There are many services and supports within the NDIS, each carrying different levels of risk, knowledge, education and compliance requirements. Every role within the scheme is essential to its sustainability and integrity.

Currently, around 60% of participants choose to use a plan management provider. The NDIA has established rules governing how plan managers must operate, and all must be registered with the NDIS Quality and Safeguards Commission. The Commission regulates providers to ensure the NDIS Code of Conduct and NDIS Practice Standards are met. Failure to meet these requirements can result in non-compliance, de-registration, and, in some circumstances, legal action.

To remain compliant, plan managers must adhere to a range of regulatory obligations. Below are the key areas of compliance.

Plan intention

“A Plan Manager’s role is to ensure a plan is implemented as intended, including ensuring funds are being spent in accordance with the plan.” - NDIA

Every invoice a plan manager submits to the NDIA must align with the intent of the participant’s plan. It’s important to note that intention is not the same as reasonable and necessary, only NDIS planners can determine this.

Plan managers support participants to understand their budgets, what each budget is designed for, and how funding can be used depending on how the plan is written, including stated and non-stated supports.

Plan intention can be understood through:

• The plan itself: Plans with more detail provide clearer guidance on how funding is intended to be used.
• Plan breakdowns: These may include planner notes or additional context behind decisions.
• Declined supports: Visibility of declined requests helps clarify what funding cannot be used for.
• Documented communication with NDIS planners: Emails or letters between NDIS planners and support coordinators, participants or nominees can outline intended use and NDIA decision-making.
• Documented communication with my NDIS contact: While my NDIS contacts cannot determine reasonable and necessary (unless they are also NDIS planners), they can help participants understand and use their plans.

NDIS supports

“Plan managers help make sure NDIS funds are used according to the participant’s plan and legislative requirements. These legislative requirements include ensuring supports being accessed or paid for are approved NDIS Supports.” - NDIA

Under NDIS legislation, some items and services cannot be funded and are considered non-NDIS supports. While there are limited exceptions, such as replacement supports, plan managers can only process invoices for supports on the approved list and only where they are appropriate for the individual participant.

This links directly back to plan intention. If a plan manager submits a claim for something that is not an NDIS support, they are acting non-compliantly and in breach of NDIS law. While this can feel confusing or frustrating for participants and providers, it is a clear legal boundary for plan managers.

NDIA compliance

A plan manager’s role is to support participants and providers while remaining compliant. This includes explaining why plans differ, helping resolve confusion, and supporting participants to understand how their individual funding can and cannot be used under the scheme.