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

David Kinnane · 3 April 2025 · Leave a Comment

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

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

David Kinnane · 18 March 2025 · Leave a Comment

Drova has released its NDIS Provider Outlook report for 2025. The report looks at the sector as a whole. But it contains several sobering facts and helpful ideas for allied health NDIS providers looking to clarify their strategic priorities:

By the numbers:

  • More than half of providers operated at a loss in 2023-24.
  • Cash reserves are down 17%, and asset sales are up.
  • More than 80% of provider revenue is consumed by staffing costs.
  • More than 75% of providers think system navigation is taking time away from service provision.
  • 80% of staff report reform-fatigue.
  • More than 20% of providers are considering amalgamating with another provider or exiting the sector altogether. 

Cynical times:

  • The Government continues to lean heavily into the “dodgy providers” narrative to justify reforms.
  • Economic sustainability of the scheme dominates media coverage, rather than participant choice and control, and quality of life.
  • Some providers and participants question the government’s sincerity on reform consultations and the co-design of services.
  • Governments haven’t agreed on the funding for Foundational Supports but the NDIA (with the benefit of new laws) continues to revoke and deny access to the scheme to people with disability and delay. 

Tough times:

Key challenges for providers:

  • Ongoing financial viability.
  • Maintaining service quality for participants.
  • Regulatory and compliance uncertainties and burdens.
  • Recruiting, retaining, training, and managing staff. 
  • Market consolidation (increased competition from larger providers and difficulties scaling profitably with limited resources to build systems). 
  • Increased digital transition and cybersecurity risks.

Strategic priorities:

  • Rebuild financial sustainability: Conduct service profitability audits. Reduce waste. Diversify revenue streams. Focus on cash flows. 
  • Improve participant safety and outcomes with better services: Better frameworks to track functional outcomes. Better participant feedback systems. 
  • Improve staff engagement and retention: Better leadership. Reducing busywork/workloads. Better training. Better supervision and mentorship. Clearer career pathways. Safer workplaces.
  • Improve operational efficiencies and effectiveness: Better dashboards. Focused offerings (phasing out of unprofitable services). Streamlined workflows. Fewer non-staff overheads. Better financial, operations and compliance systems. More automation. More AI and other digital tools for planning, and reporting. 
  • Strengthen compliance and governance: Better training. Standardised incident and complaints reporting. Systems to make your compliance a competitive advantage. More automation.
  • Scale “the right way”: Efficiency before size. Don’t add complexity without careful financial and risk modelling. Partnerships and collaborations are lower risk ways to expand compared to mergers. 
  • Learn from the best: Map your business against high performing providers. More collaboration across provider types. Participate in industry groups for stronger advocacy, e.g. around funding reforms.

Bottom line:

As allied health NDIS providers, we help people with disabilities live better lives. But to support people well, we need to survive the reforms financially and build sustainable, well-managed, innovative and reputable businesses that attract talented people to work (and stay) with us and deliver high quality and safe services to clients (including participants). The Drova report includes many good ideas and suggestions to think through all this complexity, and is well worth a read.  

Read more: 

Drova. (2025) NDIS Provider Outlook Report 2025

(Any errors of interpretation are, as always, my own.)

When it comes to revoking participants’ NDIS access, the NDIA is not getting everything its own way

David Kinnane · 6 February 2025 · Leave a Comment

The big picture:

In the wake of 2024 reforms, thousands of now-former NDIS participants have lost access to the Scheme. Anecdotally, the NDIA’s revocation decisions continue apace in early 2025. But the NDIA has not gone unchallenged.

Why it matters:

With so many people affected, it’s easy to get lost in abstractions quoted in government press releases, like “aggregate savings”. Too easily, we forget that each decision by the NDIA to revoke an individual’s access affects a real person with disability and/or medical conditions – and also has knock-on effects for mainstream and other systems and services (and thus taxpayers). 

Zoom in:

If the NDIA decides to revoke an individual’s access to the Scheme, the individual loses all NDIS Act benefits entirely. This is serious, and the individual has legal rights of review. They can seek an internal (NDIA) review of the decision, and they can seek a review by the Administrative Review Tribunal (ART) under section 103 of the NDIS Act. Not everyone is in a financial or health position to take on the NDIA. But some do, including some participants with the help of community legal services, like the Villamanta Disability Rights Legal Service. 

Case in point:

In Stephan-Miller and NDIA [2025] ARTA 43, General Member Bubutievski granted a conditional stay on the NDIA’s decision to revoke a participant’s access, stating:

“The NDIS Act is beneficial legislation which is intended to confer a benefit on the [participant] if she is qualified to receive such a benefit. Removal of such benefits in their entirety is a matter to be approached with good procedure and solid evidence. The manner in which the [NDIA] has approached revocation in this case is troubling. The impact of the loss of services on a vulnerable person with a disability or medical conditions is serious and has a much greater impact on their health and quality of life than the continued provision of those services on an interim basis to a single individual would have on the [NDIA].” (Our emphasis.)

Context:

In this case, the applicant has been a participant in the scheme since 2019 and has a number of disabilities, medical conditions and functional impairments. General Member Bubutievski found that the participant was “at risk from the sudden and complete cessation of supports”, and granted a six-month stay on the NDIA’s decision to revoke access pending an independent functional assessment and resolution of the review. In the meantime, this order allows the applicant to continue to be a participant and to expend plan funds in accordance with the NDIS Act.

What we’re watching:

Although the participant succeeded in obtaining a conditional stay on the NDIA’s decision about her access, there’s no guarantee she will succeed with her main application. The NDIA contended that the applicant was not qualified to be a participant but, as General Member Bubutievski observed, “that is far from clear”, and “the matter does have a prospect of success”. If the applicant does win, her access to the Scheme will be restored.  

Read more:

Stephan-Miller and National Disability Insurance Agency (Practice and procedure) [2025] ARTA 43 (14 January 2025)

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

David Kinnane · 21 January 2025 · Leave a Comment

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 

David Kinnane · 18 December 2024 · Leave a Comment

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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Recent Posts

  • Small allied health NDIS providers: should we all be registered?
  • 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
  • When it comes to revoking participants’ NDIS access, the NDIA is not getting everything its own way
  • Allied Health NDIS Providers: Keep your eye on the ball in 2025!

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