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  • Butler's Badmath: The Perils of Advanced Registration

Figure 1:  The expansive impact of high-level single-tier Advanced Registration on the provision of NDIS funded care support which covers 75% of all Non-SIL funded care support

 

Such an expansive definition of ‘high risk supports’ would effectively eliminate sole providers from providing care support on the scheme– restricting their role to social outings only– due to the complex cumbersome ‘advanced registration’ requirements which cost thousands and are designed for care companies only. Industry estimates suggest the cost of NDIS registration, including documentation and compliance systems, ranges from a few thousand dollars to $15,000 or more, depending on complexity of the services offered. These are compliance hurdles that sole providers – most of whom are lower income- cannot hope to afford. In order to make registration accessible to sole providers registration fees must be under $200 – and take weeks not months.

Minister Butler has chosen this inaccessible registration model as he perceives sole providers– sole traders directly contracted by participants provide care support on NDIS– as a fraud risk and is seeking to eliminate them from providing care services on the scheme in an indirect attempt to reduce fraud by strangling the provider pool to ‘a trusted few’ – as per his budget speech. While the official reason for introducing mandatory registration is to ‘improve care quality’, the underlying motive – and possibly the dominant one – is to make budget savings through fraud reduction with a ‘proportionate reduction in fraudulent activity and funds leakage’ listed as a key success metric for Advanced Registration in the official Impact Analysis Equivalent submitted to Parliament.[1]

 

However, sole providers– who will be excluded from Advanced Registration due to its structure, cost and complexity–  are the only source of low-cost care support on the scheme and provide the bulk of care – making up 80% to 94% of all care providers. Due to low overheads, sole providers are able to offer care services priced up to 35% lower than those offered by care companies who have high margins. In contrast, not only do care companies charge maximum NDIS hourly rates (with up to 35% mark up (to a day rate of $72/h), but often insist on 3-hour minimum shifts and a $500 joining fee– which wastes far more money than fraud and hands hefty margins to care companies at the time when the government desperately needs to make budget savings.

[1] Department of Health, Disability and Aging, Impact Analysis Equivalent: Mandatory Registration of all NDIS Providers 2026

 

Figure 2: Sole Providers versus Care Companies

 

Examples rates and overhead for Sole Provider versus Care Companies

A. Large Provider Case study: Care Company markups start at 29%. For example, national registered provider Hireup's rates start at $72 per hour with 29% of the cost comprising of overheads.  Hireup has one of the leanst business structures in among registered providers - most of whom charge 3-hour minimum shift which wastes participant care budgets.

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 

Any increase to the hourly market rate of care will be subtracted from fraud savings. This means that the introduction of Advanced Registration – which drives up the hourly market care price by up to 35% as NDIS participants are forced to source personal care only from care companies at high mark up – will devour care budgets and with it any savings made from fraud reduction, as participants struggle to purchase the essential care hours they require with reduced purchasing power.

 

This sudden hike in care prices would wipe the single-digit savings made by fraud reduction at least twice over– making the Minister’s proposed Advanced Registration model futile as a budget savings measure– the underlying reason for its introduction and the Ministers refusal to implement the heavily consulted on NDIS Provider and Worker Taskforce Registration Model which enables sole providers – whom Minister Butler  considers a fraud risk – to register easily, demonstrating a confusion about how budget savings can be achieved on NDIS.

 

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.

______________________________________________________________________

Fraud Holes in the proposed Mandatory Registration

However most concerningly, the proposal to only register ‘highest risk supports’ leaves sole providers providing Social and Community Engagement Program unregistered. This prevents sole providers from being screened for criminal and fraudulent activity before being admitted onto the Digital Payment Platform which helps track provider payments. Currently the government is planning on admitting up to 200,000 sole providers onto the Digital Payment Platform to dispense 25% of the Non-SIL scheme ($4.5 Billion dollars)– without any identity checks, criminal background checks, character checks, or verification of financial details – which is irresponsible and undermines the heavy regulation of Advanced Registration.

 

It is risky to allow any provider onto a Digital Payment Platform without first verifying their identity and whether their banking details and taxation and registration numbers match – as mismatched ABNs, TFNs, well as rotating bank accounts are likely a common practice by those seeking to defraud the scheme. Screening and vetting of sole providers should be a precondition of being admitted onto the Digital Payment Platform which otherwise Social and Community Engagement – valued at $4.5 Billion dollars (25% of the scheme)– is left unprotected and vulnerable to fraudulent billing.

