The issue of registered and unregistered providers has been one of the most contentious areas of the NDIS Review. The NDIS Provider and Worker Registration Taskforce (the Taskforce) was established to provide advice on the design and implementation of the new graduated risk-proportionate regulatory model proposed in the Review. Following a strong community response, the Taskforce has now published its final advice in a comprehensive 117-page report. A summary of advice can be found here.

Key Findings

• The current registration system is not fit for purpose.
• Greater visibility is needed on who is providing NDIS supports, achievable through a registration and payment system.
• Choice and control are crucial for people with disability.
• Providers need to be viable to provide high-quality services and require support to innovate.
• Registration and auditing should be based on the supports a provider delivers.
• Other registration systems, such as those for allied health professionals (usually registered with AHPRA), should be recognised.

Departure from NDIS Review Recommendations

In a significant departure from NDIS Review recommendations, the Taskforce has suggested that not all providers should be registered to protect choice and control for participants. While further consultation with the disability community and sector is required, the Taskforce recommends that:

• Unregistered providers supporting self-directed participants may be exempt from compulsory registration.
• Self-directed supports could fall under a new registration category, subject to review and audit to ensure safety and quality.
• Goods purchased off the shelf from mainstream providers may also be exempt.

Proposed Registration Categories

 The Taskforce recommends four types of registration:

Advanced Registration: For providers offering high-risk supports and services in high-risk settings, including daily living supports in closed settings like group homes.

 General Registration: For providers offering medium-risk supports such as:

• High-intensity daily personal activities
• Supports requiring extra skills and training (e.g., complex bowel care or injections)
• Supports involving significant one-on-one contact with people with disability.

Self-Directed Support Registration: For participants, their guardian, or legal representative who contract all their supports directly, including through direct employment, Services for One, and independent contractors.

Basic Registration: For providers offering lower risk supports, such as sole traders or supports where social and community participation involves limited one-on-one contact with people with disability.

Audit Process Recommendations

 The Taskforce recommends that all Advanced and General Registered providers be subject to audits, with a redesigned audit process. Key suggestions for the redesign include:

• A co-design format involving people with disabilities, their families, and the sector.
• Risk-proportionate auditing responding to service type and size.
• Recognition of providers’ past performance, leading to ‘earned autonomy’.
• In-depth observational audits for Advanced Registration category providers.
• Graduated and proportionate audits for General Registration category providers.
• Face-to-face elements in verification audits, moving beyond desktop reviews.
• A core team of NDIS Commission auditors for highest-risk supports.
• Specific training and professional development for approved quality auditors.
• Cost-effective processes, potentially proportionate to organisation income or registration category.
• Subsidised travel costs for auditors in rural and remote areas.
• Auditor appointment by the NDIS Commission, not provider selection.

Additional Considerations

• The importance of co-design in developing the new registration system and practice standards for psychosocial supports.
• The need for a transition period and support for providers, especially smaller organisations, to adapt to the new system.
• Consideration of the impact on rural and remote service provision, particularly for First Nations providers.
• The need to align the new registration system with other NDIS reforms and the broader mental health support ecosystem.
• The importance of addressing workforce shortages while implementing new registration requirements.
• Ensuring that the registration process supports, rather than hinders, innovation in service delivery.
• The need for clear guidance to help participants understand the benefits of specialised psychosocial supports compared to general NDIS supports.

Impact on Community Mental Health and Wellbeing Providers

 While most Community Mental Health and Wellbeing providers are expected to fall under the General Registration category, the final advice report does not provide specific details on how the proposed model will impact psychosocial support providers. The report acknowledges that further consultation with the disability community and sector is required.

The Taskforce’s recommendations regarding self-directed supports may impact recommendation 7.4 of the NDIS Review, which stated that providers delivering psychosocial supports should be registered and comply with a new support-specific Practice Standard. However, the final advice does not provide clarity on this potential impact.

In its submission, QAMH raised several concerns including the need for clarity on new Practice Standards, potential administrative burden, recognition of existing qualifications, barriers for peer workers, funding for new requirements, maintaining diverse support options, and transition support. Upon review, many of these concerns have not been fully addressed or clarified in the final report, suggesting that further consultation and consideration of the community mental health sector’s specific needs will be crucial as the new registration model is developed and implemented.

For more information, a provider fact sheet is available here.