies

| 5

Submission 685

iii.Lack of clarity around future review of evidence and interim supports Absent from the proposed changes, are the provisions that will be provided to participants who may have their therapy supports reduced in instances where they have been deemed to lack evidence. During consultations with the EAC, it has been acknowledged that in cases where peer-reviewed literature is still emerging (particularly for rare or complex disabilities), that other forms of evidence will be considered, and the potential for supports to continue in the interim until more research is published.

AMTA notes that evidence is continually developing. If lived experience and clinical expertise evidence are deprioritised, as appears to be implied in the proposed changes, then there should be a clear process on how emerging research will be considered in updating decisions about what is and is not funded.

Recommendations:

Interim measures should be put in place for participants who lose existing supports due to evidence reviews
Clear pathways for funding decisions to be updated when new evidence emerges

Registration of Providers (Schedule 2, Part 1) AMTA has previously made submissions, including with AHPA, on how RMTs and other allied health professionals are defined as NDIS providers, and the need for risk-proportionate registration. AMTA emphasises that being unregistered under the NDIS does not mean being unregulated or unqualified. As Australia’s government-recognised certifying body for music therapy, and a member of AHPA and NASRHP, AMTA sets national standards, scope of practice and assessment processes, with certified RMTs required to meet strict professional and consumer safety standards.

AMTA supports the reform of practice standards within the NDIS to ensure the quality and safety of supports. However, we, along with other peak bodies, strongly urge that any updates to the regulatory framework are proportional to practice size, and take into consideration other external regulation mechanisms to avoid duplication of processes and costs to providers. AMTA expresses concern that any mandatory registration that does not take these factors into account may result in loss of access to services for vulnerable participants.

AMTA joins AHPA and other peak bodies in recommending that any future regulatory frameworks recognise existing regulatory requirements for certified RMTs and other allied health professions.

Recommendations:

Existing regulatory requirements for allied health professions are considered
Cost and administrative burden to already regulated professions must be minimised | 6

Submission 685

AMTA supports AHPA’s recommendation of an ‘enrolment’ model alongside current regulatory approach

Reducing Claim Times (Schedule 2, Part 5) AMTA expresses our concern about the reduced claim time from 2 years to 90 days. While we support improved processes that will enable claims to be processed more easily, AMTA holds concerns regarding scenarios where delays to claims are outside of providers control. RMTs frequently report issues with processing claims due to ongoing confusion about the legitimacy of music therapy in the scheme, and confusion relating to stated support policy. In many cases, 90 days is not an adequate timeframe in which to rectify these issues. AMTA joins AHPA in calling for assurances that claims are able to be processed in compliance with this new policy, and that in instances where the timeframe is exceeded due to circumstances outside of the provider’s control, that clear pathways to rectify are provided.

Recommendations:

More clarity about the process
Safeguards for situations beyond the provider’s control

Pricing – Decision Making (Schedule 3, Part 1) AMTA supports in-principle the move to independent price setting. However, as has been our experience in the past 12 months, AMTA highlights the lack of transparency and due process in current pricing decision-making. AMTA supports AHPA’s call for; (1) greater clarity about benchmarking; (2) how the data gaps will be addressed and; (3) how the cost-of-service delivery is quantified.

AMTA notes that the decision to reduce the hourly rate for music therapy was made based on inaccurate data, and we have yet to receive clarification on the process that led to this decision. While AMTA acknowledges the importance of government oversight in pricing for scheme sustainability, we express our concern that current proposed changes allow for the Minister to make changes to the pricing with no clear independent oversight. These changes risk the introduction of unsustainable rates for providers, which places participants at risk of being unable to access essential services. AMTA joins AHPA and other peaks in calling for amendments that will ensure that pricing is reviewed independently, through genuine, meaningful consultation, and that findings are published transparently. AMTA also seeks to ensure that evidence and explanations for any pricing decisions are made public.

Recommendations:

The Minister does not have unilateral decision making on pricing
Independent pricing reviews are undertaken and published
Evidence and explanations for pricing changes are made public | 7

Submission 685

Automation of Administrative Action (Schedule 3, Part 2) AMTA joins participants and provider peak bodies in expressing concern that automation of systems may pose a risk to participants that we have witnessed in other similar automated systems, including Robodebt and the Support at Home ‘Integrated Assessment Tool’. AMTA is particularly concerned about proposed changes that imply that automation can include ‘evaluative judgement’, without clinical judgement or oversight. We share concerns about reduced pathways to challenge decisions, whether human or automated, and advocate for clear appeal pathways.

Recommendations:

Ensure the right to challenge decisions is maintained
Ensure that automated systems have built-in human oversight and monitoring procedures AMTA thanks the Committee for considering these concerns, and welcome ongoing engagement with the Committee and Government to support a fair and sustainable NDIS.

Contact Details

Amanda Quealy

Chief Executive Officer

Australian Music Therapy Association

Dr Zara Thompson

Disability Advisor

Australian Music Therapy Association

| 8

Submission 685

References

Kamper SJ. Generalizability: Linking Evidence to Practice. J Orthop Sports Phys Ther. 2020 Jan;50(1):45-46. doi: 10.2519/jospt.2020.0701. PMID:
Mulhall, P., Taggart, L., McAloon, T. and Coates, V. (2021), Challenges to conducting randomised controlled trials with adults with intellectual disabilities: Experiences of international experts. J Appl Res Intellect Disabil, 34: 891-904. https://doi.org/10.1111/jar.12838
Müller AR, Brands MMMG, van de Ven PM, Roes KCB, Cornel MC, van Karnebeek CDM, Wijburg FA, Daams JG, Boot E, van Eeghen AM. Systematic Review of N-of-1 Studies in Rare Genetic Neurodevelopmental Disorders: The Power of 1. Neurology. 2021 Mar 16;96(11):529-540. doi: 10.1212/WNL.0000000000011597. Epub 2021 Jan 27. PMID: 33504638; PMCID: PMC8032375.
Brodsky SL, Lichtenstein B. The gold standard and the pyrite principle: toward a supplemental frame of reference. Front Psychol. 2020;11:562. doi:10.3389/fpsyg.2020.00562
Australian Government Department of Health, Disability and Ageing. NDIS EAC assessment process [Internet]. Canberra: Australian Government Department of Health, Disability and Ageing; 2026 [cited 2026 May 25]. Available from: https://www.health.gov.au/resources/publications/ndis eac-assessment-process
Australian Government Department of Health, Disability and Ageing. NDIS Evidence Advisory Committee [Internet]. Canberra: Australian Government Department of Health, Disability and Ageing; 2025 [cited 2026 May 25]. Available from: https://consultations.health.gov.au/evidence advisory-committee-eac/september2025/supporting_documents/eac_sep2025consultationsupportsfaq-pdf
Australian Music Therapy Association. AMTA gravely concerned about quality of NDIA report. Australian Music Therapy Association. Published March 18, 2025. Accessed May 25, 2026. https://www.austmta.org.au/news-item/18874/amta-gravely-concerned-about-quality-of-ndia-report

| 9