Butler's reform isn't the concern.

The reform pattern is the problem

Part one of a seven-part series on the 22 April NDIS reform announcement and what it is asking of providers.

On 22 April 2026, Minister Butler used his National Press Club address to set out a substantial reform agenda for the NDIS.

Broadly, he presented twelve propositions which would result in $15 billion in projected annual savings by 2030. They were:

• functional capacity assessments
• the reassessment of all current participants
• a "repositioning" of around 160,000 to other support schemes (though I believe this number is an understatement)
• foundational supports for those outside the scheme
• a 5% growth rate cap
• expanded mandatory provider registration
• a new digital payment system
• a 30% cut to intermediary spending
• a quality provider shortlist
• an expanded fraud response
• an aged care interface fix
• legislation in the next parliamentary sitting

Some have called it the biggest reset of the scheme to date.

It was a lot to take in, and for many participants and providers, it provoked a familiar fear about what comes next.

Public commentary since 22 April has been dominated by the delivery frame, focused on whether the reforms will ship, on what timeline, and with what compliance burden.

But before we begin to panic, it is worth reading the speech alongside one given three years earlier and considering the broader reform patterns.

> Ridding the scheme "of the criminals and rorters and the slum landlords using housing and living supports to take advantage of people with disability."

> "The good old days of under-servicing and overcharging will come to an end."

Sound familiar?

These lines weren't Minister Butler last week. It was Minister Shorten in December 2023, announcing the release of the NDIS Review. It's the same vocabulary, the same framing, and the same political function.

Different minister, three years apart.

And it is not just a Labor pattern. From 2018 to 2022, Prime Minister Morrison spoke of independent assessments as a necessary mechanism "to keep the NDIS sustainable and affordable." Minister Reynolds echoed the sentiment at Senate Estimates that costs were rising "far more significantly, year on year, than was ever expected."

Slightly different vocabulary across nearly a decade and three governments, but all stating the same thing. This isn't a political problem about who is in power. It's a problem about how the NDIS itself is structured to operate.

Each successive cycle tightens the controls on what the system already does, but none address the underlying root cause that the scheme is delivering exactly what it was designed to produce.

Put more simply, we have likely spent over a billion dollars diagnosing bullet wounds and prescribing Band-Aids.

Time to get real

The starting point in a systems view is that every system is perfectly designed to produce the outcomes it produces. When a system, or a scheme like the NDIS, has been delivering the same pattern of outcomes across a decade, with multiple governments and leaders, those outcomes are not a failure of delivery. They are a signal that there is a functional problem with what the system rewards.

So the test for any reform announcement is not whether it sounds significant, or whether it will be delivered. It is whether the reform, delivered exactly as announced, would change the structure producing the failure.

What we have seen over the short life of the NDIS to date are simply activity adjustments. Mechanisms that tighten or enforce the things the system already does. They are improvements to the administrative layer. They increase the compliance effort required of providers and the oversight effort required of regulators, but do not change what the scheme is structurally designed to produce.

We need to be altering the conditions generating the outputs. The list of where to start is broad:

• A redesign of the pricing model to pay for outcomes rather than activity
• A proactive monitoring framework that replaces complaints-dependent safeguarding
• Defining reasonable and necessary in operational practice
• Assigning responsibility for housing supply

Some may argue that expanding provider registration is structural too. But if it only adds data without changing what the Commission does with it, then it's another activity adjustment. However, if paired with a proactive monitoring framework that changes the regulatory model, that is what will drive real change.

Foundational supports are another area where the approach will determine if change is actually likely. It's an activity adjustment if we are simply creating a new and limited function to serve as a landing pad for participants moved off the scheme. It would mean more expense (albeit under a different budget line) and more administration. However, it has the potential to be structural if we design supports to meet the actual needs of people with disability without significant daily impairment.

Design intent, not the reform label, will determine whether we are still having this exact conversation in 10 more years.

The next test of the reform: the price guide

The pricing model is arguably the most structural lever in the scheme. It determines what gets paid for, which determines what gets delivered, which determines what participants experience.

The agency is expected to release a new price guide following the budget and legislation.

We don't yet know the rates that the guide will carry, or if there will be any reductions. But the question everyone in the sector needs to ask is whether the new guide has been built on a structural review of the pricing model, or whether it is just adjusting rates inside a model whose structure has not been examined.

The reason that question matters now is that the structural review already exists.

The Independent Health and Aged Care Pricing Authority (IHACPA) is a statutory body not much older than the NDIA. It has unified hospital funding across every state and territory through a single national pricing methodology, essentially solving the same federal-state coordination problem faced by the NDIS and broader disability support funding. It is also the same statutory body that took aged care pricing out of departmental calculation and gave it a published methodology, a public consultation process, and an obligation to show its working. That move changed who sets the price, what evidence the price is grounded in, and who can challenge the methodology. It is structural because it replaced the pricing mechanism, not because it produced a better number from the same mechanism.

The same body was funded to undertake equivalent pricing work for the NDIS. Its final report, "A Fresh Approach to NDIS Pricing," was completed.

On 26 August 2025, the Senate ordered the production of that report. The government claimed public interest immunity and did not table it. As far as I have been able to research, the Senate order remains outstanding.

