Policy analysis disclaimer: This article is an independent policy analysis intended for public interest and advocacy purposes. It does not constitute legal advice for NDIS participants, carers, or providers. Participants with queries about their individual plans or access decisions should contact the NDIA directly or seek support from a registered disability advocate. The Coalition for Better Health is an independent health policy advocacy organisation with no commercial interests in disability services markets.
Introduction: A Scheme at a Crossroads
The National Disability Insurance Scheme was one of the most ambitious social policy reforms in Australian history. Launched in 2013 and fully rolled out nationally by 2020, the NDIS was designed on a clear moral premise: that Australians with permanent and significant disability have a right to the individualised support they need to live ordinary lives. The shift from block-funded, institutionalised service delivery toward consumer-directed, portable funding represented a generational change in how Australia understood and delivered disability support.
By 2023, the NDIS was serving more than 600,000 participants and spending approximately $38 billion per year — with Treasury projections suggesting costs could reach $100 billion annually by 2030 if the scheme's trajectory remained unchanged. That fiscal trajectory, combined with growing evidence of market failures, planning inconsistencies, and uneven outcomes for participants, created the political conditions for the most significant review since the scheme's founding.
The 2023 NDIS Independent Review, led by Professor Bruce Bonyhady AM and Ms Lisa Paul AO PSM, produced a landmark report finding that the NDIS had "lost its way" — but also one with genuine achievements worth preserving. The review was not a demolition order. It was a blueprint for returning the scheme to its original purpose while placing it on a financially sustainable path.
Three years into that reform agenda, the picture is one of partial progress, contested implementation, and unresolved tensions that go to the heart of what the NDIS is supposed to be.
What the NDIS Was Designed to Do
The foundational architecture of the NDIS rested on several interlocking principles that distinguished it from every previous model of disability support in Australia.
Rights-based individualised funding meant that support was not a discretionary government benefit — it was a legal entitlement for eligible Australians. Participants received individual budgets they could direct toward supports that met their goals, rather than being assigned to block-funded services determined by provider capacity.
Separation of funding from provision was structurally significant. The NDIA funded support; it did not deliver it. This created a market of disability service providers competing for participant spending — a deliberate design choice intended to drive quality and responsiveness. The theory was that participant choice would discipline the market in ways that block contracts never could.
Long-term investment logic underpinned the scheme's economics. The architects, drawing on work by the Productivity Commission, argued that early intervention and sustained support would reduce lifetime costs by enabling people with disability to live independently, participate in employment, and reduce reliance on more intensive crisis supports over time. The scheme was intended to pay for itself in part through avoided costs in health, aged care, and welfare.
These were serious, defensible ideas. The 2023 review did not repudiate them. It concluded that the implementation had, in critical respects, failed to honour them.
The Financial Crisis and the Sustainability Trigger
NDIS costs grew at approximately 14 percent per year through the early 2020s — nearly double the 8 percent annual growth projected at scheme design. Per-participant costs had grown substantially from initial modelling. Participant numbers grew faster than anticipated, driven in part by the scheme's success in reaching previously underserved populations, and in part by access pathways that were broader than originally intended.
The Productivity Commission flagged sustainability concerns as early as 2017. By 2022, NDIS costs had become a significant line item in Commonwealth budget projections, and the political consensus that had protected the scheme from scrutiny began to fracture under fiscal pressure.
It was this fiscal reality — not merely quality or equity concerns — that generated the political will for significant reform. This matters for understanding the reform agenda: some of the most contested recommendations were directly responsive to cost pressures rather than participant outcomes. The reform process was never purely a technocratic exercise in scheme design. It was also, unavoidably, a budget exercise.
The 2023 Independent Review: Key Findings
The Bonyhady-Paul review consulted extensively — more than 10,000 submissions, engagement with participants, families, providers, researchers, and system administrators. Its findings were nuanced and, in places, genuinely critical of the scheme's direction.
The review found that the NDIS had produced genuine positive outcomes for many participants. Employment rates, community participation, and housing choices had improved for cohorts who had previously been locked out of mainstream life. These achievements were real and the review was clear that they must be preserved.
But it also found serious structural failures. Market failure was pervasive. The provider market was fragmented and unreliable, particularly outside metropolitan areas. Thin markets in regional and rural Australia meant that participants had nominal choice but no real options. "Plan inflation" — the practice of building in larger plans to manage uncertainty about what would actually be available — had become embedded in planning culture, distorting both individual plans and scheme-level costs.
