NDIA Accountability Project

Support Needs Assessments for Planning/Funding

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Submission to the Joint Standing Committee on the National Disability Insurance Scheme

Submitted by Sally Loader

Adelaide Wellbeing Society

Address: 9A/1700 Main North Road, Salisbury Plains, 5109

Contact Number:

Email Address: admin@wellbeingsociety.com. au

Annual Report No. 2 of the 48th Parliament

Submission 54

Table of Contents

Submission 34

ADELAIDE WELLBEING SOCIETY

Adelaide Wellbeing Society strongly supports the long-term sustainability, integrity and accountability of the NDIS. We recognise the need to address fraud, improve governance, strengthen provider accountability and ensure that Scheme funding is directed towards supports that are effective, evidence-based and provide genuine value for money. However, sustainability should not be achieved simply by reducing participant funding or restricting access to supports that maintain independence, function and quality of life.

As a small multidisciplinary allied health provider working directly with NDIS participants and their families, we are increasingly concerned by the gap between how the Scheme is intended to operate and the experiences of participants and providers on the ground. We see significant inconsistencies in planning outcomes, limited consideration of clinical evidence, lengthy review and appeal processes, confusing PACE funding arrangements, and participants being asked to obtain additional assessments and reports without sufficient funding to pay for them. These issues disproportionately affect participants and families who do not have the financial resources, knowledge or capacity to continually challenge decisions.

We are particularly concerned by reductions in rehabilitation and capacity-building supports. For people living with permanent neurological and physical disabilities, including stroke, brain injury, amputation and progressive neurological conditions, rehabilitation is not simply treatment of a health condition. It can be essential to maintaining mobility, independence, activities of daily living, community participation and quality of life. Reducing these supports may lower the immediate cost of an individual NDis plan but can contribute to functional deterioration, increased reliance on paid supports, preventable hospitalisation and greater long-term costs across government systems.

We also believe greater clinical expertise is required within NDIS decision-making. Allied health professionals undertake comprehensive assessments and provide evidence regarding participants’ functional capacity and disability-related needs, yet this evidence can be given limited weight or overridden without a clear clinical rationale. Where the NDIA disagrees with qualified clinical evidence, participants should be provided with a transparent, evidence-based explanation and, where appropriate, the evidence should be reviewed by a suitably qualified professional.

There must also be greater equity in the review and appeals system. Participants should not be required to privately fund repeated assessments and reports in order to challenge an NDIS decision, nor should the system rely on allied health providers completing substantial amounts of professional work without payment. A participant’s ability to demonstrate their disability-related needs or challenge a decision should not depend on their personal financial circumstances.

At the same time, provider sustainability must form part of the discussion about NDIS sustainability. Allied health providers are experiencing increasing wages, superannuation, insurance, rent, equipment, vehicle, compliance and administrative costs while many NDIS price limits have not kept pace. Reduced travel funding is also making outreach increasingly difficult to sustain, disproportionately affecting participants who cannot readily attend clinic-based services. If experienced providers reduce NDis services or leave the Scheme because they are no longer financially viable, participant choice and access will inevitably be reduced.

Annual Report No. 2 of the 48th Parliament

Submission 34

ADELAIDE WELLBEING SOCIETY

We support mandatory provider registration and stronger safeguards against fraud and exploitation. Hoverever, regulation should be proportionate to risk and recognise existing professional regulation and accreditation of allied health practitioners. At the same time, credible reports of inappropriate billing, conflicts of interest and misuse of participant funding must result in timely investigation and meaningful enforcement.

Ultimately, reducing funding does not reduce disability or the need for support. Where necessary supports are removed, the cost does not simply disappear; it may be transferred to participants and families, providers delivering unpaid services, hospitals and state health systems, or to the NDIS itself through greater future support needs. Reform should therefore focus not only on reducing expenditure, but on achieving better long-term outcomes from that expenditure.

We ask the Committee to support an NDIS that is financially sustainable while remaining participant-centred, clinically informed, evidence-based and equitable. The objective should be a Scheme that invests in appropriate supports at the right time, prevents avoidable deterioration, protects participant choice and independence, holds misuse of public funding to account, and maintains a sustainable market of high-quality providers capable of delivering those supports.

Introduction

Adelaide Wellbeing Society welcomes the opportunity to provide this submission to the Joint Standing Committee on the National Disability Insurance Scheme.

A multidisciplinary allied health provider working directly with NDIS participants and their families, we see firsthand both the significant positive impact the NDIS can have on the lives of people with disability and the challenges that can arise when the Scheme does not operate as intended. Our experience spans clinic, home, school and community-based service delivery, supporting participants with a diverse range of disabilities, functional needs and personal circumstances.

We strongly support the NDIS and recognise the importance of ensuring the Scheme remains sustainable for future generations. We support appropriate reform, stronger safeguards, effective action against fraud and misuse of funds, and measures that ensure NDIS funding delivers genuine outcomes for participants. However, we believe that financial sustainability must be considered alongside participant outcomes, quality of life, equitable access to supports, and the sustainability of the providers required to deliver those supports.

The following outlines a number of issues we have observed through our direct experience within the Scheme, including planning and funding inconsistencies, access to rehabilitation and capacity-building supports, consideration of clinical evidence, review and appeal processes, provider regulation, pricing, travel and the ongoing viability of allied health service delivery. Many of these issues are interconnected and ultimately affect the ability of participants to access appropriate supports when they need them.

We respectfully provide these observations and recommendations to assist the Committee in considering how the NDIS can continue to evolve while remaining fair, evidence-based, participant-centred and sustainable for the people with disability who rely upon it.

Joint Standing Committee on National Disability Insurance Scheme Terms of Reference

The committee is tasked with inquiring into the following:

e The implementation, performance and governance of the National Disability Insurance Scheme;

e The administration and expenditure of the National Disability Insurance Scheme; and

e Such other matters in relation to the National Disability Insurance Scheme as may be referred to it by either House of Parliament.

after 30 June each year, the committee is required to present an annual report to the parliament on the activities of the committee during the year. The committee also undertakes inquiries into specific aspects of the national disability insurance scheme (ndis).

