Submission 772
Submission to the Senate Community
Affairs Legislation Committee
Inquiry into the National
Disability Insurance Scheme Amendment
(Securing the NDIS for Future Generations) Bill 2026
Submitted by: nib Thrive Pty Ltd
Date: 1 June 2026
Submission 772
Contents
Introduction …………………………………………………………………………………………………………… 3 Overall Position on the Bill ………………………………………………………………………………………. 3 The Role of Intermediaries in a Mature NDIS ……………………………………………………………… 4 Integrity and Fraud Measures ………………………………………………………………………………….. 5 Intermediary and Plan Management Reforms …………………………………………………………….. 6 Planning and Reassessment Reforms ………………………………………………………………………. 8 Sustainability and Market Stewardship ………………………………………………………………………. 8 Conclusion ……………………………………………………………………………………………………………. 8
nib Thrive Pty Ltd | Submission to the Senate Community Affairs Legislation Committee | 2Submission 772
Introduction
nib Thrive Pty Ltd (Thrive Plan Management) welcomes the opportunity to provide a submission to the Senate Community Affairs Legislation Committee regarding the National
Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill
2026 (Cth) (the Bill).
The National Disability Insurance Scheme (NDIS) is one of Australia’s most important social reforms. At its core, the Scheme exists to ensure people with disability can access the supports they need to live with dignity, exercise genuine choice and control, and participate fully in community and economic life.
Thrive Plan Management currently supports around 42,000 participants, processing more than 2.7 million claims in FY25 on behalf of Australians with disability. Through this work and drawing on nib health funds’ more than 70 years of experience supporting Australians to access health care and wellbeing services, Thrive Plan Management has developed significant operational capability in plan management, payment integrity, provider engagement, claims processing, including fraud detection and participant support.
As the NDIS matures, we believe capable and accountable intermediaries can play an increasingly important role in:
- supporting participants to navigate complexity
- strengthening payment integrity
- improving transparency and accountability
- identifying inappropriate claiming and market misconduct, including fraud and waste
- supporting participant safeguards
- contributing to a more stable and sustainable support ecosystem Thrive Plan Management welcomes the Government’s focus on these issues and broadly supports the passage of the Bill.
At the same time, implementation and appropriate transitional arrangements will be critical. Reform should strengthen participant outcomes while maintaining continuity, confidence and stability for people with disability. This will require extensive engagement with the intermediaries’ sector, providers and comprehensive co-design with people with disability, their families and carers.
Overall Position on the Bill
Thrive Plan Management broadly supports the reforms contained within Parts 5 and 6 of the Bill, including measures relating to payment integrity, claim timeframes, registration conditions and strengthened regulation of plan management providers.
Thrive Plan Management supports measures aimed at:
- improving the long-term sustainability of the Scheme
- strengthening fraud and integrity protections
- increasing transparency and accountability
- improving consistency in planning and reassessment processes nib Thrive Pty Ltd | Submission to the Senate Community Affairs Legislation Committee | 3
Submission 772
- supporting a more mature and capable provider and intermediary market The rapid growth of the NDIS over recent years has delivered significant benefits for many Australians with disability. However, it has also created operational complexity, inconsistent participant experiences and, in some cases, opportunities for poor market conduct and inappropriate claiming.
In this context, reforms aimed at strengthening governance, market oversight and payment integrity are appropriate and necessary.
In our view, integrity and sustainability measures should not be viewed as separate from participant outcomes. Fraud, weak oversight and poor market conduct ultimately divert resources away from participants, undermine confidence in the Scheme and reduce its capacity to deliver high-quality supports over the long term.
The challenge moving forward is to curb the rate of cost growth and waste whilst simultaneously working to ensure the Scheme continues to deliver high-quality outcomes for participants in a way that remains sustainable, equitable and trusted by the Australian community.
Thrive Plan Management supports reforms that contribute to that objective.
The Role of Intermediaries in a Mature NDIS
As the NDIS matures, intermediaries such as plan managers will continue to play an important role in supporting participants to navigate an increasingly complex service environment.
