Submission 836
Chief Executive Officer
My Plan Manager Group
Level 9 400 King William St
Adelaide SA 5000
In response to NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026
For the attention of the Community Affairs Legislation Committee
Introduction
Thank you for the opportunity to provide feedback to the Legislation Committee. We are Australia’s largest plan manager comprised of the My Plan Manager and National Disability Support Partners brands, today representing in excess of 80,000 clients. We are broadly supportive of the proposed reforms but believe some aspects of the current bill addressing related parties’ concerns may have unintended consequences and significant impacts to participants unless clarified. Below we have set out a rationale for clarification as well as proposed amendments to aid clarification.
Section 73(C)(1)– Related Party Restrictions
Section 73(C)(1) of the draft Bill is intended to prohibit related parties providing other supports or services under the NDIS. The Explanatory Memorandum to the Bill identifies integrity, safeguarding, and conflict-of-interest mitigation as the primary policy intent underpinning these reforms. It recognises that plan managers occupy positions of influence given their role in managing funding and assisting participants to navigate provider markets.
We acknowledge and support the policy objective of addressing conflicts of interest, particularly in vertically integrated models where financial incentives may exist to steer participants toward related service providers delivering direct supports or coordination services. However, the application of this provision to corporate groups operating multiple plan management entities introduces scope for significant participant disruption without commensurate benefit.
No Commercial Incentive in Plan-Manager-to-Plan-Manager Referrals
Where a corporate group operates multiple plan management brands through separate but related legal entities, there is no commercial incentive to steer participants between related plan management providers because doing so does not create additional revenue for that corporate group within the NDIS ecosystem.
My Plan Manager Group Level 9, 400 King William Street, Adelaide 5000, SA Enquiries: 1800 861 272 Page 1
Submission 836
Further:
Participants dissatisfied with a plan manager are unlikely to seek replacement recommendations from that same provider.
In practice, participants rely on independent channels (e.g., word-of-mouth, advocates, support coordinators) when changing providers.
Accordingly, the risk of conflicted behaviour is materially lower than in vertically integrated service models, and the policy rationale underpinning section 73(C)(1) does not apply with the same force in this context.
Disproportionate Operational and Participant Impact
The practical effect of this provision is likely to:
Trigger considerable participant reassignments, requiring fresh service agreements and administrative onboarding
Create significant disruption for participants during a period of broader scheme reform and transition
Across the largest plan management groups, this could affect up to approximately 220,000 participants, with no corresponding integrity benefit.
This introduces high system friction without commensurate risk mitigation, which is inconsistent with the stated objective of improving Scheme efficiency and sustainability.
Proposed Amendment
We recommend that Section 73(C)(1) be amended to clarify that a related party of a registered plan manager must not provide any supports or services under the NDIS other than plan management.
This would:
Preserve the policy intent of preventing vertically integrated conflicts
Avoid unintended consequences for corporate structures that do not present integrity risks;
Maintain continuity for participants and minimise disruption
This recommendation is consistent with the broader framework in Section 73(F)(2)(k), which already limits plan managers and their related parties to providing plan management services only.
My Plan Manager Group Level 9, 400 King William Street, Adelaide 5000, SA Enquiries: 1800 861 272 Page 2
Submission 836
Section 73(F)(2)(j) – Key Personnel Restrictions
Section 73(F)(2)(j) proposes that a member of key personnel of a registered plan management provider must not also be a member of the key personnel of another NDIS provider.
The Explanatory Memorandum suggests that overlapping directors, executives, or senior managers may create risks including conflicts of interest and coordinated self-referral behaviour. While this concern is valid in the context of vertically integrated providers delivering multiple service types, its application to multiple plan management entities within a single corporate group does not reflect the risk profile of a key personnel arrangement giving rise to the opportunity for self-referral behaviour.
No Vertical Integration Risk in Plan Management Structures
Where shared key personnel exist across related plan management entities:
There is no pathway for self-referral into higher-margin service lines
The structure does not create incentives to increase utilisation or direct participant funds inappropriately
Accordingly, shared governance and leadership structures in this context:
Do not inherently create conflicts of interest
Do not undermine Scheme integrity
Risk of Unintended Market and Governance Consequences
If implemented without amendment, this provision may:
Require duplication of executive and board functions across related plan management entities Increase administrative cost and complexity without improving participant outcomes
This is inconsistent with broader reform objectives to improve efficiency, sustainability, and system performance.
Proposed Amendment
We recommend that Section 73(F)(2)(j) be amended such that a member of the key personnel of a registered plan management provider must not be a member of the key personnel of another NDIS provider other than a plan management provider within the same corporate group.
Thank you for considering our feedback. We are supportive of the proposed reforms to ensure the scheme is sustainable for generations to come. Our strongly held view is that these minor but important amendments will only help to strengthen and deliver on the scheme’s intent to deliver integrity, efficiency, and sustainability.
My Plan Manager Group Level 9, 400 King William Street, Adelaide 5000, SA Enquiries: 1800 861 272 Page 3
Submission 836
Yours sincerely,
Chief Executive Officer
My Plan Manager Group
My Plan Manager Group Level 9, 400 King William Street, Adelaide 5000, SA Enquiries: 1800 861 272 Page 4