Submission 750 - Supplementary Submission
SUBMISSION TO THE SENATE COMMUNITY AFFAIRS
LEGISLATION COMMITTEE
National Disability Insurance Scheme Amendment (Securing the NDIS for
Future Generations) Bill 2026
Senate Community Affairs Legislation Committee
Submission 2 of 5: Workforce Integrity, Competency-Based Pricing, and a Verified
Service Delivery System
Submitted by: Independence & Beyond Support Services (IBSS)
ACN: 658 366 360
Contact: ibss.qld@gmail.com
Phone: Not provided
Address: [Address] Date: 1 June 2026 Submission type: NDIS provider — unregistered Confidentiality: Non-confidential — the submitter consents to publication Related submissions: This is one of five complementary submissions made by Independence & Beyond Support Services (IBSS) to this inquiry. Each submission addresses distinct provisions of the Bill. A covering letter introducing the suite has been lodged separately.
- Purpose of this Submission This submission addresses the following provisions of the Bill:
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Schedule 2 provisions expanding mandatory provider registration and enrolment requirements;
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provisions strengthening NDIA monitoring, investigation and civil penalty powers; and
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the stated policy objective of reducing fraud, overpayment and non-compliant service delivery.
Executive Summary
The Bill’s worker registration provisions address one dimension of the NDIS workforce integrity problem — the identity of who enters the sector. They do not address the second dimension — what workers deliver once they are in it — or the third — whether what they are billing reflects what they are actually qualified to provide. This submission proposes two complementary measures that address those gaps directly: a tiered competency register connecting verified specialist experience to billing rate eligibility for participants with ASD Level 2 and Level 3; and a technology-based
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verified service delivery record system linked to the NDIS invoicing process. Both are grounded in the Bill’s existing registration and pricing provisions and require no new legislative framework.
This submission does not oppose the registration and integrity provisions of the Bill. It submits that those provisions, while necessary, address only the first dimension of the problem. The second and third dimensions — service content and competency-to-billing alignment — require the measures proposed here.
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Worker Registration Addresses Identity, Not Service Content The Bill’s expanded registration and enrolment provisions create an identity gate — screening
who enters the sector through criminal history checks, identity verification and basic
compliance requirements. This is a necessary and overdue improvement to scheme integrity.
However, registration does not — and cannot — address what happens once a worker is inside the scheme. The current framework contains no mechanism to verify that a support worker who invoices three hours of community access under a participant’s plan actually delivered three hours of genuine, goal-directed developmental support during that time.
NDIS Quarterly Report data for the June 2025 quarter confirms that only 7 per cent of participants have their plans managed entirely by the NDIA, while 66 per cent use a plan manager and 27 per cent self-manage. For the 93 per cent of participants outside direct Agency management, the service engagement is a market transaction between a family and a provider — with no mandatory record of what was delivered, no verified connection between the service code on an invoice and the activity that actually occurred, and no longitudinal audit trail of participant outcomes against plan goals.
In this environment, an independent worker with minimal training can invoice for skilled developmental support while delivering a beach walk, a family grocery run, or a recreational outing with no therapeutic or developmental content. Neither the family, the plan manager, nor the NDIA has any systematic mechanism to distinguish genuine skill-building support from activity that does not constitute a reasonable and necessary NDIS support. Registration does not close this gap. It is a different gap entirely.
The integrity risk is not evenly distributed across the three management types. For the 7 per cent of participants whose plans are managed directly by the NDIA, the Agency has the greatest direct oversight — the gap here is smallest. For the 66 per cent using a plan manager, the plan manager receives and approves invoices but has no visibility over what actually occurred during the session — they are approving a code and a timestamp, not a verified account of service delivery. For the 27 per cent who self-manage, there is no intermediary at all — the family approves their own invoices with no independent oversight whatsoever. This is where the integrity risk is highest, where the financial incentive for non-compliant billing is greatest, and where participants with complex support needs are most exposed. The verified service delivery system proposed in Section 5 is designed specifically around this structure — addressing each management tier differently, closing the oversight gap that registration alone cannot reach.
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The Pricing and Qualification Transparency Problem The NDIS Pricing Arrangements and Price Limits 2025–26 set a maximum billable rate of approximately $70 per hour for community access support. The SCHADS Award rate for support workers ranges from approximately $31 to $44 per hour. For registered, compliant
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providers the gap represents legitimate overhead — insurance, supervision, training,administration and organisational infrastructure. For independent workers operating outside formal employment structures, that gap is effectively unaccounted for with no requirement that it be spent on any quality-related purpose.
Critically, the pricing system does not distinguish between an experienced, specialist-trained
worker with a documented history of supporting participants with complex autismpresentations and a worker with a recently completed online Certificate III, no specialist training, and no verified hours in the field. Both bill at the same rate. Both are invisible to the system in terms of quality and competency once their screening clearance is obtained.
