NDIS supports

Small NDIS allied health providers: keep moving, and don’t give up

David Kinnane · 28 November 2025 · Leave a Comment

State of play:

As at the end of November 2025, NDIS reforms include lots of parts, uncertainty, and complexity.

Unknown unknowns:

Small allied health providers must plan for 2026. But how can we make decisions about strategy, services, marketing, recruitment, training, compliance, resources, and finances with so many balls up in the air?

Chessboard fallacy:

More than 250 years ago, Adam Smith warned us not to look at policy reforms as a game in which governments rearrange people like chess pieces. We make better decisions if we accept that every person and organisation affected by NDIS reforms has their own goals, incentives and biases (including us).

Not about us, or “us versus them”:

It sometimes feels like small providers have been targeted for elimination. But the stakes are much higher for participants. And we shouldn’t assume governments, regulators, the media, large providers or others are acting with malice. We all want better value services and outcomes for people with disability. We all want the NDIS to survive.

So what do we expect in 2026, and why?

1. Increased NDIS allied health funding pressures as:

participants lose scheme access through eligibility reassessments;
children with ‘mild and moderate autism or developmental delay’ are diverted to Thriving Kids (see below);
the early intervention pathway is abolished for most kids;
new plans are approved with tighter funding controls;
I-CAN support needs assessments roll out for participants aged 16 and over (perhaps with algorithmically-determined funding);
the permanent definition of “NDIS supports” is released and implemented;
the NDIS Evidence Advisory Committee’s Capacity Building and Therapies Subcommittee scrutinises the cost-effectiveness and quality of evidence for different therapies (including dosages);
recommendations emerge from the therapy pilot (commencing in January 2026) to “better understand costs and characteristics of quality service delivery”. (Controversially, this was commissioned through a closed, non-competitive tender that locked out small providers); and
additional/differential pricing limits are imposed for different types of therapy, and travel (e.g., the new price limits for music and arts therapists from 24 November 2025).

2. Continued government and media narratives about “dodgy providers” and “unregistered cowboys”

Politicians conflate “unregistered providers” with bad actors and fraudsters to maintain public and taxpayer support for urgent reforms.
Large registered providers – with very real profitability challenges – continue to run the “unregistered = dodgy cowboy” line because it helps them lobby for special pricing arrangements, mandatory registration of all providers, and taxpayer bailouts. They know these changes would drive more small allied health providers out of the sector and reduce competition – and participant choice.
Allied health professionals are regulated. Duplicative rules increase costs and distract from service delivery, which is why we endorse the NDIS Provider and Worker Registration Taskforce 2024 recommendation to “deem registration” of allied health providers based on existing allied health regulations plus worker checks.

3. More small providers will exit the sector, but others will adapt and keep going

On 24 November 2025, the NDIA said that, as the market matures, some providers will decide to stop delivering all or some sorts of NDIS supports.
In June 2025, the Independent Pricing Committee predicted much the same thing, recognising that pricing limits make it difficult for small allied health clinics with staff to remain viable (see links).
We are not powerless pawns. Lots of small providers are advocating for “reforms to the reforms”, making submissions to consultations, meeting with MPs, working with peak bodies, unionising, and/or supporting disability advocates and affected participant groups.
No one is going to bail out insolvent small allied health providers – and nor should they. Over the last 18 months, many providers have worked hard to reduce their dependence on NDIS funding. Unavoidably, this has reduced access to therapy for participants in some areas.

4. Families will be underwhelmed by Thriving Kids programs and outcomes

Thriving Kids, not yet agreed, looks like a return to block-funded programs, general strategy-sharing, parent training, and (possibly) short interventions, perhaps in groups.
Evidence-based early intervention programs, like Inklings, show promise. Outcome data for school programs are much less compelling (see links).
We don’t know who will deliver Thriving Kids programs ‘on the ground’, although we expect large registered providers (with subcontractors), and/or state government employed workers.

5. New allied health service gaps will emerge

Public disability, health and education systems in many states are under stress.
Funding systems are built on the false premise that people’s disability, health and education needs are unrelated:
- If you have a disability or have worked for a person with disability or delay – an autistic toddler, a dyslexic teenager, a young adult with cerebral palsy, an older adult with Parkinson’s disease, for example – you know this is untrue.
- Health, education and disability systems and budgets are interdependent, which explains, in part, why governments have handcuffed Thriving Kids to the 5-year public hospital deal negotiations.
- State governments, like NSW, continue to consult on “Foundational Supports” (talking about the same cohort of kids as Thriving Kids). Thriving Kids may look very different state-to-state, region-to-region.
Overall demand for allied health services remains high. But the allied health workforce is limited, especially in rural and remote settings.
Many allied health providers work across multiple systems and will split their resources based on client demand, professional interests and skills, and system incentives. In states like NSW, health and education bureaucracies don’t always get along, and working between systems is inefficient, with access and other real world logistical challenges.
A large chunk of the allied health workforce with disability experience is employed in the private sector because of the way the NDIS used to work. As the model changes, the workforce and employers will adapt. But this will take time, and new service gaps will emerge.

