What is OTA doing to advocate on NDIS pricing?

OTA has been loudly calling for fair NDIS rates for OTs for many years. Every year we compile member feedback and make a submission to the NDIA’s annual pricing review, supplying our own data and evidence from across the sector on the inadequacy of NDIS pricing for occupational therapists. We have surveyed and spoken to thousands of members to collect feedback and data to inform our position.

We have also called for a better pricing approach though submissions to the NDIS Independent Review, and to a special inquiry by the Independent Health and Aged Care Pricing Authority (IHACPA).

We also work with our own peak body Allied Health Professions Australia (AHPA) to collaborate on NDIS pricing issues with other allied health profession peaks. This included supporting the 4ABetterNDIS campaign: https://www.4abetterndis.com.au/.

Since the release of the June 2025 NDIA pricing decision OTA has:

• Launched a National campaign including a petition and email-your-MP tool.

• Created a Meeting with Your Local MP about the NDIS Pricing Decision guide to support members to advocate.

• Meetings with a wide array of key decision makers and Parliamentarians including:

  • Office of NDIS Minister Jenny McAllister MP

  • Office of NDIS and Health Minister Mark Butler MP

  • Independent MP Sophie Scamps

  • Nationals MP Pat Conaghan

  • Greens MP David Shoebridge

  • Senator Jacqui Lambie. Following our meeting, Senator Lambie wrote to Hon Mark Butler, as well as both the Premier of Tasmania and the Tasmanian Leader of the Opposition to advocate for a reversal of the price changes that reduce access to care. The Senator also published two Op-Eds highlighting the devastating impact the APR's pricing decision will have on access to care, and expressing her support for the value of OT.

  • NDIS Quality & Safeguards Commissioner Louise Glanville

  • Senior NDIS provider liaison staff

• Written to the Australian Greens, who have subsequently issued a media release calling for a reversal of the pricing decision.

• Written to Dean Winter, Tasmanian Opposition Leader, explaining the pressure this decision will place across all systems, with a request to raise with his federal counterparts

• Raised concerns directly with the NDIA

• Engaged with the media to highlight the impact, with Chief OT Michelle Oliver being interviewed on Hobart Radio, and having an Op Ed published in the Canberra Times, and the issue being raised on Radio National.

• Collaborated with Allied Health Professions Australia (AHPA) and other allied health peaks to strengthen our collective voice, including a Joint Statement

• Collaborated with the Council of Small Business Australia (COSBOA) to ensure they understand the impact of the pricing decision on a range of allied health small businesses. COSBOA have agreed to write a joint letter with OTA to Opposition Minister for Small Business Tim Wilson.

Is OTA working with anyone else to advocate against the pricing cuts?

We know that there is strength in numbers and we always seek to work with other allied health profession peak bodies wherever possible to amplify our voice, through our peak body Allied Health Professions Australia (AHPA)

In the case of our current pricing campaign, we felt there was an urgent need to act to directly support occupational therapists.

We are continuing to reach out to other allied health professional bodies to understand their approaches and see if there are ways we can support each other.

Why is OTA asking for a 7% increase to OT NDIS rates?

We have based this ask on recent data from by Ability Roundtable, which represents 21% of the NDIA registered provider market, which identified a need for an immediate 7% pricing increase for providers to address current provider losses across small, medium and large providers.

OTA’s advocacy ask also factors in the current economic conditions which include weakening inflation, the fact that cuts have been applied to other allied health professions, and the prevailing bipartisan approach from both Labor and the Coalition to reign in NDIS budget costs.

OTA is aware that practitioners may be experiencing higher losses in some cases and we welcome feedback on our current ask to help inform our future pricing advocacy.

OTA has for many years been advocating for a fit for purpose allied health pricing model which would appropriately cost and fund allied health services, including OT, to meet our long-term goal of a thriving and sustainable NDIS provider market.  In the meantime we are pursuing an immediate, urgent pricing uplift to keep providers afloat while we continue to pursue this goal.

Will OTA develop a recommended price for OT fees?

OTA is aware that some other allied health professions have published schedules of suggested fees for services. We have heard from members that they would like OTA to show leadership on OT pricing rates to assist in achieving fair and sustainable remuneration when providing fees under government funded schemes, and in the broader private market.

In the 2025-26 financial year, OTA will explore the option of investing in work to develop a recommended schedule of fees for OT services, which will include economic and legal advice.

Why is the NDIA’s pricing methodology flawed?

The NDIA’s pricing decision has relied on limited data and data sources that are not comparable. The latest pricing review relies on data from Medicare and private health insurance. OTA maintains that it is not appropriate to compare rates from such different schemes, which utilise a different scope of OT services and different billing rules. It is not accurate to compare rates for a physical rehabilitation appointment, or a Medicare Better Access appointment, with a comprehensive functional capacity review, or delivery of complex therapeutic interventions for a client with multifactorial disability.

