NDIS supports

“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. 

Go deeper:

Full report (very difficult to search for, and find, on the NDIA website):

NDIA (Policy, Evidence and Practice Leadership Division), The Introduction of defined NDIS supports, funding amounts, funding periods and funding components – Early observations on implementation, Version 1.0 – June 2025.

Consultation on NDIS Supports rules

NDIS Evidence Advisory Committee

*quote, from p28 of the report.