About Adelaide Wellbeing Society

adelaide wellbeing society is a small multidisciplinary allied health service based in adelaide. our organization includes an all-abilities rehabilitation gym, play therapy centre, consulting rooms, and community outreach services. we provide clinic-based, home-based, and school-based services to individuals across adelaide, particularly within the northern suburbs.

many of the families we support experience socioeconomic disadvantage, limited access to transport, unstable housing, and reduced informal supports. In numerous households, multiple family members live with disability, making access to community-based allied health services essential.

lile many allied health providers, we operate within narrow financial margins despite the perception that allied health services are highly profitable. The available evidence suggests that this perception does not reflect the financial realities of delivering ndis-funded allied health services. ato small business benchmark data for allied health businesses (physiotherapy benchmark) demonstrates the substantial proportion of turnover consumed by business expenses, while the major allied health professional bodies are reporting increasing concerns regarding provider sustainability.

our organisation was developed by three Allied Health Professionals who dreamed of building a place where people in the community could access high quality services without long wait lists, and not having to travel to access multiple services. A place where we can provide inclusive multi disciplinary support to people of all ages and abilities. Adelaide Wellbeing Society opened a purpose built facility in 2024 - the dream is real.

some issues | will raise below will identify that the NDIS framework in its current state is not keeping pace with inflation or business expenditure, and the pricing model and administrative burden is limiting providers’ ability to keep performing at high standards placing substantial pressure on providers attempting to maintain accessible and sustainable services.

Submission 34

\ADELAIDE Wellington

The introduction of PACE plans has created additional administrative complexity for participants, families and providers. Inconsistency in Planning Outcomes

There continues to be significant inconsistency in NDIS planning decisions, with participants who have comparable disabilities, functional impairments and support needs receiving substantially different levels of funding. In our experience as an allied health provider, we have observed participants of a similar age and with similar conditions receiving immensely different plans.

For example, two people recovering from stroke with very similar deficits - receive vastly different levels of Support. The consequences can be significant: while one participant with appropriate supports has been able to restore some of their health, function and independence, another with inadequate funding has experienced further decline, poorer outcomes, still no use of his right side, difficulty with walking and speech, and lastly repeated hospital admissions.

A client was going to appear in front of the committee to share his story, but he is unfortunately in hospital again. This is not the only case we have seen of inconsistency, and it raises concerns about the standards, equity and evidence base of planning decisions.

Finally, participants and providers frequently receive inconsistent information from Local Area Coordinators (LACs), support coordinators and other individuals involved in navigating the NDIS. Different advice may be provided regarding funding, eligible supports, plan implementation and Scheme requirements. A lack of consistent training, guidance and interpretation can leave participants uncertain about their entitlements and can contribute to inequitable outcomes. Greater standardisation of training, decision-making guidance and communication across the NDIS would improve transparency, participant confidence and consistency of Scheme outcomes.

The introduction of PACE plans has created additional administrative complexity for participants, families and providers, with many families reporting that the new plan structure and funding categories are difficult to understand and navigate.

We have experienced situations where the cost of an assessment and associated report from one allied health provider has reduced or exhausted the available budget within a funding category, resulting in invoices from other providers subsequently being rejected despite those services forming part of the participant’s ongoing support needs.

For example, a child is undertaking both OT and Speech as part of their plan. In one quarter a Speech Assessment might require a Speech Pathologist writing up a report, which takes up extra funding during the quarter (which has been budgeted for in the average cost of services across a year). This means in that same quarter an OT might have their therapy invoice rejected as funds for that particular quarter have been exhausted.

There also appears to be insufficient understanding within the planning and administrative process of the different scopes of practice of allied health professions, which can result in funding being allocated inappropriately or participants being directed towards services that do not adequately address their functional needs. In addition, participant goals contained within plans can at times appear generic, arbitrary or poorly

Annual Report No. 2 of the 48th Parliament

Submission 34

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aligned with the participant’s actual disability-related needs and priorities. These issues create unnecessary confusion for families and providers and can interfere with coordinated multidisciplinary care. Greater clarity around PACE funding categories, improved understanding of allied health scopes of practice, and stronger processes for ensuring participant goals and budget allocations reflect assessed individual needs would support more effective and equitable use of NDIS funding.

Diagnosis and Funding Application Issues

There are significant concerns regarding how new or additional diagnoses are considered during NDIS planning and reassessment processes. We have observed circumstances where updated diagnostic information has been provided within supporting documentation but does not appear to have been adequately reviewed or reflected in subsequent funding decisions. Participants can then face a difficult and circular process when attempting to have their changed, or additional disability-related needs, recognised. They may be advised that further assessments, reports or clinical evidence are required to demonstrate their functional impairment and support needs, while at the same time funding for those assessments and reports is declined or their existing plan contains insufficient funding to obtain the required evidence.

A provider, we have spent countless hours undertaking assessments and preparing detailed clinical reports for participants who have insufficient funding remaining in their plans to pay for this work. This is particularly concerning where participants have been specifically requested to obtain additional reports or evidence to support an NDIA plan reassessment, internal review or Administrative Review Tribunal (ART) matter. In practice, providers can be placed in the position of either completing substantial professional work without payment or declining to provide evidence that may be critical to a participant demonstrating their disability-related needs.

Small allied health providers cannot sustainably absorb the cost of repeated assessments, reports and supporting documentation required by the Scheme, yet participants - particularly those experiencing financial disadvantage – may have no capacity to fund these reports privately.

This creates an inequitable system in which a participant may be told that additional clinical evidence is required to justify appropriate supports but is not provided with sufficient funding to obtain that evidence. The ability to demonstrate disability-related need should not depend on a participant’s personal financial resources or on the willingness and financial capacity of their treating providers to undertake unpaid work. A clear mechanism should therefore exist to fund assessments and reports specifically requested or reasonably required by the NDIS, including evidence required for plan reassessments, change or addition to diagnosis, internal reviews and ART proceedings.

Rehabilitation Services Facing

Funding Cuts

Our service supports many NDIS participants living with the permanent functional consequences of brain injuries, stroke, amputations, neurological and progressive disabilities, and significant mobility impairments. We are increasingly seeing participants experience substantial reductions in funding for rehabilitation services that are directly related to their permanent disability.

Rehabilitation should not be viewed simply as short-term recovery treatment, treatment of an acute health condition, or a substitute for a health service. For many people with permanent disability, rehabilitation is an ongoing disability-related support that enables them to maintain or improve functional capacity, mobility, balance, strength, independence, ability to undertake activities of daily living, community participation, and overall health and wellbeing. Stroke survivors, for example, may require extensive community-based rehabilitation long after they have been discharged from the hospital system.

We have seen clients only months after having a leg amputated have their rehabilitation funding substantially reduced before they have even received their prosthetic limb. Receiving a prosthesis does not, by itself, restore a person’s mobility. Learning to walk again and developing the balance, conditioning, strength and coordination required to safely use a prosthetic limb are essential parts of learning to live with that permanent disability. These skills can determine whether a person is able to independently access their community, undertake meaningful activities of daily living, build capacity and potentially return to work. Participants cannot reasonably or safely be expected to achieve these outcomes without access to appropriate professional rehabilitation therapies. In this example, providing a participant in these circumstances with only one Exercise Physiology appointment per month, and no other rehabilitation therapies, represents a neglectful response to their disability-related needs.

