Addressing administrative burden and financial anxiety in NDIS self-management (Family or carer experience)

Submission 833

The National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026

Parliamentary Submission

SUBMITTED BY

Founder, Ability8

About the Submitter

Lived Experience as a Parent and Carer

brings lived experience as a carer for his daughter, , who was born with multiple severe physical and intellectual disabilities needing 24 hour care. Over more than two decades, and his family have worked closely with a wide network of participants, families, support workers, carers, allied health professionals, teachers, service providers and medical specialists. This experience has given first-hand insight into the complexity of coordinating care, sharing sensitive information safely, and building trust with every person involved in a participant’s support network. It is this lived experience that sits at the heart of Ability8, ensuring the platform is designed around the real needs of participants, families, and carers.

Ability8 is an all-in-one NDIS self-management app that centralises care management, fund tracking, invoice management, staff coordination, and care planning in a single secure platform. It supports sharing and communication with family members, carers, and support workers, and includes advanced payroll features such as Single Touch Payroll for ABN and WPN holders, Pay Day Super, and Beam Clearing House integration — all accessible from anywhere.

Business and Technology Background

has established and grown three businesses in the telecommunications sector, including ventures that have developed sophisticated corporate and government software solutions for telecoms and data billing (Defence Dept, Victora Govt and numerous Universities). He brings more than 30 years’ experience founding, building, and managing successful businesses in Australia. This combination of lived experience and technology expertise positions to identify both the practical barriers facing self-managing participants and the technical solutions that can address them.

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Submission 833

NDIS Self-Management and Direct Employment: A Case for Policy Reform and Better Guidance

Submission to Parliament on Supporting Participants and Families in NDIS Self-Management by Ability8

Executive Summary

Self-managed NDIS participants represent the most efficient use of funding, yet uptake remains limited due to lack of government guidance on direct employment practices. This submission outlines the problems with current NDIS pricing models, the barriers to direct employment, and proposes a coordinated government approach to unlock significant cost savings and better outcomes for participants, families, and the NDIS system as a whole. It also demonstrates how digital tools like Ability8 can enable efficient self-management when proper government frameworks are in place.

Critically, this submission addresses a recent and urgent problem: recent system changes— including the transition to the PACE claims system and the introduction of complex multi threshold spending limits in November 2025—have dramatically increased the administrative burden on self-managing participants. What used to take 5-6 minutes now takes 20-24 minutes. Families managing complex disabilities now face 2-3 times the administrative work. These changes have directly undermined the efficiency argument for self-management. Additionally, the absence of API integration between self management tools and the NDIS platform forces duplicate manual data entry, multiplying the burden further. This submission proposes solutions including simplifying threshold design, implementing PACE claim batching for categories, and opening API access to government systems (similar to service provider api access).

Beyond these technical barriers, the submission also identifies a critical psychological barrier: financial anxiety. Capable families who want self-management abandon it because managing substantial sums of money creates fear of making mistakes, worry about audit liability, and stress about compliance complexity. They pay additional fees to hire accountants or use Plan Management instead, losing choice and system efficiency. This submission demonstrates how digital tools like Ability8 eliminate financial anxiety by automating record-keeping, ensuring compliance, and giving families confidence in their financial accuracy and legal standing.

The implementation of the Securing the NDIS for Future Generations Bill 2026 introduces substantial change to the Scheme and places significant new responsibilities on self managing participants; this submission supports the intent of those reforms, while going further by identifying practical weaknesses in the current design and proposing measures to make self-management more efficient, accessible, and sustainable.

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Executive Summary 2

Expected Outcomes and Recommendations

Implementation of this coordinated approach, supported by digital tools, will deliver significant benefits:

• For Participants and Families: Greater choice and control. More efficient use of NDIS budgets. Confidence to directly employ without fear of legal or tax complications. Dramatically reduced administrative burden. Recognition that unpaid care work is supported by better systems.

• For the NDIS: Significant cost savings through increased uptake of self-management and direct employment—the most efficient use of funds. Plans right-sized for actual service costs rather than inflated service provider overhead. Cleaner, faster audit processes with standardised digital tools. Reliable data for planning and resource allocation.

• For Support Workers: Fair and transparent employment practices. Direct relationships with participants. Clear understanding of wages, conditions, and rights.

• For the System: Reduced reliance on intermediaries. More efficient allocation of NDIS funding. Better outcomes across the ecosystem. A model and platform that scales to aged care, Thriving Kids, and other support schemes.

The Path Forward—Six Critical Actions

• Resolve System Failures: The PACE claims system must be reformed to restore batching. Spending thresholds should be simplified from tracking 17 possible simultaneous spending windows per plan.

• Unlock API Access: Enable digital platforms like Ability8 to integrate with NDIS, ATO, and Fair Work systems, eliminating duplicate data entry and speeding submission from 20-24 minutes to 30 seconds per invoice batch or wages processing.

• Establish Inter-Agency Coordination: Government agencies must work together on communicating an agreed standard documentation around employment rates, Awards, tax obligations, and compliance. Currently, families receive conflicting advice.

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• Resolve the WPN Crisis: The MyID changes prevent Single Touch Payroll submission from 1 July 2026 for WPN holders, forcing regression to manual tax reporting. This must be resolved as priority.

• Support Digital Tools: Recognise platforms like Ability8 as compliant record-keeping systems that help participants meet both ATO Pay Day Super and NDIS Amendment Bill 2026 requirements.

• Monitor and Evaluate: Track uptake of direct employment, cost savings, participant satisfaction, and system efficiency gains following implementation.