 

It’s unlikely that any fraud reductions will be made in the Social and Community Engagement Program, rather criminal activity on NDIS will likely just relocate from the heavily regulated personal care to this unmonitored part of the scheme– which has been carelessly left open as a back door for fraud, while the front door is excessively regulated.

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.

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2.0 Harm and Dysfunctions Caused by Advanced Registration

If the proposed Advanced Registration model merely wiped fraud savings and left Social and Community Engagement Program open to fraud, it could be deemed futile rather than dangerous. However, by the excluding highly trained and low-cost sole providers from providing personal care, the Advanced Registration model creates several unintended policy dysfunctions across-the-scheme, and will make NDIS unsafe for its disabled users, including:

  1. Overall reduction in care quality: Disbanding of highly-trained and hand-picked care teams of sole providers
  2. Creating shortages of care support workers in rural and regional areas
  3. Precipitate a care-crisis across the scheme: increases to the market price of personal care of up to 35% will reduce the purchasing power of participants leaving them unable to buy the care hours they require with the same budget;
  4. Increase liability for NDIA: resulting in large and costly class-actions for the Agency.

 

A. Scheme-wide Decline in the Standard of Care 

Excluding sole providers– who provide stable and dedicated long-term care support for many on the scheme– from providing personal care on NDIS using Advanced Registration, will force participants to disband hand-picked and highly specialised care teams that support their needs. Advanced registration is being introduced under the flag of improving the ‘quality of care’ on the scheme, however while care companies can guarantee a minimum standard of care, that standard is low and inflexible– and should only be imposed on participants who lack the mental capacity (and familial support) to manage staff and are considered susceptible to being defrauded.

 

Inflexible start and finish times and rota of randomly selected carers that care companies (registered providers) offer may be tolerable for a few short years as end-of-life support– as in aged care– however permanent disability is a lifelong proposition– meaning the low quality and rigid care services offered by large providers prevent disabled participants from living a normal life and are unsuited young people. As the Diploma in Community Services has no educational prerequisites and requires only 19 weeks part-time study, it cannot guarantee a reasonable standard of care. Only 6% of participants source care support from registered providers (who are typically large care companies) while 94% opt for unregistered providers– who are typically hand-picked sole providers. The big swing away from registered providers– who had and lost their market monopoly of the care sector once competition was allowed in– reflects the poor quality and unsuitability of the services they offer. The market's assessment (94%:6%) of the suitability and standard of care delivered by care companies and sole providers is not wrong; sole providers– who make up between 80% to 94% of all NDIS providers– should be screened, vetted and registered rather than crushed in an attempt to catch a handful of criminals.

 

Given the rigidity and low standards of care offered by registered providers, only intellectually disabled participants who lack the familial support necessary to hire and manage sole providers should be required to source care from registered providers as they are at high risk of fraud.

 

B. Care worker shortages in rural and regional areas 

As rural and regional areas are typically not serviced by large providers and already struggle to access services, excluding sole providers from providing personal care will cause care shortages in rural and regional areas– making the exclusion of sole providers from registration unviable. NDIA policies by which harm participants– such as disrupt the supply of care support– will attract liability under common law (as a duty-of-care exists between NDIA and its disabled participants due to the proximity of the relationship and foreseeability of harm). In order to avoid a class action, it is imperative that the Agency ensure accessible and continuous care support nationwide – retaining sole providers in the NDIS provider market is necessary to maintaining sufficient care service delivery across the country, especially in rural and regional areas.

 

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

The exclusion of low-cost sole providers from providing personal care on NDIS– under the onerous Advanced Registration model– would force NDIS participants to exclusively source personal care services from large providers– who have large margins and charge up to 35% more per hour than sole providers.

 

Figure 6:  Advanced registration would result in insufficient care hours for many participants on the scheme who do not have any slack in their budget and so will be unable to afford to purchase the care hours they need at upto 35% increase in market rate. 

Such a sudden and sharp increase in care prices would precipitate a crisis of neglect across NDIS, as the purchasing power of participants would be reduced. This would result in many disabled participants being unable to afford the care hours they require to cover their essential care needs. 