There also appears to be insufficient recognition within current funding decisions of the preventative and capacity-building value of disability-related rehabilitation. Appropriate Exercise Physiology, Physiotherapy, Occupational Therapy and other rehabilitation supports can assist participants to maintain function, safely manage the long-term consequences of their disability, prevent deterioration, reduce secondary complications and falls, maintain independence and participate in their community. Ongoing allied health intervention can also reduce avoidable hospital admissions and delay or reduce reliance on long-term care and more intensive disability supports.

Removing or restricting rehabilitation does not eliminate the participant’s need for rehabilitation. Instead, it risks functional deterioration, poorer quality of life and increased reliance on carers, support workers, assistive equipment, emergency departments, hospitals, aged care and other government-funded systems. While the financial cost of an unavoidable hospital admission may ultimately fall to a state health system such as SA Health rather than the NDIS, transferring the financial burden to another government system should not make preventable deterioration or hospitalization an acceptable outcome for a person with disability.

We are concerned that reductions in rehabilitation funding for participants with permanent neurological and physical disabilities may therefore be both clinically unsafe and economically short-sighted. Funding decisions should consider a participant’s long-term functional outcomes, independence, safety and quality of life, rather than focusing primarily on reducing the immediate cost of an individual NDIS plan or whether future costs can be transferred to another government system.

Annual Report No. 2 of the 48th Parliament

Submission 34

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The objective of the NDIS should be to invest in appropriate, evidence-based supports that build and maintain capacity, prevent avoidable deterioration and enable people with permanent disability to live as independently, safely and meaningfully as possible. Rehabilitation that is directly attributable to a participant’s permanent disability and is necessary to build or maintain functional capacity should therefore be clearly recognised and protected within the NDIS.

Support Needs Assessments for Planning/Funding

We hold serious concerns regarding proposals for support needs assessments to be administered by non-clinically qualified NDIS employees without adequate weighting given to allied health and medical evidence.

Many NDIS participants live with cognitive, neurological, psychosocial, intellectual, or communication-related disabilities that affect their ability to independently participate in assessments or accurately communicate their needs and limitations.

Without meaningful input from treating allied health professionals and medical practitioners who understand the participant’s clinical history and functional capacity, there is a substantial risk of inaccurate assessments, inappropriate funding reductions, and unsafe support outcomes.

Participant assessments must remain evidence-based, clinically informed, and supported by qualified healthcare professionals.

Suspension of Funding Following “Reasonable Attempts”

We are concerned by provisions allowing participant funding to be suspended or revoked where participants are deemed “uncontactable after reasonable attempts.”

This terminology is ambiguous and fails to account for the realities many participants face, including hospitalisation, mental health crises, unstable housing, communication barriers, homelessness, domestic violence, or reliance on carers and advocates to manage correspondence. Our service has supported participants who have spent extended periods in intensive care or hospital settings without access to phones, email, or mail. Under the proposed provisions, there is concern that individuals could lose funding during periods of medical crisis despite urgently requiring supports upon discharge.

Greater safeguards, clearer definitions, and compassionate review processes are required to ensure vulnerable participants are not unfairly penalised.

Submission 34

\ADELAIDE WELFARE SOCIETY

Automated Planning and Computer–Generated Budgets

We are troubled by proposed automated planning systems and computer-generated participant budgets.

The NDIS participants often have highly complex and individualised circumstances that cannot be accurately captured through standardised algorithms or automated assessments. Effective planning requires nuanced consideration of allied health evidence, psychosocial factors, communication barriers, cultural needs, and fluctuating functional capacity.

The proposed approach raises concerns similar to those identified during the former Centrelink Robodebt scheme, where automated decision-making processes contributed to widespread errors, distress, and unfair financial consequences.

A significant risk exists that providers may deliver services in good faith under existing plans only to later discover funding has been reduced or withdrawn, potentially leaving participants personally liable for unpaid invoices, which essentially puts providers further out of pocket when these funds are unable to be recovered.

These proposals appear inconsistent with Section 31 of the NDIS Act, which requires participant plans to be highly individualized, participant-directed, and tailored to unique goals and circumstances.

Fraud and Compliance Concerns & Conflict of Interest

Serious concerns exist regarding the apparent lack of timely and effective action when suspected fraud, inappropriate billing, and conflicts of interest are reported within the NDIS. As a provider, we are aware of matters involving support workers that have been reported on multiple occasions, including allegations of workers billing for time spent at a participant’s hospital bedside when that support was not required, attending a participant’s home when the participant was not present (and hadn’t been booked) but billing for the service regardless. Despite concerns being reported and follow-up occurring with the relevant fraud team, an effective resolution or meaningful action hasn’t been observed to prevent this conduct from continuing.

Concerns also have been raised through the NDIS Quality and Safeguards Commission and escalated with assistance from a Member of Parliament in some instances. While those concerns have been acknowledged, they haven’t necessarily resulted in clear or timely resolutions.

A situation has occurred where significant concerns were encountered about conflict of interests within support coordination; e.g., if a support coordinator employs the same people delivering substantial portions of funded supports to participants, there may be financial incentives involved maintaining worker funding.

The experience includes one instance wherein review opposition by a Support Coordinator arose during assessment concerning whether reducing support work funds would occur.

Annual Report No. 2 of the 48th Parliament

Submission 34

(because the support worker was employed by the Support Coordinator), despite the participant requiring reassessment for additional or appropriately allocated funding for allied health therapy.

Arangements of this nature have the potential to compromise independent decision-making, participant choice and control, and the appropriate allocation of funding according to the participant’s actual needs.

We have had multiple phone calls and emails with NDIS Quality and Safeguards Commission regarding a client who had a support worker billing his plans for services and he wasn’t even their client, they somehow obtained his details via his housemate in an independent living facility. The clients themselves and the plan nominee also reported this. The NDIS QSC investigated by contacting the Support Coordinator to look at the use of funds, and the outcome was that the Support Coordinator stated that the Support Worker was moved to other clients, they weren’t stopped from working with NDIS participants altogether. The Support worker was also employed by the Support Coordinator. After the investigation concluded, the Support Coordinator ceased all services with our therapists so we could no longer interact with the client and check in.

As a whistleblower speaking out against fraudulent activity there are no safeguards in place whereby the client or the provider making the complaint is protected.

We are additionally concerned about conflict of interest referral practices where participants appear to be directed towards particular providers located significantly further from their home despite suitable services being available closer to them. Seemingly pushed by a Support Coordinator to attend services that provide a similar but less clinically appropriate service for a particular individual, without a clear clinical or participant-driven rationale. This can increase travel costs charged to a participant’s plan and reduce the funding available for direct supports, or create undue funding costs to the NDIS. Where repeated referral patterns occur, they can also create a perception that commercial relationships or referral incentives may be influencing provider selection. We are not in a position to determine whether such incentives exist; however, these patterns warrant appropriate scrutiny where concerns are raised.

