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Unregistered allied health NDIS providers: Do not ignore the NDIS Practice Standards Review

David Kinnane · 23 October 2025 · Leave a Comment

Registered NDIS providers must meet the NDIS Practice Standards (Standards) to become and remain registered.

The NDIS Quality and Safeguards Commission, with the help of KPMG, is consulting on revisions to the NDIS Standards, and has released a discussion paper about it (the Paper).

Unregistered allied health providers are not subject to the Standards. But they should follow the consultation anyway.

Why?

Participants deserve excellent services: The revised Standards will include practical guidance and examples to help providers deliver higher quality, safer supports to participants – something we all want.

Mandatory registration of allied health providers seems likely: Back in August 2024, a task force recommended that AHPRA and/or self-regulatory certification may suffice, with additional worker checks (see link below). We don’t yet know what the government thinks about this idea. But, if any form of NDIS registration becomes mandatory, allied health NDIS providers will have to meet the Standards. 

NDIS Code of Conduct: The Code of Conduct already applies to all providers. The Standards overlap with the NDIS Code of Conduct. The practice guidance and examples in the Standards may help inform unregistered allied health providers about how to meet their Code obligations to participants.

Key proposals

Revised Standards: a core focus on participant rights, provider leadership, safe supports and effectiveness of supports, with supplemental quality standards for things like early childhood supports, behaviour supports, and meal assistance.

Revised structure: Standards with clearer outcome statements, reflective questions, and specific participant-centric, outcome focused, and evidence-based requirements for each Standard. 

For providers of low risk supports: replacement of the Verification Module with specific conditions on registration and guidance.

New Quality Framework: with principles, standards and provider obligations, a  revised quality assessment approach, evidence categories, and transparent performance information.

More resources to support compliance: practical guidance to support implementation of the Standards for frontline workers, managers, and provider leadership, including case studies, self-reflection tools, and focused resources.  

Contingency planning (practical takeaways)

The Paper highlights several themes all allied health providers should think about as they look to improve their systems and supports:  

Improved participant safety: e.g., better systems for risk identification and management, supporting participant decision-making, connecting participants to other services, incident management, and complaints management. 

Improved provider leadership: e.g., better systems for pre-employment checks, staff induction and ongoing competence assessments, and supervision training.  

More effective supports: e.g., better systems for continuous practice improvement and quality management, including structured practice supervision, improved staff development and performance plans, and better workforce training.  

Consultation open: below, we’ve linked to the Paper, and a survey that providers can fill in at any time before close of business on 13 November 2025. Providers can also make written, audio or video submissions by 14 November 2025.

Bottom line 

Regardless of what happens with mandatory registration, the revised Standards will shape expectations for how reputable NDIS providers think about the safety, effectiveness, and quality of their NDIS supports;  as well as the quality improvement and other systems we must implement and test to deliver them to participants.  

Related reading:

NDIS Practice Standards Reform

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

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NDIS, NDIS 2024-2025 Reforms, Provider Tips allied health providers, NDIS, NDIS participants, NDIS providers, NDIS Reforms

About David Kinnane

David Kinnane owns and operates The Provider Loft. David is a Certified Practising Speech Pathologist, Lawyer, Writer and Speaker.

David also owns and manages Banter Speech & Language, an independent private speech pathology clinic in Sydney.

David also volunteers his time as a Board Member of SPELD NSW, a charity for children and adults with specific learning disorders.

You can read more about David’s professional background, qualifications and experience here.

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