8 audiology australia
SUBMISSION:
30 SEPTEMBER 2026
Audiology Australia welcomes the opportunity to respond to the NDIS Access Changes Consultation. Audiology Australia is the peak professional body for the health profession of audiology, representing over 3,800 audiologists across Australia and 95% of all practicing audiologists in the country. Audiologists are Masters-qualified hearing health practitioners who support Australians across their lifespan to preserve, manage, and improve their hearing, balance, and auditory processing ability. These domains are foundational to communication, learning, behaviour, and social participation. Audiologists provide a range of NDIS-funded hearing services across the lifespan, supporting timely intervention and ongoing management of ear and hearing conditions.
GUIDING PRINCIPLES
1. DO THE DRAFT GUIDING PRINCIPLES PROVIDE THE RIGHT FOUNDATION FOR A FUTURE NDIS ACCESS PROCESS?
Audiology Australia is mostly in support of the proposed guiding principles as they appropriately emphasise human rights, person- and disability-centred practice, evidence-based decision-making, accessibility, equity, and continuous improvement. However, while the guiding principles provide the right foundation and sound reasonable at face value, they are too high-level, too vague, and fail to address several major risks for people with disabilities.
The principle of ‘evidence-based and consistent’ requires further refinement and could be strengthened by explicitly recognising the importance of disability-specific expertise in both the development and application of the access process. While consistency is an important objective, it should not be interpreted as standardisation at the expense of disability-specific approaches. Different disability cohorts experience different functional impacts, face different barriers to accessing supports, and may require different forms of evidence. A highly standardised approach risks creating inequitable outcomes, particularly for cohorts whose disability is less visible, fluctuating, episodic, or more difficult to assess through generic functional assessment tools. Ensuring that disability-specific clinical and allied health expertise inform access decision-making will help achieve equitable, rather than merely uniform, outcomes.
From an audiology perspective, the proposed foundation risks creating a system that appears fair and evidence-based but could systematically under-recognise hearing-related disability. The central problem is that the consultation proposes moving away from diagnosis-based access and towards a standardised assessment of functional capacity. While this is presented as a fairness measure, hearing loss is one of the clearest examples of a disability where functional impact is often invisible, context-dependent, and poorly captured by generic assessments.
For many people with hearing loss, disability is not obvious in a clinical interview or a single assessment appointment. A person may appear highly functional because they have spent years developing compensatory strategies such as lip-reading, avoiding challenging environments, withdrawing from social situations, relying on family members to communicate on their behalf, or accepting reduced employment opportunities. These adaptations can mask the true impact of disability. A functional assessment process that does not specifically account for communication disability risks concluding that a person is coping well when they have in fact structured their entire life around an impairment.
Audiologists routinely assess hearing function through a combination of audiometric measures, speech perception, communication outcomes, hearing technology benefit, and patient-reported participation restrictions. If the NDIS develops a generic functional assessment tool and gives it greater weight than specialist audiological evidence, decision-making may become more consistent but less accurate. A consistent system that consistently underestimates hearing disability is not an improvement.
2. SHOULD ANY PRINCIPLES BE ADDED, REMOVED OR CHANGED?
Communication accessibility
The access process should be accessible to people with communication disabilities, including people who are deaf, hard of hearing, DeafBlind, use Auslan, or experience other communication barriers. Communication access should be considered throughout application, assessment and review processes.
Evidence-based and consistent
This principle should be expanded to explicitly include disability-specific expertise, recognising that functional impacts, barriers to support access, and evidentiary requirements vary across disability cohorts.
ACCESS DECISION-MAKING PROCESS DESIGN
3. WHAT DO WE NEED TO CONSIDER WHEN DESIGNING AN ACCESS DECISION-MAKING PROCESS THAT IS FAIR, CONSISTENT, TRANSPARENT, DISABILITY-INFORMED AND EVIDENCE-BASED?
A fair and evidence-based access process must do more than apply a standardised assessment framework. It must accurately capture the lived experience of disability, recognise the limitations of existing support systems, and ensure that people are not excluded from the NDIS on the assumption that alternative supports are available when in many cases, they may not be. The proposed reforms place significant emphasis on determining whether the NDIS is the most appropriate support system. Therefore, the adequacy and availability of alternative supports must be a central consideration in any future access process.
It is also proposed that the boundaries between the NDIS and other services systems, such as Foundational Supports and Thriving Kids, be strengthened. However, many of these systems are not yet fully established. It remains unclear how applicants who are found ineligible for the NDIS will access equivalent supports during this transition period or in geographical areas where services are unavailable. Individuals should not be excluded from the NDIS based on future policy intentions rather than the supports that currently exist in practice.
It is also important to consider the unintended gaps that may arise in hearing-related funding pathways. For example, there are limited publicly funded pathways for auditory processing disorder (APD) assessment or auditory training for individuals outside the NDIS, and access varies considerably across jurisdictions and service settings. Applicants with APD who are found ineligible for the NDIS may therefore be left without access to essential intervention despite ongoing functional impairment. Without appropriate intervention, auditory processing difficulties can persist into adulthood and
may continue to interfere with communication, social and emotional wellbeing, education, and employment.