For participants with ASD Level 2 and Level 3, this is not a pricing abstraction. It means a
participant whose safety, regulation and developmental progress depends on skilled,experienced, behaviourally-informed support is just as likely — more likely, given the volume of independent workers entering the market — to be supported by someone who has never worked with this cohort and entered the sector because the billing rate far exceeds other entry level work. The Bill’s registration provisions do not change this. A worker is screened once at the point of entry. Nothing in the Bill creates any connection between what the worker knows, what they have demonstrated, and what they are permitted to bill.
- A Tiered Competency Register: Connecting Verified Experience to
Billing Rate Eligibility
This submission proposes that the Bill’s registration framework be extended to create a tiered competency register connecting a worker’s verified specialist experience and training to their billing rate eligibility. This is not a proposal to change the SCHADS Award — wage rates are a matter for the Fair Work Commission and fall outside the scope of this Bill. It is a proposal to change what providers and independent workers are permitted to bill to participant plans based on demonstrated competency — which is squarely within the Bill’s registration and pricing provisions.
The mechanism would operate as follows. All workers entering the sector would be registered at a standard tier, eligible to bill at the base community access rate. Workers seeking to bill at the full community participation rate for participants with ASD Level 2 and Level 3 — a cohort whose support requirements are substantially more complex than general disability support — would be required to demonstrate:
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a minimum number of verified hours of community access support delivered specifically to participants with ASD Level 2 and Level 3, as recorded through the verified service delivery system described in Section 5;
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completion of recognised specialist autism training at a minimum standard defined by the NDIA in consultation with the Autism CRC and specialist providers; and
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a clean incident record within the scheme’s worker screening and compliance system. Workers meeting these criteria are registered at a specialist tier and eligible to bill at the full rate for this cohort. Workers who do not are eligible to bill at a reduced rate — reflecting the lower complexity of support they are qualified to deliver — until they accumulate verified specialist hours and training. This creates a direct financial incentive for workers to develop genuine specialist competency, rather than entering the market and billing at the maximum rate regardless of experience.
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This addresses a structural problem the Bill’s current registration provisions do not touch: the absence of any quality or competency gate in the billing rate. Registration creates a floor — it confirms a worker is not disqualified from the sector. A tiered competency register creates a ceiling — it confirms a worker has earned the right to bill at a rate that reflects the complexity and risk of the support they are providing.
This is not a novel mechanism. Allied health billing rates under the NDIS already reflect qualification levels — a specialist practitioner bills at a higher rate than a graduate generalist.
The same logic applies to disability support work. The absence of any competencydifferentiation in current support worker billing rates is not a principled policy position. It is a gap in the framework that the Bill’s registration provisions are well-placed to address.
For participants with ASD Level 2 and Level 3 — who cannot easily communicate distress, who may be harmed by a worker’s failure to recognise a trigger, and whose developmental progress depends on workers who understand their specific functional profile — the question of whether the person billing for their support has any demonstrated competency with this cohort is a safety and quality issue. The Bill should treat it as one.
- A Verified Service Delivery System: Proposal and Design This submission proposes that the Committee recommend development and mandated adoption of a verified service delivery record system for community participation and daily living supports delivered by independent and unregistered providers. The system would operate as follows.
5.1 Session verification At the commencement of each support session the worker confirms attendance via a purpose built application using GPS location verification and biometric confirmation linked to their NDIS worker screening clearance identity. The participant’s family or nominee receives an automatic real-time notification that a session has commenced against the participant’s plan.
At randomised intervals during the session the worker receives unpredictable prompts requiring situational responses — brief structured observations about the participant’s current activity, engagement or response — that cannot be pre-fabricated by a worker who is not present. These prompts are drawn from the participant’s current plan goals and vary progressively as goals are achieved, preventing recycling of generic responses.
5.2 Family sign-off and plan manager visibility The completed session record is pushed to the family or nominee for digital sign-off before an invoice can be generated. Sign-off confirms the session occurred but does not override the verification chain — GPS timestamps, biometric check-in, randomised mid-session responses and structured notes form an independent corroborating record visible to the plan manager and, on audit, to the NDIA. The participant’s plan manager receives an automated weekly summary of all sessions, invoices and goal progress, creating a second layer of oversight independent of the family.
5.3 Invoice generation and code verification On family sign-off the invoice is automatically generated using the correct NDIS support item code, pre-populated with verified hours, GPS-confirmed location, activity type and goal references. The invoice cannot be generated for hours exceeding the verified checkout timestamp. The system displays the current NDIS price limit for the selected service code at
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the point of session creation and requires explicit acknowledgement if a self-managed rate exceeds the applicable price limit.
5.4 Longitudinal progress and anomaly detection The system maintains a longitudinal record of participant progress against plan goals across all workers and sessions. Where goals show no measurable progress over an extended period despite regular sessions, the system flags the record for plan review. Automated anomaly detection identifies patterns inconsistent with genuine service delivery: GPS data not matching the claimed activity location, session note responses statistically identical across multiple sessions, billing patterns inconsistent with plan goals. These are flagged for plan manager and NDIA review without requiring a formal complaint.
