The Provider Loft

Supporting small and medium NDIS and health providers in Australia

NDIS 2024-2025 Reforms

Divided we fall: provider vs. provider, and the unbundling of allied health provider NDIS therapy services 

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The big picture:

The 2024-2025 Annual Pricing Review, released by the NDIA on 11 June 2025, is full of bad news for allied health providers and the participants we serve. Most commentary so far has focused – quite rightly – on the most imminent price limit cuts for physiotherapists, dietitians, and podiatrists, as well the tough pricing limits for allied health provider travel. But there’s a lot more in the review to think about.    

The bigger picture:

The NDIA has abandoned the idea of a flat hourly NDIS price limit for allied health therapies, deeming it “no longer necessary to facilitate market expansion” (p12). It has signalled it will move toward:

  • a differentiated pricing approach (pp13, 88); and
  • an unbundling of some allied health services to provide greater transparency and oversight of allied health therapy services/activities (pp82-84).  

Market context:

In the six months to December 2024: 

  • more than 55,000 allied health providers provided NDIS services to almost 413,000 participants;
  • total allied health therapy payments reached $2.4 billion; and
  • five types of therapies accounted for more than 75% of therapy payments: occupational therapy, early childhood, behaviour support, speech pathology, and physiotherapy (pp51-54). 

Dual market structure:

There is a growing schism in the market for NDIS allied health therapy services:

  • Registered: About 10% of providers are registered, and make up about 62% of total payments. (The top 10 registered providers have a total market share of around 10.5% – p57-58.) Registered providers tend to operate at scale. 
  • Unregistered: About 90% of therapy providers are unregistered and make up about 38% of total NDIS payments. Unregistered providers tend to be small businesses, with “flexible business models and lower administrative overheads” (p56).  

Why it matters:

The NDIA recognises that differences in provider scale, cost structure and administrative capacity will influence providers’ responses to price limits (p61). In various parts of the review, the NDIA appears to:

  • contrast “small-scale, low overhead unregistered providers” with “a small number of larger registered providers with greater infrastructure and clinical governance capabilities” (p 11);
  • suggest that the diversity of business models across the sector “highlights emerging challenges with the alignment between current price limits and they way therapy supports are being delivered in practice” (p13);  
  • opine the registered providers “represent a relatively stable base” (p63); and
  • conclude that its ongoing therapy review pricing should consider factors like “practitioner qualifications, workforce availability, service settings, regulatory obligations  and the nature of participant outcomes achieved” (p88).

Unbundling therapy services:

NDIS therapy supports currently include direct face-to-face time as well as indirect participant-related planning, clinical communication, documentation, resource creation and travel (p82-83). The NDIA thinks this “bundling” makes it difficult to determine whether providers are being efficient. It recommends: 

  • “unbundling” provider travel for therapy supports (with effect) from 1 July 2025 (p83); 
  • exploring whether to impose new price limits and other guidance on report-writing arrangements (p84); and
  • closer scrutiny on session lengths and visibility of what is delivered in each session (p.86). (This appears to underpin the recommendations about presenting therapy support price limits in 10-minute increments (p16)). 

What we’re watching:

  • Future pricing limit reforms: In addition to different pricing limits for different kinds of therapies, we may end up with different pricing limits for different provider types (e.g. registered, unregistered), support complexity and delivery settings (p87).  
  • Further ‘unbundling’ of therapy support services: The NDIA may seek more granular oversight of therapy supports to increase its visibility over different components of our services (p 86).
  • Interaction with other reforms: Further pricing limit reforms are likely to be affected by mandatory registration proposals (and vice versa), including the still-open question of whether AHPRA registration and professional self-regulation of allied health professionals will satisfy NDIS registration requirements (in whole or in part). 

Read more:

2024-2025 Annual Pricing Review

Small allied health NDIS providers: should we all be registered?

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It depends on what you mean by “registration”. 

The debate: 

Large disability providers continue to lobby for universal mandatory provider registration, arguing it will enhance participant safety and the quality of supports, create an even playing field, and increase regulator oversight of the 90%+ of providers who are currently unregistered. 

Leading disability advocates and some smaller providers argue universal provider registration would be a huge mistake because it would reduce participant choice and control, drive out small providers (reducing access), decrease competition for large providers, reduce incentives for innovation, and do nothing of itself to increase service quality or participant safety. 