NDIA also said they looked at other pricing data through reviewing allied health provider websites. They only looked at 50 data points for occupational therapy, which is a very small sample.

Last year OTA undertook its own analysis of current comparable market pricing from hundreds of OTs which showed that pricing was much higher when comparing disability specific supports. This was provided to NDIA on two occasions, however this was not even acknowledged in the final review report. 

NDIA has also disregarded economic modelling provided by Ability Roundtable, a body representing a large number of NDIS service providers, which commissioned Deloitte to undertake economic modelling of the cost of service provision for therapy supports. Their review has shown that provider costs were well in excess of the current maximum price for the ‘therapy supports’ item over the past three review cycles. 

OTA is also extremely disappointed that in 2025, NDIA did not conduct its usual consultations with the NDIA provider market before making its decision. OTA was invited to a meeting with junior NDIA staff in January 2025 and was told this was to collect specific feedback on OT billing practices. It was only through concerted questioning by OTA that we learnt there would be no consultation on the price review in 2025, which usually happens every year. Even though NDIA did not seek submissions, OTA provided evidence to the NDIA on the impact of the continuing pricing freeze, and data on market withdrawals that have already occurred and the estimated impact on thousands of participants to ensure that NDIA did not make decisions without this important information.

How is the allied health pricing campaign having impact?

Along with OTA, other allied peaks are also continuing their advocacy, and we have seen a wide range of media across print, web and radio discussing the impact of the pricing decision on service provision, especially in regional and remote areas, affecting a range of services including OT.

Politicians from across the spectrum have been receptive to the allied health sector campaign with Senator David Pocock and Senator Jacquie Lambie expressing their support, along with Dr Sophie Scamps, the Australian Greens and the Coalition who have written to the NDIS Minister Mark Butler demanding Labor delay any pricing changes by at least three months to enable government to properly consider the implications of the price cuts.

What is changing for occupational therapists from 1 July under the new price guide?

The major change for occupational therapists working under the NDIS is reduction in how much can be charged for travel to provide face to face participant supports. Read more on this in the travel section below.

There are no changes to the rates that OTs can charge for participant support services. Under the 2025-26 PAPL occupational therapists can continue to bill clients at the current maximum hourly rate of $193.99 (or higher if the participant is located in a remote or very remote area), as outlined in the table below, for capacity building supports.

Maximum prices for OT services (face to face, non-face to face and telehealth)

PAPL Item Name	NDIS plan support category	Item code	Maximum rate National	Maximum rate Remote	Maximum rate Very Remote
			MMM1-5 (per hour)	MMM6 (per hour)	MMM 7 (per hour)
Early Childhood Intervention Professional – Occupational Therapist (See page 91 in PAPL)	Capacity Building – Improved Daily Living	15_617_0118_1 _3	$193.99	$271.59	$290.99
Assessment Recommendation Therapy or Training - Occupational Therapist (See page 94 in PAPL)	Capacity Building – Improved Daily Living	15_617_0128_1_3	$193.99	$271.59	$290.99

Source: NDIS Pricing Arrangement and Price Limits 2025-26 Version 1.0. Released 16 June 2025

Note there are separate rates that apply for other OT supports including disability related health supports, employment supports or specialist support coordination. See pages 60, 74 and 80 of the PAPL for more details.

What are the changes to OT travel?

From 1 July 2025, new rules apply for provider travel billing for therapy support providers (i.e. OTs).

For therapy support providers, including early childhood therapy, the price limit for provider travel time is 50% of the regular price limit for these items (i.e. HALF the hourly rate).

Travel caps continue to apply, and this does not impact the amount that can be claimed for non-labour costs.

For example, if an occupational therapist travelled for 1 hour in an MMM5 area to deliver support to a participant, the maximum claimable for this travel time component would be $97.00 (which represents 50% of the direct hourly price limit of $193.99, which is $97.00, billed for the 1 hour of travel). Additional non labour costs can also be billed including KMs travelled, tolls and parking.

In another example if an occupational therapist travelled for 30 minutes in an MMM2 area to deliver support to a participant, the maximum claimable for this travel time component would be $48.50 (which represents 50% of the direct hourly price limit of $193.99, which is $97.00, billed for 30 minutes). This does not impact the amount that can be claimed for non-labour costs.

If you have agreed to charge a participant less than the maximum price cap, your travel labour costs should be 50% of this agreed rate.

Maximum hourly rates for OT Travel (labour) costs from 1 July 2025

NDIA PAPL Item Name and Notes	50% hourly rate travel billing rule applies from 1 July 2025?	Item code to bill for provider travel (labour costs)	Maximum1 travel rate MMM1 – 54 (per hour)	Maximum1 travel rate MMM6 (per hour)	Maximum1 travel rate MMM7 (per hour)
Early Childhood Intervention Professional – Occupational Therapist	Yes	15_617_0118_1 _3	$97.00	$135.80	$145.50
Assessment Recommendation Therapy or Training - Occupational Therapist	Yes	15_617_0128_1_3	$97.00	$135.80	$145.50

Source: NDIS Pricing Arrangement and Price Limits 2025-26 Version 1.0. Released 16 June 2025 (as interpreted by OTA).

