PWDA Response to the NDIS Quality and Safeguards Commission Consultation Paper on Mandatory Registration for Platform Providers
7 March 2025
Following the government's decision to make registration of Platform Providers, PWDA welcomes the commitment from the NDIS Quality and Safeguards Commission ('NDIS Commission') to consult with the community.
PWDA reviewed past investigations and conducted a survey of members and the disability community.
PWDA recognises that Platform Providers offer significant advantages for NDIS participants and play a key role in ensuring individuals have choice and control over their supports. The platforms eliminate the administrative burden of participants directly employing workers, which can be a complex and time-consuming process.
Additionally, platforms can provide options that allow participants to choose providers who align with their values, needs, or cultural backgrounds, in a way that is more difficult when engaging with traditional large providers, who allocate the workers.
PWDA recognises that there are gaps in the current system and generally supports the proposal to introduce mandatory registration for platforms for the purpose of protecting NDIS participants and making sure they receive quality support.
If done correctly, PWDA thinks that registering Platform Providers will make service relationships clearer, enhance safety and quality for participants, and create needed accountability for both platforms and workers.
PWDA emphasises that for the reform to work well, it must involve people with disability at every step of creating and putting it into action.
PWDA remains committed to working alongside the NDIS Commission, Platform Providers, and people with disability to ensure that any regulatory changes uphold the principles of choice and control, maintain access to essential services, and reflect the lived experience and expertise of people with disability.
Recommendations
Recommendation 1: Amend the definition of Platform Providers to:
- explicitly state that Platform Providers function as online intermediaries, rather than being directly employed by the platform.
- explicitly state that Platform Providers function as online intermediaries, connecting participants with workers rather than directly delivering services.
Recommendation 2: Require Platform Providers to clearly define service relationships as part of the registration process, ensuring participants and workers understand their legal rights and responsibilities.
Recommendation 3: Require Platform Providers to ensure all workers meet NDIS worker screening requirements before offering services. Additionally, platforms should ensure workers have training that reflects the type of support they are providing.
Recommendation 4: Require Platform Providers implement clearer cancellation policies to minimise last-minute disruptions for participants.
Recommendation 5: Encourage incentives such as bonuses or free certified training for platforms and workers that provide higher intensity supports, as well as supports in under serviced markets and rural, regional, and remote areas.
Recommendation 6: Require Platform Providers to establish clear, accessible, and consistently applied complaints mechanisms for both participants and workers and inform people of these processes when they sign up to the platform.
Recommendation 7: Mandate consistent data collection and reporting for Platform Providers, including information on the types of supports provided, complaints, incidents of misconduct, participant demographics, service cancellations and availability of services, including in rural, regional and remote areas and in off-peak times.
Recommendation 8: Ensure that Platform Providers collect and store all information and data in accordance with all national privacy laws, including the Privacy Act 1988.
Recommendation 9: Collect and store all information and data in accordance with all national privacy laws, including the Privacy Act 1988.
Recommendation 10: The NDIS Commission should ensure that registration requirements are simple and proportionate to the size of providers and the type of supports they provide.
Recommendation 11: Include provisions to screen workers. However, individual workers listing their services on digital platforms should not be required to register separately. This will prevent duplicate obligations and avoid reducing workforce availability.
Recommendation 12: To avoid making it harder for people to work in communities with existing shortages, such as First Nations and rural, regional, and remote areas. Collaborate with communities through consultation and genuine co-design to develop suitable guidelines.
Recommendation 13: Require Platform Providers should be required to implement accessible systems with filters to help participants find workers who have specific skills, speak specific languages or come from specific cultural or social backgrounds.
Recommendation 14: Implement measures such as regulating platform fees, setting price caps, and ensuring compliance costs are not duplicated in platform fees. Additionally, avoid duplicating registration requirements across both Platform Providers and individual workers who list their services on the platforms.
Recommendation 15: Provide clear, accessible information in multiple formats, including plain language guides, videos, infographics, and translated materials, co-designed with people with disability. Direct updates should be provided to participants and providers through multiple channels and co-design with people with disability should be embedded in the transition process.
Recommendation 16: Implement a phased transition approach with time allowed for Platform Providers to register, without participants losing their supports in the interim. Additionally, there should be clear contingency plans for participants whose regular providers face delays in registration. Through the transition period, the NDIS Commission should maintain communication with Platform Providers and disability representative organisations to monitor and address emerging issues.
Recommendation 17: The NDIS Commission must ensure that the implementation of mandatory registration processes for Platform Providers aligns with existing and emerging NDIS frameworks, particularly those relating to self-directed supports and self-management, to avoid conflicting requirements.
Recommendation 18: Ensure mandatory registration for Platform Providers aligns with broader NDIS provider registration reforms. While Platform Providers should be held to equivalent standards as traditional providers, the registration framework must account for the unique nature of platform-based service delivery to avoid unnecessary administrative burdens and maintain participant choice and flexibility.
Recommendation 19: Must engage in genuine co-design with people with disability and representative organisations at every stage of the policy design and implementation process. This should include prioritising input from multiply marginalised communities to ensure that registration requirements enhance safety and quality without restricting choice, autonomy, or access to supports.
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