So who’s right when it comes to small allied health NDIS providers? And is there a middle path?

Context:

Under current rules, registration isn’t required for most of the work allied health providers perform to support self-managed and plan-managed NDIS participants (who make up over 90% of all participants). Among other things, unregistered allied health providers can’t support NDIA-managed participants or use regulated restrictive practices.  

Why not register?

Getting and staying registered is too expensive and time-consuming for many small allied health providers – especially for providers who also work with other clients outside the disability sector (e.g. in health or education). 

Many NDIS registration obligations duplicate existing professional and health regulations, requiring registered allied health providers to develop systems to comply with two sets of overlapping rules.

Unregistered ≠ unregulated:

Most evidence-based allied health professionals in Australia are regulated either by AHPRA, or by self-regulatory bodies and state statutory codes of conduct that impose similar requirements, including rules about professional ethics, standards of practice, scope of practice, mandatory declarations, complaints, certification, continuous professional development, and professional indemnity insurance. All providers – including unregistered providers – must abide by the NDIS Code of Conduct. 

Deemed registration proposal:

In August 2024, the government released the advice of the NDIS Provider and Worker Registration Taskforce. The task force acknowledged the arguments of disability advocates and proposed that, to avoid duplicate accreditation and registration requirements:

  • AHPRA-registered allied health professionals have their existing registration recognised for NDIS registration purposes; and
  • consideration be given to the appropriateness of extending this recognition to allied health professionals who are self-regulated by rules that mirror AHPRA’s requirements (e.g. speech pathologists).

Avoiding false binaries:

Everyone wants participants to be safe and to receive high quality supports. But, as recent history makes clear, NDIS registration does not guarantee safety or quality. 

Regardless of registration status, providers can – and should – look for practical ways to work with participants to improve the quality and safety of their services, including with robust worker screening processes and complaints and incidents management systems. 

Bottom line: 

  • Mandatory registration of allied health providers under existing rules would be likely to reduce participant choice and control because it would drive many small allied health providers out of the sector. 
  • Recognising allied health providers’ existing health registrations/self-regulations as NDIS registration appears to be a sensible, risk-weighted approach. But we don’t yet know whether the government – now, or after the election – agrees or will agree with the task force’s recommendations. 
  • Whatever happens, allied health NDIS providers must, in partnership with the NDIS participants they serve, continue to:
    • assert their value in increasing participant choice and control; and
    • work to improve the quality and safety of their supports.

Get ready:

NDIS Incident Management and Reportable Incidents System Policy and Procedures

NDIS Complaints Management and Resolution System Policy Document and Complaint and Feedback Form

Go deeper:

NDIS participants want safety and quality…but they also want choice. Article by Dr George Taleporos in The Australian (paywalled). 27 March 2025.

NDIS Provider and Worker Registration Taskforce Advice

Read more:

Allied Health NDIS Providers: Keep your eye on the ball in 2025!

Election-mode engaged: allied health NDIS providers must keep an eye on federal health, education and disability policy priorities to support people with disability – and to anticipate service-delivery changes

Allied health NDIS providers must face facts, and make painful – but necessary – changes to survive

Election-mode engaged: allied health NDIS providers must keep an eye on federal health, education and disability policy priorities to support people with disability – and to anticipate service-delivery changes

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Big Picture:

Many allied health providers straddle and navigate three imperfect systems to support clients: health, education and disability. Ahead of the Federal Election, the Grattan Institute has published its helpful 2025 Orange Book, setting out what it sees as policy priorities for each of these systems, regardless of who wins. Here are some takeaways:

Context:

  • To maintain systems and to improve living standards for Australia, we need productivity growth. 
  • To improve productivity, the government needs to strengthen our foundations, including health and education for all Australians, including for people with disability.

Health:

  • More focus on preventing chronic disease (including incentives to encourage better diets, more exercise, fewer drugs and less alcohol, and more social connection).
  • Fund Primary Health Networks to create more multidisciplinary primary care teams – especially in under-served areas – with implications for scope of practice, workflows, supervision, teamwork, and business models/fees.
  • More support for GPs, including a shift away from “fee-for-service” service payments and better access to specialist advice.
  • More transparency on fees charged by specialists. 

