Butler’s Bad Math: The Perils of Advanced Registration

By Disabilitywatch

In an effort to reduce fraud and make budget savings on the NDIS, Minister for the NDIS, Mark Butler, has proposed the introduction of mandatory registration for NDIS care providers and has submitted the Securing the NDIS for Future Generations Bill 2026 to Parliament which lays the legal foundation for mandatory registration across NDIS. Minister Butler hopes that by mandating the registration of care providers, fraudulent providers will be excluded from the provision of NDIS care services, which will help make budget savings. NDIA currently estimate that 6 to 10 percent of care funding is lost to fraudulent billing– so up to $2.3 Billion annually (Non-SIL).

Lack of regulation of the NDIS provider market has left the scheme vulnerable to unauthorized billing and overbilling. Currently only 6% service providers are registered, meaning that the NDIS Quality and Safeguard Commission currently lacks oversight over 93% of NDIS providers. Scheme-wide registration of providers is also required in order to screen and safely register all providers onto a Digital Payment Platform which would make payments visible to NDIA thus easier to scan for irregular billing patterns– helping reduce fraud.

So while some form of scheme-wide registration is required- does Minister Butler's proposed ‘Advanced Registration’ model tick all the boxes as outlined in the scheme's blueprint for reform: the NDIS Review?

And most importantly, does ‘Advanced Registration’ deliver anticipated budget savings? The overriding purpose of the reforms.

The maths suggests otherwise.

Minister Butler's proposed ‘Advanced Registration’ model (as outlined Impact Analysis Equivalent: Mandatory Registration of all NDIS Providers 2026 ), requires advanced registration of providers carrying out ‘highest risk supports’ only. Although this sounds like a narrow registration category which will affect few, Minister Butler stated in his budget speech that the scope of ‘highest risk supports’ will be expansively defined to include ‘Assistance with Daily Living and Personal Domestic Support’- a definition which encompasses the provision of all personal care on NDIS – even outside care homes.

This means that high level, complex and onerous regulation would be applied to all support across the scheme– except Social and Community Engagement– which amounts to 75% of the scheme (Non-SIL).

Butler’s Bad Math: The Perils of Advanced Registration

By Disabilitywatch

Figure 2: Sole Providers versus Care Companies

Examples rates and overhead for Sole Provider versus Care Companies

B. Sole Provider Case study: without overheads sole providers can charge rates upto 35% less than care companies- though rates vary as they are by negotiation (NDIS participant post scorced from Reddit)

An increase to the hourly market rate of care will devour fraud savings

Figure 3: No budget savings can be made under the current proposal of Advanced registration: any savings made from fraud reduction will be wiped twice over by the increase in hourly care prices.

In order for budget savings to be made, the market rate for personal care must be minimised (and participant purchasing power maximized) so that savings made from fraud reduction are not devoured by participants seeking to cover their essential care needs at marked up large provider prices.

Figure 4: Imposing Advanced Registration on Personal Care will result in no savings as participant budgets will devoured by increased prices. However imposing lower pricing limits on sole providers scheme-wide yields substantial savings- see Part 5 for discussion on 'How to make Savings Safely'.

Figure 5: Budget Saving Theorem: in order to retain savings from fraud reduction the market rate for personal care must be minimised and participant purchasing power maximized.

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Fraud Holes in the proposed Mandatory Registration

Figure 6: as Advanced Registration only applies to part of the scheme , it leaves a 25% fraud hole in Non-Sil funded support . Without any screening or ID checks leaving a quarter of the scheme vulnerable to fraudulent billing-- despite the other three quarters being over regulated.

2.0 Harm and Dysfunctions Caused by Advanced Registration

A. Scheme-wide Decline in the Standard of Care

B. Care worker shortages in rural and regional areas

C. Crisis of Neglect across-the-scheme due sharp price increase

D. Increased Liability for NDIA

Conclusion

Recommendation: The Impact Analysis Equivalent of Mandatory Registration of all NDIS Providers 2026 requires revision and resubmission due to the incorrect assumption of uniform pricing in before Securing the NDIS for Future Generations Bill 2026 can be considered by Parliament

4.0 Successive Sleights-of-Hand : selling Advanced Registration to Parliamentarians in pursuit of gaining support for an Amendment Bill

Summation

No budget savings

5.0 How to make budget savings safely

5.1 Expanding the NDIS Worker Screening Check into a Registration process for Sole Providers

5.3 Implement the NDIS Provider and Worker Registration Taskforce Model instead of the Advanced Registration Model

6.0 Conclusion

7.0 Recommendations:

1. Request that the Impact Analysis Equivalent for Mandatory Registration of all Providers is revised and resubmitted (with independent economic modeling) to the House of Representatives before Securing the NDIS for Future Generations Bill 2026 can be considered by Parliament.

• The Committees of Privileges to consider whether false statements in documents submitted by Minister Butler to Parliament amount to misconduct under section 4 of the Parliamentary Privileges Act 1987;

3. Refuse Passage to Securing the NDIS for Future Generations Bill 2026 until it:

• complies with transparent and democratic standards of governance processes

• can be evidenced to make budget savings safely; and

• does not harm NDIS severely disabled participants by creating care supply shortages or sudden increases in the market price of care.

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Helping salvage Choice and Control by reimagining frauding proofing sole provider billing

Disabilitywatch will pro-bono investigate the options around invoice and shift verification with a bioinformatics expert based on approaches used by large Australian retailers to prevent over billing and unauthorized billing by sole providers and remove the need for auditing.