 

This is cause for alarm, as NDIS participants are severely disabled and often have fragile health, which can easily worsen. Decline in health typically causes a decline in capacity; which will result in a need for additional care hours at the next capacity assessment and increase the long-term care costs. An increase in accidents, worsening of capacity and widespread neglect should be expected from a care hour shortage. Disabilitywatch will be tracking and reporting on the harm caused to participants from the implementation of advanced registration

 

Fig 7: Forcing participants to exclusively source high cost care support (marked up by up to 35% to $72/h) from large registered providers will result in fewer care hours for participants and trigger widespread neglect across the scheme. 

 

Implementing policies that increase the price of care support by up to 35%, is akin to cutting participant care budgets by the same percentage– as participants' purchasing power is commensurately reduced. NDIS’ severely disabled participants are unable to weather any reductions to their care budgets. NDIA presently lowball participants' care hour allocations in expectation that they will squeeze the necessary care hours from their funding by hiring low-cost sole providers. So if a participant’s occupational therapist requests 9 hours of care per day, NDIA will rarely adhere to that professional recommendation, and generally lowball by allocating only 6 hours of care per day– in expectation that participants can still have their care needs met by economizing and hiring sole providers. 

 

Should participants suddenly be prevented by NDIA from sourcing low-cost sole providers due to restrictive registration– a very clear and foreseeable care crisis would emerge. In the past 18 months many NDIS participants have received deep cuts (often ranging from 30%-50% to offset the rapid admission of minors onto NDIS), meaning they depend more on low-cost sole providers now more than ever to have essential care needs met. It is therefore dangerous to suddenly force participants to source care support at maximum NDIS rates– and would attract significant liability for the Agency.

 

D. Increased Liability for NDIA

As a duty-of-care exists between NDIA and its disabled participants, where NDIA policies cause foreseeable harm to participants– for example, result in reduced care hours and prospective neglect by driving up the market price of care– the Agency would likely be liable under torts law for any out-of-pocket care costs incurred by participants attempting to cover their OT recommended care needs. When determining liability– common law courts would employ the ‘reasonable person test' and would be guided by professional allied-health recommendation for care hours– which are typically much higher than NDIA’s allocation which rarely follow professional recommendations. So in addition to wiping gains made for fraud reduction, registration which drives up the market price of care by excluding sole providers, may actually increase the Agency’s care costs– making it wholly ineffective as a budget saving measure.

 

For NDIA to avoid large class actions, it is imperative that the market rate for care support remains steady– this can be achieved by developing a registration process which includes sole providers as recommended by the NDIS Providers and Workers Taskforce– rather than eliminating them from the provision of personal care which drives up the market price of care support. Any new registration process for sole providers can include screening and vetting of sole providers for general criminal activity and fraudulent billing, expanding on the existing NDIS Worker Screening Check.

 

Introducing an additional layer of shift verification technology prior to billing, would help verify invoices claimed by sole traders further preventing unauthorized billing and overbilling– so the scheme's open structure ceases to be a fraud risk (see Box 1 at the end).

 

Conclusion

Policies that trigger mass neglect across a scheme for the severely disabled– especially with no financial benefit– clearly fail to meet the minimum safety and economic standard required of any government policy, which should be evidence-based. The incorrect assumption of uniform pricing by DHDA renders the Impact Analysis Equivalent of Mandatory Registration of all NDIS Providers submitted to Parliament to secure support for the controversial Securing the NDIS for Future Generations Bill 2026 incorrect and has resulted in:

• The design of an unsuitable registration model ie. Advanced Registration

• a false analysis of the impacts of the proposed Advanced Registration.

 

A de novo assessment of the relative merits of both the NDIS Taskforce Registration model and the Advanced Registration model is required, so that the resulting registration model does not:

• disrupt the supply of services; or

• drive up the market price of care; or

• trigger a crisis of neglect across the scheme

• squander budget savings

 

Given that NDIS supports the severely disabled, the scheme’s number one priority should be to ensure sufficient and accessible provision of care services Australia-wide.