Education:

  • Lift our game to ensure more students leave schools with essential skills, like reading and numeracy: currently ⅓ of students – 1.3 million students – are at risk of leaving school without essential skills.
  • Set more ambitious targets, e.g. that at least 90% of students reach proficiency in reading and numeracy.
  • Mandate phonics checks across all schools in Year 1, with a Year 2 re-sit for at-risk students.
  • Invest more in:
    • research to identify best practices in real world school settings (e.g. like the Australian Education Research Organisation’s work on secondary literacy instruction); and
    • an independent, non-government, not-for-profit body to quality assure curriculum materials (like EdReports in the USA).
  • Support teachers with evidence-informed guidance, and professional development and training, starting with reading and maths instruction, linked to practical materials (e.g. off-the-shelf curriculum materials and assessment tools) so all teachers have access to high quality materials including teachers working in disadvantaged schools.

Disability: 

  • Stay the course on NDIS reforms to realise the original vision of a multi-tier scheme with different levels of coverage, clear eligibility criteria, data-led resource allocation, and proper operational risk management.
  • Implement a fair, objective, and consistent method for allocating NDIS support packages (including, controversially, a standardised assessment and planning framework). 
  • Re-think Section 10 and interim rules about NDIS Supports, which constrain participant choice and control. 
  • Empower the NDIA to become a more active steward to encourage innovation, intervene when markets fail (e.g. by commissioning services directly), and create a network of regional hubs mirroring the Primary Health Networks.
  • Invest seriously in Foundational Supports (including by redirecting some NDIS funds) so that the wider population of disabled Australians have their needs met, while reducing pressure on the NDIS.
  • Integrate and deliver Foundational Supports in mainstream settings.

Bottom Line: 

  • The major parties – and most of us – want a healthier, more prosperous Australia that allows everyone to live a good life. But times are uncertain, resources are limited, and current systems are imperfect. 
  • Because of our work, allied health providers are in a unique position to:
    • understand the interdependence of health, education and disability systems; and 
    • recognise that changed policy settings in one system can have significant, sometimes unintended, knock-on effects to other systems.
  • To help support participants and other clients, governments should prioritise a new National Disability Agreement clarifying how mainstream health systems, the NDIS, Foundational Supports, mainstream childcare, education and other systems will work together to:
    • support Australians, including people with disability and developmental delay; and 
    • give at least a bit more certainty to the allied health providers who support them, so we can make investment, recruitment, service mix, and other business decisions needed to stick around.

Go deeper:  

Orange Book 2025: Policy priorities for the federal government – Grattan Institute (Errors of interpretation and emphasis in this summary are my own.)

Unleashing the Potential of our Health Workforce – Scope of Practice Review Final Report

Australian Education Research Organisation

EdReports (USA)

More from us:

Allied health NDIS providers must face facts, and make painful – but necessary – changes to survive

Allied Health NDIS Providers: Keep your eye on the ball in 2025!

Allied health NDIS providers: back yourself to try new things, and help more people: a case study

NDIS “ins and outs” for participants seeking “mixed” disability, health and education supports: mind the gaps between NDIS and mainstream services

Allied Health NDIS Providers: Keep your eye on the ball in 2025!

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Happy new year, allied health NDIS providers! 

After the wild lead up to the end of 2024, we hope you managed to get a break and to reset for what promises to be another eventful year.

Media watch: Did you (like me) spend part of your break reading the steady stream of NDIS media reports, press releases, and commentaries? 

  • Some providers are allegedly committing all sorts of alleged frauds, rorts, scams, misleading advertising campaigns, and worker abuses, warranting continuing ‘crack downs’ by regulators, including the NDIS Commission and the ACCC.
  • To some economists, the NDIS is a productivity drain producing jobs that take workers from other, “more productive” sectors, putting pressure on budgets and interest rates.
  • Investigations by Rick Morton and others suggest that children have been affected most by NDIS cuts and reforms to date.
  • The long-term funding of music therapy remains uncertain.
  • The costs of assessments remain a significant barrier for some looking to access NDIS supports. 
  • Some allied health providers have gone into liquidation or otherwise gone out of business over the break.
  • Governments are establishing a National Disability Data Asset to consolidate 18 existing data sets to connect Federal and state information about people with disability (expected to be operational in 2026).
  • The NDIA has more representatives with disability.
  • We have a new national Autism strategy, but it is unclear as to how it will work with the NDIS and Foundational Supports. 
  • Lots of positive anecdotal participant stories have been shared through NDIA press releases.
  • We have a new NDIS Minister.

