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).
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