The instrument for structural pricing reform exists. The work has been done. The evidence base is sitting in a report being withheld from the Parliament that ordered it.

What that means for the next price guide is precise. If a guide arrives before the IHACPA report is tabled, the rates in it have been set inside the existing pricing model rather than emerging from a published methodology. Cuts in such a guide would be activity adjustments to a structurally unchanged pricing model, not the structural pricing reform the IHACPA work was funded to deliver.

This is not an argument against making pricing decisions or even reducing prices. It is an observation that pricing decisions made without the tabled structural review are reform of a particular kind. Participants, their loved ones, and providers are entitled to be precise about which kind.

The pattern, not the moment

The IHACPA story is one instance of a much larger pattern.

Between 2016 and 2025, the Australian Government commissioned over 40 reviews, audits, inquiries, and Royal Commissions touching the NDIS. The minimum documented cost to the taxpayer is $680 million.

Supporting Potential has mapped the 528 formal recommendations from that body of work. When those recommendations are consolidated to root cause rather than treated as a sequence of individual reports and recommendations, our findings indicate they reduce to only five design failures that have persisted across the entire decade-plus of the scheme's operation.

All five trace back to a single feature. No universally accepted statement of what a successful NDIS actually looks like has ever been established:

• The Productivity Commission in 2011 defined what was broken. It did not define what success would be in measurable terms.
• The NDIS Act sets out purposes, not success criteria.
• The Outcomes Framework exists, but it is self-reported, has no targets, and no causal link to scheme decisions.

A scheme whose success has never been operationally defined cannot be reformed against a target it does not have. So the easy option is to initiate reforms that optimise what is measurable:

• Cost
• Misconduct
• Activity

The things that are not measurable, outcomes, thriving development, and increased participation, are left to provider goodwill and an overarching sentiment of hope.

But we also need to take reform announcements with a grain of salt. The base rate of recommendation implementation across the 528 recommendations is 2.5%.

For recommendations that directly address one of the five root cause design failures, the rate is under 1%.

What can we expect next?

Only one of the twelve propositions in Butler's 22 April agenda directly addresses a root cause. Foundational supports have genuine structural potential, conditional on state governments funding the receiving tier and commissioning architecture designed to serve the specific needs of the "repositioned" cohort rather than replicating the existing defaults.

Those conditions are significant and not currently met.

The other eleven, in their current presentation, only adjust activity inside an unchanged structure. The next blog will go into this in more detail.

What this asks of providers now

The instinct, after a decade of this pattern, is to disengage. Reform fatigue is real and rational. But the right response to ineffective structural change is not to withdraw from the reform process entirely. The right response to big problems is to use big tools. Providers can get ahead of "formidable regulation" by engaging with their own ways of operating, at the structural level.

We can assume that the reforms that can be delivered by the Commonwealth alone will become real. This means we can expect:

• Mandatory registration expansion from 1 July 2026
• The digital payment system
• Reassessment administration
• Legislative change

Pricing decisions will arrive too.

The organisations that prepare now will absorb them with less strain than the ones waiting for clarity that will not come in time.

Equally, organisations should resist the urge to change their operating models based on assumptions of proposed structural change. For example, there is currently no evidence to suggest that the intermediary cuts will be delivered with a Navigator redesign, or that lower-support-needs participants will be efficiently transitioned to a fully operational foundational support program. Structural improvements, if they come, need to be viewed as a bonus rather than a dependency.

So the question for every provider CEO this week is not how to absorb another round of compliance change. The sharper questions are about what is actually inside your control.

How do you KNOW that what you say you are delivering is being delivered, consistently, by every team, on every shift?

How do you KNOW that risk is being actively managed, not just documented annually?

How do you KNOW that the support being delivered is improving participant outcomes, and that those outcomes are shaping and evidencing service delivery, not just capturing presence?

Because doing more of the same will be catastrophic. The Commission's enforcement footprint is expanding, the Integrity Act's enforcement powers apply retrospectively, and the reforms that ship will tighten the controls on what providers do without changing what the system is designed to produce. A provider whose evidence base is process-only, whose risk register is theatre, and whose participant outcomes are anecdotal will have nowhere to stand when the controls land.

Individually, I urge sector leaders to consider what contribution they can make to shift the sector conversation from delivery framing to structural framing. We only have a short window in which the accountability instruments are still live.

The sector has taken the delivery framing as far as it can go. The structural framing is the conversation that has not yet been had at scale. Providers who enter that conversation now are not just preparing for what is coming. They are participating in whether what is coming will eventually change anything.

Remember, announcement is the cheapest part of reform. Delivery is the next cheapest (when planned well). Robust planning and changing the structure producing the failure is the work that has been consistently deferred across a decade, across multiple governments, across a $680 million review investment.

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Next instalment: Running Butler's twelve propositions through the structural test and what providers should be doing to prepare.

Supporting Potential works with NDIS providers to build systems that deliver quality at scale. Our submission to the JCPAA Inquiry into the Administration of the NDIS consolidates 528 prior recommendations into five structural root causes and maps 42 of the other public submissions to the inquiry against them.