The APS welcomes the opportunity to comment on the proposed National Disability Insurance Scheme (NDIS) provider definition framework but raises concerns about how the model treats established, highly regulated health professions such as psychology. While the APS supports a risk‑proportionate approach to safeguarding NDIS participants in principle, we argue that the proposed graduated risk model does not appropriately account for the extensive regulatory structures already governing psychologists.
The APS also raised our concern regarding the absence of clear government policy on whether Ahpra‑regulated health professionals will be required to register with the NDIS. Without clarity on mandatory registration settings, the APS argues that stakeholders cannot meaningfully assess or respond to the proposed model. This uncertainty limits the value of the consultation process and prevents targeted, practical feedback. The APS emphasises the need for explicit policy direction before further consultation can be productive and looks forward to engaging once this foundational issue is resolved.
View submission