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

 

To avoid service disruptions, ensure safety on the scheme and retain budget savings, sole providers cannot be excluded from the provision of personal care. Rather, sole providers must be allowed to register scheme-wide as part of a broader registration process that encompasses all providers (as per NDIS Review Recommendation 17). To avoid squandering savings made from fraud reduction, the provider pool cannot be notably restricted in an attempt to curb fraud, as Advanced Registration (which seeks to exclude sole providers who make up 80% of all providers) aims to do. Rather, all providers need to be screened and vetted as part of registration, with additional shift and invoice verification technology deployed – see Part 5 for an alternative registration approach that screens for fraud, makes budget savings and is safe for NDIS’ disabled participants.

 

A registration model which includes sole providers has already been designed by the NDIS Provider and Worker Registration Taskforce, who designed a scheme-wide registration model with 4 risk-graduated registration categories (advanced, medium & low risk support) plus, a separate category for ‘self-directed supports’ which would enable sole traders to register– in order to protect Choice and Control: the right of participants to handpick a care team. In doing so, the Taskforce implemented a key recommendation of the NDIS Review 2023 namely: to design ‘a graduated risk-proportionate model for the visibility and regulation of all providers and workers’ (Recommendation 17). Such a recommendation ensures that:

• the level of regulation is appropriately matched to the level of risk, so as to:

•  avoid disrupting the provision of care support or distorting the provider market due to excessive regulation; and

• preserve Choice and Control: the ability of participants to handpick a care team

 

• Registration covers all NDIS workers and providers scheme wide (not just for personal care as proposed by Advanced Registration), so that all NDIS workers and providers:

• fall within the regulatory ambit of the NDIS Commission

• can be screened and vetted in order to be safely admitted on the Digital Payment Platform so their invoices are visible to NDIS

 

However surprisingly, Minister Butler rejected the scheme-wide graduated risk-proportionate registration model developed by the NDIS Provider and Worker Registration Taskforce– in a confused attempt to make budget savings by eliminating sole providers to reduce fraud risk. (This is evidenced in the ‘success metrics’ for Advanced Registration which list ‘a reduction in fraudulent activity and funds leakage’ as a key expected outcome resulting from the implementation of Advanced Registration). Nonetheless the Taskforce’s model was rejected by the Minister, despite having firm democratic footing– having resulted from consultation with 2,200 people and 32 roundtables.

 

Instead, Minister Butler decided to develop his own alternative NDIS Advanced Registration model with no consultation. This was achieved by:

■ Dismissing the extensively consulted on registration model developed by NDIS Provider and Workforce Registration Taskforce which implemented Recommendation 17 of the NDIS review for graduated risk-proportionate model.

 

■ Sidestepping the National Disability Insurance Agency (who are the disability experts) in an attempt discard the NDIS Taskforce’s model and drive through a political reform agenda, by referring the development of the alternative registration model to the Department of Health, Disability and Aging (DHDA)– who are not the lead Agency on disability policy and don't administer NDIS– having only recently forayed into the field and added ‘Disability’ to their departmental name in the past 2 years, and therefore :

o lack a working knowledge of the disability market; and

o Are small and recently established; and therefore

o lack the necessary expertise in disability to design a registration model for NDIS safely.

Department of Health and Aged Care report from March 2025

Both of these deeply flawed proposals– the registration model and the analysis– have been submitted to Parliament in the Impact Analysis Equivalent: Mandatory Registration of all NDIS Providers to support the passing of Securing the NDIS for Future Generations Bill 2026. As such they require evidence-based review and resubmission before the Amendment Bill can be considered by Parliament.

 

■ Misquoting key recommendations made by the NDIS Review in the Impact Analysis of Mandatory Registration submitted to Parliament namely:

‘that the NDIS review proposed a risk-based regulation approach applying regulatory obligations at the highest risk supports and services while releasing lower risk supports and services from burdens and regulations.’ 

What NDIS Review actually recommended (17.1) was:

‘Design and implement a graduated risk-proportionate regulatory model for the whole provider market.’

o the requirement that NDIS regulation encompass ‘the whole provider market’ has been redacted from the ‘quoted’ NDIS recommendation in order to misrepresent the recommendation which green lights the development of a model that covers only part of the scheme, which is what the proposed Advanced Registration does. Nonetheless the the proposed registration models still returns to be all encompassing, with title of the proposal being: Mandatory Registration of all NDIS Providers

 

o the requirement for a ‘graduated model’ has been cleverly side-stepped. Despite the merits of a ‘graduated model’ being discussed for over four pages in NDIS Review (p.212-215) DHDAs impact analysis cherry-picked the one sentence which ‘graduated’ was not in because ‘regulation of all providers and workers’ was instead recommended, which in combination with ‘risk-proportionate’ means graduated. However disingenuously they also dropped the recommendation for ‘regulation of all providers and workers’ does doctoring the meaning of the Recommendation 17 of the NDIS Review in a document to Parliament.