These actions are achievable within 6-12 months and will transform self-management into a mainstream, efficient model. The cost of inaction far exceeds the investment required to implement these solutions.

See detailed recommendations and summary on pages 24 to 26.

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1. The Problem: Confusion and Cost Inefficiency 7 1.1 Current Pricing Misalignment 7

1.2 The Guidance Gap: No Clear Employment Framework 7

1.3 The Hidden Cost: Unpaid Family Labour 7

Financial Anxiety as a Hidden Barrier to Self-Management 8

1.4 Inter-Agency Communication Failures 9

1.5 System Changes and Administrative Explosion: The PACE System and Complex

Thresholds 9

The PACE System Change: From Batched to Individual Claims 9

Complex Spending Thresholds: Monitoring Multiple Timescales Simultaneously 11

The API Gap: Manual Data Entry as a Policy Failure 12

The Hidden Cost of Invoice Complexity: Data Integrity and Systemic Distortion 12

Solution 1: Temporal Distribution 13

Solution 2: Sequential Depletion 13

Solution 3: Detailed Entry 13

The Problem: These “Solutions” Create Systemic Data Corruption 13

For Participants and Families: 13

For the NDIS: 13

For System Planning and Equity: 13

The Root Cause: System Design, Not User Failure 14

The Solution: Remove the Complexity at Source 14

Why This Matters for the NDIS Bill 2026 14

2. The Impact: Lost Efficiency and Missed Savings 15
3. The Solution: Coordinated Government Action 15 3.1 Establish an Inter-Agency Working Group 15

3.2 Develop a ‘Self-Management Roadmap’ for Participants 16

3.3 Revise NDIS Pricing Guidance for Self-Managers 16

3.4 Fix the WPN and Single Touch Payroll Issue 17

4. The Role of Digital Tools: Ability8 as an Enabler 18 4.1 What is Ability8? 18

4.2 Core Features and How They Address the Problem 18

4.2.1 Centralised Data Management 18

4.2.2 Data Control and Privacy: Participant-Led Permissions 18

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4.2.3 Circle of Support and Shared Responsibility 19

4.2.4 Cross-Platform and Cross-Scheme Portability 19

4.2.5 Payroll and Tax Integration 19

4.2.6 Claims and Fund Tracking 20

4.3 The Time Savings Benefit 20

4.4 Standardisation and Industry Best Practice 20

4.5 API Integration with Government Systems 21

4.7 Alignment with NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 21

Record Retention and Compliance (Schedule 2, Part 4) 21

Reducing Claim Times (Schedule 2, Part 5) 22

Fraud Prevention and Verification (Schedule 2, Parts 1-3) 22

Automation of Administrative Actions (Schedule 3, Part 2) 23

Support Linking to Impairment Verification (Schedule 1, Parts 3 & 6) 23

Plan Renewal and Fund Management (Schedule 1, Part 5) 23

4.6 What Ability8 Does NOT Do 24

5. Expected Outcomes and Benefits 24
6. Recommendations 25
7. Conclusion 27 31 May, 2026 Ability8 Submission 6

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1. The Problem: Confusion and Cost Inefficiency

1.1 Current Pricing Misalignment

The NDIS price book is designed for service providers, not for families engaging staff in the direct employment model. This creates a fundamental misalignment between the pricing guidance available, and the costs faced by self-managing participants:

• Service providers have built-in overhead costs: facility maintenance, team building, management layers, administration, insurance, and compliance

• The NDIS cost model reflects these service provider overheads, pricing care work at the top end of the market scale

• Self-managing families and participants engaging in direct employment do not incur these overhead costs

• Without proper guidance, families default to NDIS price book rates, leading to overpayment and inefficient use of NDIS funding

1.2 The Guidance Gap: No Clear Employment Framework

Families choosing to directly employ support workers often have no business or HR background. They lack guidance on:

• Fair and appropriate wage rates for direct employment (beyond the arbitrary service provider benchmarks)

• Employment law and compliance requirements

• Tax obligations and ABN or WPN number administration

• Superannuation, insurance, and payroll responsibilities

• Bookkeeping, accounting, and legal considerations

• How to structure fair employment contracts This information gap forces families to either hire through expensive service providers or navigate employment law without adequate support—many choose to avoid direct employment altogether, limiting their choice and control. Note: The WPN (Withholding Payment Number) is similar to an ABN from the Australian Tax Office, the difference being it is specifically designed for non-commercial, non- company based employment of staff, yet still allows the entity to withhold the PAYG tax due and submit to the ATO, without the other ABN company based tax and legal responsibilities.

1.3 The Hidden Cost: Unpaid Family Labour

An often-overlooked reality in self-management is that families bear the entire administrative and compliance burden unpaid. Participants, parents, nominees, and caregivers must:

• Track invoices, receipts, and claims across multiple systems
• Manage payroll, tax reporting, and superannuation contributions
• Maintain compliance records for audits
• Coordinate rosters and staff communications 31 May, 2026 Ability8 Submission 7

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• Navigate multiple government agencies and their requirements
• Keep spreadsheets, notepads, and fragmented records All of this is done without payment, training or formal recognition. For families already stretched thin by caring responsibilities, this administrative burden often makes self management feel impossible. Time spent on paperwork is time not spent with the person they care for or on their own wellbeing. Every hour saved on administration is an hour returned to the family.

Financial Anxiety as a Hidden Barrier to Self-Management Beyond the sheer time burden, many families experience significant financial anxiety and stress when managing NDIS money. This psychological barrier is often unspoken but is a primary reason families abandon self-management despite wanting the choice and control it offers.