5.5 Worker professional record and competency pathway Each worker’s verified session data builds a portable professional record — hours completed by support category, participant cohort, goal areas worked in, progress contributions and incident management history. This record is the mechanism through which workers accumulate the verified specialist hours required for progression to the specialist billing tier described in Section 4. It transforms disability support work from an entry-level role with no professional visibility into a skilled vocation with a documented and rewarded career trajectory. A worker with five hundred verified hours of complex autism community access support, demonstrated goal progress and a clean incident record is a measurably different proposition from a worker with equivalent hours of undifferentiated activity. For the first time, that distinction is visible.
- Why the Bill’s Registration Provisions Alone Cannot Achieve These
Outcomes
The Bill’s expanded registration requirements will improve identity accountability and raise the compliance floor. This submission supports those provisions. However, registration is a point-in-time gate. It confirms a worker met a minimum standard at the point of entry. It does not confirm what that worker delivers on any given afternoon in a shopping centre with a non verbal participant experiencing sensory overload.
The integrity problem the Bill identifies — fraud, overpayment and non-compliant service delivery — is primarily a service content problem, not an identity problem. Solving only the identity problem leaves the scheme vulnerable to the service content fraud, quality failure and systematic mismatch between billing rates and demonstrated competency that currently characterises community participation support delivery for participants with the most complex needs.
A verified service delivery system and a tiered competency register address the second and third dimensions of the problem directly, at a fraction of the cost of the investigative and penalty infrastructure required to pursue non-compliance after the fact.
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Recommendations This submission respectfully recommends that the Committee:
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Recognise that the Bill’s registration and enrolment provisions address identity accountability but do not address service content accountability or competency-to billing alignment — and that all three are required to achieve the Bill’s stated integrity objectives.
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Recommend that the Bill’s registration framework be extended to create a tiered competency register for community participation support workers, distinguishing between a standard tier eligible to bill at a base rate and a specialist tier eligible to bill at the full rate for participants with ASD Level 2 and Level 3, based on verified specialist hours, recognised autism training, and a clean compliance record.
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Recommend that the Government develop and mandate a verified service delivery record system for community participation and daily living supports, linked to the NDIS invoicing and claiming process, as a complementary integrity measure to the registration provisions in the Bill.
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Recommend that any such system incorporate GPS session verification, biometric worker identification linked to screening clearance records, goal-referenced structured session notes, family sign-off, automated anomaly detection, and a portable worker professional record forming the basis for specialist tier progression.
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Recommend that the system display applicable NDIS price limits at the point of session creation to improve pricing transparency for self-managed and plan-managed participants engaging independent workers.
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Recommend that the Government commission a feasibility study and prototype development process in consultation with providers, families, participants, the Autism CRC and technology developers, with a view to mandated implementation within a defined timeframe.
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Conclusion The NDIS workforce integrity problem has three dimensions. The first is who is in the sector — which the Bill’s registration provisions address. The second is what they do once they are in it — which no current provision addresses. The third is whether what they are billing reflects what they are actually qualified to deliver — which no current provision addresses either.
Solving only the first problem leaves the scheme vulnerable to service content fraud, quality failure and the systematic mismatch between billing rates and demonstrated competency that currently disadvantages participants with the most complex support needs. The two measures proposed in this submission address the second and third dimensions directly. They are not alternatives to registration. They are its necessary complement.
Together, they provide the foundation for transforming disability support work from an undifferentiated entry-level job into a skilled, documented, accountable profession — one in which genuine expertise with complex participants is visible, rewarded and verifiable. That transformation is in the long-term interest of participants, families, the workforce, and the scheme.
Thank you for considering this submission.
Authorised by:
The Directors
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Submission 750 - Supplementary Submission
Independence & Beyond Support Services (IBSS)
Date: 1 June 2026
References
NDIA (June 2025). NDIS Quarterly Report Q4 2024–25. National Disability Insurance Agency. Available at: https://www.ndis.gov.au/media/7950/download
NDIA (2025). NDIS Pricing Arrangements and Price Limits 2025–26. National Disability Insurance
Agency. Available at: https://www.ndis.gov.au/providers/pricing-arrangements
Autism CRC (2023). National Guideline for supporting the learning, participation and wellbeing of autistic children and their families in Australia (2nd ed.). NHMRC-approved. Available at: https://www.autismcrc.com.au/best-practice
Centres for Medicare and Medicaid Services (United States). Electronic Visit Verification: Overview
and Requirements. Available at: https://www.medicaid.gov/medicaid/home-community-based-services/electronic-visit-verification [Precedent for mandatory verified service delivery in equivalent government-funded care programs]
Department of Health, Disability and Ageing (May 2026). NDIS Amendment (Securing the NDIS for
Future Generations) Bill 2026 — Fact Sheet. Available at:https://www.health.gov.au/securingtheNDIS
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill
2026 (Cth), introduced 14 May 2026. Available at:https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Community_Affairs/ND ISFutureGenBill
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