Five Problems We Can Fix
Australia has spent more than $680 million reviewing the NDIS. The reviews keep finding the same five problems. Here is what the evidence shows, and what you can do about it now.
The bar was never set
Over the last decade, the Australian Government commissioned review after review to interrogate the NDIS and make it fit for purpose. A Royal Commission. An independent review of the scheme. Parliamentary inquiries. Performance audits. More than $680 million of work.
We read all of it. We consolidated 676 formal recommendations from 63 reports between 2016 and 2025, alongside 51 public submissions to the current parliamentary inquiry and the 451 separate issues those submissions raised.
This is not a story about discovering what is wrong. We already know what is wrong. The work ahead is to act on what a decade of evidence has already made plain.
The decade in numbers
What ten years of reviewing the same scheme actually produced.
Whatever the exact mix of done, in-progress and unknown, the recommendations are accumulating faster than they are being closed. The design failures named a decade ago are still being raised in submissions to Parliament today.
The five problems
Tap any problem to see the diagnosis, what has already been tried, what is still missing, and where the 2026 reforms actually land. The number on the right is how many years it has gone unresolved.
1
"Reasonable and necessary" is undefined in practice
Toward a clear line of sight between need, funding and life quality
9years
â–¾
The "reasonable and necessary" test is the gateway between a person's need and their funding. It has never been defined operationally. The Act sets out criteria, the guidelines paraphrase them, and the planner applies them. Two participants with similar needs receive different decisions. The system filters applications through a definition it has not actually written.
206 recommendations
40 of 51 submissions raise it
68% of tribunal cases settle before hearing
What has been tried
- Episodic conditions recognised in legislation (2022)
- Getting Back on Track Act statutory tools
- Section 10 support lists (what funding can buy)
- Refreshed guidelines and planner training
What is still missing
- A method that makes two planners reach the same decision
- Disability context built into the "everyday items" rule
- Funded access for people who cannot afford the evidence
- Published consistency measures the scheme is judged on
2
A transaction-based workforce with no support circle
Toward defined roles, qualifications, interfaces and shared accountability
10years
â–¾
Every role inside the NDIS workforce was scoped to perform an activity. None was scoped to support a participant's outcome with accountability for it, or as part of a connected circle around the person. A decade in, the workforce still operates as a collection of independent transactions rather than a coordinated quality system.
Many participants direct their own supports well. The design fails the participant whose risk, complexity or constrained capacity means they need a dedicated function working in their best interests. No current role is scoped to be that function, so when outcomes are poor, accountability cannot be located.
247 recommendations
45 of 51 submissions raise it
10 roles, same design flaw
What has been tried
- Navigator role proposed to replace LACs
- Behaviour support workforce supply strategies
- Mandatory registration for SIL and platforms
- Stronger regulator powers after harm
What is still missing
- The support circle architecture itself
- A minimum qualifications baseline per role
- Defined handovers and joint accountability between roles
- Outcome measures built into role design, not bolted on
3
No proactive quality system, only reactive complaints
Toward quality built into the system, not extracted after harm
10years
â–¾
The NDIS has no proactive quality system. Quality monitoring relies on participants raising complaints when something has already gone wrong. The complaints model assumes the participant knows what good looks like, can compare alternatives, and can walk away. A person living in supported accommodation cannot walk away from a complaint without losing their home.
285 recommendations
46 of 51 submissions raise it
Complaints up 20-fold in 5 years
What has been tried
- Expanded complaint-handling capacity
- Integrity and Safeguarding Act 2025 penalties
- Expanding worker screening
- Some state-based community visitor schemes
What is still missing
- Adult safeguarding and reportable conduct schemes
- A national community visitor scheme with real powers
- Funded, independent, unannounced welfare visits
- Safe arrangements during a complaint investigation
4
Individual funding applied to group economics
Toward a model that aligns funding with how supports are actually delivered
6years
â–¾
The NDIS funds individual entitlements. Supported accommodation runs on group economics. The two logics are incompatible, and the provider absorbs the gap. When a room sits vacant the provider keeps staffing the ratio while income falls. Vacancy risk sits entirely on the provider; the NDIS does not fund it.