The sources of financial anxiety include:

• Fear of making financial mistakes: Without clear guidance or a trusted system, families worry they will make errors in tracking spending, miss compliance requirements, or be held personally liable for mistakes. The prospect of owing money back to the NDIS creates genuine anxiety.

• Lack of confidence in financial record-keeping: For many family members, managing substantial sums of money on behalf of another person feels daunting, especially when they lack financial or business background. The responsibility feels overwhelming.

• Uncertainty about audit vulnerability: Families know that NDIS participants can be audited, and worry that fragmented records, honest mistakes, or missing documentation will result in demands to repay funds—particularly with the new 2026 Bill’s emphasis on record retention and compliance.

• Stress from complexity: The combination of multiple invoices, category allocations, threshold tracking, and payroll management creates genuine cognitive and emotional burden. Some families simply decide the stress is not worth it, even if they could technically manage it.

Real-world outcome: Capable families who want self-management abandon it. They hire accountants or switch to Plan Management, paying additional fees despite understanding that self-management would give them more choice and better budget efficiency. The stress relief of outsourcing the work is worth the cost to them. This represents lost choice, lost autonomy, and lost system efficiency.

This is precisely where digital tools like Ability8 provide exceptional value. By automating financial management, providing clear audit trails, offering transparent records, and giving families confidence that their financial administration is correct and compliant, tools like Ability8 eliminate the source of the anxiety. When a family can see that all their records are accurate, timestamped, and organised—and that the system automatically checks for compliance—they can confidently self-manage.

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1.4 Inter-Agency Communication Failures

Government agencies responsible for NDIS, taxation, and employment law do not effectively communicate with each other or with self-managing participants. Examples of this breakdown:

• The ATO (Australian Taxation Office) staff do not understand WPN numbers; many advise participants to obtain ABN numbers instead

• Recent identity management changes have made it impossible from 1 July 2026, for WPN holders to electronically submit Single Touch Payroll (STP), forcing a regression to manual reporting and paper based ATO Payments Summaries (old Group

Certificates)

• This contradicts the government’s aim to automate the tax system

• Fair Work Australia, NDIS, and ATO operate in silos with no coordinated guidance for direct employers

• Participants receive conflicting advice depending on which agency they contact and in some cases within the same agency

• ATO staff attending self-management webinars often lack understanding of WPN holders and self-direction, conflating it with gig economy work

1.5 System Changes and Administrative Explosion: The PACE System and

Complex Thresholds

Recent system changes have dramatically increased the administrative burden on self managing participants in ways that directly undermine the efficiency argument for self management. These changes represent a critical blind spot in NDIS policy implementation and must be addressed urgently.

The PACE System Change: From Batched to Individual Claims

When the NDIS transitioned to the PACE CRM/Participant system, a critical functionality was lost: the ability to batch multiple invoices with multiple cost categories into a single claim. This represents a fundamental step backward in user experience for self-managers.

Under the old system:

• Two invoices received, each containing two or three support categories (e.g., personal care, community access, therapy)

• The Ability8 app automatically collated these into ONE claim with the categories properly separated

• Claim submission took 5-6 minutes per invoice batch, where a batch could be 2 to 4 invoices

Under the PACE system:

• Each support category must be submitted as a separate claim (the system no longer accepts batches with multiple categories)

• Two invoices with two categories each = four separate claims instead of one 31 May, 2026 Ability8 Submission 9

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• Claim submission now takes 20-24 minutes—four times longer The mathematical, human impact and risk of errors of this change is severe. For participants with complex disabilities who have multiple support categories and multiple invoices per week, this system change has multiplied the administrative burden 2-3 times. A family spending 10 minutes per week on claims now spends 40-70 minutes. For participants already stretched managing care responsibilities, this is an additional 2-3 hours of unpaid administrative work per month.

What is particularly problematic about this design is the inefficiency it creates for both self managers and the NDIS. Self-managers must now:

• Receive a properly formatted invoice from a support worker or provider (e.g., one invoice containing personal care, community access, and therapy costs together)

• De-construct that invoice by manually splitting it into separate components

• Submit each component as a separate claim through the NDIS portal, with a copy of the same invoice attached to each claim as evidence

• Meanwhile, the NDIS system receives these four separate claims (with 4 copies of the same invoice) and must re-construct them to understand they all came from a single invoice

This is a profound system design failure. The invoice enters the system properly structured, gets manually torn apart by a family member, submitted in fragments, and then reconstructed on the NDIS side. Everyone does extra work. Nobody benefits. It is the definition of waste. How long would a commercial business survive with this process!

This problem has a straightforward technical solution: an API (Application Programming Interface or application to application communications). With NDIS API access, Ability8 (or similar platforms) could accept the invoice in its original, proper format, automatically handle the de-construction and submission of separate claims, and push everything to the NDIS portal with a single button. The time saved would be immense—from 20-24 minutes down to 30 seconds per invoice batch, an efficiency improvement of nearly 98%! The NDIS would receive properly formatted, standardised claims with no manual re-construction needed. This is automation that serves everyone: families get their time back, support workers can submit invoices in a natural way, the system operates efficiently, and the NDIS receives clean data.

NDIS API integration already exists in the Service Provider and Plan Management spaces, these businesses would not survive if manual processing of invoices like a self-manager was the only option.

