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Initial Response to the NDIS Review Final Report


In October 2022, the Commonwealth Minister for the National Disability Insurance Scheme (NDIS or the scheme), the Hon Bill Shorten MP, initiated an independent review into the scheme due to concerns raised by the disability community about the operations of the NDIS.

Issues included unequal distribution of NDIS benefits, difficulty and trauma in the application process, and the NDIS becoming financially unsustainable. The NDIS Review Panel, after extensive consultation, identified key challenges, such as inadequate investment by state and territory governments in mainstream services, an unexpected increase in children on the NDIS, inflated pricing by service providers, and confusion around the term ‘reasonable and necessary supports.’

The final report, Working together to deliver the NDIS, released on 7 December 2023, includes 26 recommendations to improve participant experience, build trust, enhance usability, ensure value for money, and help individuals achieve their goals.

Our Approach

PDCN’s work is driven by our membership. We engage with our members through individual conversations, member surveys and community consultations. We also meet routinely with one of our key advisory bodies, the Lived Experience Advisory Panel, for advice and guidance about our priorities.

From our consultative efforts and initial review of the NDIS, we have compiled (a) a list of key issues raised by our community and (b) a list of changes to the disability landscape proposed in the NDIS review. We will use this list in NDIS consultations with the advocacy sector and co-design activities with governments to identify gaps and consider the specific needs of people with physical disability.

Noting the NDIS Review did not consider the operation of the NDIS in the context of different types of disability, we will also use data and research to make sure new NDIS frameworks, policies and initiatives consider the specific needs of people with physical disability. We will also ask our members for feedback on the recommendations to make sure our advocacy efforts are focused on the issues our community cares about most. Joint submissions to the government will be facilitated through the NSW Disability Advocacy Network (NDAN).

PDCN has broken down our response to key recommendations into identifying what problem the recommendation is trying to address, the proposed solution to the problem and, where relevant, what work PDCN has done or will do in this space.

How the NDIS Will Work for You

Recommendation 1.1:

Design, fund and commission an expanded and coherent set of foundational disability supports outside individualised NDIS budgets.

The Problem

The NDIS was designed to be one part of the disability service and support sector. The significance of introducing the NDIS saw governments prioritising its roll out and getting people onto the scheme as soon as possible. This came at the expense of investing in mainstream services outside the NDIS. Many existing services for people with disabilities in NSW were rolled into the scheme, leaving non-NDIS participants with limited-service options. This is particularly true for people living in rural and remote areas.

A shortage of available disability services and support outside the NDIS is a significant problem that has been raised by our members and the wider disability community on numerous occasions.

The Solution

The Review proposes a system of foundational disability support to complement mainstream and NDIS services. Foundational support is designed to offer people with disabilities a foundation to live a good life and feel included in the community, regardless of whether they are on NDIS or not.

Two types of foundational supports are proposed:

General foundational support would include programs and activities like information and advice, individual and family capacity building, peer support, self-advocacy, and disability employment supports.

Targeted foundational support is available for people aged under 65 with disability who are not eligible for the NDIS. This should include home and community support, such as shopping and cleaning or aids and equipment for people with less intensive support needs. Targeted support should be matched to people’s level of need.

Foundational supports should be designed to meet the diverse needs of individuals and of particular community groups, including First Nations, Culturally and Linguistically Diverse (CALD), LGBTQI+SB and people with disability who live in rural or remote areas.

Our Advocacy

PDCN will monitor the expansion of foundational support through data analysis, research, and membership engagement. We will recommend the NDAN works with us to review the Foundational Support Strategy and monitor the roll out of foundational support across NSW.

Recommendation 3.2:

The National Disability Insurance Agency (NDIA) should introduce a new Access Request Form and Supporting Evidence Form and accompanying guidance to make the process of applying for NDIS access more transparent and simple.

The Problem

People in the disability community say the current Access Request Form is complex and difficult to use. There are additional barriers for participants who are from CALD backgrounds, those with lower levels of literacy, and intellectual disability. This creates inequities in the application process.

Additionally, many people say obtaining the required supporting evidence is too challenging and costly. This has left some people who are entitled to be on the NDIS without access to support or funding for services.

The Solution

The NDIS Review proposes a new dynamic online access form. The form will provide guidance at each step, making it clear what information is needed and why.

There should be guidance for treating professionals on what evidence is required (and why) with a view to making access more equitable. There should also be enhancements to verbal and printed access forms.

