Let’s Talk About the Gaps in NDIS Behaviour Support
The NDIS Behaviour Support landscape is facing serious systemic challenges. While frameworks and legislation exist to guide quality and safeguard participants, the real-world application of Positive Behaviour Support (PBS) continues to be undermined by significant gaps in practitioner experience, governance, and workforce development.
These gaps are not just technical oversights — they’re letting down participants, their families, and the support providers doing their best on the ground. The cost isn’t only personal, it’s systemic — with millions of taxpayer dollars being invested in services that aren’t consistently delivering safe, effective support. We have a collective responsibility to do better.
It’s time to break down these challenges, examine where they’re coming from, and commit to better systems that truly support quality behaviour support delivery.
Scope of Practice: From Aspiration to Execution
The concept of “working within scope” is a well-intentioned safeguard—but in a thin market, it’s become dangerously vague. Alternative pathway entries into behaviour support were introduced to address workforce shortages. While these allow for diverse entry points, they often place inexperienced practitioners into roles that far exceed their clinical and operational readiness.
Many new Behaviour Support Practitioners (BSPs) have:
- Limited training and no prior experience delivering behaviour support on the ground
- Little or no experience in the disability sector
- Minimal understanding of professional compliance requirements and clinical risk
- Irregular and time-limited supervision — often from a practitioner with under two years of their
own experience
These practitioners are also under significant pressure to meet KPIs, while navigating complex roles with minimal experience and unclear guidance. Many don’t fully understand their obligations under the NDIS — including their specific requirements to maintain registration and compliance. Even clinical leads have been unaware of basic requirements clearly outlined in the Practice Standards. The result? A workforce that is under-supported, under-trained, and overwhelmed. These practitioners are expected to uphold complex NDIS compliance requirements, manage high risk caseloads, write high-stakes behaviour support plans, and navigate restrictive practice legislation — often without accurate or meaningful guidance.
It remains unclear what “working within scope” truly looks like in context:
- Which participants are appropriate for early-career BSPs?
- What constitutes a safe, sustainable caseload?
- How are risks identified and mitigated?
Although ongoing professional development is a requirement, I’ve worked with hundreds of practitioners who haven’t received even basic training in Positive Behaviour Support (PBS). Their only exposure is often a generic online induction — developed in-house by other inexperienced practitioners or L&D teams who lack the required clinical knowledge.
While professional development is a requirement, it doesn’t replace real-world experience. Supervision, which is only required to occur on an undefined ‘regular’ basis, is often ineffective and isn’t enough to bridge the gap.
The increased uptake in remote and contract roles — especially for early-career BSPs — compound these issues.
Without regular proximity to experienced supervisors or colleagues, practitioners miss out on:
- Incidental learning
- Modelling and feedback from seasoned clinicians
- Informal oversight and quality assurance
These roles reduce opportunities for reflection, peer learning, and spotting red flags early. And when a practitioner “doesn’t know what they don’t know,” but isn’t regularly interacting with a clinical or operational team, the risk becomes exponential.
We cannot underestimate the role of daily, informal supervision and workplace culture in shaping competent, ethical practitioners.
The Endorsement Problem: No Standardisation, No Oversight
The NDIS Commission provides a detailed Behaviour Support Practitioner Competency Framework, which unfortunately in my experience is an underutilised tool — but it does not regulate the endorsement process or its outcomes.
Instead, endorsement is left to:
- Registered providers
- Supervisors (often inexperienced or under pressure and at times external to the organisation the practitioner is employed with)
- Internal teams managing competing priorities
This results in:
- Inconsistency in how competency is assessed
- A lack of robust or standardised endorsement processes
- Operational pressures influencing decisions (e.g., needing more “proficient” BSPs to supervise others)
There are documented cases of BSPs with under 12 months’ experience being endorsed as “proficient”. I’ve seen this process carried out by non-clinical managers or based solely on organisational pressure rather than demonstrated competence. Meanwhile, funding continues to grow. The NDIS Quarterly Report (March 2025) notes increased investment in behaviour support under the justification that capacity building will reduce long-term costs.
But what happens when that investment pours into a workforce unequipped to deliver? The demand rises, but quality and safeguards remain weak.
The Supervision Gap: Who’s Supporting the Supervisors?
While the endorsement of practitioners is unregulated, so too is the clinical supervision that underpins practitioner development. There is currently no national capability framework, minimum qualification, or experience threshold for someone providing clinical supervision to Behaviour Support Practitioners (BSPs).