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Submission 833

Complex Spending Thresholds: Monitoring Multiple Timescales Simultaneously

In November 2025, the NDIS began applying spending thresholds to new plans with a critical flaw: these thresholds are not uniform within a single plan. This creates an unprecedented level of complexity for self-managers.

Within a single 12-month plan, a self-manager must now track spending against four different time periods depending on the support category:

• Annual threshold categories: Can spend the full annual amount across all 12 months

• Quarterly threshold categories: Annual budget must be divided by 4; can only spend 1/4 per quarter

• Monthly threshold categories: Annual budget must be divided by 12; can only spend 1/12 per month

• Carried over unspent funds from previous periods which dynamically changes funds available in remaining periods

Example of administration complexity within a single plan:

• Personal care support: Annual threshold—self-manager monitors against a single annual limit

• Community access: Quarterly threshold—self-manager must divide annual budget by 4, track spending for Q1, Q2, Q3, Q4 separately

• Therapy services: Monthly threshold—self-manager must divide annual budget by 12, track spending against 12 different monthly limits

• Adjust future period thresholds to understand available funds remaining The mathematical result: Within a single plan, a self-manager is simultaneously tracking 1 annual period + 4 quarterly periods + 12 monthly periods = 17 different spending windows. The unpaid administrative work required to manage this is substantial and often invisible to policymakers.

This administrative complexity is directly compounded by the PACE system changes. Each submission into a new spending period requires a separate claim (or multiple claims if there are multiple categories).

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Submission 833

The API Gap: Manual Data Entry as a Policy Failure

The PACE and threshold problems would be significantly mitigated if self-managers could automate claim submissions via API integration. However, no such integration exists. This represents a fundamental gap in the NDIS technology strategy.

Current workflow for Ability8 users:

• All invoice and payroll data is entered once into Ability8

• Data must be extracted/exported and manually re-entered into the NDIS self- management portal

• Each support category on each invoice must be submitted as a separate claim

• All claims must be submitted through the NDIS portal manually, one at a time This duplication of data entry is not just inconvenient—it violates basic principles of efficient systems design and wastes time and money across the entire ecosystem. Digital tools like Ability8 can solve the problem if given API access to the NDIS platform. With NDIS API integration, claims could be submitted directly from Ability8 with a single click, eliminating the manual re-entry entirely.

The time and money savings with API access would be immense and benefit all stakeholders:

• For families: 20-24 minutes per invoice submission reduced to 30 seconds. For a family with two invoices per week, that is 80-96 minutes saved per week, or 350+ hours per year. This is time returned to care, family wellbeing, and employment.

• For support workers and invoicing providers: They submit invoices once in their natural format and never have to manually de-construct them. No more confusion about claim format or payment delays due to submission errors.

• For the NDIS: Elimination of duplicated processing work (no need to reconstruct claims from fragments). Claims arrive in standardised, properly formatted structure. System processing becomes more efficient, errors reduce, and staff time is freed for higher-value work like plan review and support to complex cases.

The absence of API access is not a technical limitation—it is a policy choice. The government has chosen to keep the NDIS portal isolated, forcing manual workarounds that place the entire administrative burden on families while creating unnecessary processing work for the NDIS itself. This contradicts both the stated goal of making self-management attractive and sustainable, and the government’s objective to create efficient, streamlined public services.

The Hidden Cost of Invoice Complexity: Data Integrity and Systemic Distortion

When self-managers face the complexity of splitting invoices across multiple categories and submitting separate claims for each one, they naturally seek workarounds to reduce administrative burden. Research and user feedback reveal three common “solutions” that participants adopt:

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Solution 1: Temporal Distribution

Rather than split a single invoice across multiple categories, participants assign the entire invoice to one funding category. When the next invoice arrives from the same provider, they assign it to a different category. Over the course of a year, with multiple invoices, costs are distributed across categories—but arbitrarily, based on invoice timing rather than actual support delivered.

Solution 2: Sequential Depletion

Participants select one category and draw funds from it until the annual allocation is completely exhausted. They then move to the next category and repeat. This continues through all categories. While administratively simpler, the spending pattern bears no relationship to actual service delivery or participant needs.

Solution 3: Detailed Entry

Participants spend the extra time to correctly split invoices and submit multiple claims per invoice, accurately reflecting the true cost allocation across support categories.

The Problem: These “Solutions” Create Systemic Data Corruption

While these workarounds ease the administrative burden for individual families in the short term, they create serious problems for the entire NDIS ecosystem:

For Participants and Families:

• Inaccurate spending data means their own plans are based on false information

• When plans are renewed, the NDIS uses distorted spending patterns to allocate future funding

• Participants may receive inadequate funding for categories they actually need, while other categories remain over-funded

• Plans do not reflect true support needs For the NDIS:

• Spending data collected from self-managing participants becomes unreliable

• Category-level spending patterns are distorted across the participant population

• Statistical analysis of where funds flow and which supports are actually needed becomes meaningless

• Future pricing and funding allocation decisions are informed by corrupted data

• The NDIS cannot accurately answer fundamental questions: Where is money being spent? What supports do participants actually need? Where are gaps?

For System Planning and Equity:

• Aggregate NDIS data on support spending becomes unreliable for policy and planning

• The government cannot accurately assess whether the NDIS funding model is appropriate

• Resource allocation decisions across the scheme are made on false premises

• Equity analysis comparing spending across participant cohorts becomes impossible

• Long-term planning for scheme sustainability is undermined 31 May, 2026 Ability8 Submission 13

Submission 833

The Root Cause: System Design, Not User Failure

These workarounds are not evidence of participant irresponsibility. They are rational responses to an unreasonable system burden. When the system makes accurate data entry impossibly time-consuming, participants choose between:

• Spending 2-3 hours per week on administrative tasks, or
• Taking shortcuts that reduce accuracy Many choose option 2—not out of negligence, but out of necessity. The problem is not the participants. The problem is that the system has been designed in a way that makes accurate data entry incompatible with reasonable time burden.

