Allan Dall · Group Managing Director and CEO, The Glue Group
22 April 2026
Today at the National Press Club, Minister Mark Butler announced the most significant reset of the NDIS since its inception. The numbers are confronting: growth halved from 10 per cent to 5 per cent annually, around 160,000 participants to be moved off the scheme, and $15 billion in projected savings by 2030. The Bill, to be introduced after the 2026-27 Budget, will be built on four pillars covering eligibility, planning, registration and payments.
As a registered provider that has spent years operating at the frontline of the scheme, I want to start with something that often gets lost in this debate: the sustainability problem is real. A program growing at double digits indefinitely is not a program that survives. The NDIS will not be there for our children or grandchildren with disability if it cannot be brought onto a sustainable path. Reform is not the enemy of the scheme. Drift is.
I also want to acknowledge two specific elements of today's announcement that closely track arguments we have been making to Government for some time.
The first is the commitment to enrol providers in a digital payment system. In our January 2026 submission to the Joint Committee of Public Accounts and Audit, Assistive Tech argued that the current self-managed payment pathway contains a structural fraud gap, and that where a valid invoice from a registered provider is submitted, payment should flow directly to the provider by default, with reimbursement reserved for participants who can evidence they have already paid. Seeing that principle reflected in the reform program is genuinely encouraging. It is the kind of plumbing reform that sounds unglamorous but prevents real harm, to providers, to participants, and to the scheme's integrity.
The second is the move to cut spending on third-party intermediaries by 30 per cent and shift to a panel-style shortlist of quality intermediaries from which participants can choose. In the same submission, we argued that the current fragmentation across more than 1,400 plan managers is not a market, it is regulatory outsourcing by default. A national, rules-based scheme cannot function when 1,400 intermediaries independently decide what is claimable. Consolidation into a smaller panel of high-quality, accountable intermediaries is the right answer, and the Minister deserves credit for committing to it.
Both of these are substantive reforms. Both tacitly accept that the status quo has been producing the wrong outcomes. That matters.
But I want to use this moment to make a harder argument. The four pillars announced today are, broadly, a cost-control plan and a fraud-control plan. They do not yet fully address the third failure mode that runs through every provider's experience of the scheme: ambiguity.
Ambiguity is the quiet driver of most non-compliance in the NDIS. It is not organised crime. It is not the “shonks and lowlifes” the Minister rightly wants to pursue. It is the daily reality that ordinary participants, family members, therapists, plan managers and providers cannot confidently determine what is claimable, what is not, and on what authority.
If the reforms do not fix this, tighter rules will not create a better scheme. They will create a more punitive one.
What ambiguity looks like at the coalface
At Assistive Tech we supply communication devices, AAC tools, environmental controls and related equipment. Our business is built on compliance. We invest heavily in training, conservative interpretation of the Act and Rules, and participant education. And yet, every week, we deal with the same set of structural problems.
Participants call the NDIA National Contact Centre and receive different answers on different calls about whether an item is a Funded Support, a Replacement Support, or Not an NDIS Support. None of it is documented or shared with the provider, parent, carer or intermediary. When the claim is later rejected or audited, the participant, provider and intermediary carry the risk, even though they acted on advice from the Agency itself.
Plans are written in broad functional terms: “assistive technology to support communication”. Does that include an iPad with a communication app? A dedicated speech-generating device? Something else entirely? The plan does not say. The participant, their therapist, their plan manager and NDIA staff will often reach different conclusions. The participant is then told their plan “already covers this” without any mechanism to determine what “this” actually means in practice.
Public NDIA guidance has been openly acknowledged by the Agency as out of date. Providers and participants are told, in effect, to rely on primary legislation in the interim. More than a year after the October 2024 amendments, families and frontline staff are being asked to do statutory interpretation that most lawyers would charge for.
