NDIA Accountability Project

This project is in DRAFT

Intermediary Services within the NDIS (Individual advocacy)

‹ PrevPage 1 of 7 · Source p. 1Next ›

Submission 865

Inquiry into the National Disability Insurance Scheme Amendment (Securing

the NDIS for Future Generations) Bill 2026

Submission Focus: Intermediary Services within the NDIS

Support Coordination and Plan Management

Submitted by:

Support Navigation Services

Introduction

This submission focuses specifically on the role of intermediary services within the

National Disability Insurance Scheme (NDIS), particularly Support Coordination and

Plan Management providers.

Intermediary providers play a critical role in ensuring participants can navigate an increasingly complex system, access appropriate supports, exercise genuine choice and control, build provider networks, manage risks, and remain engaged in their communities.

While the stated intent of the proposed reforms is to improve sustainability and integrity within the Scheme, there are significant concerns that aspects of the proposed legislation may unintentionally undermine participant outcomes, reduce market diversity, destabilise local providers, and increase barriers to access for vulnerable participants.

This submission outlines concerns and recommendations regarding:

  • Commissioning arrangements
  • Registration requirements
  • Market stewardship
  • Local provider sustainability
  • Ownership structures
  • Conflicts of interest
  • The future role of Support Coordination
  • Participant access and continuity of service
  1. The Critical Role of Intermediaries in the NDIS Support Coordinators and Plan Managers are often the operational backbone of participant plans.

These services:

Submission 865

  • assist participants to understand and implement plans;

  • identify and mitigate safeguarding risks;

  • coordinate complex service systems;

  • support crisis prevention and hospital avoidance;

  • facilitate informal and mainstream supports;

  • build participant capacity and independence;

  • assist participants to navigate housing, justice, health, education and employment systems;

  • ensure providers are held accountable;

  • reduce administrative burden on participants and families. For many participants — particularly those with psychosocial disability, intellectual disability, autism, acquired brain injury, or complex behavioural support needs — intermediary supports are essential to achieving meaningful outcomes under the Scheme.

Without effective intermediary supports, participants are at significantly greater risk of:

  • provider exploitation;
  • service disengagement;
  • homelessness;
  • hospitalisation;
  • justice system involvement;
  • abuse and neglect;
  • social isolation;
  • plan underutilisation or inappropriate spending.
  1. Concerns Regarding Proposed Commissioned Provider Panels The proposed commissioned provider panel model lacks sufficient detail and transparency.

There is significant concern that commissioning may:

  • reduce participant choice and control;
  • favour large national providers over smaller local organisations;
  • create barriers to market entry;
  • centralise services away from local communities;
  • unintentionally reduce innovation and responsiveness.

Submission 865

The NDIS was designed as a market-based system built on participant choice and control. Restricting intermediary services to limited commissioned panels risks creating a quasi-monopoly environment that undermines these principles.

Recommendation

If commissioning proceeds:

  • all Plan Management and Support Coordination organisations that meet clear, transparent criteria should be eligible for commissioning arrangements;

  • commissioning must not be capped to a small number of preferred providers;

  • regional and local providers must be prioritised and protected;

  • there must be independent review and appeal mechanisms for providers excluded from commissioning arrangements.

  1. Concerns Regarding the Previous Support Coordination Trial The previous trial involving selected Support Coordination organisations demonstrated significant flaws in both process and implementation.

Numerous organisations that met the stated eligibility criteria were reportedly excluded from participation without clear explanation or transparency regarding decision making.

This created:

  • uncertainty within the sector;
  • perceptions of unfairness;
  • reduced trust in commissioning processes;
  • concerns regarding consistency and procedural fairness. Future commissioning or panel arrangements must avoid repeating these issues.

Recommendation

Any future selection or commissioning process must include:

  • publicly available eligibility criteria;
  • transparent assessment methodologies;
  • published conflict-of-interest management processes;
  • procedural fairness and review pathways;
  • meaningful sector consultation prior to implementation.
  1. Mandatory Registration of Support Coordination Providers All Support Coordination providers should be required to be registered NDIS providers.

Submission 865

Support Coordinators frequently work with highly vulnerable participants and have significant influence over:

  • service access;

  • safeguarding responses;

  • restrictive practice escalation;

  • housing pathways;

  • crisis responses;

  • provider selection;

  • financial decision-making. Given this level of influence, mandatory registration would improve:

  • accountability;

  • safeguarding oversight;

  • complaints management;

  • worker screening compliance;

  • participant protections.