The Solution: Remove the Complexity at Source

This data corruption problem cannot be solved by exhorting participants to “try harder” or threatening them with audits. It can only be solved by:

• Simplifying invoice processing: Allow invoices with multiple categories to be submitted as a single claim (restore PACE batching)

• Automating data extraction: Email invoices to Ability8, which automatically extracts categories and allocations

• Enabling API submission: Push claims directly to NDIS without manual re-entry

• Providing real-time feedback: Show participants immediately if their claim allocation matches invoice detail, with warnings if discrepancies appear

With these solutions in place, accurate data entry becomes the path of least resistance. Participants no longer have to choose between accuracy and time. The system supports accurate behaviours, and the NDIS receives reliable data to inform planning, pricing, and resource allocation.

Why This Matters for the NDIS Bill 2026 The new NDIS Amendment Bill requires the NDIA to have reliable data for monitoring, compliance, and fraud prevention (Schedule 2, Parts 2-3). However, if the current invoice complexity drives systematic data corruption, the NDIA’s monitoring and oversight will be based on fundamentally unreliable information. Fixing this system design issue is essential to making the Bill’s compliance and monitoring requirements actually achievable.

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2. The Impact: Lost Efficiency and Missed Savings The lack of clear guidance and coordination has serious consequences:

For Participants and Families: Limited choice and control. Fear of legal, tax, and employment complications drives families away from self-management and direct employment. The unpaid administrative burden discourages uptake even when families want to self-manage.

For the NDIS: Plans are larger than necessary because funds are allocated at service provider rates. Participants cannot efficiently use their budgets. The system loses the cost benefits of self-management.

For the Broader System: The most cost-efficient model (self-management with direct employment) is underutilised. Unnecessary money flows to service providers and plan managers. Both the government and families miss out on savings.

3. The Solution: Coordinated Government Action

3.1 Establish an Inter-Agency Working Group

The government form a working group bringing together representatives from:

• National Disability Insurance Agency (NDIS)
• Australian Taxation Office (ATO)
• Fair Work Ombudsman / Fair Work Commission
• Department of Social Services
• Business.gov.au This group should be tasked with developing clear, coordinated guidance for self-managing participants and families who choose direct employment.

The critical purpose of this inter-agency group is to create a single, authoritative source of truth that addresses the vast majority of employment issues that arise in direct employment within the disability care sector. Currently, self-managers receive conflicting advice from different government agencies, unreliable information from social media, and well-intentioned but incorrect guidance from friends, family, and informal networks. This creates confusion, fear, and decision paralysis.

Research into self-management barriers shows that 90%+ of employment questions can be addressed by clear, consistent guidance on standard processes. These include what wage rates are fair and legal, how to set up payroll, how to manage tax obligations, how to navigate Awards, how to write employment contracts, and how to maintain compliance records. Only a small percentage of participants require specialised one-on-one advice (e.g., complex award negotiations, unusual employment arrangements).

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When government agencies—the bodies that set the rules—align on advice content and publish it as official guidance, that guidance becomes the legitimate source of truth. Participants can trust it. Support workers can reference it. Advocates can rely on it. This single point of reference eliminates the uncertainty that currently deters participants and families from self-managing.

The outcome benefits everyone: participants gain confidence and choice; government agencies receive fewer confused inquiries; the NDIS can reliably estimate costs; support workers understand expectations; and the system functions more efficiently. This is not a complicated fix—it requires only coordination and commitment to a shared standard.

3.2 Develop a ‘Self-Management Roadmap’ for Participants Similar to government guidance for starting a business at https://business.gov.au/guide/starting

Create a comprehensive ‘Self-Management Roadmap’ that outlines:

• Employment standards and fair wage guidance (including Awards, minimum entitlements, and direct employment rate expectations)

• Step-by-step employment compliance and legal requirements

• Tax and superannuation obligations (with clarity on WPN vs. ABN and when each applies)

• Payroll and Single Touch Payroll requirements

• Insurance, liability, and risk management

• Bookkeeping and accounting essentials

• Contract templates and employment agreements

• Resources for ongoing support and advice

3.3 Revise NDIS Pricing Guidance for Self-Managers

Update the NDIS pricing structure to reflect the different cost profiles of self-managed direct employment, recognising that:

• Direct employers do not incur service provider overheads

• Fair wage rates for direct employment are typically lower than service provider rates

• Participants should have flexibility to pay different rates based on skills, qualifications, location, and role

• The pricing model should encourage efficient, direct employment rather than incentivising service provider use

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3.4 Fix the WPN and Single Touch Payroll Issue

Immediately address the recent identity management changes (MyID) that prevent WPN holders from using Single Touch Payroll from 1 July 2026. This is a critical blocker to direct employment and contradicts government automation objectives.

Ensure Self Managers can:

• Submit Single Touch Payroll electronically

• Receive consistent guidance from ATO staff

• ATO staff to understand the WPN to NDIS employment relationship

• Avoid being advised to obtain ABN numbers when WPN is the more appropriate designation

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4. The Role of Digital Tools: Ability8 as an Enabler 4.1 What is Ability8? Ability8 is a digital platform designed specifically to support self-managing NDIS participants, nominees and their families in managing their plans, coordinating care, and administering direct or contractor employment. It serves as a single, secure hub for all care related information, reducing the fragmentation and administrative burden that currently falls on families unpaid. This is not about just a convenience application, it is about Ability8 as a compliance and claims integrity partner for self-managed participants.

