The NDIS Annual Pricing Review (APR) continues confuses professional equivalence with service equivalence. While Allied Health Professionals may work across Medicare, private practice, the NDIS and other schemes, the services delivered under the NDIS are fundamentally different in complexity, governance, documentation, travel, risk management and participant goals and outcomes. Benchmarking disability therapy against mainstream health consultation fees ignores these differences and risks undermining the very workforce the NDIA acknowledges is already in critical shortage. An evidence-based pricing review should begin with the efficient cost of delivering specialised disability services—not the reimbursement rates of unrelated funding schemes for unrelated services.
It is evident that the NDIA has once again failed to undertake a robust economic assessment of the efficient cost of delivering specialised disability services. Instead, the Annual Pricing Review relies predominantly on benchmarking against unrelated funding systems rather than analysing the actual cost drivers unique to NDIS allied health services. Consequently, the recommendations do not provide a sound evidentiary basis for achieving the stated objectives of supporting participant outcomes, workforce investment, quality supports and access to services.
The deficiencies identified throughout this submission raise serious questions about the effectiveness of the governance arrangements surrounding the Annual Pricing Review. The NDIA has a statutory responsibility to act as steward of the disability market. Government, in turn, has a responsibility to ensure that the Agency’s advice is founded on robust evidence and sound economic analysis. Where pricing recommendations are accepted despite failing to assess the efficient cost of delivering specialised disability services, both the Agency and those responsible for overseeing its performance have failed to provide the level of scrutiny that decisions of this magnitude demand.
The evidence for this conclusion
1. The benchmarking is against the wrong market
The report states that therapy prices should be benchmarked primarily against Medicare Benefits Schedule (MBS) and Private Health Insurance (PHI) rates because allied health professionals operate in the same labour markets. That assumption ignores the fact that the service is different, not just the profession.
An Occupational Therapist completing a complex home modification assessment, Functional Capacity Assessment or Assistive Technology prescription under the NDIS is not delivering the equivalent of a 20–60 minute outpatient consultation under Medicare.
Likewise:
- NDIS Psychology involves complex disability, behavioural support interfaces, trauma, autism and intellectual disability.
- NDIS Physiotherapy often involves lifelong neurological disability rather than musculoskeletal treatment.
- NDIS Exercise Physiology addresses complex disability participation and functional outcomes, not short-term rehabilitation.
- Allied Health Assistants work under delegated clinical governance requiring supervision, competency assessment and documentation.
The report compares services delivered by the same basic Allied Health qualification, but fails to compare the actual services and recognising the unique specialisations of professionals in a qualified field.
2. Medicare is not a cost benchmark
The APR repeatedly references MBS and PHI as evidence of “market rates”. However, MBS fees are Government policy settings, not economic cost models.
Every allied health peak body has argued for years that Medicare rebates significantly underfund service delivery.
Using one arguably underfunded government schedule to justify reducing another government schedule is circular logic—not economic analysis.
3. NDIS providers carry substantially higher overheads
The report acknowledges that providers operate under registration, governance and quality obligations, yet completely ignores many of the costs unique to disability practice.
Examples include:
- Funding approval
- NDIS Practice Standards
- Quality audits
- Clinical governance
- Restrictive practice compliance
- Worker screening
- Incident management
- Complex documentation
- Participant safeguarding
- Travel across community settings
- Collaboration with multiple stakeholders
- Plan reviews
- Evidence gathering
- Functional reporting
These costs simply do not exist in a standard private clinic billing Medicare or Private Health Insurance.
4. Therapy is not just “face-to-face time”
The report proposes separating non-face-to-face activities into separate line items to provide more transparency to where costs are being incurred.
While transparency is reasonable, it fundamentally misunderstands disability therapy.
Clinical reasoning occurs:
- before the appointment
- during the appointment
- after the appointment
Preparation, risk assessment, equipment specification, liaison, documentation and outcome measurement are integral components of therapy—not administrative extras.
Separating these activities risks suggesting non-face-to-face activities may hold different value to face-to-face activities. The suggested separation of service activities also continues to fail to deliver on a key insight that should be clinical vs community based activities.
5. The report ignores workforce shortages while recommending price reductions
Elsewhere the report acknowledges that Occupational Therapists, Physiotherapists and Psychologists remain occupations in national shortage and that demand will continue growing strongly.
Yet despite recognising shortages, it recommends reducing prices for Exercise Physiology and Dietetics while effectively freezing or reducing the purchasing power of other therapy professions.
If supply is already constrained, reducing revenue is unlikely to improve participant access.
That is inconsistent economic reasoning.
6. Disability therapy is outcome-based, not throughput-based
Private health and Medicare generally fund episodes of care.