Ignore the spin: Don’t be distracted by news cycles. Here are six issues I’m watching like a hawk in 2025:

1. Independent Assessments 

  • Who will be eligible to do them, and how will independent assessors be hired, trained and paid (and by whom)?
  • How will independent assessors balance their legal and professional obligations to participants against their obligations to the NDIA? To whom will they be accountable?
  • Which assessment tools will be used and will they be valid and reliable for the wide range of people being assessed?
  • What reports and other outputs will be produced from assessments? Will they be detailed enough to enable allied health providers to work with participants and families to generate management and therapy plans with meaningful outcome measures?
  • Explore further

2. Foundational Supports

  • When will the agreement between states and the Federal Government be made and disclosed so we can understand funding arrangements? 
  • How will funds be allocated, e.g., between cities and rural and remote communities? Will individuals (or groups) be funded, or organisations?
  • Who will be eligible to receive supports? Autistic children? Children with language or learning disabilities and disorders? Who will be ineligible?
  • Who will deliver? Will allied health professionals be involved, or will most front-line services be delivered by assistants or other paraprofessionals? What role (if any) will the private sector allied health providers play? Will allied health professionals be contracted or employed?
  • Where and access? Assuming Foundational Supports will be delivered in mainstream settings, like childcare centres and schools, how will access to settings work in states without integrated health and education systems (like NSW)?  
  • How will supports be delivered? Whole class, small groups, 1:1,  face-to-face, distance learning, and/or in other ways? Pull-out, inclusive?
  • ‘Dosage’: The consultation documents to date contemplate ‘low dose’ or short-term interventions. Will dosage be determined by evidence, funding constraints, or in a different way?
  • Goals and outcomes: How will goals be set and outcomes measured to ensure supports are effective and value for money?
  • Explore further

3. Mandatory NDIS Provider Registration

  • When will the government respond to the recommendations made by the NDIS Provider and Worker Registration Task Force (released 2 July 2024) in relation to allied health professionals?
  • If the government decides to move forward with mandatory registration of allied health providers:
    • will allied health workers with more than incidental contact with participants require worker screening? (This seems almost certain.) 
    • will Australian Health Practitioner Regulation Agency (AHPRA) registration suffice to fulfil the requirements for NDIS registration for registered allied health practitioners?
    • will self-regulatory certification suffice for allied health practitioners who are self-regulated by peak bodies who themselves are National Alliance of Self Regulating Health Professions (NASRHP) members?
    • what (if anything) will multidisciplinary and corporate allied health providers be required to do for registration assuming allied health professionals are registered with AHPRA or self-regulated by a member of NASRHP? 
    • what (if any) additional compliance requirements will currently unregistered providers be required to meet for registration, e.g. for complaints management or incidents reporting.  
  • Explore further 

4. Pricing

  • We await the recommendations of the Independent Pricing Committee announced in September 2024 and headed by Stephen Anthony. These recommendations are expected in February 2025.
  • We understand this advice will be used to develop the Annual Pricing Review for the coming year.
  • If pricing limits are not lifted meaningfully this year, we predict an exodus of reputable providers from the sector as they will not be able to afford to train, pay and/or supervise their teams properly within current settings.
  • Explore further

5. Allied health services as NDIS supports

  • Given all that’s happened – and is still happening – to music and arts therapy providers, we all need to be on guard for any announcements, proposals or changes to the definition or interpretation of allied health-related NDIS supports.
  • Explore further

6. Participant choice and control

  • As we work hard to adapt our supports and services to changing regulatory and business environments, providers must never lose sight of participants at the centre of the NDIS. 
  • Two key questions:
    • How will participant choice and control be protected as NDIS consultations and reforms continue to roll out at a rate of knots?
    • Will participants and other stakeholders have an opportunity to participate meaningfully in the co-design of supports and services? 
  • We should continue to resist any attempts to sow seeds of division between participants and providers. 
  • Reputable allied health providers and the participants we serve are all in this together.

