recognition that the current system contributes to high clinician burnout rates and needs to change;

hopes the new system will increase access for families to supports in natural environments, with less red tape;

observations that we’ve seen these kinds of models before; 

fears Thriving Kids will reduce our professional autonomy and flexibility of work; 

questions about potential ethical challenges some of us may face when seeking to deliver evidence-based care to kids within constrained systems and programs; 

acceptance we may need to make big changes to our business models - especially single-discipline clinic owners in metropolitan areas; and

concerns about workplace satisfaction and meaningful career paths, including access to adequate supervision, training, and professional growth opportunities - especially for early career SLPs.

It’s very likely that allied health NDIS providers will need to become registered providers. 

But it’s not yet clear:

There are a few practical things we can do now to prepare. But, many of us have other urgent business and compliance priorities right now, and we shouldn’t over-react to future registration requirements until we know more details.

Most small allied health providers are unregistered because of the expense, time-commitment, and red tape involved in becoming and staying registered, including the costs of audit or verification processes.

Large registered providers have long argued that this creates an uneven playing field, favouring unregistered providers.

Disability advocates and small allied health providers have counter-argued that, forcing small providers to register under current rules, would cause many providers to exit the sector, reducing participant choice and control (and competition for the big providers).

criticising the number of unregistered providers; 

suggesting, fairly openly, that unregistered providers are a bunch of unregulated cowboys in a sector riddled with fraud, waste and poor safety; and

not mentioning that many of the most egregious participant safety incidents to date, including participant deaths, and large fraud cases involve registered providers.

Unregistered ≠ unregulated: Allied health NDIS providers are bound by the NDIS Code of Conduct and health laws. 

SLPs in private practice are regulated as CPSPs and are subject to SPA’s professional standards, Code of Ethics and complaints processes. (These mirror AHPRA rules that regulate other allied health professionals, like occupational therapists, physiotherapists, and psychologists.)

What will mandatory registration involve? 

When will it be required?

What, if anything, should we be doing to prepare for it? 

AHPRA-registered allied health professionals have their existing registration recognised for NDIS registration purposes; and

“consideration be given” to the appropriateness of extending this recognition to SLPs and other allied health professions who are self-regulated by rules that mirror AHPRA’s requirements.

It’s likely that SLPs will eventually be granted access to the National Registration and Accreditation Scheme (NRAS) through a ‘light touch’ professions registration pathway, giving us a form of registration, with AHPRA oversight. This should bolster the argument that SLPs should be treated in the same way as AHPRA-regulated allied health professionals. 

The 2024 Scope of Practice Review report into the health workforce recommended that the regulatory model for professions operating outside of the NRAS (including for SLPs) be strengthened and standardised.

The Productivity Commission also wants greater regulatory alignment across the care sector.

mandatory registration of all providers (p 5), including allied health and therapeutic services, early childhood and early intervention services, health services, such as paediatric support and peer support programs and initiatives (p 8);

a risk-proportionate regulatory model (p 7) and a regulatory system that reflects the level of risk and complexity of services delivered (p 2);

a registration system “where providers of similar services are on a level playing field” (p 3); and

participants to have choice and control of accessing supports (p 4).

The Government knows that, if it gets it wrong, reforms could have unintended consequences, including disruptions to services and unnecessary red tape (p 4). 

Through its pricing controls, Thriving Kids, and its other reforms, governments are deliberately seeking to restructure the market for NDIS and other publicly funded supports, including allied health supports. 

Solo speechies in metropolitan areas and clinic owners who train and supervise SLPs are particularly vulnerable to further changes, like mandatory registration, that might increase their compliance costs and other overheads. 

Many SLPs are working hard to reduce their reliance on NDIS funding. 

It’s likely some SLPs will not want to register, requiring them to cease providing NDIS supports altogether, reducing participant choice and control.     

Stay calm, watch and wait for the outcome of the consultations.

Ensure your Worker Checks are up to date.

Review your policies for compliance with both professional rules and the NDIS Code of Conduct.

Implement/revise your Incident Management, Complaints Management and other compliance systems and policies to ensure they meet NDIS requirements that currently apply to registered providers.