The NDIS recently updated its conflicts of interest obligations, which can be found here.

Below are some key takeaways from the team at myAutonomy Plan Management.

Managing conflicts in NDIS plan management

Sometimes an NDIS provider will offer both Support Coordination and plan management. In these cases, managing conflict of interest is important.

If someone is handling a participant’s funding decisions, they shouldn’t also have a role in delivering services as there’s the incentive to offer certain services and providers for financial gain.

There are essential strategies to be aware of to help reduce the risk of conflict of interest.

Clear role separation


Separating the roles of Support Coordination, plan management and service delivery is important to reduce the risk of conflict. That means having separate staff members work on each function and not cross over at any point.
It’s also beneficial to have a separate organisational structure so that the functions are separate within the business, further reducing the risk of conflicts of interest.

Participant-centric focus


Rather than focussing on financial gain, the organisation should also promote participant-centric decision-making.

For Support Coordinators, that means the focus should be on helping participants understand their NDIS plans and gain the right supports for them. Decisions should be made on the basis of what’s best for the participant, not the business.

Plan managers should also manage budgets and claims independently to ensure that participants can make the most out of their plans and that they aren’t steered in a direction that’s better for the organisation.

In all cases, participants should understand that they have the right to choose independent providers even if an organisation offers multiple functions.

Transparency and clear communication


Any potential conflicts should be made clear to participants. If an NDIS provider offers both Support Coordination and plan management, this should be disclosed to participants upfront. How those conflicts are managed by the provider should be clearly communicated.

Participants must be made aware that they have the freedom to choose from various providers and they should be offered information about different service options.

Keep in mind: a participant might not know how conflicts of interest can impact decision-making in the NDIS space. Adequate information should be offered to participants about the different roles within the business and how these impact decision-making and finance so that there’s clarity and understanding.

Regular audits and monitoring


If both Support Coordination and plan management are being offered, there should be a process of regular audits in place. This can help ensure there’s no undue influence over participant’s plans or decision-making.

Audits can check for any signs of biased decision-making, where a participant might be steered toward using certain services because the provider is managing their plan.

Monitoring systems can also help ensure that there’s no improper influence on participant’s service choices. These could include gaining feedback from participants, such as via surveys, where participants can express any concerns they have. Staff should also be able to report any perceived conflicts of interest anonymously.

Comply with the NDIS Code of Conduct


All NDIS providers must adhere to the NDIS Code of Conduct which includes the requirement to act in the best interests of participants and to avoid conflicts of interest. This involves ensuring that participants’ NDIS plans are managed and implemented in a way that prioritises their needs and goals, free from conflicts of interest.

Providers must comply with any NDIS Quality and Safeguarding Framework requirements as well, which may include specific obligations to manage conflicts of interest in plan management and support coordination.

Consider additional safeguards


There are additional ways to reduce the risk of conflict of interest. These include:

• Having a third party review an organisation’s conflict of interest policies and processes periodically.


• Using external auditors or independent third parties to oversee financial processes, thus reducing risk.


• If there’s concern about conflict of interest, the providers should encourage participants to access independent plan managers.

Examples of potential conflict of interest & solutions

Scenario 1: A Support Coordinator recommends in-house therapy

Solution: The provider must have a process in place to ensure the Support Coordinator offers multiple options to the participant. This helps ensure the participant has a clear understanding of all available choices.
The relationship between the coordinator and the in-house services should also be disclosed.

Scenario 2: A plan manager recommends their in-house Support Coordination

Solution: The provider should ensure that the participant receives multiple choices for Support Coordination. The relationship between the provider and Support Coordination must also be disclosed. Additionally, the plan manager’s performance and decisions should be regularly reviewed by an independent third party to ensure they are acting in the participant’s best interest.

How myAutonomy manages conflict

As an independent plan manager, myAutonomy has made a conscious effort to only provide plan management. This ensures we’re not in a position of potential conflict of interest.

We’re a call away

Have a question or query for myAutonomy? Contact us today on 1300 60 33 89 or send us an email at [email protected].