A major funding stream for audiology is the Hearing Services Program (HSP) which provides valuable support for eligible Australians, including access to fully or partially subsidised hearing devices, the latter of which often includes significant out-of-pocket contributions. For many Australians receiving funding from both the HSP and the NDIS, fully subsidised hearing devices are not adequate to achieve listening, communication and functional goals, particularly if the participant is engaged in the workforce or other social and community participation activities. This can result in a significant financial burden to the participant, which is not managed by any other funding streams.
The existence of the HSP should not be interpreted as evidence that all hearing-related support needs are met. Access to hearing aids does not eliminate communication disability, and many supports that enable participation in education, employment, and community life are not funded by this pathway. Therefore, it is imperative that before determining that an applicant’s needs can be met elsewhere, decision-makers should be required to identify an actual, available, and funded alternative support pathway.
In order to make this process fair, consistent and disability-informed, it cannot rely solely on generic functional assessments, especially those without disability-specific evidence or expertise. Hearing loss, auditory processing disorder and vestibular conditions present unique challenges, where an applicant may function well in a clinical assessment environment yet experience substantial functional impact in communication in complex listening environments, listening effort and fatigue, or barriers in education, employment, healthcare settings and community environments. Assessment should therefore consider real-world participation rather than relying solely on performance in controlled settings.
The access process should be supported by an appropriately skilled assessment workforce. Assessors should have expertise in understanding disability-specific functional impacts, communication needs, cultural considerations, and cognitive challenges. While some straightforward cases may be suitable for streamlined assessment pathways, the default approach for more complex access decisions should involve appropriately qualified allied health or medical professionals.
The process should also recognise and build upon the existing role of treating health professionals. Many people seeking access already engage with audiologists, speech
pathologists, psychologists, occupational therapists, physiotherapists and medical specialists. Existing assessments and reports should be accepted wherever possible, with appropriate consent arrangements to allow information sharing. This would reduce duplication, lower costs and burden, and improve accuracy.
Access processes should be aligned with assessment and referral processes used by foundational and mainstream services. Where a person is found ineligible for the NDIS but demonstrates support needs, existing evidence should facilitate streamlined entry into appropriate alternative supports, such as Thriving Kids or other foundational supports. Similarly, access assessments should be designed to minimise duplication with subsequent NDIS support needs assessments and planning processes.
4. HOW COULD THE ACCESS DECISION-MAKING PROCESS, INCLUDING REFERRAL PATHWAYS, BE DESIGNED TO REDUCE ADMINISTRATIVE BURDEN AND MAKE IT EASIER AND MORE EQUITABLE FOR PEOPLE WITH DISABILITY, THEIR FAMILIES AND CARERS TO UNDERSTAND WHAT INFORMATION IS NEEDED AND HOW DECISIONS ARE MADE? HOW COULD THIS SUPPORT A PROPORTIONATE APPROACH TO MINIMISE THE ASSESSMENT BURDEN ON PERSONS WHO ARE CLEARLY ELIGIBLE WITH VERY SIGNIFICANT FUNCTIONAL IMPAIRMENT?
A simpler and more equitable access process should focus on reducing duplication, recognising existing clinical evidence, and adopting proportionate assessment requirements based on the nature and severity of the disability. While the proposed reforms aim to improve consistency and transparency, there is a risk that introducing new functional capacity assessments could inadvertently increase the burden on applicants if they are required to undergo multiple assessments despite already having extensive, high-quality clinical evidence. Access assessments should wherever possible align with support needs assessments, planning processes and referral pathways into other support systems, where applicable. Applicants should not be required to repeatedly provide the same information to multiple systems when existing assessments could be shared and reused.
A key principle should be that applicants only provide the evidence necessary to establish eligibility and should not be required to repeatedly demonstrate impairments that are already well documented and unlikely to change. The process should recognise
and utilise existing assessments wherever possible, rather than creating additional layers of assessment that increase cost, complexity and delays for individuals, families and clinicians.
For hearing-related disabilities, comprehensive audiological functional assessments and communication reports should be accepted as primary evidence of both impairment and functional impact. Audiologists are professionals responsible for assessing hearing function, communication outcomes and the effectiveness of hearing technologies and are therefore well placed to provide evidence for access assessments. This evidence often provides detailed information about hearing impairment, communication limitations, participation restrictions, and likely long-term support needs. Requiring applicants to undergo further generic assessments when this evidence already exists would add unnecessary burden without improving decision-making quality.
Some cohorts may not respond well to a standardised assessment conducted by a person with whom they have no therapeutic relationship. This is particularly relevant for people with communication disabilities, psychosocial disability, cognitive disabilities, and complex support needs. In these cases, specialist assessment pathways that draw heavily on existing treating professionals may produce more accurate and equitable outcomes.
