Dear Committee Secretary and Members of the Joint Standing Committee on the National Disability Insurance Scheme,

I am writing as an experienced frontline NDIS practitioner to raise what I believe is an important systemic issue concerning provider accountability, participant safeguarding, plan integrity, and the practical ability of Support Coordinators and Psychosocial Recovery Coaches to respond when concerning provider practices are identified.

I currently work independently as both a Level 2 Support Coordinator and Psychosocial Recovery Coach, predominantly supporting participants with psychosocial disability and complex support needs. My professional qualifications include a Master of Community Development, Bachelor of Dementia Care, Diploma of Professional Counselling and Certificate IV in Child, Youth and Family Intervention. I am also currently undertaking postgraduate studies in Client Assessment and Case Management at Swinburne University, with my current studies focusing on professional and ethical practice, legislation, professional responsibilities, safeguarding and accountability. This has further prompted me to critically examine how these obligations translate into day-to-day NDIS practice and, importantly, where gaps appear to exist between professional responsibility and the mechanisms available to practitioners to act upon serious concerns.

I am increasingly concerned by patterns I am observing across NDIS service delivery that extend beyond ordinary professional disagreement or poor communication.

These include:

• apparent over-servicing and delivery of supports without sufficient regard to the sustainability of a participant’s plan;

• providers delivering hours beyond agreed allocations or service arrangements;

• inadequate documentation demonstrating what NDIS-funded support was actually delivered;

• concerns about whether invoicing and support-item codes accurately represent the services provided;

• concerns regarding cancellation and non-face-to-face claiming practices;

• insufficient transparency regarding worker qualifications, experience and NDIS Worker Screening;

• significant service decisions being made with vulnerable participants without adequate consideration of whether the participant understands the financial or service implications;

• reluctance by some providers to provide reasonable information required for effective coordination of a participant’s supports; and

• situations where legitimate safeguarding, budget or compliance concerns raised by the person coordinating the participant’s supports are disregarded rather than addressed collaboratively.

I recognise that individual allegations must be properly investigated and substantiated. I am therefore not asking the Committee to determine whether individual providers have breached

A gap between responsibility and authority

Support Coordinators and Psychosocial Recovery Coaches can be among the professionals with the broadest understanding of how a participant’s NDIS supports are operating collectively. We may understand the participant’s functional vulnerabilities, communicate across multiple providers, observe expenditure patterns and identify when service arrangements are becoming unsafe, ineffective or financially unsustainable.

Yet when concerning provider practices are identified, our practical authority to address them can be extremely limited.

We can raise concerns, document risks, educate and support the participant to make informed decisions, communicate with providers and report serious matters to the appropriate authorities. However, providers may disregard attempts at coordination and continue delivering and claiming supports.

This raises what I believe is an important systemic question:

Who is actually responsible for protecting the integrity and sustainability of an individual participant’s plan before the funding is exhausted or harm occurs?

The NDIA administers the Scheme. The NDIS Quality and Safeguards Commission regulates provider conduct, quality and safety. Plan managers process claims. Providers deliver services. Support Coordinators and Recovery Coaches assist participants to implement their plans.

In practice, however, there can appear to be no adequately resourced person responsible for bringing all of this information together, identifying concerning patterns early and ensuring action occurs before the participant experiences harm or loses access to essential supports.

Participant choice and control must remain central

I strongly support participant choice and control. However, genuine choice and control requires informed decision-making.

Some participants I work with experience significant psychosocial, intellectual, cognitive or functional impairment. They may have difficulty understanding complex service agreements, NDIS pricing arrangements, invoices, support-item codes, cancellation provisions or the longer-term consequences of consuming substantial portions of their funding early in a plan.

Respecting choice and control should not mean that potentially exploitative, excessive or inappropriate practices are left unchallenged simply because a participant initially agreed to a service.

In my view, safeguarding and autonomy must operate together.

Support Coordination and Psychosocial Recovery Coaching

I am also concerned about the lack of practical clarity regarding the distinction between Support Coordination and Psychosocial Recovery Coaching when these situations arise.