 

By omitting the cornerstone NDIS Review recommendation for a graduated scheme-wide registration model from the Impact Analysis of Mandatory Registration submitted to Parliament:

• the proposed Advanced Registration model appears to comply with the NDIS recommendations and

• later claims to be ‘built on’ NDIS Review recommendations and 

• can falsely claim the extensive consultation of the NDIS Review as its own.*

 

● Such intentional misquoting and distortions of NDIS Review recommendations: 

o appears to stem from a politicisation of the policy process; and

o may constitute a breach of the APS Code of Conduct by the Department of Health, Disability and Aging; and requires investigation by the Australian Public Service Commission.

o may amount to misconduct under section 4 of the Parliamentary Privileges Act 1987;

o May constitute an offence under section 137.1 the Criminal Code Act Cth 1995 which criminalizes the giving of false or misleading information or omissions in compliance or connection with a law of the Commonwealth. Absolute liability applies; please see Part 7: Recommendations

 

■ Adopting the language of graduated risk in the Impact Analysis of Mandatory Registration submitted to Parliament by claiming that registration will apply to ‘highest risk supports only,’ despite Advanced Registration:

o only having a single-tier high-level registration: with no graduated risk framework proposed

o ‘high risk supports’: being defined expansively to include all personal care (Assistance with Self-care Activities and Personal and Domestic Support) which will encompass 75% of care funded support (Non-SIL).

 

■ Adopting the language of scheme-wide registration in the Impact Analysis of Mandatory Registration submitted to Parliament despite the providers of the Social and Community Engagement Program– which makes up 25% of the budget ($4.5 Billion per year)-- being exempted from registration:

o The title of the ‘Impact Analysis Equivalent is: Mandatory Registration of all NDIS Providers,’ which is incorrect and blatantly misrepresents the proposed registration model as scheme wide. 

o Without any fraud screening (as part of scheme-wide registration) the Social and Community Engagement Program fraudulent activity on the scheme will simply relocate to the unscreened and unmonitored part of the scheme. 

 

■ Misleadingly claims to ‘build on’ the recommendations of the NDIS Review. On p.11 of the Impact Analysis of Mandatory Registration, the Advanced Registration model claims to ‘build on’ the NDIS Review despite having discarded key recommendations for:

o scheme-wide registration: despite the NDIS Review recommending the regulation of all providers and workers’, under advanced registration 25% of the Non-SIL supports will be staffed by unregistered providers.

o a graduated approach: Advanced Registration is a single-tier model, with no framework for future multi-tier provided, just a promise of one forthcoming.

o a risk-proportionate approach: Advanced Registration has classified 75% of the scheme high-risk and requiring heavy-handed advanced regulation, while leaving 25% of the scheme unregistered – with no regulatory coverage at all.

 

The false claim that the Advanced Registration model ‘builds on’ recommendations of the NDIS Review was enabled by earlier misquoting of the NDIS Review Recommendations as being solely ‘risk-based’ without any mention of graduation, or requirement of scheme-wide registration (which demands a graduated risk-proportionate model).

In contrast, the sidelined NDIS Taskforce’s model can claim to be built on the NDIS Review having developed a scheme-wide graduated risk-based registration model with different 4 registration categories which appropriately balanced risk and regulation, including: advanced, medium, self-directed and low risk support.

 

■ Disingenuously appropriates the extensive consultation carried out by the NDIS Review and NDIS Provider and Worker Registration Taskforce claiming it ‘informed their work’ and padded out Parliamentary documents by describing the NDIS Review’s and Taskforce's extensive consultation processes in detail for over half a page on p.153 Explanatory Memorandum (Securing the NDIS for Future Generations Bill 2026) despite having disregarded key recommendations for scheme-wide, graduated or risk-proportionate registration– having developed a diametrically opposed single-tier high-level model that is neither scheme-wide, graduated nor risk- proportionate – although claims to be all three.