High-quality intermediaries can help participants:
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exercise choice and control
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access supports safely and efficiently
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navigate provider markets
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resolve administrative complexity
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engage confidently with the Scheme At the same time, intermediaries can contribute to broader system integrity through:
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payment oversight
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fraud detection
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provider accountability
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data visibility
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administrative consistency In our view, intermediaries should not simply be regarded as administrative functions, but as part of the operational infrastructure that supports participant confidence and market integrity across the Scheme.
Participants benefit when intermediaries are:
- transparent nib Thrive Pty Ltd | Submission to the Senate Community Affairs Legislation Committee | 4
Submission 772
- well-governed
- operationally capable
- accountable for service quality and participant outcomes Financial stability is also important if the sector is to continue investing in technology, operational capability and workforce development that improve participant outcomes over time.
A well-functioning intermediary sector is not only about service provision, but also about market design that ensures people with disability are informed and empowered decision makers on issues that affect their lives.
We note with interest that the structure proposed by the Government aligns closely with independent analysis Thrive Plan Management commissioned in May 2024. The report,
Navigating Towards a More Sustainable and Supportive Market for Disability Services, was
prepared by Dr Angela Jackson and Alistair Webster, and the team at Impact Economics and Policy.
This aligns with broader policy work developed by Dr Angela Jackson examining the long term capability required across Australia’s care and support economy and the market settings required to support participant outcomes, integrity and sustainability. Thrive Plan Management therefore welcomes reforms aimed at strengthening standards, accountability and integrity across the intermediary sector and believes these reforms present an opportunity to build a more mature and capable intermediary market that better supports participants while strengthening public confidence in the Scheme.
Integrity and Fraud Measures
Thrive Plan Management supports the integrity measures contained within Part 5 of the Bill, including amendments relating to claim timeframes under proposed amendments to paragraph 45A(5)(a), as well as strengthened record retention obligations and compliance arrangements.
Public confidence in the Scheme depends on participants, providers and the broader community having confidence that NDIS funding is being used appropriately and transparently.
Fraud and poor market conduct harm participants first. They divert resources away from people with disability, undermine trust in the Scheme and weaken the long-term sustainability of the NDIS.
Thrive Plan Management supports:
- stronger compliance and enforcement powers
- clearer provider obligations
- improved record retention requirements
- greater transparency around payments and claims
- measures that improve oversight and accountability across the ecosystem nib Thrive Pty Ltd | Submission to the Senate Community Affairs Legislation Committee | 5
Submission 772
Large-scale intermediaries with strong governance, reporting and technology capability can play a constructive role in identifying anomalies, inappropriate claiming patterns and emerging market risks.
Thrive Plan Management also supports the proposed deed arrangement framework under the new proposed section 73EA, including requirements relating to verification of supports, integrity systems and claims management processes.
As implementation progresses, it will be important that verification obligations clearly delineate responsibilities between the NDIA, providers and plan managers, and are proportionate to operational risk.
Over time, there may also be opportunities to leverage standardised digital verification systems and platform-based confirmation processes to improve integrity outcomes while minimising duplication, participant delays and unnecessary administrative burden.
Whilst Thrive Plan Management engages with the NDIA on a range of payment integrity measures, there may be opportunities to further strengthen collaboration between Government and intermediaries over time, including in relation to:
- payment integrity
- fraud detection
- market monitoring
- provider oversight
- participant safeguards As implementation progresses, clear guidance and staged transition arrangements will be important to minimise participant disruption and support operational consistency across the market.
Intermediary and Plan Management Reforms
Thrive Plan Management supports the proposed reforms contained within Part 6 of the Bill relating to registered plan management providers, including the proposed registration and conflict management provisions contained within sections 73E, 73EA and 73F.
Participants should have confidence that intermediaries are acting transparently, appropriately and in the participant’s best interests.
Thrive Plan Management also supports reforms that contribute to a more professionalised and accountable plan management market.