Read more: 

For those of you who want to do a deep dive into recent NDIS news, here are links to some of the key news stories published over the break:

Allegations some providers self-serving, fraudulent, running scams, etc: 

Pauline Hanson rips into NDIS as an ‘absolute scam’

NDIA Empowered to Scrutinise Providers Under the NDIS Act for Overutilisation of Funds | Moray & Agnew

NDIS fraud crackdown recovers millions in nationwide sweep | Insurance Business Australia

Millions saved as NDIS fraudsters cut-short by Government taskforce | Media Release from the Minister for the NDIS Bill Shorten

ACCC puts NDIS providers who engage in ‘problematic advertising practices’ on notice – Product Liability & Safety – Australia

ACCC puts NDIS providers who engage in ‘problematic advertising practices’ on notice

NDIS providers slammed for being overly ‘self-serving’

Authorities raid properties connected to one of Australia’s worst NDIS providers | A Current Affair

NDIS participant’s family fears son being exploited for $670k plan – ABC News

ACCC Federal Court action against NDIS and aged care provider welcomed | Department of Social Services Ministers

ACCC targets NDIS provider over alleged misleading sales practices | Insurance Business Australia

See also Daily Telegraph articles (not linked due to paywalls)

Some NDIS providers are allegedly exploiting workers: 

Unions claim disability workers underpaid over Christmas – ABC listen

Australian disability support worker denounces big-business attacks on “sleepover” rates and other hard-won rights

Disability staff lose big on Christmas workday: union

NDIS as a drag on productivity, increasing interest rates:

Government jobs boom thwarts RBA rate cuts – MacroBusiness

Unsustainable NDIS spending exposes budget and economy – MacroBusiness

Costs of Assessments a barrier to support: 

NDIS access fails at first financial hurdle for families with disability – ABC News

NDIS participants fear high assessment costs are proving a barrier to support | The West Australian

Independent assessments:

PWDA, Disability Groups Oppose New Support Assessment | Mirage News

Future of music, arts, play therapy: 

Future of music therapy NDIS funding in doubt as review announced – ABC News

‘It would deflate our world’: how NDIS cuts to music therapy may silence Ava’s voice | National disability insurance scheme | The Guardian

Families to keep music and art therapy funding as Shorten pauses cuts

Play Therapy, the forgotten psychological science in our NDIS – The Big Smoke

Amanda Rishworth as likely NDIS Minister (now confirmed):

Amanda Rishworth tipped to take over NDIS from Bill Shorten in pre-election cabinet reshuffle | Australian politics | The Guardian

Problems getting access to assessments and reviews: 

NDIS reforms leave families pleading for in-person assessment | A Current Affair

A Current Affair: NDIS reforms leave families pleading for in-person assessment

Couple face barriers to attract NDIS review – The Warragul and Drouin Gazette

Children targeted in NDIS reforms: 

Exclusive: Children targeted in NDIS crackdown | The Saturday Paper

Exclusive: ‘Catastrophic errors’ seen in rushed NDIS reform | The Saturday Paper

Robodebt shadow leaves fears NDIS will be next victim of disabling policy

What does the future hold for the NDIS – and its participants? | SBS News

NDIA has more representatives with disability:

Australian government expands disability representation with NDIA appointments | Insurance Business Australia

Bill Shorten will leave the NDIS in the hands of people with disability

More people with disability appointed to the NDIA Board and NDIS Independent Advisory Council

Will new National autism strategy and foundational supports work together?

Australia has a new autism strategy but questions remain for those who don’t get NDIS support

Funding cuts threaten early intervention program for kids with autism

Good news stories about people with disabilities getting support: 

Laura is grateful the NDIS is there when she needs it

From Bench to Home: How the NDIS Empowered Jack

A big believer in the NDIS, Mandy is now helping others

Shorter hospital stays for NDIS participants saving ‘hundreds of millions’, Bill Shorten says | National disability insurance scheme | The Guardian

Providers going out of business:

Another Geelong disability organisation goes bust

NDIS provider collapses right before Christmas, staff learn in brutal text message

Foundational supports: 

New report calls for more foundational support for early childhood

State premiers petition against proposed federal NDIS overhaul

Linking disability data:

World-first data asset to improve outcomes for people with disability | Press Release from the Minister for Social Services Amanda Rishworth

Benefits of self-management to get the most out of plans and NDIS workshop, NDIS app on self-management: 

Parents Jennifer and Josh are thinking creatively to get the most from their sons’ NDIS plans.