Notes:

1. If you have agreed to charge a participant less than the maximum price cap for OT supports, your travel labour costs should be 50% of this agreed rate.

2. Travel billing for provider travel (labour) costs is subject to NDIA travel caps of maximum of 30 mins of travel in MMM1 -3 areas or 60 minutes in MMM4-5 areas. Find out more about MMM areas here.

Note that NDIA policy requires providers travelling to provide services to more than one participant in a ‘region’ to apportion all of the travel time (including the return journey where applicable) between all the participants who received support from the worker. This apportionment should be agreed with each participant in advance as part of the service agreement.

What are Non-Labour travel costs?

These are non-salary costs that may be incurred during travel to provide face to face services such as road tolls, parking fees and the running costs of a vehicle. A provider can negotiate with the participant for them to make a reasonable contribution towards these costs. The NDIA PAPL states that the following would be reasonable contributions for these costs:

• For a vehicle owned by the provider or the worker, up to $0.99 a kilometre; and

• For other forms of transport or associated costs, such as road tolls, parking, public transport fares, up to the full amount.

Note that the $0.99 per kilometre amount is not mandated by the NDIA, and is a guide only. Providers should ensure that the rate for any KMs charged is reasonable, and agreed with a participant, and set out in the Participant Service Agreement.

Codes for OT Travel (non-labour) costs

NDIS PAPL Item Name	NDIS plan support category	Item code to bill for provider travel (non-labour) costs
Early Childhood Intervention Professional – Occupational Therapist	Capacity Building – Improved Daily Living	15_799_0118_1_3
Assessment Recommendation Therapy or Training - Occupational Therapist	Capacity Building – Improved Daily Living	15_799_0128_1_3

Source: NDIS Pricing Arrangement and Price Limits 2025-26 Version 1.0. Released 16 June 2025.

How do I bill for travel (labour and non labour)?

Travel costs should be claimed separately to the face-to-face services provided. For each service that involves travel a provider may bill for:

• Primary support (i.e. support provided face to face) – billed per hour using relevant item code and hourly rate.

• Provider travel (labour) – billed per hour, applying the 50% travel rate adjustment to the same rate as the primary support. Apply any relevant regional travel caps, and use the same item code as the primary support. Bill using the “Provider Travel” option in the myplace portal.

• Provider travel (non-labour) – billed per item, using item code in the table above, (e.g. 36 kms charged at $0.99, parking costing $12).

Ensure that you discuss all travel related costs and seek the participant’s agreement before charging for these items). It is recommended that these details are documented in a Service Agreement.

Does the 50% travel rate apply for specialist support coordination done by an OT?

OTA’s assessment of the PAPL is that OTs providing Level 3 Specialist Support Coordination are not impacted by the 50% travel billing restriction. If you are registered under Registration Category code 0132 Specialised support coordination, then continue to bill at 100% of the hourly rate.

What do I need to do to enact the new changes?

OTA recommends you update your client service agreements for any services provided after 1 July 2025 to reflect new travel rates and discuss with clients if the changes mean you need to alter the travel services you offer. Some providers do not currently bill for KMs travelled, and you may wish to consider billing for this to ensure you recoup any travel costs in light of the 50% hourly rate cut for travel billing.

How do I charge for service provided before 1 July 2025?

Services provided up to and on 30 June 2025 should be billed using the arrangement in the 2024-25 PAPL.

Can I charge a gap fee for NDIS services?

Under NDIS rules, registered providers must not add any other charge to the cost of the supports they provide to any participant, such as credit card surcharges, or any additional fees including any ‘gap’ fees, late payment fees or cancellation fees, unless otherwise permitted by the NDIS Pricing Arrangements and Price Limits.

Self-managed participants can use registered or unregistered providers and are not subject to the pricing arrangements set out in the PAPL. This means that rates above the maximum rates set in the PAPL can be agreed with self-managed participants.

We note that NDIS Commission expects that NDIS Providers will not participate in or promote sharp practices. This includes:

• Not charging a NDIS Participant more than another person for substantially the same product, support or service, without objectively sufficient justification; or

• Not promoting, advertising or publishing higher prices for substantially the same products, supports or services for Participants compared with other people, without objectively sufficient justification.

This means that you should consider your pricing and ensure that you provide an accurate description of the services you provide, and the relevant price, ensuring that it provides appropriate description and distinction from any other services you provide.

Where can I get more help?

The NDIA has launched a Provider specific contact number to enable NDIA providers to obtain advice. For provider specific questions OTs can now contact 1300 311 675 Monday to Friday 8am to 8pm (local time).

Contact info@otaus.com.au for additional questions.