These experiences highlight a broader risk that significant resources are being directed towards reducing participant plans and scrutinising legitimate disability supports, while providers and participants can experience considerable difficulty obtaining meaningful action when potentially fraudulent billing, conflicts of interest or inappropriate use of Scheme funds are reported. A sustainable NDIS requires strong accountability on both sides: appropriate scrutiny of participant expenditure must be accompanied by prompt investigation, transparent outcomes and meaningful enforcement when credible concerns regarding provider conduct or misuse of NDIS funds are raised, whilst safe-guarding the whistleblowers attempting to stop corruption..

Planner and LAC Qualifications

and Clinical Evidence

We have significant concerns regarding the qualifications and clinical knowledge of some NDIS planners and Local Area Coordinators (LACs) who are involved in decisions that directly affect the supports available to people with complex disabilities. Planners and LACs are often required to interpret information relating to diagnoses, functional impairment, prognosis, rehabilitation needs and the recommendations of treating health professionals, despite not necessarily having clinical qualifications or discipline-specific knowledge.

Annual Report No. 2 of the 48th Parliament

Submission 34

ADELAIDE WELLBEING SOCIETY

health providers, we invest considerable professional time undertaking assessments, applying validated assessment tools and preparing detailed, evidence-based reports that explain a participant’s functional capacity, disability-related needs, risks and recommended supports. Despite this, we have experienced circumstances where this clinical evidence appears to be given limited weight, or recommendations are declined based on the judgement of a non-clinical decision-maker without a clear clinical rationale or equivalent assessment being provided. This is particularly concerning for participants with complex neurological, physical or developmental disabilities, where understanding the functional implications of a diagnosis requires appropriate professional expertise.

While funding decisions cannot and should not be determined solely by a treating provider’s recommendation, where the NDIA proposes to depart substantially from evidence provided by appropriately qualified clinicians, there should be a transparent and evidence-based rationale for doing so. For complex matters, consideration should also be given to review by an appropriately qualified and independent health professional with relevant clinical expertise. This would improve the consistency, transparency and safety of planning decisions and provide greater confidence that decisions affecting a participant’s independence, capacity and wellbeing are informed by appropriate evidence.

Support Coordination - Need for Consistent Qualification and Practice Standards

Support coordinators can play an extremely important role in helping participants understand their plans, navigate the NDIS, connect with appropriate services and advocate for their needs. However, we are concerned that the level of responsibility carried by support coordinators is not matched by sufficiently consistent minimum qualification, training and competency requirements across the sector. Support coordinators may be responsible for assisting participants to navigate complex review processes, understand funding categories, obtain appropriate evidence and make decisions about how limited plan funding should be utilised. Poor understanding of NDIS processes, evidence requirements, disability, allied health scopes of practice or available review pathways can have significant consequences for participants, including missed opportunities to provide appropriate evidence, inappropriate allocation of limited funding, engagement of services that do not address the participant’s actual needs, and potentially the loss or reduction of important supports. A lack of appropriate training can also limit a support coordinator’s ability to effectively advocate for participants when funding decisions are challenged or circumstances change.

We are apprehensive about potential conflicts of interest where support coordination organisations also provide other funded services and participants are referred to support workers or other services operated by the same organisation. While integrated service models are not inherently inappropriate, there should be strong safeguards to ensure referrals are based on participant choice, need, quality and value for money rather than the financial interests of the organization.

Given the influence support coordinators can have over how substantial amounts of public funding are spent and the outcomes achieved by vulnerable participants, we believe the NDIS should establish clear minimum competency and training requirements, ongoing professional development expectations, transparent conflict-of-interest requirements and stronger accountability standards for those delivering support.

Cost and Administrative Burden of Mandatory Registration for Allied Health

We strongly support the principle of mandatory registration for NDIS providers. Participants with disability should be able to have confidence that the organisations and individuals providing their supports meet appropriate standards of safety, quality, competency and accountability. Our concern is not with the requirement to be registered, but whether the proposed cost and administrative burden of registration is proportionate for small and medium-sized allied health providers that are already operating within established professional regulatory and accreditation frameworks.

We have been working towards undertaking Registration ourselves and the hours required for producing the requested documentation are far outside what can easily be provided by a small administration team. The documentation seems heavily geared toward Support Workers, Independent Living and Accommodation providers, not for accredited allied health professionals seeing someone in the presence of a support person for 60 mins in a professional therapy session.

For a small allied health practice, the financial and administrative requirements associated with NDIS registration can be substantial. Preparing policies and procedures, implementing additional compliance systems, undergoing audits, maintaining documentation and allocating staff time to ongoing registration requirements all carry significant costs. For smaller providers operating on relatively low margins, these requirements can become disproportionately burdensome and may ultimately affect the viability of continuing to provide NDIS services.

This is particularly concerning where allied health professionals are already subject to significant professional regulation, accreditation, codes of conduct, continuing professional development requirements and professional accountability through bodies such as AHPRA, ESSA, SPA and other recognised professional organisations. Practitioners can face serious professional consequences, including restrictions on practice or loss of registration or accreditations, where they fail to meet required professional or ethical standards. While NDIS registration serves an important purpose and should remain mandatory, there appears to be considerable opportunity to recognise these existing safeguards rather than unnecessarily duplicating them through an additional layer of costly auditing and administration.

The burden is further compounded by NDIS price limits and increasing business costs, including wages, insurance, rent, equipment, vehicles, professional development and other compliance obligations. There is a real risk that an overly complex and expensive registration model will not improve participant safety proportionately, but will instead drive reputable small allied health providers away from the NDIS market. This could reduce participant choice and access to local services, particularly in communities where accessing Allied Health Services is already difficult.

We therefore strongly support mandatory provider registration, but recommend that the registration framework adopt a proportionate, risk-based and streamlined pathway for allied health providers who are already professionally regulated or accredited. Existing AHPRA, ESSA, SPA Accreditation and equivalent Professional

Annual Report No. 2 of the 48th Parliament

Submission 34


The governance frameworks should be formally recognised within the NDIS registration process, reducing duplication, audit costs and administrative burden while still ensuring strong safeguards and accountability for participants. The objective should be to make registration rigorous enough to protect participants, but not so costly and administratively burdensome that it inadvertently forces reputable small providers out of the Scheme.

Assessments, Reports and Decision-Making

The current weight, or lack of, given to functional capacity assessments and allied health reports within NDIS planning and review processes is risky to individuals’ ongoing supports. Allied health professionals spend considerable time undertaking comprehensive assessments, using validated assessment tools, reviewing clinical history and functional performance, and preparing evidence-based reports that explain a participant’s disability-related functional impairment, risks, support needs and recommendations. Despite this, we regularly encounter situations where detailed clinical evidence appears not to have been read in full, is misunderstood, or is given limited weight in the final funding decision. This is particularly alarming when a non-clinical decision-maker determines that a recommended support is unnecessary or reduces funding without providing a clear explanation of why the clinical evidence has not been accepted. Providers are then frequently asked to prepare further reports or provide additional evidence addressing matters that have already been comprehensively documented, creating unnecessary cost, administrative burden and delays for participants and providers.