We note that stability within the plan management sector will remain important to support continued investment in technology, workforce capability and participant service quality.
Thrive Plan Management supports the policy intent underpinning the proposed new subsection 73E(2B) and new paragraph 73F(2)(k), which seek to strengthen conflict of interest protections and reduce opportunities for collusion and inappropriate claiming within the plan management market.
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Thrive Plan Management recognises these reforms will require significant operational transition across parts of the sector. Appropriate implementation timeframes, transition arrangements and operational guidance will therefore be important to support continuity for participants and enable orderly market adjustment.
We note that Item 101 of the Bill (Transitional – Registered Plan Management Providers) establishes a six-month transition period for registered plan management providers and support the inclusion of transitional arrangements to enable orderly implementation across the sector.
Implementation settings will also be important to ensure reforms strengthen participant outcomes without creating unintended disruption.
In particular:
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transition arrangements should prioritise continuity of support for participants
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implementation timeframes should be operationally achievable
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approval and procurement frameworks should appropriately recognise governance capability, participant safeguards and operational resilience
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participants should receive clear communication and support throughout implementation and transition processes
In assessing future approved providers or panel arrangements, Thrive Plan Management supports the Government’s focus on:
- participant safeguarding capability
- governance and compliance systems
- financial sustainability
- fraud prevention capability
- operational resilience
- regional servicing capability
- technology and reporting capability
- complaints handling and participant support systems Thrive Plan Management notes the proposed amendment to paragraph 45A(5)(a) in Item 89 of the Bill, reducing the statutory claims period from two years to 90 days.
Thrive Plan Management supports the integrity rationale underpinning this amendment, while noting that flexibility within implementation arrangements will remain important where payment delays arise due to circumstances outside provider control, including participant disputes or delayed approvals.
As the Scheme matures, participants will increasingly rely on intermediaries that can provide consistent, transparent and high-quality support within a more regulated operating environment.
The reforms present an opportunity to strengthen the capability and accountability of the intermediary ecosystem while improving participant confidence and market integrity over the long term.
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Planning and Reassessment Reforms
Thrive Plan Management broadly supports reforms aimed at improving consistency, clarity and transparency within planning and reassessment processes.
As reforms are implemented, it will be important to ensure administrative complexity does not unintentionally create barriers for participants or reduce confidence in the Scheme. Plan managers can play a constructive role in supporting participants through these changes.
Sustainability and Market Stewardship
Long-term sustainability is essential to ensuring people with disability can continue to access high-quality supports into the future.
A sustainable NDIS requires:
- strong integrity settings
- effective market stewardship
- capable providers and intermediaries
- stable operating settings
- transparent and accountable governance arrangements Sustainable participant outcomes also depend on a sustainable provider and intermediary ecosystem.
Stable and predictable market settings support investment in:
- workforce capability
- technology and systems
- compliance and safeguarding
- participant service quality
- regional and thin market servicing Government, the NDIA, providers and intermediaries all have a role to play in supporting a mature, sustainable and participant-focused NDIS.
Thrive Plan Management supports ongoing collaboration across the sector to strengthen participant outcomes while ensuring the long-term viability and integrity of the Scheme.
Conclusion
The reforms contained within the Bill present an important opportunity to strengthen the long-term sustainability, integrity and effectiveness of the NDIS while improving outcomes and confidence for participants.
People with disability deserve a Scheme that is transparent, sustainable, well-governed and capable of delivering high-quality supports over the long term. All Australians deserve to have confidence that taxpayer money is being used as efficiently as possible.
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As the NDIS continues to mature, capable and accountable intermediaries can play an important role in supporting participant confidence, safeguarding public resources and strengthening market integrity.
Thrive Plan Management stands ready to work constructively with Government, the NDIA and the broader sector to support implementation of reforms that deliver a stronger, safer and more sustainable NDIS for Australians with disability.
Thrive Plan Management supports passage of the Bill and encourages ongoing consultation regarding implementation, transitional arrangements and operational guidance.
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