Self-manager Gill is using the tools and resources available to help her get the most out of her NDIS plan

Bree and Mitch built their capacity to self-manage by starting small and learning what works best for them. | NDIS

Paediatric allied health providers: government-funded, dedicated, multi-disciplinary needs assessors to provide “free” assessments for children under 9 

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What’s happened:

As part of the NDIA’s early designs for a new early intervention pathway for children under 9, the Government plans to create and fund a “dedicated, multidisciplinary workforce” of needs assessors to assess children under 9 with developmental delay or disability. Families will not need to pay for these assessments.

Driving the change:

  • The authors of the 2023 NDIS Review recommended the NDIA should reform the early intervention pathway for children under the age of 9 to enter the NDIS; and introduce a more “consistent and robust approach to assessing developmental delay”. 
  • The Government claims that creating a new workforce of dedicated needs assessors will mean that allied health professional time will be “freed up” so we can spend more time delivering supports, “putting downward pressure on waiting times…over the next 5 years”. 

Anti-provider undercurrents? While acknowledging allied health professionals have a “crucial role in the Scheme”, the Minister, in his press release (linked below): 

  • states repeatedly that the aim of the change is to put participants “back in the centre of the scheme”, suggesting they’re not there now; and
  • unhelpfully claims allied health professionals write “expensive 80-page reports which are not able to be implemented”. (!)

Reality checks: 

  • Nothing is changing right now for participants or allied health providers. The NDIA will need time to:
    • create and (presumably) train a new dedicated workforce of needs assessors; 
    • consult with participants and professionals to identify valid and reliable assessment tools they can use to determine the NDIS support needs of children; and
    • co-design and implement the rest of the early intervention pathway.
  • If the announced changes are implemented, families will have less choice and control over who assesses their child.
  • The proposal is a sustainability measure. There is no such thing as a free assessment – somebody will pay, e.g.:
    • some families, through Government savings from decisions to revoke or not grant access to the NDIS, or through significantly reduced plan funding; and
    • taxpayers.

What to watch:

  • What criteria (experience, qualifications, checks) will be required for someone to become a needs assessor? 
  • How will needs assessors balance their NDIA policy objectives with their legal, ethical, and professional obligations to clients, their professions, and to the public?
  • Who will train and supervise needs assessors? To whom will they be accountable?
  • Which assessment battery/tools will needs assessors use to assess participants, and are they valid and reliable for the children assessed?
  • How will the (as yet undesigned) new early intervention pathway interact with the (as yet unfunded and unannounced) Targeted Foundational Supports system, and various mainstream supports systems in different settings and states to support children?

Assessment quality affects the safety and quality of NDIS supports: 

  • To deliver safe, evidence-based, and quality NDIS supports to young children, allied health professionals need accurate, complete, and reliable assessment data, communicated in clear, trustworthy reports written by qualified professionals. 
  • Reports shouldn’t be 80-pages long. But, to meet NDIS objectives and measure outcomes, they must take into account:
    • a child’s delay or disability;
    • the effects of the child’s delay or disability on their real-world functioning, inclusion, participation, and quality of life; and 
    • the family’s priorities and concerns. 
  • Without solid assessment data and reports, allied health professionals will struggle to provide personalised, evidence-based and family-centred care, and to measure outcomes without spending scarce therapy time establishing baselines and evidence-informed therapy goals. 

Bottom line

  • Allied health professionals should:
    • continue to advocate for the choice and control of participants and families; 
    • push back against unhelpful anti-provider rhetoric that seeks to pit participants against providers in a zero-sum-game; and
    • be proud of the work we do to deliver high quality, safe supports to children across the country, despite all the uncertainties and risks created by rolling reforms.

Read more: 

Minister for the NDIS Media Release: Putting participants back at the centre of the NDIS

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