We recognise that an allied health professional’s recommendation should not automatically determine an NDIS funding decision; however, where the NDIA chooses to depart from the findings of a suitably qualified clinician, particularly following a comprehensive functional assessment, there should be a clear, evidence-based rationale for that decision. Where clinical evidence is disputed, it should be reviewed by an appropriately qualified professional with relevant expertise rather than effectively overridden by a non-clinical interpretation. Greater transparency regarding how clinical evidence has been considered would improve accountability, reduce duplication and give participants greater confidence that decisions about their supports are based on a genuine understanding of their functional needs.

Reviews, Change of Circumstances, Appeals and Tribunal Process

The current processes for changes of circumstances, plan reassessments, internal reviews, appeals and matters progressing to the Administrative Review Tribunal (ART) can be lengthy, complex and costly for participants, families and providers.

We have experienced circumstances where substantial clinical evidence and detailed allied health reports have already been provided, yet the information appears not to have been fully considered or understood,

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Submission 34


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with participants subsequently being asked to obtain further assessments or additional reports addressing issues that have already been documented.
This creates a particularly concerning cycle for participants whose plans have insufficient funding to pay for the additional evidence being requested. To challenge a decision or demonstrate a change in functional need, participants may require updated assessments and reports from occupational therapists, physiotherapists, exercise physiologists, speech pathologists or other clinicians, yet they may have no remaining funding available to pay for this professional work.

As a small allied health provider, we have spent countless hours completing assessments, preparing additional reports, responding to requests for clarification and providing further evidence for participants undergoing reviews and appeals where there has been insufficient funding available to compensate providers for this work. Providers are frequently faced with an unacceptable choice: undertake significant professional work without payment or decline to provide evidence that may be critical to the participant’s ability to challenge a decision.

This is neither fair nor sustainable, particularly for small providers operating within capped NDIS pricing and increasing business costs.

More importantly, the current process risks creating an inequitable system in which a participant’s ability to successfully challenge an NDIS decision can depend on their personal financial capacity or whether their treating clinicians are willing and financially able to provide services without payment. Participants who can privately fund comprehensive assessments, reports and professional assistance are inherently better positioned to provide the evidence required through review and tribunal processes than participants who cannot. Access to a fair review process should not depend on a person’s capacity to privately purchase evidence.

Where the NDIA requires additional clinical evidence for a change of circumstances, reassessment, internal review or ART matter, there should be an accessible mechanism to fund the reasonable cost of obtaining that evidence. There should also be greater accountability for ensuring that evidence already submitted is properly considered before participants are required to obtain further reports. A fair appeal system must provide participants with a genuine and equitable opportunity to challenge decisions, regardless of their financial circumstances or the capacity of their treating providers to undertake unpaid work.

Planning Meetings and the Planning Process

We are uneasy about the accessibility and fairness of the current NDIS planning process. Participants and families can receive very little notice of planning calls, leaving insufficient time to prepare, arrange for a support person or advocate to attend, consult with treating professionals, or ensure that relevant clinical evidence has been submitted and considered. Significant decisions about a participant’s supports and funding can therefore be influenced by an unexpected or poorly prepared telephone conversation, sometimes without the participant fully understanding the purpose or potential consequences of the questions being asked.

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Submission 34

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The is particularly problematic for people with disability, whose parents and carers may unintentionally understate the participant’s support needs. Questions about functional capacity are not always asked with sufficient detail or clinical understanding.

For example, asking a participant whether they “can get dressed” may produce a simple answer of “yes”, despite the person requiring prompting, supervision, adaptive equipment, substantially more time, assistance with particular garments, or experiencing fatigue, pain, cognitive difficulties or safety risks while completing the task.

There is an important distinction between being technically capable of completing an activity and being able to complete it independently, safely, reliably, repeatedly and within a reasonable period of time. Without appropriate assessment, significant functional impairment can easily be overlooked.

the lack of routinely available face-to-face planning meetings further compounds these issues. A Scheme designed for people with disability should recognise that telephone-based communication will not be appropriate or accessible for every participant. Participants may have cognitive, communication, psychosocial, hearing, intellectual or other disability-related needs that affect their ability to understand questions, process information and accurately communicate their circumstances during a telephone call. Families from culturally and linguistically diverse backgrounds and participants with limited understanding of the NDIS may face additional barriers.

Participants should be provided with reasonable notice of planning and reassessment meetings, clear information about what will be discussed, an opportunity to submit evidence beforehand, and sufficient time to arrange for an advocate, family member, support coordinator or treating professional to participate where appropriate. Participants should also have genuine choice regarding how their planning meeting occurs, including access to face-to-face or other accessible formats where required. A planning process should be designed around the communication and disability needs of the participant, rather than requiring the participant to adapt to an administrative process that may itself create barriers to their participation.

Duplication of Services

Through a large number of Planning, Review ART processes, we have received documentation with repeated characterisation of multidisciplinary allied health supports as a “duplication of services”. Participants with complex disabilities frequently require input from multiple allied health disciplines, including occupational therapy, physiotherapy, exercise physiology and speech pathology. While there may be some overlap in broad goals, each profession has a distinct scope of practice, clinical expertise and therapeutic purpose.

For example, an occupational therapist may address functional independence, activities of daily living, assistive technology and environmental barriers; a physiotherapist may address gait, transfers and hands-on therapy; an exercise physiologist may provide ongoing disability-related exercise interventions to build or maintain physical capacity; and a speech pathologist may address communication and swallowing. These services can work towards a shared participant goal while providing fundamentally different interventions.

We have provided reports that specifically explain the respective roles of different clinicians and demonstrate why recommended supports are complementary rather than duplicative. Despite this, participants and providers can continue to be asked during planning, review and Administrative Review Tribunal processes to

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Annual Report No. 2 of the 48th Parliament

Submission 34

justify why multiple allied health disciplines are required, even where this has already been comprehensively addressed in the clinical evidence. This can result in unnecessary additional reports, delays and administrative burden, and in some cases may contribute to reductions in clinically appropriate supports. This is again evidence that the planners do not understand the evidence, the clinical indicators, or the scope of the various therapists.