Importantly, there is a proposal that the cost for supporting evidence (speech therapy reports, medical reports etc.) will be covered by the NDIA to make sure access to the NDIS is more equitable.

Our Advocacy

Through individual member consultation, PDCN is aware that the application process can be confusing and lead to inconsistent and unfair outcomes. We will undertake testing of the new form to ensure usability. We also plan to consult with Carers NSW and the Royal Australian College of General Practitioners to make sure the guidance about completing the form is appropriate and useful. We will also monitor changes to NDIA policy to make sure the cost of supporting evidence is funded in whole or in part.

Recommendation 4.3:

Deliver local navigation support within a nationally consistent framework.

The Problem

Unclear roles and varying service quality among Local Area Coordinators (LACs), Early Childhood Partners, and support coordinators are issues which we hear about regularly from our members. LACs often focus solely on NDIS participants (despite being expected to also support non-NDIS participants), while Early Childhood Partners sometimes lack the required training. Support coordinator quality varies, particularly in applying the ‘reasonable and necessary’ concept, creating challenges for those with complex physical disabilities because the complexity of their condition doesn’t fit within the standard guidelines for decision making.

The Solution

The Review suggests a new Navigator function for all people with disabilities, regardless of NDIS status. Navigators, with local connections, will assist in finding and coordinating support, emphasising individual goals. Specialist Navigators will be available for complex support needs.

Our Advocacy

PDCN supports this recommendation, however the quality of the navigation function is largely dependent on the educational background of the Navigator, their level of relevant work experience and the training provided. We will request specific information about the recruitment strategy and position descriptions for Navigators from the NDIA.

Thin Markets

Recommendation 13:

Strengthen market monitoring and responses to challenges in coordinating the NDIS market.

The Problem

The NDIS faces a crisis of ‘thin markets’ in regional, rural, and some metropolitan areas, hindering participant access to support. The NDIS review highlights this issue as persistent in the disability support sector.

The Solution

The NDIS Review recommends four key actions to address thin markets, including active market monitoring, establishing a provider of last resort policy, implementing provider panel arrangements for allied health supports in smaller towns, and developing a matching tool for participants to pool budgets.

Our Advocacy

PDCN members have raised issues about service shortages; the Lived Experience Advisory Panel has raised issues about the cost of services, members have reported service shortages in residential areas, and the NSW Disability Advocacy Network has raised issues about service provision in rural and remote areas in terms of quality, availability, and cultural appropriateness. In response, we have sent submissions to the NSW Government, the NDIA and the NDIS Review Panel about problems relating to thin markets.

We intend to monitor the market across NSW to make sure markets gaps are reduced. We will provide advice to the Government about strategies for building the online repository (service directory). And we will continue to work with our members outside the NDIS to see if they are connected to foundational support.

Recommendation 14:

Improve access to supports for First Nations participants across Australia and for all participants in remote communities through alternative commissioning arrangements.

The Problem

There is limited access to supports for First Nations participants and people who live in rural and remote areas of NSW. Of the services and support that are available, there are limited numbers that are culturally appropriate. This means that many First Nations participants may have to choose between supports that are not culturally safe or not using supports at all. Current NDIS funding does not include specific First Nations cultural activities to support the participant.

Historically, government ‘protection’ and ‘intervention’ efforts have negatively impacted First Nations people. Mistrust is intensified by social challenges like power imbalances, and a lack of First Nations decision makers in government. Past legislation, including assimilation policies, contributed to the lasting socio-economic disadvantage of First Nations people and resulting inter-generational impacts.

The Solution

The NDIS Review suggests the NDIA works in partnership with First Nations representatives, communities, participants and relevant government agencies to roll out alternative commissioning arrangements for both First Nations and remote communities. This is to be designed in partnership with First Nations people. It is crucial that First Nations controlled organisations are empowered to provide a bridge between First Nations communities and government bodies, where mistrust may otherwise prevent meaningful engagement. The commissioning arrangements should be built on community strengths and preferences, considerations of what is culturally appropriate, outcome-based processes, and use practical and community driven processes for data collection and evaluation.

Our Advocacy

PDCN wants to see positive, long-term change for First Nations people with physical disabilities. PDCN’s advocacy will involve undertaking consultations in rural and remote areas of NSW to better understand the needs of First Nations people with physical disabilities so we can plan accordingly.

Recommendation 15:

Attract, retain and train a workforce that is responsive to participant needs and delivers quality supports.

