NDIS reform: integrity is only half the story

Jul 13, 2026 | Governance

On 16 July, I will be speaking at the NDISLink Conference in Perth on NDIS integrity, compliance and fraud risk management. See the attached link if you wish to attend: https://www.ndislinkevents.com/perthfinanceandcompliance2026

The title of my session is deliberately direct: What WA providers are getting wrong — and how it’s being exposed. But there is another issue sitting just beneath that discussion.

The Federal Government’s proposed NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 is being framed around sustainability, fraud control, clearer eligibility and better governance. Those are legitimate objectives. In my view, there is a pretty strong case for saying that the NDIS does need stronger controls, clearer evidence, better provider visibility and a more defensible funding model. However, providers should not treat this Bill as only an integrity Bill.

It is also a market reset Bill. One of the most significant proposed changes is the reset of Social, Civic and Community Participation funding. Government material says SCCP budget allocations are proposed to be reduced by 50 per cent, with Capacity Building daily activity budgets reduced by 10 per cent, effective 1 October 2026, as plans are renewed or reassessed.

The Government has also said that critical supports, including employment supports, are not intended to be impacted. That distinction matters, but it does not remove the risk.

In practice, as every provider offering these critical services knows, many employment outcomes are supported by activities that are not neatly labelled “employment support”. Community access, routines, travel practice, confidence-building, supported volunteering, social skill development, preparation for work, and staying connected to ordinary community life can all be part of the pathway to employment.

That is why providers are understandably concerned. The label may be social participation, but the impact may be on employment, wellbeing and service continuity.

The Summer Foundation has reported that participants with high support needs use SCCP funding for medical appointments, errands, community activities, transport, sport and recreation, and maintaining paid employment. Its recent survey found 37 per cent of participants used this funding to maintain paid employment, and 70 per cent used it flexibly to meet other disability support needs. That should make every provider pause.

If the funding category is reduced bluntly, some participants may not lose a “discretionary” activity (whatever the heck that means or how it’s defined under an NDIS which is supposed to support NDIS participants to lead ‘ordinary lives’). They may lose the practical support that keeps them working, connected, healthy and self-confident.

For providers, however, this is not just a critical policy issue; for many, it is a board-level risk.

Providers should be asking now:

  • Which participants rely on SCCP-funded supports to remain employed or work-ready?
  • Which services become unviable if SCCP revenue reduces materially?
  • Which programs rely on transport, group participation or thin-market delivery?
  • Which regional services have no realistic alternative provider if the current provider withdraws?
  • Which participants face increased isolation, carer breakdown, health risk or loss of employment if supports are redesigned too quickly?

These issues are particularly critical and present in regional, remote and very remote parts of Australia.

Thin markets, long travel distances, workforce shortages and limited alternative providers mean a funding reset can have a sharper effect in these regions than in metropolitan markets. In fact, the Senate committee has specifically recommended further clarification on how impacts on thin markets, including regional, rural and remote areas, will be monitored, and how employment support budgets will be preserved from the SCCP-related changes.

My advice to providers is therefore pretty simple: do not wait for plan renewals to expose the risk; start now.

Map your SCCP exposure by participant, site, region and program. Identify which supports are genuinely social participation and which are employment-enabling, health-enabling or independence-enabling. Model the 50 per cent downside. Decide which services remain viable. Document participant transition risks before making any service changes.

And most importantly, do not make abrupt exits: a provider can make a legitimate commercial decision to exit an unviable service. But a provider cannot abandon a participant. The governance test is not only whether the numbers stack up. It is whether participant harm, notice, transition, communication and documentation have been properly managed.

We all know that the NDIS environment has changed. Providers are more visible. Claims are more traceable. Evidence matters more. Funding assumptions are less stable. Boards can no longer treat compliance as a back-office issue. Integrity is now a financial control. Funding reform is now a service-continuity risk.

And the providers that survive the next phase will be the ones that can prove, adapt and transition faster than the system disrupts them.

I am looking forward to speaking with WA providers at the #NDISLink Conference in Perth on 16 July. And if you are attending, I look forward to seeing you there!

David Moody, Head of Strategic Relationships/Consultant, MGA Group

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