This means that clinical supervisors — the people guiding others through high-risk work — may
themselves:
- Have limited experience delivering behaviour support in practice
- Lack formal training in supervision models or frameworks
- Receive no ongoing professional development
- Operate without accountability, standards, or peer review
Supervision structures vary widely. In some cases, supervision:
- Is purely administrative or focused on caseload allocation
- Happens irregularly or is deprioritised due to KPIs
- Focuses more on documentation than critical thinking or reflection
- Lacks standardised or evidenced-based feedback on PBS fidelity and plan quality (beyond the limited BSPQE-II), or ethical practice
There is no requirement for supervisors to hold qualifications in PBS Supervision, and no oversight to ensure they are equipped to provide effective guidance in high-risk areas such as restrictive practices, trauma-informed care, or mental health complexity.
This gap directly undermines the integrity of the endorsement process. Without qualified, experienced supervision, even well-intentioned practitioners can:
- Develop poor habits or incorrect interpretations of practice
- Miss critical learning opportunities
- Remain unaware of compliance failures or clinical risk
To build capability and safeguard quality, supervisors must themselves be supported, trained, and held to defined standards. Without this, the whole system remains vulnerable.
Salary Pressures, Sustainability, and Skill Gaps
The thin market has inflated BSP salaries — even for those lacking core skills. This is unsustainable and risky.
To compensate, some providers:
- Cut supervision hours
- Skip essential training
- Push higher KPIs onto already underprepared staff
Even those motivated to grow struggle to access meaningful development — and often lack the time to engage due to billable targets. The result is a revolving door of burned-out practitioners and deepening skill gaps across the sector.
The Governance Gap
Too many Specialist Behaviour Support Providers lack robust clinical governance systems. Where these are missing, poorly structured, or reactive, the quality of support is inconsistent at best—and dangerous at worst.
Strong clinical governance should include:
- Proactive risk identification and mitigation systems — including clinical risk, restrictive practice misuse, and practitioner scope-of-practice concerns
- Structured pathways for practitioner development standardised against the BSP Capability Framework
- Clear definitions of scope at each endorsement level
- Standardised and evidence-based plan review and quality assurance mechanisms, beyond the limited BSPQE- II
- Reflective supervision and incident learning systems
- Safeguards to detect drift from ethical or evidence-based practice
When implemented well — ideally from the beginning — governance becomes the guardrail that enables quality, safety, competency building and staff retention. It supports compliance not through fear, but through confidence.
The Compliance Reality
Practitioners and Senior Operational teams are expected to uphold complex legislation, yet many are often unaware of their basic compliance responsibilities, many have never read the NDIS (Restrictive Practices and Behaviour Support) Rules 2018 or the NDIS Quality Indicators in full.
Instead, they rely on:
- Advice from peers on social media
- Conflicting or inadequate internal training
- Supervisor interpretations (which may also be incomplete)
When faced with unrealistic KPIs, heavy caseloads, and limited access to quality training,
Practitioners experience burnout, imposter syndrome, and confusion around what “best practice”
actually looks like.
This creates inconsistent practice, unsafe use of restrictive practices, and poor-quality behaviour
support plans. Many don’t even realise what they’re doing is non-compliant — until it’s too late.
So, What Can We Do?
Prioritise Sustainability Over Salary Inflation.
Instead of offering inflated salaries to attract Behaviour Support Practitioners, providers should invest in sustainable workforce strategies that promote wellbeing, retention, and growth. High salaries without adequate support often lead to burnout and turnover—exacerbating workforce shortages.
Redirect investment into meaningful supervision, professional development, manageable KPIs, team building, and strong governance systems. Staff stay, thrive and deliver quality services when they feel supported, connected, and able to grow. Investing in your people isn’t just good practice— it’s essential for service quality, compliance, and long-term sustainability.
Operational managers and CEOs responsible for overseeing behaviour support services are advised to take personal responsibility in being knowledgeable about relevant regulatory requirements, rather than over relying on their ‘Senior’ Practitioners who realistically have limited experience. They should also seek advice from individuals with proven experience and expertise, and establish effective governance systems.
For those of us who have a role in delivering NDIS behaviour support, we have a responsibility to
bridge the gap between aspiration and execution — and support the sector to build well. To build
ethically. To build confidently.
Because every practitioner deserves the right tools. Every organisation deserves sound governance. And every person with a disability deserves safe, ethical, and effective support.
This isn’t just about compliance.
It’s about rights.
It’s about dignity.
It’s about doing better.
Let’s Talk
- What’s your experience of working in NDIS Behaviour Support?
- What do you expect from a Core vs Advanced Practitioner?
- What support do your teams need?
👉 Join the conversation.
Let’s build better. Together.
About the Author
Rachael Cleary is the founder of Buildwell Behaviour and has extensive experience in Positive Behaviour Support across government, non-profit and private sectors for over 20 years. Buildwell exists to bridge the gap between aspiration and execution in NDIS behaviour support — providing training, supervision and governance support to BSPs and providers who want to do better.
Visit Buildwell Behaviour.