The NDIS Review recommends big changes for unregistered NDIS providers. They’ll be required to register as early as 2026. So, would it be better to register your NDIS business early? Or wait? This post will help you think strategically — whether you’re looking to start out, want to grow your existing unregistered business, or have simply been putting off registering for a while.
If you want to know more about the proposed changes, see our post NDIS Review: What does it mean for you?
Here, we consider three things:
- The compliance requirements — current and proposed (for the supports you deliver).
- The advantages that early registration might bring.
- The strategic alternatives for different supports.
COMPLIANCE REQUIREMENTS — CURRENT AND PROPOSED
Organisations must currently be registered if they provide:
- Specialist Disability Accommodation (SDA), Behaviour Support, or Plan Management.
- Supports to agency-managed NDIS participants.
If you don’t provide those services or work with agency-managed NDIS participants, you’re not currently required to register as an NDIS provider.
This will change — all NDIS providers will be required to register. The NDIS Review proposes four risk-based levels of registration:
- Advanced Registration for high-risk supports — Audits against general (Core Module) and support-specific standards. (Most likely: SIL, Behaviour Support, large organisations, and complex supports)
- General Registration for medium-risk supports — Audits against general standards (Core Module), ‘graduated’ and ‘streamlined’ where appropriate to risk levels. (Possibly: High Intensity supports, and Core supports such as Daily Personal Activities and Community Access)
- Basic Registration for lower-risk supports — Audit replaced by self-assessment and declaration of compliance with the (simplified) NDIS Practice Standards. (Possibly: supports with limited one-to-one contact e.g. cleaning, transportation, mainstream services such as yoga, group activities)
- Enrolment for lowest-risk supports — No audits, but providers are subject to complaints processes. (Possibly: supports with minimal contact, e.g., Adaptive Equipment, Assistive Technology)
ADVANTAGES OF EARLY NDIS REGISTRATION.
1. Avoid the rush, avoid delays
There will definitely be delays. The NDIS Commission will use the provider registration process to weed out unsuitable applications in the higher registration levels. (Delays are less likely for the Enrolment level process).
The requirements will be rolled out in stages, so that the NDIS Commission can ensure continuity of service delivery. Supported Independent Living (SIL) and Early Childhood providers have been identified for priority registration in the rollout.
Registered providers should manage the transition more easily. They’ll entirely avoid the sudden rush to register. And they can smooth the path by drawing on their experience within scheme, previous audits, knowledge of their Quality and compliance systems, and established relationships with relevant business supports.
The NDIS Review Report suggests that audits could be graduated and streamlined, that there should be incentives for well-managed Quality. The sooner providers enter the audit cycle, and demonstrate their commitment to Quality, the sooner those incentives can apply.
2. Opportunities for growth — Supports
For many providers, if not most, growth inevitably means working with a wider range of potential clients in their area of operations.
Registered NDIS providers can provide any support for which they are registered. This opens the door to additional opportunities for growth and expansion. They’ll take that accredited experience into the next phase of the NDIS.
Unregistered NDIS providers can’t work with all NDIS participants and can’t access a large part of the market. Around 60% of the current NDIS funding goes to supporting NDIS participants who need help managing their plans, finding specialist accommodation, have behavioural issues, or who choose to have their account managed by the NDIA. These supports can only be delivered the estimated 10% of providers who are currently registered. (see NDIS Quarterly Report Q4 2023)
Would registering early allow your organisation to expand its client base into the agency-managed market? If so, this is a one-time opportunity — and at minimal cost! Early-bird registrations will only undergo one audit prior to 2026, while securing their position in that extended market!
3. Opportunities for growth — Market position.
Many providers haven’t registered because of the compliance burden. We expect many of them will exit the scheme in 2026. That means greater demand for services and/or established businesses coming onto the market. Registered providers that remain, especially those interested in growing their NDIS business, will be better placed to seize this once-in-a-lifetime opportunity.