A multidisciplinary approach should not be considered duplication simply because two professions contribute towards the same broad functional outcome. In many cases, coordinated multidisciplinary intervention is precisely what enables a participant to achieve that outcome. Where the NDIA considers that recommended allied health supports constitute duplication, the decision should clearly identify the specific interventions considered duplicative and explain the evidence supporting that conclusion. Where detailed clinical evidence demonstrates that each discipline is addressing a distinct disability-related need or providing a different intervention, that evidence should be appropriately considered and given meaningful weight.

Fluctuating Needs and Funding Timelines

The current NDIS funding and review processes do not always respond adequately to the fluctuating, progressive or time-sensitive nature of disability. Neurodegenerative conditions such as Multiple Sclerosis can involve significant and sometimes rapid changes in function, fatigue, mobility and support requirements; however, requests for changes to funding can take months to assess and implement. By the time additional supports are approved, a participant’s circumstances may have changed substantially, or an important opportunity to prevent deterioration and maintain independence may have been lost. A disability support system must have sufficient flexibility to respond to changing functional need in a timeframe that reflects the reality of the participant’s condition, rather than relying on administrative processes that can take many months.

the consequences of delay are particularly concerning participants requiring time-critical supports.

We have experienced communication device applications taking 12 months or longer to progress. For a non-speaking or minimally speaking child, a year represents a significant period of development during which access to effective communication can influence language development, participation, education, behaviour, relationships and independence. For an adult losing their speech this is a critical intervention and support. Where an application is subsequently declined, families may then face further delays of approximately 12 weeks or more while additional evidence is obtained and the application or review process is commenced again.

there are not simply administrative delays; they can represent lost developmental opportunities and critical communication abilities which are crucial to a person’s independence.

we also see participants requiring additional funding for supports where the clinical need has been identified and justified, yet requests for additional funding are not necessarily approved in a timely or predictable manner.

pareents and participants will become reluctant to request a reassessment or advocate for additional supports because they fear that reviewing the plan may result in existing supports being reduced.

o participant or family should feel that seeking assistance for a newly identified or increased disability-related need places their existing essential supports at risk.

Submission 34

ADELAIDE WELLBEING SOCIETY

The NDIS requires more responsive mechanisms for fluctuating, progressive and time-sensitive disability needs, including expedited pathways where delays may result in deterioration, increased risk or the loss of a critical developmental opportunity. Funding decisions should recognise that early and appropriately timed intervention can not only improve participant outcomes and quality of life, but may also reduce the need for more intensive and costly supports in the future.

The financial viability of allied health providers within the NDIS is becoming increasingly challenging, particularly for small and medium-sized practices. Allied health businesses generally operate with relatively small margins while carrying substantial operating costs, including clinician wages and employment on-costs, professional and public liability insurance, clinical equipment and assessment tools, leases, vehicles, administration, supervision, professional development, accreditation and compliance. At the same time, providers are frequently absorbing the cost of clinically necessary work that cannot be billed because a participant’s funding has been reduced or exhausted. This includes assessments, reports, communication with families and other professionals, and work required to support participants through plan reviews and appeals. While providers may undertake this work because of their professional and ethical commitment to their clients, routinely relying on allied health businesses to provide unfunded professional services is not a sustainable funding model.

Provider travel is a particularly significant viability and access issue. Delivering a service in a participant’s home, school, workplace or community requires the clinician to be paid for their time regardless of whether the NDIS reimburses that time at the same rate as direct service delivery. Travel also carries additional costs including vehicles, fuel, insurance, maintenance and administration. Restrictions on the amount of travel that can be claimed, including limits on travel time and reduced travel rates, do not necessarily reflect the actual cost to a provider of employing a qualified clinician for that period. Providers cannot simply reduce a clinician’s wage by the same proportion because the NDIS has reduced the amount that can be claimed for travel.

For example, a child receiving support at home in Two Wells from the office location is a 30 min drive in each direction - 60 minutes total. Under the current travel reductions the maximum charge is 30 mins billed at half the usual rate, which is essentially 25% of the in-clinic service which would alternatively be billed. This 25% charge does not even pay the salary for the employee let alone the additional costs for running a business, Superannuation, fuel, car expenses etc. A provider would in fact lose money by providing services in that area.

The consequences extend well beyond provider profitability. When outreach becomes financially unviable, providers are forced to restrict their service radius, require participants to attend clinics, or cease offering mobile services altogether. This disproportionately affects participants from lower socioeconomic communities, families without reliable transport, people whose disability prevents them from travelling independently, families where parents or carers work full-time, and participants who require assessment or intervention within their natural environment. A reduction in travel funding can therefore translate directly into a reduction in access to disability supports.

A sustainable NDIS requires a sustainable provider market. Pricing decisions should reflect the genuine cost of employing appropriately qualified allied health professionals and operating safe, compliant and high-quality services, including the costs associated with travel and outreach. Continuing to constrain pricing while

Submission 34

ADELAIDE WELLBEING SOCIETY

increasing regulatory, employment and operational costs risks driving experienced providers away from the Scheme, reducing participant choice and creating greater access inequity. Allied health pricing and travel arrangements should therefore be regularly reviewed against actual service-delivery costs and should recognise that maintaining a viable provider market is fundamental to ensuring participants can access the supports funded in their plans.

The increasing cost of living and cost of operating an allied health practice have not been adequately reflected in NDIS pricing. Over recent years, providers have experienced substantial increases in wages, s \uperannuation, rent and lease costs, insurance, utilities, vehicles and fuel, clinical equipment, assessment tools, professional development, accreditation and general business expenses. Many of these costs are unavoidable and continue to increase through inflation, Award wage increases and other regulatory requirements, while price limits for a number of allied health services have remained frozen, have been reduced or have not increased at a rate that reflects the actual increase in service-delivery costs. A price freeze does not mean that the cost of providing a service has remained frozen; rather, the difference is absorbed by the provider each year, progressively reducing the financial viability of delivering NDIS services.

Australian Bureau of Statistics Data shows that CPI inflation has risen approximately 28% in the same period of time since the NDIS Occupational Therapy and Speech Pathology prices have been frozen and EP rates have been reduced.

Whilst we provide OT and Speech where NDIS pricing has been frozen and costs are rising, we also provide Exercise Physiology where pricing has reduced and this is a particularly concerning example. Exercise physiologists provide complex disability-related therapy, and capacity-building interventions for participants with neurological conditions, acquired brain injury, stroke, amputation and other permanent disabilities, to name just a few areas of scope of practice. Despite being an equally university-qualified and accredited allied health provider, the NDIS pricing arrangements for Exercise Physiology have reduced and were already ata lower rate than other allied health professions. This has resulted in a substantially lower effective hourly rate than that available to many other allied health disciplines. Once GST is accounted for where applicable, the amount retained by the provider can be approximately $147 per hour, compared with rates of approximately $193-$250 or more per hour for a number of other allied health services. This disparity does not reflect a comparable reduction in the costs of employing an Accredited Exercise Physiologist or operating an exercise physiology service. Exercise physiology practices when providing disability-specific equipment and rehabilitation gyms require thousands of dollars per month in equipment and commercial lease costs, and still incur clinician wages, superannuation, leave entitlements, administration, insurance, professional accreditation, vehicles and other operating costs, whereas other therapies can be provided with minimal equipment and building costs. The acknowledgement of costs for Exercise Physiology services is well recognised within other Government Funding Schemes, however NDIS remains underfunded when compared to other services.

