NDIS Integrity Unit System Operating Policy

1. Purpose

The NDIS Integrity Unit exists to perform a function currently absent within the National Disability Insurance Scheme: a dedicated, upstream intelligence and systems-analysis capability focused on identifying emerging integrity risk, clarifying patterns, and supporting earlier, better-informed decision-making.

The Unit operates prior to investigation, prior to escalation, and prior to loss.

Its mandate is analytical and structural, not operational or determinative.

2. Position in the System

The NDIS Integrity Unit does not replace, replicate, or assume the functions of:

• the National Disability Insurance Agency
• the NDIS Quality and Safeguards Commission
• law-enforcement bodies
• complaints or review mechanisms
• audit or assurance entities

These bodies act within defined statutory mandates, typically after behaviour becomes visible within their respective systems.

The Integrity Unit exists to improve earlier visibility, contextual understanding, and system-level insight, not to intervene directly.

Its role is to integrate signals, identify emerging patterns, and surface material integrity risk in a form suitable for consideration by the appropriate authority.

This function is not otherwise performed within the NDIS ecosystem.

3. Core Functions

3.1 Intelligence Intake and Triage

The Unit receives information from participants, families, providers, workers, advocates, and other sources.

Information is logged, categorised, contextualised, and prioritised for analytical purposes, based on relevance to scheme integrity and potential systemic impact.

Most information contributes to broader pattern analysis rather than discrete matters.

3.2 Pattern and Behaviour Analysis

The Unit analyses aggregated and contextual indicators, including:

• billing and claiming behaviour
• service delivery patterns
• geographic or temporal clustering
• referral or network relationships
• repeat typologies or anomalies

Analysis is directed toward identifying emerging trends and risk indicators, not assessing individual culpability.

3.3 Systemic Risk Identification

Where repeated anomalies or structural weaknesses appear, the Unit prepares system-level intelligence briefs describing observed patterns and potential integrity pressures.

These briefs are analytical in nature and do not constitute findings, determinations, or conclusions.

3.4 Escalation and Decision Support

Where defined internal thresholds are met, the Unit may share structured intelligence with the relevant authority for awareness and consideration.

Any escalation represents an analytical signal only.

No escalation constitutes a recommendation, determination, or view regarding legality, breach, intent, or liability.

4. Matters Outside Scope

The NDIS Integrity Unit:

• does not conduct investigations
• does not compel information
• does not issue compliance directions
• does not make findings of wrongdoing
• does not determine breaches or liability
• does not name providers or individuals publicly
• does not replace or override statutory decision-makers

The Unit produces analysis, not verdicts.

5. Escalation Thresholds

Escalation is selective and used sparingly.

The Unit considers escalation only where:

• risk indicators are material and coherent
• multiple signals align over time or context
• the behaviour has potential systemic relevance
• the information adds analytical value beyond existing visibility

The Unit does not escalate:

• personal or commercial disputes
• isolated or unsupported allegations
• retaliatory or vexatious complaints
• matters already subject to active regulatory or law-enforcement processes
• information lacking systemic relevance

This approach protects participants, providers, and the integrity of the scheme.

6. Data Handling and Confidentiality

Information is handled using controlled-access, intelligence-style processes, proportionate to sensitivity and risk.

Identifiable case-level information is not published.

Public outputs are aggregated, non-identifying, and system-focused.

Information is shared externally only with entities authorised to receive it, and only for integrity-related purposes.

7. Independence

The NDIS Integrity Unit operates independently.

Engagement with regulators or oversight bodies does not confer direction, approval authority, or control over analysis.

External bodies:

• do not set conclusions
• do not approve outputs
• do not direct escalation decisions

Independence is fundamental to analytical credibility and institutional trust.

8. Reliance, Limitations, and Responsibility

All outputs of the NDIS Integrity Unit:

• are analytical in nature
• reflect information available at the time of preparation
• may change as additional information emerges
• are provided without warranty as to completeness or accuracy

Responsibility for any action taken in reliance on the Unit's material rests solely with the receiving authority.

9. Policy Rationale

This framework exists to ensure:

• procedural fairness
• clarity of role and mandate
• institutional neutrality
• legal defensibility
• scalability to a funded national capability

The policy is designed to strengthen the NDIS without distorting or duplicating existing statutory functions.

10. Strategic Outcome

This operating model supports improved:

• early risk visibility
• structured intelligence flow
• allocation of investigative resources
• protection of participants
• long-term sustainability of the scheme

The NDIS Integrity Unit functions as system infrastructure, not an enforcement body.