Supported accommodation is too often presented as a choice between group living a person did not choose and individual living that is not available at scale. Group economics can be retained without surrendering a person's right to direct their own supports, choose who they live with, or move without losing their funding.
93 recommendations
47 of 51 submissions raise it
Highest single concern in the submissions
What has been tried
- Recommendation to separate housing from support
- Mandatory SIL registration from July 2026
- Refreshed SIL Practice Standards
- Own Motion Inquiry into the largest providers
What is still missing
- A funding model that acknowledges group economics
- One body accountable for closing the housing gap
- Funded vacancy, mismatch and head-lease risk
- Self-direction preserved inside group settings
5
Designed for a default participant who doesn't exist
Toward a system designed from the margins so it works for everyone
9years
â–¾
The NDIS was designed for a participant who is urban, English-speaking, has a single stable disability, makes individual decisions, and can self-advocate. Anyone who does not match meets a system that was not built for them. Bolt-on strategies added to a default-participant design have not closed the access gap.
First Nations Australians are 28 percent less likely to receive NDIS supports. CALD participants are under-represented by about half. Women are around 37 percent of participants when their share of the disability population suggests closer to 50. A First Nations woman in a remote area meets every barrier at once; the strategies meant to help her operate in parallel and do not.
128 recommendations
25 of 51 submissions raise it
LGBTQIA+ data not collected at all
What has been tried
- First Nations Strategy across several iterations
- Cultural training programs
- Translated materials in major languages
- Dedicated liaison roles and group consultations
What is still missing
- Mandated intersectional data collection
- Co-designed alternative commissioning arrangements
- Published disaggregated outcomes data
- Strategies integrated into core operations, not run beside them
The pattern behind the pattern
The five do not act independently. Two relationships in particular shape what can be fixed, and in what order.
Workforce and quality are entangled, not parallel
Problem 2 (workforce design) and problem 3 (no proactive quality system) are the same gap seen from two angles. A reform that fixes one without the other leaves half the gap open. You cannot build quality into a workforce whose roles were never scoped to deliver it.
Economics sit upstream of quality
Problem 4 (funding versus group economics) comes before problem 3 (quality) in delivery sequence. Pushing harder on quality without first redesigning the economics that make quality deliverable accelerates the very provider exits the quality reform is meant to prevent.
What providers can do now
The largest design changes sit with government. The quality of service a participant receives on a Tuesday afternoon does not. Within these constraints, providers keep meaningful agency, and the providers using it are building the strongest single argument for the policy change they are waiting on.
The test is simple. Does the support worker know the behaviour support plan and have someone to call when a routine breaks down? Does the therapist's recommendation make it into the daily routine, or sit in a folder? When the participant changes, who notices, and who acts?
Document your actual cost of delivery
Line by line, against the price guide. "Pricing is too low" is a complaint. The real cost of one hour of two-to-one care, the gap, and the years you have absorbed it, is evidence. Providers who hold the data will shape the response.
Map your exposure to concurrent reforms
For each reform landing in 2026, document what it costs you to comply and when it bites. If the cumulative cost exceeds your annual margin, that is a board-level decision, and it is better made before July than under pressure after it.
Build participant-specific protocols
A team-built description of what good support looks like for this person. Without it, your team supports a category of participant rather than a human being. This is the foundation everything else sits on.
Turn incident data into pattern recognition
Most providers can record incidents. Far fewer zoom out to see what their own data is telling them. A near-miss in one house may be a pattern across three. Pattern recognition turns reactive response into preventive action.
Build supervision into the role
Supervision as a scheduled, paid activity, not something that happens when a manager has time. Workers who are alone in a home with a plan they have not seen are workers who leave. Retention is a quality strategy.
Measure outcomes the participant agreed matter
Hours billed and audits passed are visible in every provider's data. Whether the person is sleeping better, seeing more people, or under fewer restrictive practices often is not. Ask, write it down, report against it.
None of this is a substitute for system redesign. It is the difference between a participant's actual experience today and a worse one. The evidence base for the next round of reform will come from the organisations that can show, not say, what works.
Read the full analysis
The complete report sets out the evidence for each root cause, maps the reform landscape against them, segments the implications by service type, and offers an action set for government, peak bodies and providers.