The below table highlights the current 2026 pricing differences between the varied funding models.

Submission 34

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Pricing of Exercise Physiology across other Funding Models:

A table showing exercise physiology prices.

Funding Model \$Hr Without GST $/Hr With GST Difference in price per hour Difference in after GST is recovered by ATO
Medicare $190.20 $28.21 $42.94
DVA $225.30 $247.83 $85.84 $78.04
Workcover $188.90 $207.79 $45.80 $41.64
Lifetime Support Agency $188.90 $207.79 $45.80 $41.64
NDIS $147.26 $161.99

The continued compression of provider margins has consequences beyond business profitability. Providers may be forced to reduce NDIS caseloads, limit outreach and travel, shorten the geographical areas they service, reduce investment in equipment and professional development, or withdraw from the Scheme altogether. This ultimately affects participant choice, continuity of care and access to appropriately qualified clinicians. NDIS pricing should therefore be subject to a transparent and regular indexation mechanism that reflects actual increases in wages, employment on-costs, inflation and the genuine cost of delivering compliant allied health services. There should also be a review of significant pricing disparities between allied health disciplines to ensure that price limits are based on the reasonable cost of delivering each professional service and do not inadvertently make particular evidence-based supports financially unviable.

The NDIA is currently undertaking a $20 million Quality Supports Therapy Pilot involving 27 registered therapy providers to better understand the actual cost and characteristics of delivering quality NDIS therapy. Participating providers are providing financial reports and data regarding service delivery, workforce and participant outcomes, with the findings intended to inform future NDIS therapy pricing reform. This work is particularly significant given that substantial policy and funding changes affecting therapy are occurring while the NDIA’s own work to establish an evidence-based understanding of the cost of delivering quality therapy remains underway.

We are also concerned that the eligibility requirements for the Therapy Pilot predominantly capture large providers, including requirements relating to substantial NDIS therapy revenue and participant numbers. Small and medium allied health businesses operate under different cost structures and do not necessarily have the economies of scale available to large organisations. The actual costs incurred by smaller providers - including workforce on-costs, non-billable clinical and administrative time, supervision, compliance, registration, professional development, insurance, premises, clinical equipment and assessment tools, software and outreach - must also be adequately represented when determining sustainable NDIS therapy pricing.

Submission 34

ADELAIDE WELLBEING SOCIETY

The data that the NDIA Quality Supports Therapy Pilot receives from large providers will not be reflective of the costs that small to medium businesses face.

gst on Exercise Physiology Exercise Physiotherapy (EP) is the only Allied Health service billable in the NDIS that loses 10% of their revenue to GST. Accredited Exercise Physiologists are recognised as allied health professionals by Medicare, with eligible Medicare-funded EP services able to be GST-free, yet EP does not receive equivalent treatment when delivered as an NDIS support. This is particularly concerning because EP already has one of the lowest allied health NDIS price limits, with GST further reducing the amount available to providers to deliver the service.

Exercise & Sports Science Australia (ESSA) has repeatedly raised this disparity and advocated for EP to be ecognised as a GST-free health service. ESSA has highlighted that Exercise Physiologists face comparable employment and operating costs to other allied health professions despite receiving a substantially lower effective NDIS rate. In fact, as mentioned above, the expenses related to providing the equipment required to uundertake the therapy safely far outweigh the equipment costs for other Allied Health Professionals. The 2026 Deloitte Access Economics report commissioned by ESSA also estimated that exercise physiology generates approximately $2.50 in economic benefits for every $1 invested, including benefits associated with avoided hospitalisations and reduced health-system utilisation.

We acknowledge that the NDIA itself does not determine Australia’s GST legislation or ATO rulings and inferior cannot simply remove GST from Exercise Physiology. However, the fact that eligible Exercise Physiology services can already receive GST-free treatment when delivered through Medicare demonstrates that different treatment is possible under Commonwealth taxation arrangements. We therefore ask the Committee to recommend that the Australian Government, including the relevant Treasury and taxation authorities, address this inconsistency and establish an appropriate GST-free pathway for Exercise Physiology services delivered to NDIS participants.

Exercise Physiology is an evidence-based allied health intervention that supports disability rehabilitation, fuctional capacity, independence and prevention of deterioration. The combination of a comparatively low NDIS price limit and inequitable GST treatment threatens the sustainability of these services and ultimately reduces participant choice and access.

Value for Money - Exercise Physiotherapy Exercise Physiology (EP) is an evidence-based allied health intervention that can provide significant value for money within the NDIS through maintaining and improving functional capacity, independence, community participation and quality of life. The 2026 Deloitte Access Economics report commissioned by Exercise & sports Science Australia (ESSA) estimated that exercise physiology generates approximately $2.50 in economic benefits for every $1 invested, including benefits associated with avoided hospitalisations and reduced health-system utilisation. Despite this evidence, we continue to see EP questioned on the basis of value for money“ or considered a duplication of physiotherapy, occupational therapy, or personal training despite each profession having a distinct scope of practice and role in supporting participants.

Submission 34

ADELAIDE WELLBEING SOCIETY

it is also important that the NDIS does not treat health and disability as entirely separate concepts. For many people with permanent physical and neurological disabilities, their disability directly affects their health, and deterioration in health can in turn significantly worsen their functional capacity and disability-related support needs. For example, a participant with reduced mobility and physical capacity may experience preventable deterioration or hospitalisation, followed by further deconditioning and functional loss during admission. Their underlying disability may then limit their ability to regain their previous level of function following discharge, resulting in reduced independence, increased support requirements and poorer quality of life.

Apropriate EP intervention can help maintain physical capacity, prevent deterioration and support recovery and independence. These outcomes represent genuine value for money for the NDis, even where some of the broader financial benefit is ultimately realised by the health system. EP should therefore be recognised and funded according to its evidence base, distinct professional role and contribution to participants’ long-term functional outcomes and quality of life.

The proposed 10% reduction to capacity building funding is of significant concern to allied health providers and participants alike.