Whilst this sort of functionality can potentially be built into NDIS applications, the opportunity cost of a prolonged scoping and implementation plan is immeasurable. Partnering with platforms such as Ability8 allows the NDIS and self-managed participants to immediately benefit from increased compliance and reduced complexity that these existing systems can bring.

4.2 Core Features and How They Address the Problem

4.2.1 Centralised Data Management

Ability8 provides a single place to store all information relevant to the person with disability:

• All care information, preferences, medical notes, and support plans in one secure location

• No more fragmented records across multiple spreadsheets, notepads, email threads, and cloud folders

• Everyone involved (family members, support workers, caregivers) knows where to find information

• Historical data is preserved and searchable, reducing time spent looking for past records

This is particularly valuable for compliance and audits. Rather than scrambling to gather documentation from multiple sources, all records are already organised and accessible in one system.

4.2.2 Data Control and Privacy: Participant-Led Permissions

Ability8 puts data control entirely in the hands of the participant or their nominee. Users can decide:

• Who has access to the system (family members, support workers, nominated advisors, NDIS staff, auditors)

• What information each person can access (e.g., claims only, not personal profile; invoices but not health information)

• How long access is permitted (e.g., 24 hours, one week, ongoing)

• Whether access requires specific NDAs or formal agreements 31 May, 2026 Ability8 Submission 18

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For NDIS audits or third-party requests, participants can grant temporary, limited access directly through the system rather than responding to formal document requests. For example: ‘NDIS auditor can view claims and invoices for 24 hours’ or ‘Plan manager can access fund tracking for the next three months.’ This eliminates the back-and-forth of audit requests and gives participants control over what information is shared and when access expires.

This approach protects sensitive data while making compliance easier for both participants and agencies.

4.2.3 Circle of Support and Shared Responsibility Families often involve multiple people in care coordination: parents, siblings, grandparents, paid support workers, and trusted advisors. Ability8 allows:

• Defining who is in the ‘circle of support’ and what role each person plays

• Different access levels for different people (e.g., support worker sees roster and client preferences, but not financial information)

• Seamless handovers and shared understanding when someone new joins or leaves

• Real-time coordination without relying on multiple email threads or phone calls 4.2.4 Cross-Platform and Cross-Scheme Portability A major issue for families is that care information is siloed across different support schemes. Ability8 addresses this by:

• Supporting multiple funding schemes: NDIS, Thriving Kids, state-based services, aged care, and other disability support arrangements

• Allowing families to maintain continuity of records when transitioning between schemes

• For example: A child starts on Thriving Kids; when they turn 18 and move to NDIS, their care information, support history, and preferences follow them. Conversely, if an NDIS participant loses eligibility and transitions to state-based services or aged care, they retain their records.

• Creating a standard platform that works across the entire disability and aged care ecosystem

This eliminates the need to rebuild records every time a person transitions between schemes, saving families significant time and ensuring continuity of care.

4.2.5 Payroll and Tax Integration For families directly employing support workers, Ability8 simplifies payroll and tax compliance:

• Automated timekeeping and roster management

• Payroll processing integrated with tax obligations (PAYG withholding, superannuation contributions)

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• Automatic generation of Single Touch Payroll submissions (when API access to ATO is available)

• Linked invoicing and payment records for audit purposes

• Compliance documentation organised and ready for tax time and NDIS audits This transforms payroll administration from a manual, error-prone task into an automated process. Families no longer need to juggle spreadsheets, tax software, and manual record keeping.

4.2.6 Claims and Fund Tracking Self-managing participants must track claims against their NDIS budgets. Ability8 provides:

• Real-time visibility into fund allocation and spending
• Automated matching of invoices to claims for accurate budget tracking
• Early warnings when spending approaches plan limits
• Historical data for quarterly reviews and plan adjustments
• Clear reporting for nominees and family members managing the budget

4.3 The Time Savings Benefit

A critical but often unspoken benefit of Ability8 is time savings. Families managing direct employment and self-managed plans currently spend hours each week on administrative tasks:

• Tracking receipts and invoices across multiple storage locations
• Processing payroll manually or using disparate systems
• Responding to audit requests and gathering documentation
• Coordinating rosters and communicating with support workers
• Reconciling claims with actual spending
• Preparing tax records and superannuation information Every hour spent on administration is an hour not spent with the person receiving support or on family wellbeing. For families already managing complex care responsibilities, this administrative burden is often the reason they choose not to self-manage, even though self management would give them more choice and control.

By automating these processes, Ability8 returns time to families. This is not just a convenience—it is fundamental to making self-management viable and attractive.

4.4 Standardisation and Industry Best Practice

Currently, each self-managing family creates its own system: spreadsheets, notepads, cloud folders, filing systems. This creates problems:

• When someone new becomes involved (a new family member, support worker, or advisor), they must learn a bespoke system

• Handovers are difficult and time-consuming

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• Best practices are not shared or adopted By contrast, industry-standard tools (think XERO for small business accounting) create a common language and process. When a new accountant, manager, or advisor joins, they already know how the system works because it is standard across the industry.

