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If you've ever had an invoice for specialist positive behaviour support knocked back by your plan manager, I want you to know something first: it's not personal.
It's the law.
We recently ran an internal quality audit on how the "Other Professional" line item was being used across our participants' plans. It showed a pattern: specialist behaviour support practitioners billing as “Other Professional” when there was no behaviour support funding in the plan at all, or when the behaviour support funding had run out however the practitioner was still working with the family and wanted to keep getting paid.
So let's break this down properly, in plain English, so you never have to hear "we can't pay that" without understanding exactly why.
By the end of this, you'll know:
- What specialist positive behaviour support actually is under the NDIS
- Why your Improved Daily Living funding can't be used to pay for it, even when your funding is "flexible"
- What the legislation actually says (and where to check it yourself)
- Why this rule exists, and how it protects you, not just us
- What to actually do if your child needs to work with a positive behaviour support practitioner and it's not in their plan
- What to say if a provider tells you it's fine to bill it another way
What is specialist positive behaviour support?
Specialist positive behaviour support, sometimes shortened to SPBS or just "behaviour support," is its own category of NDIS funding. Practitioners MUST be registered via the NDIS Quality and Safeguarding Commission. SPBS practitioners support participants and families specifically with what it known as “behaviours of concern”. Practitioners do things like:
- Functional behaviour assessments
- Develop and help implement behaviour support plans
- Training and monitoring staff or informal supports (like you) in how to use the plan and strategies on how to help participants through those tricky behaviours
- In some cases - assist with the safe implementation (with the goal of eventual reduction) or restrictive practices. A young person does not need to have restrictive practices in order work with a SPBS practitioner.
For the NDIS to fund any of this, specialist positive behaviour support has to be stated in your plan. In a PACE plan, it will appear as Capacity Building - Behaviour Support. In an older CRM plan, it will be called Capacity Building - Improved Relationships. Different label, same support, and either way it's a separate funding category to Improved Daily Living.
Why can't I use my Improved Daily Living funding?
I don't blame anyone for asking this. Improved Daily Living funding, if written a certain way, can be genuinely flexible in terms of which allied health professionals you engage.
The issue starts when a specialist behaviour support practitioner is still providing specialist positive behaviour support, but dressing it up as a therapeutic intervention and billing it through Other Professional.
Here's the thing to remember: the Agency is watching that Other Professional line closely, because in their eyes, there are very few professions left that genuinely don't have their own dedicated line item under the Pricing Schedule.
Here's how I think of it. You have an Improved Daily Living gift card that works at a set list of shops. You can spend it however you like, across whichever of those shops you choose. An OT one week, a speech pathologist the next, a psychologist working on emotional regulation the week after that. All fine. All within the list.
Behaviour support isn't on that list. It's a different item, with a different test attached to it, and no amount of flexibility in how Improved Daily Living is worded changes that. The flexibility in Improved Daily Living operates within what it actually covers. It doesn't reach across and unlock a completely separate category of support that has its own rules.
So it's not that your funding isn't flexible enough. It's that specialist positive behaviour support is a stated support within the legislation which means it is something Improved Daily Living was never built to buy.
Here's where it gets murky. Some providers get around the rule by changing what's on the invoice, not what they're actually doing. They'll bill it as "Other Professional," as though they're delivering general therapeutic support, instead of specialist positive behaviour support. On its own, that invoice looks technically fine. But if the person delivering it is still doing specialist positive behaviour support work, a functional behaviour assessment, a behaviour support plan, working in their capacity as a specialist positive behaviour support practitioner, then that's what it is. This is where the real risk sits: not with the provider who wrote the invoice, but with the family whose plan gets audited later.
What does the legislation actually say?
I know a lot of families don't want to wade through legislation, and that's exactly why plan managers exist. But because this one gets pushed back on so often and this will help self managers as well.
The relevant law is the National Disability Insurance Scheme (Getting the NDIS Back on Track No. 1) (NDIS Supports) Transitional Rules 2024, which has been in force since October 2024. Schedule 1 of the Transitional Rules sets out every category of NDIS support.
Two items matter here:
Item 10, specialist positive behaviour support. This is defined as supports provided by professionals with specialist skills in positive behaviour support, including assessing, developing and delivering a behaviour support plan, and training staff or informal supports in using it. Column 3 of the Rules is the important bit: it says this is only an NDIS support for "participants who have the support stated in their plan and prospective participants who are likely to have this support stated in their plan." Stated. Not flexible. Stated.
Item 34, therapeutic supports. This covers evidence-based therapy to help you improve or maintain functional capacity, in things like communication, personal care, mobility, interpersonal interactions and psychosocial functioning. The participant test for this one is completely different: it's available to "participants or prospective participants generally." No stated requirement at all.
Therapeutic supports, Item 34, is what sits behind your Improved Daily Living funding, including the Other Professional line. It's available generally. Specialist behaviour support, Item 10, is a different item entirely, with a stricter gate that Item 34 simply doesn't have.
The confusing part is that the therapy techniques themselves can genuinely overlap. A psychologist doing legitimate emotional regulation work under Improved Daily Living will touch on behaviour. That, on its own, isn't specialist positive behaviour support.
