Concerns over unregistered provider rates impacting NDIS sustainability (Individual advocacy)

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

Submission 700

Registered    n                                                                       NDIS

respectABILITY Provider

SUPPORT St’AVICfS •

27th May 2026

To Whom It May Concern,

Please read through to see how one EASY change could save the NDIS $9.88 BILLION per year WITHOUT impacting participants supports.

We are writing as a small, registered NDIS provider employing 25 staff members. We entered this industry because we previously worked within a fraudulent and non-compliant unregistered service and wanted to create a provider that genuinely placed participants first, operated ethically and complied fully with NDIS standards and expectations.

We have worked extremely hard to build a strong team, deliver quality supports, maintain compliance, and operate transparently. However, the current direction and uncertainty within the NDIS is creating significant concern for providers like ours who are trying to do the right thing.

As a registered provider, we understand and support the need for reform within the NDIS. We agree that stronger safeguards, improved assessment processes and more structured, evidenced based planning are necessary to ensure participant funding is appropriate, sustainable and genuinely aligned to individual needs. However, many of the immediate changes and proposed reforms appear to be focused on achieving rapid cost reductions by reducing participant funding before appropriate systems, oversight mechanisms, and evidence based review processes are fully established. We are concerned that quick financial responses without adequate structure or planning risk negatively impacting both participants and the compliant providers supporting them.

As registered providers, we carry substantial overhead costs and compliance obligations, including:

  • External audits and registration costs
  • Internal auditing and quality systems
  • Training platforms and mandatory staff training
  • Rostering and CRM systems
  • Incident management and safeguarding systems
  • Payroll tax obligations
  • Portable Long Service Leave Levy obligations
  • Work Cover costs exceeding $35,000 annually
  • SCHADS Award obligations including penalty rates and minimum engagement requirements Despite all of this, profit margins remain extremely limited when operating correctly and ethically within the pricing framework.

The growing uncertainty within the NDIS means many small providers cannot confidently offer permanent part time or full time employment because funding changes and plan reductions create major financial risk. As a result, many staff remain casual despite providers wanting to offer greater stability. This increased gross wages, which drives up work cover, LSLL & Increases risk of payroll tax.

Respectability Support Services Pty Ltd

ABN:59665599824

NDIS Provider number: 4050168664 Phone: 0477 265 018

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

Submission 700

What is most difficult to understand is why stronger action was not immediately focused on unregistered and independent providers charging the same hourly rates as fully compliant registered organisations without carrying any of the same overheads, compliance responsibilities, or participant safeguards.

A single independent support worker with no audit obligations, no compliance systems, no training platforms, no supervision structures, no administrative staff and no operational overhead should not reasonably be charging the same base hourly rate as a registered provider operating within full NDIS compliance requirements.

Using a basic example:

  • A unregistered provider/independent charging $70.23 per hour for 38 hours per week invoices approximately $2,660 weekly

  • If that rate for independents/unregistered providers were capped at $50 per hour, a rate that still provides a strong income well above many other Australian industries while accounting for tax and superannuation obligations, the weekly cost becomes approximately $1,900

  • This represents a saving of approximately $760 per week for one independent/provider alone

  • Across a year, that equals approximately $39,520 in savings per individual provider If applied across the approximate 250,000 unregistered providers operating at a minimum of 38 hours per week, the potential annual saving to the NDIS would equate to approximately $9.88 billion per year.

This estimate is based only on a conservative 38 hour work week. The provider we previously worked for regularly billed more than 250 hours per week across participants. The scale of this issue cannot continue to be ignored.

The current system is placing increasing pressure on registered providers who are carrying the burden of compliance, workforce obligations, safeguarding expectations, and operational transparency while competing against sectors of the market operating with significantly lower accountability and cost.

We strongly believe reform should prioritise:

  • Greater regulation and oversight of unregistered providers
  • Pricing structures that reflect actual operational differences between registered and unregistered services
  • Stronger safeguards around high-volume billing practices
  • Increased focus on structured, evidence-based support delivery
  • Protection and sustainability measures for compliant registered providers Providers who are genuinely trying to deliver safe, quality supports should not be the ones carrying the heaviest financial and operational burden while others operate with minimal oversight.

We appreciate the opportunity to provide feedback and sincerely hope the concerns of compliant registered providers are genuinely considered as reforms continue.

Kind regards,

Mallory Clarke Annalise Burrows

Respectability Support Services Pty Ltd

ABN:59665599824

NDIS Provider number: 4050168664 Phone 0477 265 018