Summation

These successive administrative sleights-of-hand– that have been submitted to Parliament in explanatory documents to support the passage of Securing the NDIS for Future Generations Bill 2026 by Minister Butler– attempt to mislead Members of Parliament on the degree to which the Advanced Registration model complies with the NDIS Review Recommendations thus its legitimacy and consultative underpinning, and require investigation as to whether they are not they amount to misconduct under section 4 of the Parliamentary Privileges Act 1987.

In reality, imposing blanket high-level regulation across over 75% of funded care support (non-SIL) means that Minister Butler's proposed Advanced Registration model:

• does not comply with all three recommendations of the NDIS Review of adopting a scheme-wide, graduated or risk-based approach; and

• Has not been directly consulted on– having been developed in a bubble by the– until recently named– Department of Health and Aged Care at Minister Butler's request.

 

No budget savings

The punchline to this elaborate political game of smoke-and-mirrors in pursuit of savings, is that the resulting registration model is so poorly designed, it will fail to deliver any budget savings due to the sharp increase in the market rate of care support which will devour any savings made from fraud reduction. 

 

The proposed Advanced Registration scheme will also adversely affect NDIS severely disabled participants by:

• driving up the price of care resulting in many participants unable to cover their essential care needs and triggering a crisis of neglect across the scheme;

• creating supply shortages of care workers in rural and regional areas;

• forcing highly-trained and hand-picked care teams to be disbanded in favor of the inflexible, expensive and low minimum standard that care companies deliver– all but destroying Choice and Control.

 

5.0 How to make budget savings safely

Significant budget savings on NDIS can be made, and the above harm avoided, however only if sole providers are allowed to continue delivering personal care. 

 

Budget savings lie in both:

• Introducing scheme-wide pricing caps for sole providers (who make-up approximately 70-85% of scheme providers) so government pockets the average 25% markups rather than handing them to large providers; and

o Both Personal Care and Social and Community Engagement Program must be included

o Payments to sole providers must be direct for lower pricing limits to comply with casual loading and super contribution rules. A government run online billing platform could be considered to enable lower pricing limits and greater savings– however shift verification would be required to prevent fraudulent billing.

 

Figure 8: Larger savings lie in retaining sole providers for personal care and introducing lower pricing limits scheme-wide, then narrowly focusing on fraud reduction.

 

Tackling fraud without increasing the market rate of care– so fraud savings are not devoured by increases to the market rate of care support 

■  Sole providers need to:

  • Verify their identity with in-person ID checks  
  • Be vetted scheme-wide for fraud, rather than eliminated
  • Be Registered onto a Digital Payment Platform so their payments are visible and can be assessed via machine learning for irregular billing.

 

Savings can be maximized by combining pricing caps for sole providers with fraud reduction measures, such as screening sole providers for fraud and the introduction of: 

• invoice verification technologies– enabling shifts worked to be verified so fraud can be automatically screened-for prior to payment, rather than chased up manually afterwards.

• Machine learning: so over billing and unauthorized billing can be detected and red-flagged automatically.

 

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

 

Sole providers could be screened for both risk and fraud as part of registration. The current NDIS Worker Screening Check– which is an existing national background screening process used to assess whether a care worker poses:

• a risk to disabled persons and 

• is suited to working in high-risk NDIS roles

And could form part of a new registration for sole providers in the ‘self-directed’ supports category under the NDIS Provider and Worker Registration Taskforce’s Registration model – which should be implemented given the extensive consultation backing it.

 

The NDIS Worker Screening Check is currently required by the NDIS Quality and Safeguards Commission for workers in risk assessed roles with registered NDIS providers and could be required of all sole providers as part of scheme-wide mandatory registration. If the NDIS Worker Screening Check is deemed sufficient as a quality safeguard by the NDIS Quality and Safeguards Commission who oversee it, it’s unclear why it is not enough for Minister Butler.