Ability8 aspires to be this standard for disability and aged care management. When self management using Ability8 becomes the norm:

• New support workers and advisors can step in immediately without a learning curve

• Best practices for compliance, payroll, and budgeting are embedded in the tool

• Data is organised consistently, reducing confusion and errors

• Families and participants can receive help from others because everyone understands the same system

• Government agencies can interact with standardised data formats, reducing friction in audits and communications

4.5 API Integration with Government Systems

Ability8’s full potential is unlocked when it can integrate directly with government systems via API. This includes:

• NDIS API: Automatic retrieval of plan information, fund allocations, and claim status; submission of claims without manual data entry

• ATO API: Automated Single Touch Payroll submissions; automatic retrieval of tax rates and super information

• Fair Work API: Automated verification of Award rates and employment compliance

• State disability services APIs: Integration with other state-based support schemes With API integration, the administrative burden on families is dramatically reduced. Much of what currently requires manual data entry, cross-checking, and re-submission can be automated. This is particularly important for Single Touch Payroll—once the WPN and STP issue is resolved, API integration would allow families to submit payroll directly from Ability8 without visiting the ATO website.

4.7 Alignment with NDIS Amendment (Securing the NDIS for Future

Generations) Bill 2026

The May 2026 NDIS Amendment Bill introduces critical new compliance requirements. Ability8 is designed to support self-managing participants in meeting these obligations while simultaneously enabling the NDIA to achieve its legislative objectives. The alignment is precise:

Record Retention and Compliance (Schedule 2, Part 4) The Bill requires providers and participants to retain records relating to payment and receipt of NDIS amounts. Failure to retain records results in civil penalties for providers and debt for participants. Ability8 directly addresses this requirement:

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• Centralised record management: All invoices, receipts, claims, and payments are stored in one secure location with full audit trails, eliminating the fragmentation that currently makes compliance difficult

• Automatic record retention: Documents are automatically retained and timestamped, with no manual effort required from families

• Compliance proof: When audited, participants can demonstrate compliance instantly by sharing access to their records through the system, rather than responding to formal document requests

Reducing Claim Times (Schedule 2, Part 5) The Bill establishes a 90-day deadline for making claims after service delivery. Ability8 supports this requirement:

• Email invoice processing: Support workers and providers email invoices directly to Ability8, which automatically extracts data and generates claims ready for submission

• Automatic deadline tracking: The system alerts participants and nominees when claims are approaching the 90-day deadline, ensuring compliance

• Timestamp evidence: Each claim submission is timestamped and stored, providing proof of compliance with the 90-day requirement

Fraud Prevention and Verification (Schedule 2, Parts 1-3) The Bill introduces expanded fraud measures and information-gathering powers. Ability8 proactively helps prevent fraud and supports the NDIA’s risk assessment and monitoring obligations:

• Provider verification: ABN validation automatically checks that support worker ABNs are valid and registered, detecting fraudulent or inactive businesses

• Bank account verification: Payment destination accounts are validated, flagging mismatches or suspicious changes in banking details

• Invoice format standardisation: By requiring invoices in standardised format, the system detects anomalies (unusual fonts, formatting, or layouts that suggest altered documents)

• Duplicate detection: Automated checking of invoice numbers prevents duplicate claims and identifies potential invoice fraud

• Anomaly alerts: The system flags unusual spending patterns, sudden changes in invoice amounts or frequency, or payments to new providers, triggering review before submission

• Data integrity logs: Complete audit trails show who accessed what information, when, and what changes were made, supporting the Bill’s information-gathering and investigation requirements

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Automation of Administrative Actions (Schedule 3, Part 2) The Bill explicitly allows the NDIA to automate administrative actions, including processing claims and payments. Ability8 is built for this:

• Pre-filled claims: When invoices are processed through Ability8, they generate standardised claims that can be submitted automatically to the NDIS portal via API, requiring minimal manual intervention

• Validation workflows: Automated validation rules check claims against plan budgets, threshold limits, and reasonableness criteria before submission, reducing downstream processing errors

• NDIA integration: With NDIS API access, Ability8 can submit claims and retrieve live fund status updates, enabling near-real-time oversight of spending and compliance

Support Linking to Impairment Verification (Schedule 1, Parts 3 & 6) The Bill clarifies that supports must be linked to the impairments for which participants met access criteria. Ability8 supports this verification:

• Category tagging: Invoices automatically categorise supports by NDIS category and include impairment linkage data, enabling verification that claimed supports align with participant’s access criteria

• Plan alignment checking: The system compares claimed support types and amounts against the participant’s approved plan, flagging mismatches for review

Plan Renewal and Fund Management (Schedule 1, Part 5) The Bill introduces plan end dates and prevents carry-over of unspent funds. Ability8 manages this complexity:

• Plan cycle tracking: The system tracks plan end dates and automatically resets budgets, preventing accidental spending from expired plans

• End-of-plan reports: Automated reporting shows all spending within each plan cycle, supporting compliance with new fund carry-over restrictions

• Transition support: When plans renew, historical data is preserved and accessible, supporting continuity of care and planning for the next cycle

Ability8 is not a compliance tool imposed on families—it is an enabler that transforms compliance from a burden into a natural byproduct of good record-keeping and transparent operations. By using Ability8, self-managing participants can demonstrate full compliance with the Bill’s requirements while the NDIA gains access to standardised, auditable data that supports its monitoring and fraud prevention obligations.

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4.6 What Ability8 Does NOT Do

It is important to note that Ability8 is a tool, not a solution to all problems. It does not:

• Replace the need for clear government guidance on employment rates, Awards, and compliance

• Substitute for proper tax, legal, or HR advice

• Solve the inter-agency communication failures or the WPN/STP issue—it works within the current system

• Make direct employment easy if the regulatory environment remains unclear However, once government frameworks are clear and regulatory issues are resolved, Ability8 becomes a powerful enabler of self-management and direct employment.

