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The Productivity Commission's Issues Paper: Fifty Shades of Grey

The Productivity Commission (PC) has released the Issues Paper for the Review of NDIS Costs. As Brent Woolgar explains, it’s thrown just about every contentious NDIS issue up in the air for consideration.

By Brent Woolgar

Updated 15 Apr 202427 Feb 2017

The Productivity Commission (PC) has released the Issues Paper for the Review of NDIS Costs. It’s thrown just about every contentious NDIS issue up in the air for consideration.

The PC review represents the biggest potential change to the NDIS we have seen so far. The PC designed the NDIS and the PC Review will be the political justification for governments to make changes to the NDIS.

To make sure the PC review improves the NDIS, all organisations should consider how they can best share what’s working well and what needs fixing in the NDIS.

While it has correctly identified many of the questions that most, if not all, persons currently operating within the NDIS environment want to know the answers to, it sadly falls short in some areas which could lead to the ongoing grey areas within the scheme if all questions are not identified and addresses by the review.

The Review is in two stages – an Issues Paper and then a Draft Report. The window for making a submission to the PC for the issues quite short – submissions close on Friday 24 March so if you are planning on making a submission you had better start now.

The positives of the Issues Paper are many. These should provide renewed hope for many providers, participants and persons entering the scheme. Areas such as Early Childhood Early Intervention (ECEI), Eligibility Criteria, Interfaces with Mainstream Services, Planning Processes and Plan Utilisation challenges to date are all addressed with relevant questions to focus the review.


Some of the encouraging questions listed so far include:

  • Is the ECEI approach an effective way to ensure that those children with thehighest need enter into the NDIS, while still providing appropriate information and referral services to families with children who have lesser needs?
  • Is the current split between the services agreed to be provided by the NDIS and those provided by mainstream services efficient and sufficiently clear? If not, how can arrangements be improved?
  • How will the full rollout of the NDIS affect how mental health services are provided, both for those who qualify for support under the scheme and those who do not?
  • Are the criteriaforparticipantsupportsclearandeffective? Is there sufficient guidance for assessors about how these criteria should be applied? Are there any improvements that can be made, including where modifications to plans are required?

On face value, if the questions that appear in the issues paper are all addressed, there should be more certainty on a lot of the current key issues as we move towards the scheme’s full rollout.

However, there remain many current issues that appear to not be addressed.

Missing in the PC’s Issues Paper is a proper discussion about housing. In fact, the word ‘housing’ appears only once in the PC’s 11,500 words on cost issues. It is critical that the government provides Specialist Disability Accommodation (SDA) payment certainty into the future and further explores the separation of supports and accommodation.

Other issues not getting much of a look in at this stage are the inherent and increasing potential for conflicts of interest that are being created via the ILC and LAC contracts. And similarly,  the role of Support Coordination and the costs and potential conflicts of interest, all appear to have been missed in the issues paper.

Hopefully many organisations and individuals will make a submission to raise these and the many other grey areas that exist and that are not yet identified by the review.


Brent Woolgar

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