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NDIS

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.)

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

Allied health NDIS providers: after 6 months of havoc, make time to rest, recharge and reset for 2025 

David Kinnane · 12 December 2024 · Leave a Comment

Tumult and disorder: 

Consider just some of what we’ve endured in the second half of 2024:

  • 01.07: Pricing Limits unchanged for 5th straight year
  • 02.07: NDIS Taskforce Report on Provider registration
  • 04.08: NDIS supports “consultation”
  • 22.08: NDIS Bill No 1. Passes
  • 03.09: NDIS Commission Enforcement Policy
  • 04.09: NDIA Quality supports for Children Guide
  • 05.09: new NDIS Act becomes law
  • 16.09. First phase of mandatory registration announced
  • 18.09: NDIA CEO emails participants about changes
  • 19.09: Reform Roadmap released
  • 20.09: Foundational Supports General Supports consultation
  • 26.09 Future Conflicts of Interest resources announced
  • 26.09 Independent Pricing Committee announced
  • 01.10 Transitional Rules on NDIS Supports take effect
  • 03.10 NDIS Amendment Act comes into force
  • 07.10 NDIA CEO email to participants about transition
  • 25.10 NDIA CEO emails providers about NDIS support grace period (ends 1.11)
  • 28.10 New laws announced re increased provider penalties
  • End of October: Foundational Targeted Supports consultation paper
  • 05.11 Final Report on Scope of Practice Review released
  • 11.11. Position statement on Conflicts of Interest released
  • 13.11 Consultation in NDIS Bill 2 
  • 13.11 ACCC warning to providers about advertising
  • 26.11 Music and arts therapy announcement
  • 27-29.11 Foundational Supports seminars
  • 02.12 Ramped up fraud prevention investment
  • Sometime soon, perhaps? NDIS Operational Guidelines on therapy supports?

Overwhelmed? Worry not. Take a breath, and check out our plain English update summaries (see below).

Stand proud: Despite all the sound and fury of 2024, most of us have muddled through and worked hard to:

  • support NDIS participants, families and carers; 
  • train and supervise our teams; and
  • stay in business!

Self-care: Even if just for a day or two, take time to:

  • rest;
  • ‘touch grass’ (as the young folk say); and
  • gear up for what promises to be an eventful 2025.

Happy holidays! Thanks for your support this year. See you in 2025!

Plain English update summaries:

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

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

High alert: Allied health providers and participants on edge as NDIS funding for some therapies slashed without notice

Allied health clinic owners: avoid chaos by focusing on strategic constants in a time of rapid change

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

Allied health providers: get up to speed on the key NDIS reforms that will affect your practice (a free resource)

Allied health providers must review services for young participants to ensure they’re NDIS supports

Will NDIS reforms and foundational supports trigger the end for many paediatric allied health clinics?

The 1st Foundational Supports Consultation has kicked-off. 8 things allied health NDIS providers need to know

The Government’s Draft List of Allied Health NDIS Supports: What’s In; and What’s Out

How will allied health NDIS providers survive? Some difficult choices ahead

Therapy Support Providers: Frozen pricing limits and shorter notice cancellation rules. What was the NDIA thinking?

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

David Kinnane · 3 December 2024 · Leave a Comment

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 

David Kinnane · 30 November 2024 · Leave a Comment

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)

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