And then there is the fragmentation of plan management itself. There are currently more than 1,400 plan managers in Australia. The same invoice can be paid in full by one, partially rejected by another, refused outright by a third, and escalated for further evidence by a fourth. Participants quickly learn that if one plan manager says no, another may say yes. The system trains them to treat compliance as negotiable. That is why today's commitment to a consolidated panel of quality intermediaries is welcome, and why the detail of how that panel is constituted, governed and held to a uniform rule set will determine whether the reform actually lands. A smaller number of intermediaries, all applying different rules, would be progress in form only.
For a provider trying to operate lawfully at scale, the implications are corrosive. We cannot design a single compliant workflow. We must maintain dozens of parallel rulesets. Conservative providers lose sales to less conservative competitors, and the market quietly rewards ambiguity. Good-faith providers are commercially penalised for restraint. None of that is captured in the fraud statistics. It does not look like theft. It looks like drift.
Why this matters for the four pillars
The reforms announced today will intensify every one of these pressures unless clarity is addressed in parallel.
If eligibility is tightened and 160,000 participants are reassessed, the volume and complexity of written plans will rise sharply. Ambiguous plans plus high-stakes reassessment is a recipe for dispute, appeal and distress, not efficiency. The Administrative Review Tribunal is not a substitute for a well-drafted plan.
If mandatory provider registration is expanded from 1 July, the registered cohort will grow. That is generally positive for integrity. But registered providers are precisely the cohort most exposed to the current ambiguity problem, because we are the ones audited against rules that are not consistently published, applied or updated. Expanding registration without fixing the rules asks more providers to be accountable to a moving target.
If a digital payments system is introduced, it must be designed as a closed loop linking supply, claim and payment, not merely a faster version of the existing pay-now-check-later model. Real-time validation only works if the underlying rules about what is claimable are themselves clear, written, versioned and binding.
And if standardised, evidence-based access assessments are introduced, the scheme will have quantified the front door while leaving the interior undefined. Knowing who gets in is not the same as knowing what they can buy.
The missing pillar
The Government's plan now addresses the plumbing of payments and the structure of the intermediary market. What it has not yet addressed is the rulebook itself. I would respectfully argue that the four pillars need a fifth, running through all of them: a clarity pillar.
It would rest on three practical commitments, all of which were in our January submission and none of which have yet been picked up.
First, authoritative written advice. Every eligibility or claimability answer from the NDIA should be recorded, referenced to policy, issued in writing, accessible to the participant and their nominated providers, and binding for audit purposes. Verbal advice cannot continue to be the primary currency of a $50 billion scheme.
Second, a single source of truth. Guidance and policy must be published publicly, versioned, dated and explicit when interpretations change. Families should not have to choose between outdated public documents and primary legislation. The consolidation of intermediaries into a panel only delivers its full value if every member of that panel is applying the same rule set in the same way, which requires that rule set to actually exist in authoritative form.
Third, error-safe design. Where rules remain ambiguous, the default response should be education, not retrospective debt. Good-faith participants and providers should not be the shock absorber for the Agency's own drafting backlog.
What comes next
The Government has taken a difficult and necessary step today. The direction is right. And the inclusion of provider-direct payments and intermediary consolidation in the reform program shows that the sector is being listened to, and that submissions from frontline providers are being reflected in policy. Two of the four structural recommendations Assistive Tech put to the Joint Committee in January are now, in substance, on the Government's agenda. That is worth saying plainly.
But if the reforms are to secure the NDIS for future generations, as the Bill's title promises, they must do more than constrain cost, pursue fraud and rationalise intermediaries. They must give the 760,000 people currently on the scheme, the families who love them, the therapists who support them and the providers who equip them, a system where doing the right thing is possible without a law degree.
Sustainability and clarity are not competing goals. They are the same goal. A scheme that people cannot understand is a scheme they cannot trust. And a scheme they cannot trust will not survive the decade, regardless of how cleverly the growth curve is bent.
We stand ready to work with the Minister, the Department and the NDIA on the detail. The plumbing matters. Let's get it right.
Assistive Tech's submission to the Inquiry into the administration of the National Disability Insurance Scheme is available at aph.gov.au.