 

Additionally, fraud screening of sole providers could be added to the registration process, to protect NDIS from fraud–which Minister Butler’s primary concern– including:

• in-person verification checks of identity and financials (ABN, TFN and bank account) – requiring photoID and bank statements (which would be scanned and kept on file as part of registration.) Using a delocalised model to conduct a person checks on the large number of sole providers using:

o Local Area Coordinators at NDIA Regional Offices; or

o Local Police Stations: with hundreds of locations nationally, in-person identity checks could be outsourced to police stations to ensure accessibility and easily process all sole providers. In-person identity check at a Police Station would alone act as a deterrent to fraud, as participants would be mindful that their personal details are on-file with both the police and NDIA.

• a fraud check of sole provider’s existing NDIS invoices– requiring consistent and fraud free billing for registration. 

▪︎ any new registration process for sole providers must be accessible - costing less than $200 and taking no more than a couple of weeks

Scheme-wide registration offers greater protection for fraud than registering only ‘high risk supports’ which under Advanced Registration only applies to 75% of funded support hours and leaves the Social and Community Engagement Program– around 25% of funded care supports– unregistered and susceptible to fraudulent billing. Without scheme-wide registration, that also covers the provision of the Social and Community Engagement Program, criminally minded people and networks will simply relocate and defraud NDIS via the Social and Community Engagement Program. So while NDIS’ front gate will be over-manned, its back gate will be left wide open to fraud.

 

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

 

The scheme-wide graduated and risk-proportionate registration model developed by NDIS Provider and Worker Registration Taskforce– which was the product of extensive consultation– needs to be implemented instead of the Minister’s Advanced Registration model which:

• is not graduated or risk-proportionate; 

• does not apply to all providers on the scheme– leaving 25% of non-SIL supports ($4.5 Billion) vulnerable to fraud;

• has not been consulted on; 

And will:

• Result in insufficient care hours and a crisis of neglect scheme-wide;

• Disrupt the market and create provider shortages in rural and regional areas;

• Squander budget savings through sharp increases to the market price of care.

 

Instead, the NDIS Provider and Worker Registration Taskforce Model– which is the product of extensive consultation– should be implemented in order to enable:

• Graduated risk-proportionate registration of all providers 

• Scheme-wide registration of all providers offering better protection for fraud

• Register sole providers in a dedicated supports category, in order to:

o Prevent market disruptions;  

o Prevent a crisis of neglect across the scheme;

o Prevent highly trained care teams from being disbanded;

o Protect Choice and Control and maintain the rights of NDIS’ disabled participants;

o Enable lower pricing limits to be implemented scheme-wide so budget savings can be made safely.

 

6.0 Conclusion

Minister Butler’s Advanced Registration proposal is not based on evidence or consultation of any kind, but is merely a desperate, misguided and unevidenced political attempt to lower budgets in any way possible. Not only will Advanced Registration fail to make anticipated budget savings, but it will harm many severely disabled participants in multiple ways. Policies which are not backed by consultation or evidence – even if they claim to be – cannot be implemented.

 

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.

 

2. Investigate false and misleading statements contained in both the Impact Analysis Equivalent: for Mandatory Registration of all NDIS Providers and the Explanatory Memorandum for Securing the NDIS for Future Generations Bill 2026 (as outlined in Part 4) submitted to Parliament by Minister Butler, by referring the matter for investigation to:

• 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;

• The Commonwealth Ombudsman to assess whether false or misleading statements submitted in official documents to Parliament in pursuit of passing a Commonwealth law constitute an offence under section 137.1 the Criminal Code Act Cth 1995 which criminalizes the giving of false or misleading information or omissions in compliance or connection with a law of the Commonwealth. Absolute liability applies; 

• The Commonwealth Public Service Commissioner for breach of the APS Code of Conduct (s.13 Public Service Act 1999) by the Department of Health, Disability and Aging, due to false and misleading statements as well as, strategic omissions regarding NDIS Review Recommendations in supplementary documents (itemised in Part 4) submitted to Parliament to support the passage of Securing the NDIS for Future Generations Bill 2026.

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.

______________________________________________________________________________________________________________

 

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

In order to:

• maintain Choice and Control and 

• maximise safe budget savings from fraud reduction and

• avoid a crisis of neglect on NDIS and care supply shortages

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.

While no such fraud prevention products are available off-the-shelf, the technological components required for such a system already exist, but would need to be specifically adapted for NDIS’ decentralised structure of 300,000 work locations. Such technology would need to be easy-to-use, reliable and affordable to implement. 

 

For expressions of interest please contact us at: enquries@disabilitywatch.org

 

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