5. Expected Outcomes and Benefits Implementation of this coordinated approach, supported by tools like Ability8, would deliver:

For Participants and Families: Greater choice, control, and autonomy. More efficient use of their NDIS budgets. Confidence to directly employ without fear of legal or tax complications. Dramatically reduced administrative burden, freeing time for care and family wellbeing. Unpaid care work is acknowledged and supported by better systems.

For the NDIS: Significant cost savings. Participants self-managing with direct employment are the most efficient use of funds. Plans can be right-sized for actual service costs, not inflated service provider overhead. Reduced reliance on service providers and plan managers. Cleaner, faster audit processes when participants use standardised systems like Ability8.

For Workers: Fair and transparent employment practices. Better continuity of care. Direct relationships with participants instead of remote management by service providers. Clear understanding of wages, conditions, and rights.

For the Broader System: Reduced reliance on intermediaries (service providers, plan managers). More efficient allocation of NDIS funding. Better outcomes across the disability support ecosystem. A model that can scale and be replicated across aged care, Thriving Kids, and other support schemes. Foundation for a truly person-centred, data-driven disability support system.

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6. Recommendations We recommend that Parliament:

7. Direct the NDIS, ATO, and Fair Work Commission to establish a formal inter-agency working group

8. Task the working group with developing a Self-Management Roadmap within 6 months

9. Allocate resources to communicate this guidance widely to self-managing participants

10. Resolve the WPN and Single Touch Payroll issue as a priority—this is a critical blocker to automation and compliance

11. Develop API standards that allow digital tools like Ability8 to integrate directly with NDIS, ATO, and Fair Work systems

12. Recognise and support digital platforms designed to reduce administrative burden on unpaid family carers and nominees

13. Monitor and evaluate the uptake and cost impact of direct employment following the introduction of clear guidance

14. Establish Ability8 (or similar standardised platforms) as recommended tools for self- managing participants, with potential subsidies or integration funding to ensure accessibility

15. Urgently reform the PACE claims system to restore batching functionality: allow multiple support categories on a single invoice to be submitted as one claim, rather than requiring separate claims for each category. This alone will reduce claim submission time from 20-24 minutes back to 5-6 minutes.

16. Simplify the spending threshold model on new plans: consolidate to a maximum of two threshold types per plan (e.g., either annual-only, OR annual + quarterly, but not annual + quarterly + monthly simultaneously). The current model of 17 simultaneous tracking windows per plan is administratively unsustainable for unpaid family managers.

17. Develop and publish an NDIS API that allows authorised third-party platforms (such as Ability8) to submit claims and retrieve fund status directly, eliminating the need for manual re-entry of data. API access should also allow retrieval of threshold information and real-time spending data to support accurate budget management.

18. Establish a public specification for claim error messages and rejection reasons: when claims are rejected, provide clear, plain-English explanations of why (threshold breach,

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missing documentation, system error, etc.) and step-by-step guidance on how to correct and resubmit. Remove hidden rules and ensure transparency in the claims process.

13. In light of the NDIS Amendment Bill 2026 record retention and compliance requirements (Schedule 2, Part 4), recognise and endorse digital platforms like Ability8 as compliant record-keeping systems. Include such platforms in NDIA guidance to self managers as acceptable tools for meeting the new legal obligations for retaining payment and receipt records.

14. Support and fund the development of fraud prevention features in digital platforms (ABN verification, bank account validation, invoice format standardisation, duplicate detection, anomaly alerts). These features directly support the Bill’s fraud prevention measures (Schedule 2, Parts 1-3) and will help the NDIA meet its monitoring and risk assessment obligations without additional regulatory burden on self-managers.

15. Implement the 90-day claims deadline (Schedule 2, Part 5) in partnership with digital platforms that can automate deadline tracking and claim submission. Ability8 and similar systems can process emailed invoices automatically, extract category data, generate standardised claims, and alert participants to upcoming deadlines—making this requirement manageable for self-managers rather than burdensome.

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7. Conclusion Self-managed NDIS participants who directly employ support workers represent the most cost-efficient model in the disability support system. Yet this model remains underutilised due to lack of government guidance, inter-agency coordination, and clear employment frameworks.

Behind the statistics are families and participants who are already spending countless unpaid hours managing complex care arrangements. They deserve:

• Clear guidance on employment, taxation, and compliance
• Systems and tools that reduce, not add to, their administrative burden
• Government agencies that work together rather than in silos
• Recognition that self-management is the most efficient use of NDIS funding The solution requires immediate action in three key areas:

(1) resolve the recent system failures that have multiplied administrative burden—the PACE claims system must be reformed to restore batching, and spending thresholds should be simplified from their current unsustainable complexity;

(2) unlock API access to government systems to enable digital platforms like Ability8 to eliminate duplicate data entry, speed submission, decrease errors, improve data quality; and

(3) the long-standing issues—government agencies need to talk to each other, provide clear guidance to participants and families, resolve specific barriers like the WPN and Single Touch Payroll issue, and support digital tools that make self-management and direct employment practical.

This will unlock significant cost savings for the NDIS, provide greater choice and control for participants, reduce the unpaid burden on families, and create a fairer, more efficient disability support system.

We look forward to working with Parliament and relevant agencies to make this vision a reality.

Thank you

Regards

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