Tiered Pricing in the NDIS: Haven’t We Been Here Before?

Written by Kate Hoad

There is growing discussion again about introducing tiered pricing within the NDIS — this time linked to participant complexity and registered versus unregistered providers. For many of us who have worked in the scheme since its early years, this feels uncomfortably familiar.

Because we have been here before.

A brief reminder of the history

It’s important to be factually accurate about what has actually occurred before. Allow me to provide a loose timeline:

• 2017–2018: The NDIS operated under a standardised price guide, with some variations based on support type and location. McKinsey & Company were tendered to complete an Independent Pricing Review (IPR). They delivered their Final Report to the NDIA on 14 February, 2018.

• Late 2018: It was published that within the IPR they had recommended a two-tiered pricing structure for therapy services. This proposal raised immediate concern across the sector, both from participants and their representatives but also providers.

• December 2018: The NDIA announced a three-tiered pricing system — but this applied only to Core Supports (assistance with self-care, social and recreational activities), not Capacity Building (e.g. allied health). The rationale related to differing skill levels of support workers and participant needs.

• Early 2019: In response to sector feedback, the NDIA did not proceed with tiered pricing for therapy services. Instead, it committed to a broader review of therapy pricing, including factors such as geography, initial vs ongoing sessions, therapy assistants, and potential deregulation.

• March 2019: A draft therapy price list was anticipated following that review.

  
  

Since then, as we all know - Therapy Prices have not increased. Crucially however, the specific proposal for tiered therapy pricing based on complexity was abandoned. That decision was not accidental — it was informed by widespread concern about equity, integrity, and unintended consequences.

Why the talk again then, of tiered pricing?

The re-emergence of tiered pricing has come about due to some ahem interesting questions asked in the Current 2025-26 Annual Pricing Review Consultation - Currently Open (until 8th February) - See: https://engage.ndis.gov.au/projects/annual-pricing-review-consultations

These include:

• If registered providers could charge more than unregistered providers, how would this affect your choice?

• If registered providers charged more than unregistered providers, would you be likely to switch to unregistered providers to get more hours or support in your plan, even if quality and safeguarding was lower? (highlighting my own - Absolutely leading statement/question here - who is to say any quality and/or safeguarding is lower!?!?!?!)

• If a provider with stronger quality systems charged more, would you still choose them?

• If [Therapy Support] providers who meet higher quality standards could charge more, what would you need to make a good choice? (again - talking about regiistered supports = quality and safe(r) supports>>>???)

• What would concern you most about providers charging different prices based on quality or complexity of support?

• If the NDIA introduced different prices for Social, Community and Civic Participation support how would this affect your choice of provider? For example, if registered providers could charge more than unregistered providers.

• Since the change to travel claiming was introduced on 1 July 2025, has it been hard to find a therapist who will travel to you?

  Follow Up Question: If you had your choice, what would you prefer? (options for this included - continue 50% rate, Travel to my Therapist, Increase rate to 100%, Cap on travel time/charges) Follow Up Question: Why do your therapists travel to you?
  

  Of particular concern here are the leading nature of many questions and answers, and also the questions when framed around “complexity” of the participant/needs, or provider registration status — they raise the same fundamental concerns that led many of us to oppose it years ago.

Why tiered pricing remains deeply problematic

1. Complexity is not a price category — it is a responsibility

Participant complexity is not a discretionary add-on. It is inherent to disability. Charging more because someone is “more complex” risks reframing disability itself as a cost burden rather than a core responsibility of the scheme.

Without strict, enforceable, and objective definitions, “complexity” becomes subjective — and subjectivity creates space for inconsistent practice and, in the worst cases, exploitation. Remember, providers were just as against this as participants/disability representative organisations back in 2018. Nothing has changed here.

2. Tiered pricing invites inequity

Differentiated pricing risks creating a two-tier system:

• those who can afford higher prices (or who have stronger advocacy) access better services

• those who cannot are left with fewer options or lower-quality supports

This runs directly counter to the NDIS principles of equity, choice, and participant protection.

3. It incentivises the wrong behaviours

When higher prices are attached to perceived complexity or provider status, the system begins to reward labelling rather than outcomes. Providers may feel pressure — consciously or unconsciously — to frame participants as more complex to justify pricing, or to avoid participants whose needs are not financially “viable”.

That is not a theoretical risk. It is a well-documented outcome in tiered funding systems internationally.

4. Registration status should not be a proxy for quality

Linking pricing to whether a provider is registered versus unregistered is also hugely concerning. Registration speaks to compliance with certain safeguards or ticking boxes on a form — it does not automatically equate to better therapeutic outcomes, nor does it reflect the diversity of ethical, skilled practitioners operating outside registration frameworks.

All providers should be operating with compliance systems in place, regardless of registration status. In fact - unregistered providers are increasingly being held to the exact same standard as Registered Providers. Essentially - if you're being paid by the NDIS dollar, you follow their rules.

Using registration as a pricing lever risks oversimplifying quality and narrowing participant choice.

We opposed this then — and the reasons haven’t changed - We must oppose it now!

Many providers stood firmly against tiered pricing in 2018–2019 not because we resisted accountability or sustainability, but because we understood the risks it posed to participants.

Those risks have not disappeared.

If anything, participants today are navigating a more constrained, more complex system with fewer buffers. Introducing tiered pricing now — without extraordinary clarity, safeguards, and oversight — risks compounding harm rather than improving sustainability.

Some better questions for the government to ask...

Instead of revisiting tiered pricing, they should be asking:

• Are current prices sufficient to deliver ethical, evidence-based supports?

  Emphatically - the answer is no, there hasn't even been CPI increase in 6 years - they already know this.

  
  

• How do we fund complexity without penalising or labelling participants?

  Let's see, a start would be continuing to appropriately fund participants to then allow providers to recoup ALL costs involved in seeing more complex clients (extra preparation, extra multidisciplinary stakeholder meetings, TRAVEL at the appropriate full hourly rate)

  
  

• How do we strengthen quality without reducing choice?

  See prior answer - Particularly in light of the number of practices that we have seen close or significantly restrict services in light of the 25/26 price guide changes).

  
  

• How do we protect the integrity of the scheme while supporting a sustainable workforce?

  
  

We already learned something important from the last time this was proposed.

The question is whether we are willing to remember it.