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Supporting small and medium NDIS and health providers in Australia

allied health providers

New NDIA Therapy Guideline: 11 things allied health NDIS providers should do now to check compliance

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On 13 October 2025, the NDIA published their guideline on therapy supports (the Therapy Guideline). 

The Therapy Guideline outlines how the NDIA makes decisions about therapy supports for children aged 9 years and older. But it contains some guidance for therapists working with younger children, too.

NDIS providers – registered and unregistered – need to review the guide to ensure they comply with it (see link below).

Numbers in brackets below refer to page numbers of the Therapy Guideline.

Things to do now:

  1. Review the NDIA’s special meaning of “evidence-based” therapy supports (2-3): For example, it includes whether the therapy uses the “most up-to-date and reliable research studies” and whether it is “value for money compared to the supports available from other mainstream systems, like health or education”.  
  2. Review your outcomes measures (4, 18, 20): The requirement to measure and report therapy outcomes is a recurring theme in the Therapy Guideline. 
  3. If you are providing early childhood supports to children younger than 9, review the National Best Practice Framework for Early Childhood Intervention (6) (see link): Pay special attention to guidance on professionals working together as a team to support young children and their families.
  4. Confirm all your therapists are qualified allied health professionals for the purpose of the Therapy Guideline (6-7, 8-14): Check they are AHPRA registered, or accredited by a recognised peak body referred to in the Therapy Guidelines (8-14). For example, speech pathologists must be Certified Practising Speech Pathologists approved by Speech Pathology Australia (14). 
  5. Make sure you are not claiming NDIS funds for work done by allied health students on unpaid student placements (8): You can claim for some of the supervising therapist’s time supervising the student’s delivery of therapy to a participant – but only with the agreement of the participant. (It’s not entirely clear which supervision costs you can claim, but we assume they must be related to the therapy delivered to the relevant participant.)
  6. Check that your therapy supports meet the NDIS funding criteria specific to the type(s) of therapy you provide(8-14): This includes taking steps to…
  7. …Ensure all your services to participants are NDIS supports (15-16, 19): In addition to staying on top of the current definition of NDIS Supports (see link below), pay close attention to any:
    • Group programs (16, 19): In principle group sessions may be OK (19), but make sure there is enough evidence they are effective (e.g. the NDIA does not consider Lego therapy, yoga, art and music lessons, and drama groups to be effective therapy supports).
    • Home programs or ‘therapy in a box’ and kits (16): The NDIA does not consider therapy kits or therapy-at-home programs, once-off or ongoing subscriptions, or programs posted out by allied health practices to be NDIS supports because they are not individually tailored or evidence-based programs, and they are not overseen or delivered by a qualified therapist with a measurable outcome. 
  8. Check that your client-participants aren’t working on the same goal with you and another therapist (17): The NDIA won’t fund two therapists working on the same goal.
  9. Review your assessment report templates and practices (17, 18): They need to include recommendations for NDIS supports, dosage (including how often they are delivered), and rationales. They also need to include information about how gains or expected outcomes will be measured, and expected timeframes to achieve goals.  
  10. Review your therapy planning tools (19): For example, do they contain strategies and recommended supports to help participants build or maintain skills, that participants might want to share with other providers and informal supports?
  11. Review progress report templates and practices (19-20): For example, progress reports should include the information referred to in pages 19-20 of the Therapy Guideline, including any measurable, functional gains, and best-practice recommendations for further therapy (if relevant).

Further reading: 

Supports funded by the NDIS

‘NDIS Supports’ definition: who’s confused?

National Best Practice Framework for Early Childhood Intervention | Australian Government Department of Health, Disability and Ageing

Allied Health Providers: The NDIA Just Told Us the Truth (Again)

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What They Said

“The NDIA does not directly fund providers, but allocates funding to NDIS participants and business decisions, including whether to continue offering services through the NDIS, are a matter for individual organisations.”

(NDIA spokesperson, quoted in “NDIS providers evacuate market after pricing review,” by Sarah Ison, The Australian, 10 August 2025)

In plain English: The NDIS pricing decision was not an accident. It was designed to restructure the market. No one is coming to save providers who won’t or can’t adapt.    

So, we have a choice.

Low Agency Responses

  • Complain
  • Wait for better conditions (they’re not coming)
  • Accept razor-thin margins or losses
  • Blame the NDIA when things get worse

High Agency Responses

Ask different questions:

  • How do we build a business that thrives regardless of – or despite – the NDIA?
  • How can we turn constraints and gaps into a competitive advantage?
  • What would we do if failure literally wasn’t an option?
  • How would someone from a completely different industry solve this challenge?
  • How would we handle this if no government funding existed at all?
  • What are participants begging us NOT to change about our services? 
  • What’s the smallest step we could take today that moves us toward sustainability?
  • If we only had 6 months of funding left, what would we prioritise?
  • What would we regret not trying if we looked back in 5 years?
  • If we locked our three smartest colleagues in a room for 2 hours to work on this problem, what would they come up with?