I work under Support Coordination funding for some participants and Recovery Coaching funding for others.

I would welcome clearer national guidance regarding which role is responsible for:

• monitoring implementation and sustainability of the participant’s plan;
• coordinating multiple providers;
• identifying inappropriate or excessive service delivery;
• identifying and escalating safeguarding concerns;
• monitoring expenditure where it affects continuity of essential supports;
• requesting information necessary to understand services being delivered;
• responding to concerns about worker suitability, qualifications or screening; and
• identifying and escalating suspected inappropriate claiming or Code of Conduct concerns.

A particularly important question arises where a participant has Psychosocial Recovery Coaching but no Support Coordination.

If broader coordination and plan-monitoring responsibilities do not fall within Recovery Coaching, it is unclear who is expected to perform those functions for a vulnerable participant. If they do fall within Recovery Coaching, I believe this needs to be clearly articulated and appropriately funded.

The funding and accountability issue

There is also a practical resourcing problem.

Support Coordinators and Recovery Coaches may be expected to coordinate complex support environments, monitor plan implementation, communicate with providers, identify safeguarding risks, respond to crises, support participant capacity building, obtain evidence for reassessments and escalate concerns.

Yet the funded hours available to undertake these functions can be extremely limited.

There is a risk of creating a system in which professionals are expected to identify and respond to increasingly complex governance, integrity and safeguarding issues without being adequately funded or empowered to undertake that work effectively.

What I am asking the Committee to consider

I respectfully ask the Committee to consider whether the current NDIS framework provides sufficient:

1. clarity regarding the respective responsibilities of Support Coordinators and Psychosocial Recovery Coaches;
2. mechanisms for these practitioners to raise and escalate provider conduct concerns before participant harm or plan exhaustion occurs;
3. accountability for providers who disregard legitimate coordination, safeguarding and plan-sustainability concerns;

Submission 36

4. safeguards for participants who may have reduced capacity to identify over-servicing, inappropriate claiming or financially unsustainable service arrangements;

5. expectations regarding minimum worker screening, qualifications, documentation and transparency across registered and unregistered NDIS providers;

6. mechanisms for early identification of patterns of over-servicing, inappropriate claiming and other concerning practices at the individual participant-plan level; and

7. adequate funding for the coordination, safeguarding, monitoring and professional accountability work necessary to make these protections effective.

I have separately sought formal guidance from the NDIA and the NDIS Quality and Safeguards Commission regarding my own professional responsibilities when these situations arise. I am bringing this matter to the Committee because I believe what I am observing extends beyond isolated incidents or individual provider conduct and represents a broader systemic governance, safeguarding and Scheme-integrity concern. Unfortunately, I encounter issues involving provider conduct, questionable service delivery, documentation and claiming practices, plan sustainability, professional boundaries and participant safeguarding on an almost daily basis, and I have accumulated many practical examples across different participants, providers and circumstances. I would be very willing to provide evidence to the Committee if this would assist its work, including de-identified case examples and documented patterns demonstrating how these issues occur in frontline practice. Subject to appropriate participant consent, privacy and confidentiality requirements, I would also be willing to provide further supporting evidence, make a more detailed written submission, participate in consultation or give evidence at a Committee hearing if the Committee considered my professional experience useful.

I believe experienced Support Coordinators and Psychosocial Recovery Coaches occupy a valuable position within the NDIS because we often see how the different parts of a participant’s plan operate together. This can place us in a position to identify emerging safeguarding, expenditure and provider-practice concerns before they result in significant harm or premature exhaustion of a participant’s funding.

However, for that protective function to operate effectively, there must be clearly defined responsibilities, appropriate professional boundaries, effective escalation pathways and sufficient funding to undertake this work properly.

I respectfully ask the Committee to consider these issues as part of its ongoing oversight of the integrity, governance and sustainability of the NDIS.

Thank you for considering my concerns. I would welcome the opportunity to provide further information or evidence if it would assist the Committee.