The Problem

The disability community and advocacy agencies have reported limited access to disability services and supports for people who are from CALD communities, LGBTQIA groups, First Nations people and people living in rural and remote areas. For the NDIS itself to be inclusive, these groups need to be able to access services that account for these individual needs.

The Solution

There are several initiatives proposed in the review aimed at enhancing the skills of individual employees and building workforce capability. One recommendation is a portable workplace training program. Apart from a more flexible training approach this could also set up disability services to offer workers who have been trained to support targeted groups.

Another recommendation is to use technology to upskill workers. For example, in remote communities where providers do not currently have access to relevant technology such as telehealth, alternative commissioning approaches could look at ways of investing in training and equipment for the whole community.

Our Advocacy

Workforce capability is critical to the success of NDIS. The quality of disability services is only as good as the people who deliver it. We will follow up with the trial of the portable workplace training program, and if it is to be rolled out, we will make sure that the portable workplace training program offers guidance on caring for people with physical disability. PDCN has will continue to advocate for initiatives that champion both place-based and specialist expertise for people with physical disability.

PDCN’s community consultations and research aims to identify locations where equipment for people with physical disability is needed – either in hospitals or in community health centers – and offer this advice to the NDIA.


Recommendation 3.7:

Reform the NDIS early intervention pathway to provide supports to individuals where there is good evidence the intervention is safe, cost effective and significantly improves outcomes.

The Problem

The original vision of early intervention in the NDIS has not been realised. The intent was to fund cost-effective interventions aimed at reducing the impact of long-term disability. For example, PDCN works closely with Stroke Recovery NSW and there is evidence that the earlier the intervention for stroke patients, the higher the chances of recovery. However, currently the process of initiating early intervention and NDIS supports is inadequate. This is because instead of working alongside health treatments and professionals in the early stages of recovery, the NDIS supports only come in to play after other options have been exhausted.

Our Solution

An early intervention pathway should be implemented with distinct access and needs assessment processes to identify participants who are likely to benefit from early intervention. This should include an agreed definition of ‘likely to benefit’.

Our Advocacy

While this is a good proposal, it is not clear where early intervention efforts will be focused. PDCN has previously advocated for more early intervention supports through the NDIS and will continue to link with stakeholders in the health sector to support clarification about what health conditions lead to physical disability and of these, which patients would likely benefit from early intervention.


Recommendation 2.9:

The Productivity Commission should develop an NDIS transport policy that better meets the mobility needs of participants.

The Problem

Across NSW, there is a significant lack of accessible transport for people with disability. With train stations across the state still transitioning to full accessibility through the Transport Access Program, around 30% of stations do not have a lift. There is also a reliance on transport such as taxis, which can often be costly and hinder independence. The Review identified a lack of clear long-term NDIS transport policy, which has in turn led to a reliance on the Australian Government Mobility Allowance. A reliance on this allowance has meant that NDIS participants in need of transport-related supports are not getting transport services tailored specifically to their needs, leading to inequitable outcomes. This has also led to inconsistency for participants and an overreliance on state and territory-based taxi subsidy schemes.

The Solution

The Review proposes adopting a specific NDIS transport policy from the Productivity Commission, outlining the collaboration between mainstream transport systems and NDIS responsibilities. This involves updating mobility assessments based on individual needs, creating clear distinctions between living expenses and disability-related costs in transport. The collaboration with state and territory governments aims to implement the policy, removing taxi subsidy cross-billing arrangements for NDIS participants.

Our Advocacy

Transport is a key priority area for PDCN, with committed involvement in Transport for NSW consultations, opportunities and submissions, especially concerning issues with the NSW Taxi Transport Subsidy Scheme and declining accessibility of wheelchair accessible taxis since COVID. The shift away from state-based taxi subsidies and the development of an NDIS-specific transport policy will impact the broader use of taxis for people with disabilities, however it is unclear what these implications may be until further information is released on the development of the policy.


Recommendation 9.11:

All Australian governments should agree and publish a targeted action plan for housing under Australia’s Disability Strategy.

The Problem

There is a critical shortage of affordable and accessible housing in Australia. Most general and social housing stock is not fit-for-purpose for people with accessibility needs. There are inconsistent residential tenancy rights for participants across different dwelling types. Widespread adoption of the Silver Livable Housing Design Standard in the National Construction Code would improve accessibility of the general housing stock. But roll-out will take time and the NSW (and WA) Government has not signed up.