Take small actions now:

  1. Map dependencies – Where are you most vulnerable?
  2. Diversify revenue – Who else needs the value you provide?
  3. Build efficiencies – How can we deliver better outcomes, more quickly?
  4. Create loyalty – How do we make ourselves less generic, more useful, and more sought after?
  5. Add to choice and control – Can we deliver more and better services in different ways to increase participant choice?

Bottom line:

The NDIA’s statement isn’t a threat – it’s another reminder that things have changed. They’ve just told us exactly where we stand.

The truth is hard to take, but we can do it: 

  • Our opportunity: Providers who adapt to reality > providers waiting for rescue.
  • Our choice: Victim of policy or architect of our own solutions?

Need a 30-minute pep talk to get the creative juices going? Check out this terrific essay by George Mack.

Curious about how to actually apply high-agency principles in your practice or workplace? On 25 August, we’re releasing our Courage Playbook – available only for our Banter Booster Premium subscribers. Sign up here.

In deep water: paediatric allied health NDIS providers should read the Grattan Report

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The Big Picture:

On 29 June 2025, the influential Grattan Institute published a 108-page report with proposals to save the NDIS (link below).

Many allied health providers were distracted by financial year-end and compliance tasks to comply with the (now live) Pricing Limits for 2025-26.

But the report is well worth a read – particularly for paediatric allied health providers who own or work out of clinics.

Attention-grabbers:

The report authors, led by former NDIA senior policy advisor Dr Sam Bennett, propose several very significant changes:

  • Abolish the early intervention pathway (i.e. section 25 of the NDIS Act) (pp57, 83).
  • Abolish individualised funding for all children under 18 who are or would have otherwise been supported through the early intervention pathway (pp31, 57).
  • Redirect funds to replace the early intervention pathway with “muscular” Foundational Supports (pp56-59):
    • general supports: information and education; and
    • targeted supports, including “low-to-mid-level allied health supports to improve the long-term capabilities of children” (p13).
  • Governments to co-commission Foundational Supports:
    • with 3-5 year contracts (pp49, 71), including for “evidence-based services” to “encourage providers to offer higher-quality programs” (p57); and
    • from “lead providers” that have the capacity and systems to manage a group of sub-contractors (pp50, 73).
  • Adopt a Key Worker model to help families navigate options (p54).
  • 5-year transition to avoid service gaps and give providers “sufficient time to prepare” but with the transition to start from 1 July 2026 (p60).
  • All Foundational Supports – and thus all early intervention therapies – for children to be delivered in natural environments – not clinics – including in “supported playgroups, early childhood education settings, health and community hubs, libraries, and family- and community-led organisations” (pp30, 57).
  • No mandatory registration of allied health providers to provide Foundational Supports. Recognition of AHPRA registration/regulation by a professional body (p75).
  • Better national sharing of provider information, and better integration of provider registration and worker screening checks (pp75-76).
  • Retain individualised plan funding for children with lifelong and severe disability (i.e. for children who meet the disability requirements under s 24 of the NDIS Act) (p57).

Reality check:

These are proposals from a think tank – not government policies. But the report is well-researched and written, and is likely to get the attention of policy decision-makers, as well as media and social media critics of the NDIS.

Bottom line:

Participant and disability advocacy groups will have a lot more to say about the report and the implications for access, and for choice and control over allied health early intervention services.

But paediatric allied health providers should also consider the report when reviewing their business strategies and risks for 2025-26 and beyond.

If implemented, the Grattan proposals would:

  • transform early intervention allied health service-delivery across Australia; and
  • accelerate the sector-wide shake-out of paediatric allied health service providers.

Go deeper:

Bennett, S., Jessurun, M., and Orban, H. (2025). Saving the NDIS: How to rebalance disability services to get better results. Grattan Institute.

Targeted Foundational Supports consultations: an “idea salad” with more questions than answers for allied health providers?

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Last week, we attended two, lengthy webinars hosted by the team at The Social Deck, on behalf of the Department of Social Services, about Foundational Supports, including Targeted Foundational Supports. Our key takeaways for allied health providers of paediatric services are as follows*: 

State of play: 

  • Consultation period ends on 5 December 2024. Soon!
  • Weirdly, negotiations between governments are happening completely separately from community stakeholder consultations.
  • No update on the status of negotiations between the states and the Federal government, who will share the costs, 50:50. 