What tips something into Item 10 and specialist positive behaviour support territory is the object and the pathway, not the presence of behavioural concerns. If a provider is doing a functional behaviour assessment to inform a behaviour support plan, or working in their capacity as a specialist behaviour support practitioner to reduce behaviours of concern, that's Item 10 work. It has to be stated, and it can't be relabelled as "therapeutic support" and billed through Other Professional to get around that.
Why this matters, when it feels like red tape
I know how this lands when you're on the receiving end of it. You've found a provider who's helping. The invoice comes in. Your plan manager says no. It feels like the system is getting in the way of something that's actually working.
Here's the reframe I'd ask you to sit with: this rule is protecting you, not obstructing you.
If a plan manager pays for something that isn't actually funded under your plan, the NDIA can find that out later, in a review or an audit, and ask for that money back.
Registration with the NDIS Quality and Safeguards Commission doesn't change this either. Being a registered specialist behaviour support provider means a provider is allowed to deliver behaviour support once it's funded.
This is also on the practitioner, not just the system. The good, reputable specialist behaviour support clinics, and we work with plenty of them, know this rule inside out. They won't bill through Other Professional, because they know it isn't correct, and they'll tell you that themselves rather than let you find out the hard way. If a provider is pushing back on this, or telling you a workaround is fine, that's worth paying attention to.
So when a plan manager says no here, and does it properly, they're standing between you and a debt you never agreed to. That's the whole point of good plan management. Not making your life harder. Keeping you out of trouble you didn't see coming.
What to actually do if your child needs specialist positive behaviour support
If behaviour support is genuinely needed and it isn't currently stated in your plan, here's the actual pathway:
- Get the evidence together first. Your existing team can write evidence outlining why specialist behaviour support is needed.
- Request a plan change. You can raise this at your next scheduled plan reassessment, or request an earlier plan change if the need is current and pressing.
What if a provider tells you it's fine to bill as Other Professional?
This one comes up a lot, so let's go through the common lines you might hear, and why they don't hold up.
"We're registered with the NDIS Commission as a specialist behaviour support provider, so we can deliver it." True, and irrelevant to the funding question. Registration governs whether a provider is allowed to deliver behaviour support once it's funded. It does nothing to put the funding in your plan.
"There's no behaviour support funding, but Improved Daily Living is flexible, so we'll just draw it from there." Improved Daily Living's flexibility operates within what it actually covers. It can't reach across and fund a completely different item that has its own stated-support requirement.
"There are no restrictive practices involved, this is just behaviour therapy, we'll claim it under Other Professional." The absence of restrictive practices doesn't turn specialist positive behaviour support into a general therapeutic support. It's still Item 10 work, and Item 10 still needs to be stated, restrictive practices or not.
"We're doing a functional behaviour assessment, funded from Improved Daily Living." A functional behaviour assessment that informs a behaviour support plan can only be completed by a Commission-registered behaviour support practitioner.
"A support coordinator or LAC told us this was fine." None of these people are delegates of the NDIA CEO, and advice from them doesn't change what your plan actually funds.
FAQs
Can I use Improved Daily Living funding for specialist positive behaviour support? No. Improved Daily Living covers general therapeutic supports, like OT, psychology, speech pathology and physio. Specialist positive behaviour support is a separate funding category under the NDIS Transitional Rules, and it has to be specifically stated in your plan before it can be paid for, regardless of how flexible your other funding is.
How do I get behaviour support added to my NDIS plan? Get evidence from an existing support, such as an OT, psychologist or counsellor, explaining why specialist behaviour support is needed. Use that evidence to request the support be added at your next reassessment, or through an earlier plan change if the need is urgent.
What is the difference between therapeutic supports and specialist positive behaviour support? Therapeutic supports (Item 34 of the Transitional Rules) cover general evidence-based therapy for functional capacity, including psychosocial functioning, and are available to all participants generally. Specialist behaviour support (Item 10) is a separate, more tightly gated category that has to be specifically stated in your plan before it's funded.
Why won't my plan manager pay for behaviour support if I have plenty of funding left in another budget? Because having money left in a budget doesn't mean it's the right budget. Plan managers have to check whether a stated support is actually funded under your plan before they check whether there's money available. If behaviour support isn't stated, it fails that first check regardless of your other balances.
I’ve gone for a plan reassessment and the Agency still wont fund it. You can work with an allied health professional such as an OT or psychologist who will be able to help you determine the most appropriate next steps.
Where to from here
If you're navigating this right now, and it feels like everyone around you is speaking a different language, you're not imagining it. This is genuinely one of the more confusing corners of the NDIS, and it catches out experienced families as easily as new ones.
If you'd like a hand working out whether specialist positive behaviour support should is stated in your plan, or you just want a plan manager who'll explain the "no" instead of just saying it, [book a free discovery call with us here].
I've also put together a short factsheet on this exact topic, which you're welcome to keep on hand or forward to a provider if this ever comes up: [download the Behaviour Support and Your NDIS Plan factsheet].
NDIS changes are coming thick and fast right now. If you'd rather hear about them from someone who's already read the fine print, we've got you.
No jargon. No panic. Just the stuff that actually matters for your family.
