APS Submission to the Joint Standing Committee on the National Disability Insurance Scheme's Inquiry into the Integrity of the NDIS

The Australian Psychological Society (APS) submission to the Joint Standing Committee on the NDIS’s Inquiry into the Integrity of the NDIS reiterated our call for appropriate measures to prevent NDIS fraud, not a one-size-fits-all solution which unfairly targets ethical and effective professionals.

Our submission made the following key points:

• Psychologists are highly regulated, ethical providers who carry a low integrity risk. Psychologists are regulated by AHPRA and the Psychology Board of Australia, bound by a strict Code of Conduct, professional practice guidelines, and a robust complaints and disciplinary system as part of being an established profession. As such, psychologists are a high-integrity profession with multiple safeguards against practices which are harmful to clients and participants.
  
  The APS has no evidence that psychologists as a group are a significant source of fraud or non‑compliance. Based on our analyses, the Government’s own Fraud Fusion Taskforce has not identified a single non‑compliant psychologist since it began its work in 2022.
   
• Current compliance measures are too blunt. APS members report a growing tide of audits, paperwork and inappropriately-framed compliance requests that treat regulated health professionals the same as high‑risk, unregistered providers. This unnecessary burden diverts time from client care, makes NDIS work financially unsustainable for some members, and risks worsening the already limited supply of psychology services for NDIS participants.
   
• A risk‑based, proportionate approach is essential. The APS urges the Committee to recommend that NDIS integrity initiatives be targeted to where the real risk lies rather than spreading effort evenly across all provider types. This would protect participants more effectively while preserving the capacity of our members to deliver high‑quality services.
   
• Data sharing and co‑design with professional bodies. The APS calls for the NDIA and the NDIS Quality and Safeguards Commission to provide disaggregated data on non‑compliance by provider type and registration status. Transparent data will enable evidence‑based policy and allow professional bodies like the APS to develop targeted education, preventive tools and communication strategies in partnership with the NDIA and regulators.
   
• Pricing matters for integrity. Inadequate NDIS pricing for psychology services creates pressure to cut corners, drives skilled psychologists out of the market and opens the door for lower‑quality, less‑regulated providers. The APS recommends that pricing be reviewed to reflect the true cost of safe, ethical, and sustainable psychology supports.

View submission