Recommendation

All organisations delivering Support Coordination services should be required to maintain NDIS registration regardless of organisational size.

Registration requirements should remain proportionate and accessible for small and regional providers to avoid unintended market exits.

  1. Ownership of Intermediary Providers Support Coordination and Plan Management services hold significant influence within the disability support ecosystem.

There is growing concern regarding increasing consolidation of intermediary services by large corporations, including entities linked to overseas parent companies.

The NDIS is an Australian public service system funded by Australian taxpayers and designed to support Australian participants and communities.

Recommendation

Plan Management and Support Coordination organisations should:

  • be Australian owned and operated;
  • not have overseas parent company ownership structures;
  • maintain operational and governance accountability within Australia. This would support:

Submission 865

  • local economic participation;
  • accountability to Australian regulatory frameworks;
  • reinvestment into Australian communities;
  • reduced risk of profit extraction from taxpayer-funded disability supports.
  1. Conflict of Interest Considerations Plan Managers should remain entirely independent from direct NDIS service delivery.

Allowing Plan Management organisations to also provide other funded supports creates significant conflict-of-interest risks, including:

  • steering participants toward related providers;
  • reduced participant choice;
  • financial conflicts;
  • diminished market neutrality. Plan Managers occupy a financial gatekeeping role and should remain independent of service delivery interests.

Support Coordination presents a more nuanced situation.

While conflicts must be carefully managed, many smaller regional and local providers successfully deliver both Support Coordination and direct supports in ways that improve continuity, responsiveness, and local knowledge — particularly in thin markets.

Recommendations

Plan Management

  • Plan Management organisations should be prohibited from delivering any other NDIS-funded supports.

Support Coordination

  • Support Coordination organisations may continue delivering other supports where:

o conflicts are transparently managed;

o participant choice is documented;

o coercive practices are prohibited;

o safeguards and disclosure requirements are strengthened.

  1. Local Providers Deliver Better Outcomes In practice, many smaller and regional providers deliver significantly stronger participant outcomes than large corporate entities.

Local providers often:

Submission 865

  • understand local housing and service systems;
  • maintain long-term relationships with participants and families;
  • have stronger community connections;
  • respond faster during crises;
  • work collaboratively across sectors;
  • provide more flexible and individualised supports. By contrast, many large national organisations operate using highly centralised KPI driven models focused heavily on billable hours and throughput.

This risks:

  • reduced relationship continuity;
  • transactional service delivery;
  • poorer participant engagement;
  • workforce instability;
  • reduced responsiveness to local community needs. The sustainability of local intermediary providers is therefore critical to maintaining participant outcomes and genuine market diversity.

Recommendation

Future reforms should actively protect and prioritise:

  • regional providers;
  • small and medium intermediary organisations;
  • place-based service models;
  • thin market sustainability.
  1. Lack of Clarity Regarding the Future of Support Coordination There remains substantial uncertainty regarding:
  • the future role of Support Coordination;
  • eligibility criteria;
  • funding continuity;
  • commissioning pathways;
  • workforce implications. This uncertainty is already destabilising the sector and creating anxiety among participants, families, and providers.

Submission 865

Support Coordination should not be viewed as an administrative overhead. For many participants, it is the mechanism that makes the NDIS functional and safe.

Poorly implemented reductions or restrictions to Support Coordination will likely result in:

  • increased crisis presentations;
  • increased hospital admissions;
  • greater plan breakdown;
  • reduced participant safety;
  • higher long-term system costs.

Recommendation

The Government should:

  • publicly clarify the future role of Support Coordination;
  • undertake genuine consultation with intermediary providers;
  • ensure transition arrangements are transparent and staged;
  • avoid abrupt funding or structural changes that destabilise participants and markets.

Conclusion

The sustainability of the NDIS must not come at the expense of participant safety, continuity of support, local provider viability, or genuine choice and control.

Intermediary services are not peripheral to the Scheme — they are foundational to ensuring participants can safely and effectively navigate an increasingly complex support environment.

Reforms should strengthen integrity and quality while preserving:

  • participant autonomy;
  • market diversity;
  • local expertise;
  • safeguarding protections;
  • sustainable service delivery. The Senate Committee is urged to carefully consider the unintended consequences these reforms may have on intermediary providers, particularly small and regional organisations that play a vital role in supporting participants across Australia.