The proposed changes will put greater emphasis on compliance and Quality, with more-focused standards, at the higher risk levels. Providers will need to understand and integrate Quality into practice more seamlessly. As Tracey Mackay, the NDIS Commissioner, said about the new landscape:
“If you’re intending to be a stayer in the sector, then actually getting your head around what it means to be registered will be a really helpful thing.”
(DSC: NDIS update webinar, 14/12/2023)
Again, registered NDIS providers are better placed to get that understanding and to establish appropriate business support.
4. Credibility, Trust, Respect and Prestige
Perceptions are important — especially as the marketplace unifies! The proposed changes should give NDIS participants even more choice and control. So, providers need to think about what sets their services apart.
Registration demonstrates a commitment to quality and compliance with NDIS standards, to the NDIS principles and to contributing data essential to the industry. That’s why only registered providers can display the I ♥ NDIS logo. Demonstrating commitment can instil trust and lead to long-term, productive relationships.
This is particularly true in thin markets, when providers take on NDIS registration to support a small number of clients. Thin markets aren’t limited to rural and remote areas. They might also include participants from First Nations communities and from CALD communities.
Would being registered-by-choice make your services more appealing? If yes, you don’t have long to secure that distinction.
5. Advice and support
Audits can help NDIS providers implement sound service-delivery and management practices. Many of the obligations — such as, insurance, information privacy, WHS, incident reporting obligations — apply to all businesses. In large part, the NDIS Practice Standards simply encourage respectful and professional services.
And they’re a way of coordinating service outcomes with the wider NDIS market. That means a lot less uncertainty and guesswork, compared with businesses in other markets. Yes, audits cost money — but, depending on how providers work with auditors, they can represent real value.
Business support services such as PQplus can also provide that value. We help providers understand the compliance requirements and implement effective Quality Management strategies. And we are better able to help providers who use our Quality Management Systems.
STRATEGIES FOR UNREGISTERED NDIS PROVIDERS
Which strategies are right for your organisation and management style? Whichever you choose — you can pick more than one! — some kindof preparation will be essential.
Register ASAP: Some unregistered providers have decided to act immediately. They may need to tweak their systems as the changes are published, but they won’t be starting from scratch. Change management will be easier because they understand the system and have already completed an audit. If their audit demonstrates an attention to Quality, they’ll be in line for proposed incentives and streamlining.
This strategy would best suit organisations delivering high- and medium-risk supports — particularly SIL, Early Childhood, large organisations, and complex support providers.
Take a middle path: Another strategy is to informally take on the requirements without the full commitment. Some NDIS providers have approached us to develop NDIS policies and procedures appropriate to their businesses. They aren’t registered with the NDIS Commission, and they aren’t audited. But they are ready to register at any time if their circumstances change. Until then, it helps them to manage Quality in their business, gives staff time to learn the ropes, and signals to participants that they are serious about providing good services.
Wait a little: Where it’s entirely unclear which registration level will apply to your supports — Therapeutic Supports is a good example — it might be best to hold off. Acting too soon risks moving up to a higher compliance level, only to move down again. But do stay in touch and be ready to act immediately once the information becomes available.
Wait for the mandate: Providers of low risk supports — especially those bound for Enrolment-level registration — will not benefit from registering early. At this stage, they should wait until everything is organised and all the information is available.
Close Shop: Unfortunately, some will drop out. If you’re considering leaving because of the Quality and compliance requirements, just remember that — if the recommendations are implemented — the lower-risk supports will have very few requirements. With the right support, it might be easier than you thought.
Combined Strategies: All these strategies require a greater understanding of the Quality requirements — “what it means to be registered.” So, keep an eye on things, get proper support, and learn all you can about the Quality and compliance requirements proposed for your supports.
We’ve always supported NDIS providers to understand Quality and developed tools that incorporate Quality into daily practice. Your best strategy might begin with a free 15min consultation — just get in touch!