The planning process was highly individualised but deeply inconsistent. Two participants with near-identical support needs and circumstances could receive substantially different funding through different planners, different NDIA offices, and different review pathways. The opacity of decision-making left many participants unable to understand, challenge, or plan around their funding.
Early intervention funding was not delivering the measurable long-term outcomes the scheme's economic model depended on. Children with developmental delay were entering the NDIS in large numbers, but the connection between early NDIS investment and reduced lifetime support costs was not being demonstrated in practice.
Information asymmetry between participants and planners disadvantaged those without advocates, family support, or the resources to navigate the system. The scheme's consumer-directed design assumed an informed, capable participant — a model that worked well for some and poorly for many others.
The review's 26 recommendations were organised across five reform themes: navigating the NDIS, planning and funding, NDIS markets, government roles and responsibilities, and implementation. The recommendations were intended as an integrated package, not a menu for selective adoption.
Key Recommendations and Their Implementation (2024–2026)
1. Foundational Supports
The single most structurally significant recommendation was the creation of a new Foundational Supports tier — a layer of disability support funded jointly by Commonwealth and state and territory governments, outside individual NDIS budgets, for Australians with disability who either do not meet NDIS eligibility criteria or whose support needs fall below the intensive threshold the NDIS was designed to address.
The logic was sound: the NDIS had become the only funded pathway for disability support in many communities, drawing in people whose needs could be better met through lower-intensity, more flexible, community-based supports. Foundational Supports were intended to restore a continuum of support that the pre-NDIS system, despite its many failures, had at least nominally provided.
Early 2026 rollout of Foundational Supports has begun in some jurisdictions, but implementation is uneven. Advocacy organisations and disability researchers have raised consistent concerns that Foundational Supports remain underfunded relative to the gap they are intended to fill. The risk of a two-tier outcome — intensive NDIS support for those who qualify, inadequate alternatives for those who do not — is real and has not been resolved by current funding commitments.
2. Planning Reforms and the Navigator Model
The review recommended moving away from the highly individualised, line-item plan model toward budget-based planning — broader funding envelopes within defined support categories, offering participants more flexibility while reducing the perverse incentives of plan-by-plan negotiation.
Accompanying this was the NDIS Navigator model — a new intermediary role to assist participants in understanding their options, connecting with supports, and making informed choices. The Navigator concept was intended to address the information asymmetry problem without simply building advocacy costs into every participant's plan.
The Navigator model has been piloting from 2025. Early feedback from the sector is mixed. Some participants and families report the Navigator function is genuinely useful; others report it adds a layer of process without resolving the underlying planning inconsistencies. The budget-based planning approach is still being refined through 2026.
3. Early Childhood Approach
The review recommended a significant reorientation of early childhood disability funding — away from diagnosis-based NDIS access for children with developmental delay, toward Foundational Supports and outcomes-based early intervention delivered through mainstream services.
This recommendation has generated the most intense controversy in the reform process. Families of autistic children, in particular, report that children who previously had NDIS access have lost it in the transition period, before Foundational Supports are adequately established. For many families, this has meant a direct loss of funded support without any alternative in place. The gap between the policy intent and the lived transition experience has been acute.
4. Provider Registration Reform
The review found that inconsistent provider registration requirements had created quality gaps and left the scheme vulnerable to fraud. The recommendation to strengthen registration requirements across all provider categories — not merely the high-risk categories previously subject to registration — has been progressed through legislation in 2024 and 2025.
Improved registration requirements aim to reduce fraudulent billing, improve quality oversight, and create a more credible provider market. Implementation is ongoing, and the compliance burden on small and medium providers — including the rural and regional providers who are often the only option in thin markets — remains a legitimate concern.
5. NDIA Culture and Internal Practice
Several recommendations addressed the NDIA itself: greater transparency in decision-making, more human judgment in planning processes, and reduced reliance on automated or algorithmic planning decisions that participants cannot meaningfully challenge. These are the least visible reforms, and the hardest to assess from outside the organisation. Implementation is described by government as ongoing. Participants and advocates report that improvements, where they exist, are incremental.