Reducing funding does not reduce participant need. Instead, it limits access to therapy, rehabilitation and other essential allied health interventions that are critical for maintaining function, independence, and quality of life.

our organisation already supports participants whose plans have been substantially reduced. In some cases, clinicians continue providing services without billing because withdrawing supports would place vulnerable individuals at risk. While providers attempt to maintain continuity of care, this is financially unsustainable over the long term.

further reductions to funding, combined with existing travel cuts and stagnant pricing, risk forcing providers to reduce services, cease outreach programs, or leave the sector entirely. These impacts are particularly severe for participants living in low socioeconomic areas, rural communities, or households experiencing intergenerational disability and poverty.

the reductions to NDIs travel charging arrangements have disproportionately impacted participants with the highest support needs, particularly families without access to transport, families living in low socioeconomic areas, and households where multiple family members live with disability.

For many participants, home-based and school-based allied health services are essential rather than optional. Despite the reduced reimbursement model, our organization has continued to provide outreach services because discontinuing supports would leave vulnerable participants without access to care.

However, many providers have been unable to sustain outreach work under the current arrangements. Clinicians travelling to homes and schools are effectively billing at half rate during travel time while being able to provide fully-billed concurrent services elsewhere. Combined with rising fuel, vehicle, and staffing costs, this creates significant financial losses for providers delivering community-based services. These changes risk creating inequitable access to care where the participants facing the greatest barriers to attendance are the very individuals most likely to lose services.

Recommendations to the Joint Standing Committee on the NDIS

Adelaide Wellbeing Society respectfully recommends that the Joint Standing Committee consider the following reforms to improve the fairness, effectiveness and long-term sustainability of the NDIS:

  1. Improve consistency and transparency in planning decisions by establishing clearer national decision-making standards so that participants with comparable functional needs receive reasonably consistent funding outcomes, while still maintaining individualised planning.

  2. Give appropriate weight to qualified clinical evidence. Where the NDIA chooses not to accept recommendations contained within functional capacity assessments, allied health reports or medical evidence, the reasons should be clearly documented and supported by appropriate evidence. Where clinical evidence is disputed, it should be reviewed by a suitably qualified professional with relevant clinical expertise.

  3. Improve the qualifications and training of planners and LACs, particularly in disability, functional capacity, allied health scopes of practice, rehabilitation and interpretation of clinical evidence.

  4. Introduce minimum competency and training standards for Support Coordinators, with competency and accreditation requirement , together with stronger conflict-of-interest requirements where organisations provide both support coordination and other NDIS-funded services.

  5. Protect disability-related rehabilitation funding, particularly for participants with permanent neurological and physical disabilities. Rehabilitation required to maintain function, independence, mobility and community participation should not be excluded simply because it also produces a health benefit.

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Annual Report No. 2 of the 48th Parliament

Submission 34

6. Recognise the relationship between disability and health.

Funding decisions should consider the consequences of functional deterioration, including loss of independence, increased support requirements and avoidable hospitalisation, rather than treating the health and disability systems as entirely separate.

7. Create a funded pathway for assessments and reports required by the NDIA.

Where additional clinical evidence is requested for a reassessment, change of circumstances, internal review or Administrative Review Tribunal matter, participants should have access to funding to obtain that evidence rather than being required to pay privately or rely on providers undertaking unpaid work.

8. Reform review and appeal processes to reduce excessive delays and ensure evidence already provided is properly considered before participants are asked to obtain additional assessments or reports. Access to a fair review should not depend on a participant’s personal financial capacity. The process of review and appeal should also not take a long period of time whereby the existing evidence is considered no longer current.

9. Improve planning meeting processes by providing reasonable notice, allowing participants time to prepare and submit evidence, facilitating the involvement of advocates, family members or treating professionals, and offering face-to-face or other accessible planning options where appropriate.

10. Establish expedited pathways for fluctuating, progressive and time-sensitive disability needs, including urgent assistive technology and additional therapy or other supports where lengthy administrative delays may result in deterioration or lost developmental opportunities.

11. Improve recognition of multidisciplinary allied health care. Different allied health disciplines contributing towards the same participant goal should not automatically be considered duplication where each profession is providing a distinct intervention within its scope of practice.

13. Proceed with mandatory provider registration, but adopt a proportionate, risk-based approach. We support mandatory registration; however, a streamlined and lower-cost pathway should be established for allied health providers already subject to professional regulation or accreditation through AHPRA, SPA, ESSA etc., and equivalent professional bodies. Existing regulation should be recognised rather

Annual Report No. 2 of the 48th Parliament

Submission 34

ADELAIDE WELLBEING SOCIETY

The current excessive documentation, non-clinical activity requirements, and policy and procedure administration burden.

  1. Review NDIS allied health pricing and introduce appropriate indexation that reflects increases in Award wages, superannuation, insurance, rent, equipment, compliance and other genuine costs of delivering allied health services. A sustainable NDIS requires a sustainable provider market.

  2. Review provider travel arrangements to ensure outreach remains financially viable. Travel policy should recognise the actual employment and operating costs incurred while clinicians travel and the importance of outreach for participants who cannot reasonably access clinic-based services. The cost to undertake travel to provide services should not be less than the equivalent face-to-face services, or it will continue to limit services to those who need travel.

  3. Review the pricing of Exercise Physiology within the NDIS, including the disparity between EP and other allied health professions, taking into account its evidence base, operating costs and demonstrated contribution to maintaining functional capacity and preventing deterioration.

  4. Request whole-of-government action on the GST treatment of Exercise Physiology. While GST legislation is not determined by the NDIA, the Australian Government should work with Treasury and relevant taxation authorities to address the disparity whereby eligible EP services can receive GST-free treatment through Medicare but do not receive equivalent treatment when provided as an NDIS support, essentially handing 10% of their total revenue back to the Tax Department on top of their usual income tax.

  5. Recognise the value for money of preventative and capacity-building allied health supports. Assessment of value should consider long-term outcomes—including maintenance of independence, prevention of deterioration, reduced need for higher-cost supports and improved quality of life—rather than focusing solely on the immediate cost of a participant’s plan.

  6. Review PACE plan administration and budget structures to make plans easier for participants and families to understand, ensure funding categories appropriately accommodate multidisciplinary care, and reduce situations where necessary assessments and reports inadvertently exhaust funding required for ongoing therapy.

  7. Ensure future NDIS reform remains participant-centred, clinically informed and evidence-based. Scheme sustainability should be pursued through effective fraud prevention, efficient administration, appropriate pricing and evidence-based allocation of supports, rather than through funding reductions that transfer costs to participants, families, providers or other government systems.

Overall Recommendation

We support reform that strengthens the sustainability, integrity and accountability of the NDIS. However, financial sustainability should not be measured solely by reductions in individual participant plans. A sustainable Scheme must also consider participant outcomes, provider viability, prevention of functional deterioration, equitable access to services and the longer-term costs created when appropriate supports are withdrawn. We ask the Committee to ensure that future reforms preserve the fundamental purpose of the NDIS: supporting people with disability to maintain and build their independence, participate in their communities and achieve the best possible quality of life.

 

 

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