The Solution

The NDIS Review recommends that Australian governments should publish a targeted action plan for housing under Australia’s Disability Strategy. This plan should mandate the construction of all new social housing to Gold Level Livable Housing Design Guidelines or equivalent. Additionally, there should be a commitment from the NSW and WA governments to endorse the National Construction Code Silver Livable Housing Design Standards.

The action plan, developed by the NSW Government, should encompass measurable actions to enhance the suitability of social housing for people with disabilities, ensuring consistency in residential tenancy and occupancy rights for participants in Specialist Disability Accommodation (SDA). Moreover, the action plan should be integrated with the National Housing and Homelessness Agreement and the National Housing Plan.

Our Advocacy

PDCN have been pushing for the NSW Government to mandate these changes in the National Construction Code for over two years as part of the Building Better Homes campaign. Unfortunately, NSW remains one of the last states and territories in Australia which is yet to adopt the Silver Level Livable Housing Design Standard. PDCN want to see this recommendation adopted in NSW in the next six months. The Disability Royal Commission also made recommendation 7.35 to increase the availability and supply of accessible and adaptive housing for people with disability through the National Construction Code, recognising that accessible and safe housing is key to preventing abuse, exploitation, and violence against people with disabilities.

Recommendations 8.1 and 8.2:

The National Disability Insurance Agency (NDIA) should implement comprehensive changes to the budget-setting process and introduce Housing and Living Navigators to ensure equitable and informed housing and living support decisions.

The Problem

Unclear rules and allocation processes in housing and living support lead to unjust funding disparities, exacerbated by the NDIA’s reliance on functional assessments. Separation of decisions on housing and living support, coupled with inadequate investment, complicates matters for NDIS participants. Budget determination focuses on individual items, not overall needs, posing challenges, especially for those with cognitive disabilities or limited support networks.

The need for expert advice is evident from the NDIA’s 2021 report, with a quarter of respondents expressing the need for discussions and examples of problem-solving in housing and living support.

The Solution

Recommendation 8.1 proposes a person-centred budgeting shift, focusing on support needs over disabilities. Participants needing 24/7 support would follow a shared model, guided by a 1:3 ratio. A provisional budget, flexible in living arrangements is introduced, guided by Navigators. Recommendation 8.2 suggests Housing and Living Navigators for expert advice, working collaboratively with General Navigators. This support empowers participants to choose suitable living arrangements, with providers calculating costs, adhering to budgets and price caps. Quality measures, including a Shared Support Facilitator, ensure a supportive environment. Navigator and family skills help participants build independence, aiming to enhance the system for informed housing and living choices. PDCN supports both of these recommendations.

Data and Digital Infrastructure

Recommendation 10:

Invest in digital infrastructure for the NDIS to enable accessible, timely and reliable information and streamlined processes that strengthen NDIS market functioning and scheme integrity.

The Problem

Issues in data and digital infrastructure for disability services include a lack of information on available supports, services, and their quality. Governments lack comprehensive data on service effectiveness, and the NDIS payment system is challenging for participants. Limited data on people with disabilities hinders planning and policy development.

The Solution

The NDIS Review proposes the NDIS Digital Infrastructure Strategy Roadmap, featuring initiatives like an online registry, streamlined digital payments, linking NDIS information to myGov, and increased investment in the National Disability Data Set.

Our Advocacy

PDCN believes that expanded data collection centered on NDIS and disability more broadly is key to identifying market gaps, assessing if the NDIS is working for participants and understanding the disability community more fully.  We stress privacy considerations and advocate for a streamlined digital payment system.


PDCN is aware that there are challenges in the way that the NDIS currently works and gaps in the provision of supports provided to NDIS participants. With the announcement of a growth cap on the scheme, one of our main concerns has been that addressing those gaps may fall to the wayside in the attempt to meet the growth target.

The NDIS Review proposes a new system of more unified service delivery for people with disabilities. This system will include disability support in mainstream services, new foundational services, targeted services for people not on the NDIS and individual NDIS supports. The disability service landscape has the potential to deliver, but must ensure that people do not continue to fall through the cracks.

We are cautiously optimistic about the reforms being made to access and planning systems and the introduction of navigators to replace LAC and support coordinators. PDCN want to ensure that going forward, the recommendations to ensure housing and living will be underpinned by choice and control and the quality of services will be enhanced.

PDCN will continue to monitor this landscape on behalf of our members and people with physical disabilities and advocate for a fairer and more effective NDIS and wider disability support system outside the scheme.

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