9th July 2026

Submission to the Senate Community Affairs Legislation Committee
Ensuring NDIS reforms strengthen participant safeguarding and encourage provider
accountability

Submitted by Respectability Support Services Pty Ltd

This submission reflects the practical experiences of three working directors operating a
small, registered NDIS provider in regional New South Wales. It is offered in support of
reforms that strengthen participant safeguarding, improve provider accountability and ensure
the long term sustainability of the National Disability Insurance Scheme.

Respectability Support Services welcomes the opportunity to provide this submission
regarding the implementation of current NDIS reforms.
We are a small, registered NDIS provider based on the Mid North Coast of New South Wales.
We employ 21 local staff and provide supports across community participation, personal care,
in-home supports, capacity building and supported employment. Our organisation is owned
and operated by three working directors who remain actively involved in participant
safeguarding, compliance, governance and the day to day operation of the business.

We wish to begin by making one point very clear.
We support reform.
We support ensuring the NDIS remains financially sustainable.
We support evidence based planning.
We support stronger participant safeguarding.
We support reducing fraud and poor practice.
We support improving provider accountability.

Earlier this year we provided a submission outlining practical suggestions that we believed
could improve the long-term sustainability of the Scheme while continuing to protect
participants and strengthen provider accountability. Our submission focused on identifying
efficiencies before reducing participant supports or introducing reforms that may
unintentionally disadvantage people living with disability.

Our Concern

Our concern today is not with reform itself. Our concern is ensuring that implementation achieves the outcomes Government intends.

Our Concern

Since the announcement of the proposed pricing reforms, particularly the introduction of a pricing differential between registered and unregistered providers for certain supports from January 2027, we have observed a noticeable shift in conversations across the disability sector.

Increasingly, participants, families and providers are discussing how participants may preserve limited NDIS funding by accessing lower cost unregistered providers. We understand why these conversations are occurring.

Many participants are already experiencing tighter funding decisions and families are understandably trying to maximise the supports available within finite budgets. When presented with an opportunity to purchase additional hours of support by selecting a provider charging a lower hourly rate, many participants will naturally consider doing so.

Our concern is that this creates an unintended consequence. Rather than encouraging providers to become registered and operate within stronger quality and safeguarding frameworks, the proposed pricing settings may instead encourage participants to move towards providers operating outside those frameworks.

We do not believe this reflects the intention of the reforms.

Choice and control remains one of the greatest strengths of the NDIS. However, participants should never feel financially pressured to choose between affordability and safeguarding.

Government policy should encourage participants towards providers operating within robust quality and accountability systems not create financial incentives that may unintentionally encourage the opposite.

Why This Matters

This submission is not intended to criticise unregistered providers. Many sole traders and independent support workers provide excellent supports and have built trusted relationships with participants over many years. Our concern is about ensuring all Australians living with disability receive consistent minimum standards of safeguarding when government funding is being used to purchase disability supports.

Registered providers operate within a comprehensive framework that includes certification audits, compliance with the NDIS Practice Standards, worker screening obligations, complaints management, incident reporting, governance systems, quality assurance and continuous improvement.

These requirements are not simply administrative obligations. They exist to protect participants.

As the NDIS continues to mature, we believe the Scheme should increasingly encourage all providers delivering taxpayer funded disability supports to operate within proportionate safeguarding and accountability frameworks appropriate to the level of risk associated with the services they provide.

The disability sector should be no different from other government-funded sectors. Australians rightly expect childcare services, aged care providers, hospitals and education providers to meet recognised quality and safeguarding standards before receiving public funding.

People living with disability deserve the same confidence.

Evidence-Based Planning

We support the move towards stronger evidence based planning. Funding decisions should be fair, transparent and based upon demonstrated functional need. However, we are concerned that many participants and families currently do not have sufficient guidance or support to navigate these changes. Many participants have accessed supports for years without ever requiring formal functional assessments or extensive clinical evidence.

Others live with cognitive impairment, psychosocial disability or intellectual disability and are

simply unable to articulate the full extent of their support needs.

Without appropriate transition arrangements, there is a risk that participants who have genuine support needs may lose access to essential services because they do not understand what evidence is required or how to obtain it.

Reforms should therefore ensure participants have access to appropriate assessment pathways, education and guidance before funding reductions occur.

Registration Alone Will Not Eliminate Fraud We strongly support the Government’s commitment to strengthening provider registration and increasing accountability across the NDIS.

However, we believe registration alone will not eliminate fraudulent or inappropriate claiming.

In our experience, the current audit model is highly effective at assessing whether providers have appropriate policies, procedures and governance systems in place. These are important safeguards and should remain a fundamental component of provider regulation.

However, compliance with policies and procedures does not necessarily demonstrate that services claimed have been genuinely delivered or that public funding has been used appropriately.

We believe there is an opportunity to strengthen both the provider registration and audit process by incorporating proportionate verification measures where credible concerns or identified risks exist. As a significant number of providers transition from unregistered to registered status under the proposed reforms, consideration should be given to applying additional scrutiny where there is a history of substantiated complaints, referrals, intelligence relating to potential fraud, or other indicators of heightened risk.

Our Recommendations

We respectfully recommend that the Committee consider:

• Requiring all new providers entering the NDIS to become registered before accessing government funding.
• Introducing a staged pathway to support existing unregistered providers to become registered over time.
• Ensuring pricing reforms encourage providers to move towards registration rather than creating financial incentives for participants to move away from registered providers.
• Applying consistent minimum safeguarding expectations to all providers delivering government-funded disability supports, with compliance requirements proportionate to the level of risk associated with the supports being delivered.
• Continuing evidence based planning reforms while ensuring participants receive appropriate guidance and access to assessment before funding decisions are reduced.
• Strengthen provider registration and auditing by introducing proportionate, risk based financial verification where appropriate, including the review of service delivery records, rosters, payroll records and financial documentation where concerns regarding fraudulent claiming or misuse of NDIS funding have been identified.

Conclusion

We believe the NNDIS reforms represent an important opportunity to strengthen the long term sustainability, quality and integrity of the Scheme.

Our submission is not intended to resist reform. It is intended to support reform.

We simply ask that implementation carefully considers the behavioural responses these changes may create.

Well intentioned reform should strengthen participant safeguarding, improve accountability and increase public confidence in the Scheme.

It should not unintentionally create incentives that move participants away from the very quality frameworks the reforms seek to strengthen.

We appreciate the opportunity to provide this submission and thank the Committee for considering our observations.

Yours sincerely,

Carina Davey Director

Mallory Clarke Director

Annalise Burrows Director

Respectability Support Services Pty Ltd