6. Provider legal and compliance risks and costs will increase

Legal and compliance risks for providers, owners and managers have steadily increased over the last two years.
If enacted, the new NDIS reform bill (released on 26 November 2025) will further increase risks for all providers (not just the “fraudsters and cowboys”).
Expect insurance premiums to rise, too.

7. A flight to quality?

Regardless of funding models and business pressures, we can’t cut corners if we want to succeed:

Clients deserve excellent services: including safe, timely, evidence-based, client-centred, convenient, and high quality services.
Our staff deserve respect: Professionals want to learn, to belong, to create, to grow, and for their work to have an impact. They need to be trained and supervised properly. They need the right resources to deliver great services that produce real outcomes for clients.

Bottom line:

Small allied health providers that deliver quality services to participants while supporting teams should feel proud of their hard work this year and take heart. As 2026 approaches, we should back ourselves to compete on quality and outcomes with large providers, and to provide participants with real choice and control.

Go deeper:

The Chessboard Fallacy

Thriving Kids Advisory Group Communique – November 2025 | Australian Government Department of Health, Disability and Ageing

Foundational Supports for Children | NSW Communities and Justice

Not-for-profit disability services are closing due to untenably low price caps, NDIS architect warns

NDIS providers’ losses double, more taxpayer bailouts likely (paywalled)

New tool to deliver simpler pathway to disability supports | NDIS

NDIS Evidence Advisory Committee | Australian Government Department of Health, Disability and Ageing

Quality supports program tender | NDIS

Updated NDIS Pricing Arrangements and Price Limits 2025-26

Professionals Australia NDIS Allied Health Union

Allied health providers and pricing controls: independent providers that employ, train, and supervise staff are caught in the middle, and might not survive (and the NDIA knows it)

NDIS Supports rules | engage.dss.gov.au

Independent Pricing Committee | NDIS

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

Thriving Kids: will ‘targeted supports’ deliver what children and families need?

Thriving Kids in Schools: Will it Work?

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

David Kinnane · 15 October 2025 · Leave a Comment

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:

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”.
Review your outcomes measures (4, 18, 20): The requirement to measure and report therapy outcomes is a recurring theme in the Therapy Guideline.
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.
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).
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.)
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…
…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.
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.
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.
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?
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).

‘NDIS Supports’ definition: who’s confused?

David Kinnane · 31 July 2025 · Leave a Comment

On 30 July 2025, the Government published its report on the August 2024 ‘Consultation on Draft Lists of NDIS Supports’.

The report is very late.

The report and its timing may confuse some participants and providers.

Here is a quick recap:

The Government published its draft “in” and “out” lists to define NDIS Supports on 4 August 2024 – almost a year ago.

The consultation period was very short: 4-to-25 August 2024.

Participants, providers, advocates and others found the time to respond to the consultation: the Government received more than 7,000 responses and submissions.

The Government imposed its transitional rules for NDIS Supports on everyone on 3 October 2024 – almost 10 months ago.

Until 30 July 2025:

it was unclear whether the Government had listened to anyone who responded or made submissions;
some participants and providers thought that:
- they had wasted their time responding to the consultation paper; and/or
- the Government had ignored their submissions; and/or
- there was no real consultation about the NDIS support lists – the Government had already ‘made up its mind’ when it published the lists.

As predicted by many people who responded to the consultation, the “in” and “out” lists have been difficult to apply in practice.

The report shows that the Government knew about many of the problems with the lists, including:

the application of black-and-white inclusion and exclusion rules to “grey areas” at the intersection between disability-related supports and mainstream health care and mental health care (e.g., pp 13, 29-32);
the practical effects of excluding particular supports for a person with disability when there are well-known, significant gaps in early childhood, health, education, aged-care and other mainstream supports and systems for people with disabilities (e.g., pp 10, 13, 33-35);
the practical challenges of establishing whether an individual’s specific need in a given case may relate to their disability, healthcare, educational attainment, or employment (e.g., pp 10, 33-34);
the meaning and scope of ‘evidence-based’ therapeutic supports (e.g., pp 17-18); and
confusion about how the rules apply to the funding of various specialist and standard products and equipment, and different assistive technologies, and communication devices and information equipment (e.g., pp 11, 20, 25).

On 16 June 2025, the Government launched another consultation on the definition of NDIS Supports – this time to replace the transitional rules with a “final definition”.

