Conflict of interest in growing NDIS organisations

Are your teams actually equipped to do the right thing?

As NDIS providers grow, governance complexity grows with them.

New service lines are added. Teams expand quickly. Roles blur. Referral relationships strengthen. What began as a small, values-driven organisation can suddenly find itself navigating layers of decision making that carry real compliance risk.

One of the most common pressure points for growing providers is conflict of interest.

Not because providers are acting with intent to do harm, but because many organisations underestimate how often conflicts arise in day-to-day operations and how deeply staff understanding needs to run.

The NDIS is clear on this. A conflict of interest occurs when a person or organisation has an opportunity to place their own interests ahead of the participant’s interests. These conflicts can be actual, potential, or perceived. Importantly, all three must be identified and managed. 

For growing providers, the real question is not “Do we have a policy?”
It is “Do our people actually know how to apply it?”

Why conflict of interest becomes riskier as providers scale

In smaller organisations, informal oversight can sometimes mask underlying risk. Leaders know what everyone is doing. Conversations happen naturally. Issues are caught early. As organisations grow, those informal controls disappear.

We see conflict of interest risks increase when:

• Providers deliver multiple supports across a participant’s plan
• Staff move between coordination, service delivery, referrals, and decision making
• Referral pathways become financially or commercially beneficial
• Managers are promoted internally without structured governance training
• New staff are onboarded quickly with limited compliance context

The NDIS has identified that conflicts which are not managed effectively can limit participant choice and control, pose risks to participant safety, and create sustainability and integrity risks for providers themselves. 

From a regulatory perspective, conflict of interest is both a participant rights issue and a provider governance issue.

The compliance gap most audits uncover

When auditors or regulators review conflict of interest, they are rarely satisfied with policies alone.

What they look for is evidence that:

• Staff understand what a conflict is
• Staff can recognise conflicts in real scenarios
• Conflicts are declared, recorded, and reviewed
• Participants are informed openly and transparently
• Decisions can be shown to be in the participant’s best interests

The NDIS explicitly outlines examples of conflicts that arise when providers influence decisions, limit choice, or control multiple supports across a participant’s plan.

Yet many mid sized providers still rely on:

• A generic policy written years ago
• Induction content that briefly mentions conflict of interest once
• Assumptions that “common sense” will guide staff behaviour

That is rarely enough.

Onboarding and training is where most providers fall short

If you asked your frontline teams or managers:

“What would you do if a participant asks you to recommend another service we also provide?”
“Can you explain the difference between a potential and perceived conflict?”
“When do you need to disclose a conflict to a participant, and how?”

Would they answer with confidence?

The NDIS expects providers to have systems in place so workers can identify, disclose, and manage conflicts of interest, not just escalate them after the fact.

Best practice providers embed conflict of interest into:

• Induction programs, not just policies
• Scenario based training, using real examples
• Clear role boundaries and decision-making limits
• Ongoing refresher training, not one-off sessions
• Supervision discussions and performance reviews

This is particularly critical for roles such as support coordinators, plan managers, team leaders, and managers who influence referrals or service pathways. Without consistent training, organisations rely on good intentions rather than governed practice.

Perceived conflicts matter just as much

One of the most misunderstood aspects of conflict of interest is perception.

The NDIS recognises perceived conflicts as being just as important as actual conflicts. Even when a provider believes they are acting ethically, if it appears to a participant that a recommendation benefits the provider, trust can be eroded. 

This is where many complaints and Commission referrals begin.

Growing providers need to ask:

• Could this decision appear self-serving to a participant?
• Are we offering genuine choice and alternatives?
• Have we documented why this recommendation was made?
• Has the participant been informed clearly, not defensively?

Strong governance means being able to defend decisions not emotionally, but evidentially.

What strong conflict of interest practice actually looks like

High performing providers typically have:

• A living conflict of interest register, not a static document
• Clear escalation pathways staff understand and actually use
• Regular declarations from staff, managers, and board members
• Real examples discussed in team forums and training
• Audit-ready evidence showing how conflicts are identified and managed

Importantly, leadership sets the tone. When leaders model transparency, staff are far more likely to raise issues early rather than hide uncertainty. Conflict of interest management should feel protective, for participants and for staff.

A final question for growing providers

If the NDIS Commission reviewed your organisation tomorrow, could you confidently demonstrate that:

• Your staff understand conflict of interest in practice
• Your onboarding equips people to make ethical decisions
• Your organisation consistently puts participant interests first
• You have systems, not assumptions, managing risk

For many growing providers, this is the moment they realise compliance maturity has not kept pace with operational growth.

That is not a failure. It is a signal.

How Centro supports providers to lift governance maturity

At Centro, we work with growing providers who want confidence not just at audit time, but in everyday decision making.

Our quality and governance systems are designed to help organisations move from policy-based compliance to operational practice, embedding clear responsibilities, training evidence, and governance oversight that actually supports staff to do the right thing.

If you are scaling, adding services, or onboarding staff rapidly, now is the time to ensure your conflict of interest framework grows with you.

Because compliance should never rely on best intentions alone.