NDIS therapy delivers:
- functional independence
- home modifications
- assistive technology
- falls prevention
- behavioural stability
- carer training
- reduced hospital admissions
- reduced long-term support costs
These interventions frequently produce savings elsewhere in the health and disability systems, but require more intensive supports.
The APR infers that the services provided should be judged solely on the hourly based consultation, ignoring the downstream economic value created by the services.
7. The recommendations are inconsistent with the stated objective of market stewardship
The Executive Summary states that pricing should support:
- participant outcomes
- provider behaviour
- workforce investment
- quality supports
- access to services.
However, the methodology adopted for allied health therapy pricing fails to meaningfully evaluate whether the proposed prices are capable of achieving any of these objectives. Instead, the panel has relied predominantly on benchmarking against the Medicare Benefits Schedule (MBS) and Private Health Insurance (PHI) fee schedules, despite these funding systems being designed for fundamentally different service models. The report expressly identifies MBS and PHI benchmarking as the primary basis for determining therapy prices.
This is not an assessment of the efficient cost of delivering specialised disability services. It is a comparison against unrelated funding mechanisms that neither reflect the complexity of NDIS allied health services nor the operating environment in which they are delivered. There is no robust economic analysis of the actual costs associated with community-based service delivery, travel, reduced clinician utilisation, multidisciplinary coordination, clinical governance, regulatory compliance or the specialised assessment activities that distinguish NDIS allied health practice from mainstream healthcare.
In adopting this methodology, the panel has failed to discharge the fundamental purpose of the Annual Pricing Review. Rather than determining whether proposed prices will sustain workforce capability, participant access and quality supports, it has substituted proxy benchmarks for genuine economic analysis. This represents a significant failure of professional judgement and analytical rigour. The resulting recommendations cannot reasonably be relied upon as evidence-based advice capable of meeting the objectives that the NDIA expressly charged this review to address.
8. Community-based disability therapy cannot be benchmarked against clinic-based practice
The APR assumes that an hour of therapy is equivalent regardless of where it must be delivered. This is incorrect.
Many NDIS allied health services must occur in participants’ homes, schools, workplaces or community environments. Home modifications, assistive technology assessments, functional assessments, falls prevention, vehicle modifications and some therapy programs require clinicians to observe and assess participants in the environments in which they actually live and function.
Unlike clinic-based practice, these services inherently involve significant travel between appointments. Travel time is not discretionary; it is an essential component of delivering the support safely and appropriately.
By contrast, a private clinic operating under Medicare or Private Health Insurance can schedule consecutive appointments throughout the day with virtually no lost productive time. The clinician may bill six to eight consecutive hours of treatment. A community-based clinician may only deliver five hours of therapy within the same working day because hours are necessarily consumed travelling to provide services to participants.
The APR and NDIA pricing arrangements also fails to recognise the fundamentally different economics of community-based allied health services. Community Allied Health services are largely referral-driven, episodic and location-dependent. Providers cannot simply group participants by suburb to improve utilisation, as complex assessments such as home modifications, assistive technology and functional assessments occur on an ad hoc basis across broad geographic areas. As a result, clinicians experience unavoidable travel and reduced productive utilisation, effectively subsidising the delivery of essential community-based disability services. Benchmarking these community based services against predominantly clinic-based Medicare or private practice models therefore materially understates the true cost of delivering NDIS allied health supports in the community.
The proposed benchmarking completely ignores this structural productivity difference. The APR demonstrates a lack of understanding of the services it is providing expert review of.
9. The review ignores the cost of securing access to services
The APR assumes that the cost of delivering allied health services in the NDIS begins when a clinician commences an assessment or therapy session. In practice, specialised NDIS allied health services frequently incur significant administrative effort simply to enable the service to proceed.
Complex services such as Functional Capacity Assessments, Assistive Technology assessments and Complex Home Modifications often require substantially more funding than is available within a participant’s quarterly budget allocation. Providers are therefore routinely required to negotiate with participants, plan managers, support coordinators and the NDIA to secure funding before clinically necessary work can be completed.
Where additional funding cannot be obtained in a timely manner, providers are often faced with two unacceptable alternatives: deliver a reduced assessment that falls short of clinical best practice, or absorb the unrecoverable cost of providing the additional hours required to ensure the participant receives an appropriate outcome. Unfortunately my team are human beings and so burn themselves out taking the latter approach.
This approval and funding negotiation process is an inherent cost of delivering specialised NDIS allied health services. It has no equivalent in Medicare or private health practice and is entirely absent from the APR’s economic analysis. Any pricing methodology that ignores these unavoidable costs materially understates the true cost of delivering complex disability services and shifts the financial burden from the Scheme to providers, ultimately threatening the sustainability of participant access to specialised allied health care.