General impressions:

  • Lots of stressed attendees. (Lifeline number shared!)
  • Frequent reminders from convenors that “we won’t be able to answer some of the specific questions about how foundational supports might work in the future” because they depend on what governments may decide to do.
  • Lots of very good ideas, but not clear how they could all work together in the real world. (One participant described the session as an “idea salad”, which I borrowed for the title.) 
  • Private practitioners appeared to be under-represented in discussions, perhaps because the webinars occurred:
    • in the middle of working days; and 
    • so close to the calendar year-end. 

General themes:

Targeted Foundational Supports should:

  • include early recognition and assessment of needs;
  • be family-centred and holistic;
  • be consistent and continuous;
  • include disability-led organisations; and
  • include robust quality, safety and accountability controls.

Attendee concerns, including about:

  • NDIS changes and children falling through the “cracks” right now;
  • allied health workforce readiness, including training pathways and supervision;
  • gaps between evidence-based practices and front line realities;
  • how to ensure consistency and continuity of services;
  • how best to engage families and deliver family-centred care; and
  • how supports will work in rural and remote areas and for CALD populations.

Services delivery preferences:

General – but not unanimous – preferences for:

  • a move away from one-to-one, clinic-based therapy;
  • transdisciplinary and multidisciplinary teams;
  • service delivery in naturalistic settings using existing (public) infrastructure;
  • systems that promote longer-term relationships between families and professionals;
  • a movement away from medical models of care; and
  • key workers and allied health assistants having significant roles in the new system.

Many big questions remain:

  • Who will be eligible to deliver targeted supports and how will they be registered/certified? 
  • Who will employ, train, and supervise them? 
  • How (if at all) will allied health professionals access some settings, e.g. in states like NSW without a long history of integrated health/education service delivery?
  • Who will oversee and audit services, including outcomes?
  • How will services be funded? (Fee for service, block funding, fees for outcomes?)
  • What intensity of support is envisaged? (The consultation paper appears to envisage low intensity supports.)
  • Will recipients have any choice and control?
  • How (if at all) will upcoming elections affect the proposals, including their timing?

Lots of questions. Few answers.

Read more: 

Paediatric allied health clinic owners: things are not looking great when it comes to Targeted Foundational Supports

Foundational Supports for children with developmental concern, delay and/or disability and their families, carers and kin Consultation Paper 

Foundational Supports | Department of Social Services

* Any errors of interpretation are – as always – completely our own. 

We’d like to thank Mel Butcher and the rest of the team at The Social Deck for the work they are doing under enormous time pressures. 

Key personnel of allied health NDIS providers: your legal risks will almost certainly increase in 2025 

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Big Picture: 

Consultation is underway on proposed reforms to strengthen the regulatory powers of the NDIS Commission. 

If enacted, the proposed changes will increase legal risks for providers and for their key personnel, including directors and executives of allied health providers.

What to watch:

Proposed additional:

  • statutory duties for providers and for key personnel of providers;
  • penalties for non-compliance;
  • restrictions on advertising and marketing for NDIS supports;
  • obligations to provide documents and information to the NDIS Commission; and
  • requirements to hold information in Australia. 

New statutory duty owed by providers:

Provider obligation to ensure, as far as is reasonably practicable, that the conduct of the provider does not cause adverse effects to health and safety of participants while the provider is delivering those supports and services.

Breaches would attract a civil penalty.   

New statutory duty owed by key personnel (personally):

Key personnel to exercise due diligence to ensure the NDIS provider complies with its NDIS Act obligations. 

Likely to impose clear obligations on key personnel to train staff, manage risks, oversee and investigate incidents, and to address complaints.  

New proposed penalties for providers include:

  • criminal offences for serious failures to comply with conditions of registration; and
  • significantly increased maximum penalties for serious harm or death of a participant.

Anti-promotion orders

  • Restrictions on advertising and marketing that undermines the integrity and principles of the NDIS.
  • Broadly consistent with existing allied health professional and ACCC advertising rules.
  • Will capture shopping coupons and other exploitative and inaccurate advertising. 

Expanded information-gathering powers:

Proposed powers to: 

  • require providers to provide documents and information; and
  • require information be provided in less than the current 14-day timeline. 

Provider information must be held in Australia:

  • Information that is cloud-based and held overseas is sometimes hard to get. 
  • All providers will be required to hold information within Australia.

Have your say and plan for 2025: 

  • The consultation period ends on 20 December 2024. Give feedback as explained on the NDIS Commission reform hub.
  • Ahead of any changes, review your risk management systems, including your provider and key personnel insurance arrangements to ensure they remain adequate. 

Go deeper:

Consultation on proposed changes to the NDIS Act (Bill 2)

Reform Road Map (as at 20 November 2024)

Check out our NDIS provider and health provider resources Go to Shop