In November 2024, the National Disability Insurance Agency moved to remove art therapy and music therapy from the Therapy Support category of the NDIS Price Guide.
The supports were to be reassigned to the community participation budget and funded at a substantially lower rate. The Agency’s reason was evidentiary: art therapy and music therapy were said not to meet the standards required to be classified as therapies under the NDIS definition of supports.
The decision placed the two professions in an extraordinary position. Before practitioners could argue about the price attached to their work, they first had to demonstrate that the work qualified as therapy at all.
Following a strong sector response, the decision was paused and referred to an Independent Review into Art and Music Supports, led by Stephen Duckett.
The review found that art therapy and music therapy could be effective interventions in appropriate clinical contexts. It recommended that both continue to be funded as therapeutic supports under the NDIS.
But having confirmed that the work was therapeutic, the review recommended that it be paid at a lower rate than other allied health therapies.
At the time, the higher allied health therapy rate was $193.99 per hour. The review recommended that art therapy and music therapy instead be aligned with the counselling rate of $156.16 per hour — a difference of $37.83 per hour.
The reason given was that art therapy and music therapy were “developing professions that are not yet nationally regulated”.
This created a different problem.
The original question had been whether the therapies were supported by evidence. Once the review found that they were, regulatory status was used to determine their financial value.
Two separate institutional functions had become mixed together.
Regulation and pricing answer different questions
Professional regulation is designed primarily to protect the public.
Australia’s National Registration and Accreditation Scheme determines whether the risks associated with a profession justify statutory registration. It establishes requirements for entry to practice, professional conduct and public accountability.
It is not a system for measuring the value of work.
A profession’s position inside or outside Ahpra does not tell us:
- how complex its work is;
- how much knowledge or skill it requires;
- how much responsibility its practitioners carry;
- how effective its services are;
- what it costs to provide those services safely; or
- what value the work creates for the person receiving it.
Work-value assessment asks a different set of questions. It examines the nature of the work itself: the expertise required, its complexity, accountability, responsibility, conditions and impact.
By using registration status to determine price, the NDIS pricing process turned a regulatory category into a proxy for work value.
That is the central issue in this case.
The criterion is not applied consistently
The problem becomes clearer when the reasoning is applied across the wider NDIS pricing structure.
Art therapy and music therapy are not the only health professions outside the National Registration and Accreditation Scheme.
Speech pathology, social work, audiology, orthoptics, developmental education and rehabilitation counselling also sit outside AHPRA. Several of these professions maintain formal self-regulatory systems through professional associations and recognised credentialling arrangements.
Yet these professions remain in the higher allied health pricing tier.
| Profession | Ahpra registered? | NDIS pricing tier at the time |
| Speech pathology | No | Higher allied health rate |
| Social work | No | Higher allied health rate |
| Art therapy | No | Lower counselling rate |
| Music therapy | No | Lower counselling rate |
The issue is not that every profession must be paid the same rate.
Different work may properly attract different prices. But those differences should be supported by a transparent assessment of the work being performed.
If non-registration explains the lower price for art therapy and music therapy, it should also explain the position of other non-registered professions. It does not.
Regulatory status is therefore not the consistent organising principle of the NDIS pricing hierarchy. It became relevant when the price of these two professions was being determined.
First prove the work exists. Then accept that it is worth less.
The sequence also reveals an unequal evidentiary burden.
Art therapists and music therapists were required to demonstrate that their interventions were sufficiently effective to remain funded as therapeutic supports. The Independent Review examined the evidence and found that the interventions could be effective in appropriate circumstances.
Passing that test did not return the professions to the same pricing category as other therapies.
Instead, a new criterion was applied.
Evidence determined whether the work could remain in the scheme. Regulatory status then determined what the work was worth.
Meanwhile, other professions in the higher pricing tier were not required to undergo an equivalent review to retain either their therapeutic status or their existing rate.
This produced an unusual asymmetry:
- art therapy and music therapy had to demonstrate effectiveness to justify inclusion;
- effectiveness was not then used to determine their price;
- regulatory status was used to justify a lower price;
- the same regulatory criterion was not applied to other non-AHPRA professions; and
- higher-priced professions were not required to justify their rates through an equivalent work-value assessment.
The Independent Review itself recognised part of this problem. It recommended stronger evidentiary oversight of all therapeutic supports, not only art therapy and music therapy.
That is important. But evidence of effectiveness and assessment of work value still need to be kept conceptually separate.
A service can be effective without all effective services having the same value, cost or level of complexity. Equally, a profession can sit outside AHPRA without its work necessarily being less complex, less skilled or less valuable.
What the pricing system is actually doing
The NDIS Price Guide does more than administer payments. It helps determine which professional capabilities are recognised, which forms of work are financially sustainable and which professions can maintain a viable presence in the disability service system. When pricing categories are attached to professional titles, funding begins to reinforce professional boundaries.
The system signals:
- which work counts as therapy;
- which professional groups attract the higher rate;
- whose qualifications are financially recognised;
- which practitioners can sustain a viable business;
- which professions provider organisations can afford to employ; and
- which services participants can realistically access.
This is fiscal instantiation: professional distinctions become embedded in funding arrangements.
In the art and music therapy case, fiscal instantiation became entangled with regulatory instantiation. A profession’s regulatory position was used to determine its place in the pricing hierarchy, even though the regulatory system was not designed to assess work value.