The access process should also include streamlined pathways and varying levels of assessment for individuals whose conditions are clearly permanent and associated with significant lifelong functional impairment. This could operate similarly to current approaches where certain conditions are well recognised as meeting permanence requirements and are associated with substantial disability. Examples may include bilateral sensorineural hearing loss above 65dB in the better ear, or deafblindness. For these cohorts, there is extensive clinical evidence demonstrating that the impairment is lifelong and that significant functional impacts persist despite access to treatment and assistive technologies. Requiring extensive additional functional assessments in such circumstances would subject applicants to unnecessary stress, delay, and expense.
5. WHAT SHOULD BE CONSIDERED TO ENSURE THE ACCESS DECISION-MAKING PROCESS, AS WELL AS REFERRAL PATHWAYS, WORKS WELL FOR ALL DISABILITY COHORTS INCLUDING PEOPLE WITH COMMUNICATION, CULTURAL, COGNITIVE, DEGENERATIVE, FLUCTUATING, EPISODIC OR COMPLEX SUPPORT NEEDS?
The success of any future access process will depend on whether it can accurately assess disabilities that are not immediately visible, are highly context-dependent, or whose impacts fluctuate over time. Hearing loss, APD, vestibular disorders and many communication disabilities do not fit neatly within standardised assessment models. A process that prioritises administrative consistency over disability-specific understanding risks creating inequitable outcomes for many cohorts, particularly those with communication, cognitive, or complex support needs.
Assessment quality will depend heavily on workforce capability. Assessors should possess specialised skills relevant to the disability cohort they are assessing, including expertise in communication, cultural safety, cognitive disability, psychosocial disability, and complex support needs. For complex cases, assessments should be undertaken or overseen by appropriately qualified allied health or medical professionals rather than relying solely on generalist assessors.
A significant risk within a functional assessment model is that communication disability is underestimated as an individual may appear capable of participating in an assessment interview. For many people with hearing loss, communication difficulties are highly dependent on environmental conditions. A person may communicate effectively in a quiet one-on-one assessment, but experience substantial barriers in classrooms, workplaces, healthcare settings, public spaces, and social environments. Similarly, many individuals with hearing loss may have developed compensatory strategies such as lip-reading, reliance on communication partners, or avoidance of challenging listening situations, which can mask the true impact of their disability. Therefore, assessment processes should recognise compensatory strategies as evidence of disability impact, rather than evidence of negligible impairment.
Assessment processes should also provide accessible communication supports throughout the application process, allow information to be provided in multiple formats, consider functional impact across real-world environments, and ensure assessors understand the distinction between communication capacity in a controlled environment and communication participation in everyday life.
EVIDENCE REQUIREMENTS
6. WHAT FACTORS AND EVIDENCE SHOULD BE CONSIDERED WHEN DETERMINING WHETHER AN IMPAIRMENT IS PERMANENT OR LIKELY PERMANENT, INCLUDING WHETHER APPROPRIATE TREATMENT IS LIKELY TO IMPROVE THE FUNCTIONAL IMPACT OF AN IMPAIRMENT?
Permanence should be determined by the clinical nature, prognosis, and expected trajectory of a condition, together with the individual’s functioning following appropriate intervention. The existence of treatment should not be used as evidence that an impairment is not permanent, as treatment may reduce the impact of a disability without eliminating the disability itself.
Evidence of permanence in hearing and balance-related disabilities should include comprehensive audiological and functional assessments, specialist medical and audiologist evidence where relevant, the known natural history of the condition, and longitudinal evidence demonstrating stability or progression of the impairment.
When considering treatment, decision-makers should assess whether an intervention is clinically appropriate, evidence-based, reasonably available and accessible, and likely to result in meaningful and sustained functional improvement. For hearing-related disabilities, the focus should be on functional impact, rather than the availability of treatment itself. Hearing aids, cochlear implants and rehabilitation may improve outcomes, but they do not restore typical hearing and often do not eliminate communication difficulties, participation restrictions, listening fatigue, or the need for ongoing supports.
Assessments should consider a range of functional evidence, including speech discrimination testing (in noise or in quiet), communication outcomes in real-world listening environments, participation in education, employment and community activities, and patient-reported impacts on daily life.
An excessive focus on permanence risks creating inequitable outcomes for people who experience substantial functional impairment, but whose condition may theoretically improve in the future. Eligibility decisions should focus primarily on current and expected functional impact, rather than requiring certainty about a person’s long-term
prognosis. Importantly, it should be taken into consideration that hearing disabilities may be progressive, meaning support needs and functional impacts can change over time. To ensure fair and evidence-based decision-making, permanence assessments should therefore be based on the likely long-term impact of the condition, not simply on the availability of treatment options. Where permanence has already been clearly established through specialist evidence, applicants should not be required to repeatedly demonstrate that their condition remains permanent.