This second consultation closed on 27 July 2025.

We look forward to reading the next consultation report.

Hopefully, this time the Government will give participants, providers and other stakeholders an opportunity to see and comment on the proposed new definition well before the new definition comes into effect.

Sector on edge: the NDIA knows it needs better processes to reduce NDIS reform anxiety and to rebuild trust with participants and providers

David Kinnane · 25 June 2025 · Leave a Comment

“Implementation [of reforms] does not stop with how our service delivery staff put that in a plan. Providers also have to know the consequences, know what to do, know what participants will come to them and ask about, and be able to support them” – NDIA staff member*

Big picture:

The NDIS reforms of 3 October 2024 were not well-implemented or communicated to participants or providers. A new report reveals NDIA management knows about some of the things that went wrong internally. But will they learn from their mistakes, and listen to participants and providers?

Report:

On 23 June 2025, the NDIA’s Policy, Evidence and Practice Leadership Division published a report with its “early observations” on the NDIA’s initial implementation of NDIS Act amendments that took effect on 3 October 2024, including:

section 10 and its accompanying transitional rules defining NDIS Supports (containing the “in list” and “out list”); and
section 33 (funding amounts, periods and components).

Context:

The “in and out” lists were finalised on 2 October 2024 and implemented on 3 October 2024 (p 8) after what can be described (charitably) as a very limited consultation period. Many stakeholders were dissatisfied with the consultation timeframes (p14). After the reforms went live, NDIA staff, participant, planner, and provider confusion ensued over interpretation of the lists.

Cases in point:

For example, some participants and providers were confused about:

whether funding for food and transport (both on the “out list”) were permissible in relation to short-term accommodation (p13);
whether the use of tablets (on the “out list”) embedded in assistive communication devices (on the “in list”) were okay (p24);
what, exactly, was meant by the term ‘evidence-based therapeutic support’ (p24); and
whether therapy types that were not on the in or out lists were okay (e.g. for chiropractic therapies) (p25).

What went wrong:

Among other things, the report authors observed that:

the amendments generated participant uncertainty and anxiety (p6);
months of planning proved inadequate, and initial implementation of the changes was more challenging than expected (p26);
NDIA staff weren’t ready or adequately trained to answer some specific stakeholder questions with confidence (pp6-7, 25), including gaps in knowledge and skills needed to apply the changes to “nuanced circumstances” (i.e. beyond generic answers) (pp20, 27). To quote an NDIA staff member: “We had to do our first participant information session on the changes on the afternoon of 3 October and we were still trying to understand the changes ourselves” (p27);
the NDIA had to publish around 50 clarifications (p7) and felt some of their clarifications and corrections were drowned out by social media commentary (p13);
problem resolution was stymied by inadequately coordinated internal communications across the NDIA (p7);
some NDIA staff were unaware when previous guidance and FAQs had been superseded (p 25); and
some plan managers and providers responded by taking a “risk averse” approach to the “out list”, and erred “on the side of caution” (p8), which may not have been anticipated by the NDIA.

Lessons learned?

The report authors make some sensible suggestions for future reforms, mainly focused on improving internal processes. But stakeholders weren’t overlooked, with recommendations that included:

recognising that the pace of change may not be sustainable, given its potential impacts on stakeholders, participants and the disability community and “for ensuring continued collaboration and quality outcomes” (p31);
involving participants and sector stakeholders in the planning process to identify potential issues (p32);
more emphasis on participant communication and engagement before changes take effect (p31);
the importance of prepared resources and clear communication in place before reforms take effect (p31); and
the need to consider “unintended consequences” (secondary effects) of flurries of clarifications from the NDIA post-reforms, e.g. on participant and other stakeholder anxiety levels (p31).

Why this matters now:

Since the October 2024 reforms, stakeholder relationships have been further strained by the 2025-2026 NDIS Pricing Arrangements and Price Limits that take effect on 1 July 2025.
Section 33-empowered changes to funding periods are now being implemented, including 1, 3 and 12 month periods, affecting participants (and providers who must design systems to comply with changes).
The next major round of reforms are upon us, including:
- consultation on the final definition of NDIS Supports (to replace the transitional ‘in’ and ‘out’ list rules) will close on 27 July 2025 and we still don’t have an exposure draft of the proposed law; and
- the imminent establishment of the NDIS Evidence Advisory Committee to examine the evidence-base for different therapies and other supports.

Bottom line:

The NDIA knows it needs to maintain strong relationships with the disability community because they are “essential for the ongoing success of the reform program” (p31). It also knows that providers have to understand the rules before we can build systems to comply with them and to support the participants we serve (p28). Good internal processes and clear communication from the NDIA will play a big part in determining the outcomes of the next tranche of reforms and public confidence in the scheme.