Contested Territories and Ongoing Tensions
Access Eligibility
Tighter eligibility criteria — particularly for psychosocial disability and developmental conditions — have resulted in some participants losing NDIS access or receiving substantially reduced plans. Disability advocacy organisations argue, with force, that these changes violate the scheme's rights-based framework and breach the expectations of participants who planned their lives around continued access. Government argues the changes are necessary for fiscal sustainability and that Foundational Supports will provide alternatives.
This is a genuine values conflict, not merely a technical disagreement. The scheme's original design was rights-based. The reform process has introduced sustainability considerations that, in some cases, override individual entitlements. How Australia resolves that tension will define the NDIS for the next decade.
Foundational Supports Adequacy
The history of disability services in Australia before the NDIS is, in large part, a history of chronic underinvestment at the state and territory level. States and territories must negotiate funding contributions to Foundational Supports — and there is no binding mechanism that ensures those contributions will be adequate or sustained. Whether Foundational Supports will genuinely replace NDIS access for people with mild-to-moderate disability needs remains, as of early 2026, an open and serious question.
Thin Market Failure in Rural and Remote Australia
Reform recommendations have not resolved market failure in thin regional markets. Transport, accommodation, workforce viability, and geographic barriers remain as acute as they were before the review. Rural and remote participants face structural disadvantages that market mechanisms alone — however well-designed — cannot address. This is not a failure of the review's analysis; it is a failure of implementation ambition.
The Autistic Community and ADHD
Autism and ADHD communities have been disproportionately affected by access reform. The review's push for Foundational Supports to address lower-support-need autism is contested by disability rights advocates who argue it removes legal entitlements that participants had previously relied on and built lives around. The speed of transition, and the inadequacy of alternatives during the transition period, have created real harm for real families. This deserves acknowledgement, not only as a policy failure but as a human one.
What Genuine Reform Must Include
Reform that is merely fiscal consolidation dressed in policy language will not repair the NDIS. Genuine reform requires commitment on several fronts that the current implementation has not yet fully delivered.
Foundational Supports must be adequately and bindingly funded. Discretionary state contributions that can be reduced in a budget crisis are not a substitute for individual entitlements. If the reform agenda is asking participants to accept reduced NDIS access in exchange for Foundational Supports, the adequacy and security of those supports must be guaranteed — not aspirational.
Independent advocacy bodies need genuine authority. Ombudsman-style complaints processes are insufficient when the power imbalance between participants and the NDIA is as significant as it is. Advocacy must be funded, independent, and empowered to achieve systemic outcomes, not merely process individual grievances.
Outcomes measurement must be integrated into planning. The scheme should pay for results, not just the provision of supports. This requires investment in measuring what the NDIS actually achieves for participants — employment, independence, community participation, wellbeing — and using those measurements to drive planning decisions.
Rural and remote market viability must be addressed separately. Market solutions work in markets. Thin regional markets are not markets in any meaningful sense. Targeted rural supplements, workforce incentives, and regionalised service design are necessary to ensure that the reform agenda does not systematically disadvantage participants in non-metropolitan Australia.
Rights and sustainability are not mutually exclusive. A well-funded, well-administered scheme that invests in early intervention, supports genuine community participation, and reduces crisis costs across health and aged care systems is, over time, more fiscally sustainable than a poorly administered scheme that warehouses people with disability in inadequate supports. The reform process must not allow short-term fiscal pressure to erode the rights-based framework that gives the NDIS its moral and legal legitimacy.
Conclusion
The 2023 Independent Review was a serious piece of policy work, produced under genuine time pressure and drawing on evidence that was, in many respects, already clear. The reform agenda it produced is a reasonable response to a scheme that had developed significant structural problems. The question is not whether reform was necessary — it was — but whether the reform being implemented honours the scheme's founding commitments while making it more sustainable and effective.
As of early 2026, that question is unresolved. There have been genuine advances: the Navigator model, provider registration reform, and the structural concept of Foundational Supports all represent meaningful progress. But the implementation gaps — particularly around Foundational Supports funding adequacy, early childhood transition, and access eligibility — represent real harm to real people who were relying on a scheme they had been told was a right, not a privilege.
Disability policy in Australia has a long history of promising more than it delivers. The NDIS was supposed to be different. The reform process will be judged not by the elegance of its recommendations, but by whether people with disability in Australia — including those in rural communities, those with psychosocial disability, and those whose children are autistic — have better lives because of it.
Related reading: Aged Care Reform in Australia | Rural and Remote Health Access | Telehealth Permanency