The result was not simply a lower hourly rate. It was an institutional judgement about the relative value and standing of the work.
The role of institutional history and influence
If regulatory status does not consistently explain the hierarchy, what does?
Part of the answer may lie in historical recognition.
Professions that have long-standing relationships with government, established peak bodies, substantial policy capacity and a history of inclusion in earlier funding arrangements are better positioned to maintain their place within existing pricing systems. Smaller or more recently consolidated professions may have less capacity to participate in reviews, influence technical policy processes or challenge the assumptions embedded in funding instruments.
This does not establish that institutional power is the only determinant of price. But it raises an important question. Where the published criterion does not explain the hierarchy, are historical recognition and policy influence doing more of the work than a direct assessment of value?
The art and music therapy decision suggests that the NDIS pricing system is not based on one transparent cross-professional methodology. It is better understood as a structure that has developed incrementally, with different professions entering at different times and on different grounds. The resulting hierarchy may appear objective because it is written into a national price guide. That does not mean the categories were created through a consistent assessment of the work.
Why profession-based pricing matters
Pricing work according to the profession delivering it can produce several distortions.
First, comparable work may be valued differently depending on who performs it.
Second, work of very different complexity may attract the same rate simply because it is delivered by members of the same profession.
Third, provider organisations may design their workforce around the available billing categories rather than around the capabilities required by participants.
Fourth, new models of care can be discouraged. Task-sharing, interdisciplinary practice and capability-based workforce design become difficult when the financial system is organised around fixed professional identities.
Finally, the pricing structure can deepen existing workforce inequalities. Professions with established classifications, strong institutional recognition and secure funding pathways accumulate further economic and professional advantage. Those outside the higher tiers may struggle to build the workforce, evidence base and organisational infrastructure that would allow them to challenge their lower status.
The funding architecture does not merely reflect professional differences. Over time, it helps produce them.
A familiar work-value problem
The underlying issue is familiar from work-value and equal-remuneration cases.
Separate professional histories or institutional structures do not necessarily provide an objective justification for valuing comparable work differently.
The 1993 European decision in Enderby v Frenchay Health Authority addressed a related problem. Speech therapists, a predominantly female profession, were paid less than other professional groups performing work argued to be of comparable value. The existence of separate bargaining arrangements did not, by itself, settle the question of whether the difference was justified.
The relevance to the NDIS is not that the circumstances are identical. It is that institutional categories should not be allowed to substitute for an examination of the work.
A profession’s historical pathway into a funding system does not necessarily establish the appropriate contemporary value of the services its members provide.
Recognising the value of the work
The art and music therapy decision exposes a wider weakness in profession-based pricing. When funding categories are organised around professional titles, the value attached to a service can depend more on who delivers it than on what the work requires.
Regulatory status, historical recognition and institutional influence can become substitutes for a direct assessment of:
- knowledge and skill;
- complexity;
- professional judgement;
- responsibility and accountability;
- service-delivery costs;
- working conditions; and
- value to the participant.
This does not mean that qualifications, professional standards and regulatory obligations are irrelevant to price. They affect the cost and conditions of providing safe, high-quality services. But these factors should contribute to an assessment of work value. They should not stand in for one. A defensible pricing system would start with the work being purchased. It would ask:
What capability does this support require, what responsibility does it carry, and what value does it provide to the participant? It could then consider which practitioners are qualified and appropriately governed to deliver that work. This approach would not automatically produce identical prices for all therapies. It would produce something more important: a transparent explanation for why prices differ.
What needs to change
The NDIS does not need to invent a new concept of work value from first principles.
Australian industrial relations systems have long used work-value assessments to examine skill, responsibility, complexity and working conditions. Equal-remuneration processes have also developed methods for identifying where occupational history and professional segregation have distorted how work is recognised and paid.
These methods could inform a more transparent approach to NDIS pricing.
At minimum, future pricing reform should:
- separate questions of effectiveness, regulatory status and work value;
- publish the criteria used to place professions or services in different pricing tiers;
- apply those criteria consistently across professions;
- assess the work being purchased rather than relying primarily on professional title;
- distinguish between the cost of safe service delivery and the institutional status of the provider; and
- review whether current categories support flexible, capability-based workforce models.
The issue is not simply whether the art and music therapy rates should rise or fall. The deeper question is whether a national disability funding system should determine the value of work through categories that were never designed to measure it.
Conclusion
The NDIS initially proposed removing art therapy and music therapy from therapeutic supports because it considered the evidence insufficient. The Independent Review examined that question and found that the therapies could be effective in appropriate contexts. They remained eligible for therapeutic funding.
But the review then recommended a lower price because the professions were not nationally regulated. In that transition, a regulatory distinction became a financial judgement.
The case shows how regulatory and fiscal instantiation can become entangled: regulatory status is used to determine funding, and funding then reinforces differences in professional standing, recognition and viability. The central problem is not that art therapy, music therapy and every other profession receive different prices. It is that those differences have not been grounded in a transparent and consistently applied assessment of the work.
Regulation determines how professions are governed. Evidence helps determine whether interventions are effective. Neither, on its own, determines what work is worth. The value should attach to the work — not simply to the professional category of the person who performs it.
Find out more about the role of music therapists here.
