Submission 1 — Assistive Technology Suppliers Australia — NDIS First Nations Market and Sector Discussion Paper | External submission

The provision of complex assistive technology in remote First Nations communities
Response to the NDIS First Nations Market and Sector Discussion Paper
December 2025
Assistive Technology Suppliers Australia
Suite 302, Level 3 Lawson Place
165 -167 Phillip St Sydney NSW 2000
02 8006 7357
www.atsa.org.au
Drafted by:
Karen Larsen-Truong
Policy Officer
E: karen.truong@atsa.org.au
Approved by:
Serena Ovens
Chief Executive Officer
E: serena.ovens@atsa.org.au

Contents
Contents ……………………………………………………………………………………………………… 2
About Assistive Technology Suppliers Australia (ATSA) …………………………………….. 3
Summary of Recommendations ……………………………………………………………………… 4
Introduction …………………………………………………………………………………………………. 5
Supplying complex AT to remote First Nations communities ………………………………. 5
Who is involved …………………………………………………………………………………………. 5
The challenges of a thin market for AT provision ……………………………………………. 6
Regular servicing and repairs: difficult or impossible ………………………………………. 6
Relationship building is essential yet fragile …………………………………………………… 6
Alternative funding models have not been sustained ………………………………………. 6
Responses to Consultation Questions …………………………………………………………….. 7\

What NDIS policy and process changes would help providers deliver sustainable and culturally safe support to First Nations participants? ………………… 7\
How can NDIS pricing better reflect the context and nature of NDIS supports for First Nations participants?…………………………………………………………………………… 7\
What are the best solutions to thin markets in regional and remote areas for First Nations participants?…………………………………………………………………………… 8
Closing ……………………………………………………………………………………………………… 10
References ………………………………………………………………………………………………… 11
2

About Assistive Technology Suppliers Australia (ATSA)

Assistive Technology Suppliers Australia (ATSA) is Australia’s national peak body representing the needs of assistive technology suppliers, distributers, manufacturers and technicians. We also work closely with the allied health sector, with allied health professionals being eligible for affiliate membership.

ATSA require our members to adhere to a comprehensive Code of Practice on the provision, sales and servicing of assistive technology (AT).

We are a registered not-for-profit organisation with charitable status, ensuring we advocate for the rights of people with disability and older persons to access the most appropriate assistive technology to provide for their ongoing independence and individual needs.

Our Purpose is to support the assistive technology industry to enhance the lives of Australians with disability by:

Ensuring the provision of quality equipment
Upholding ethical business practices
Conducting research
Promoting education
Cultivating partnerships
Advocating for positive change with government and other stakeholders

We are also a member of the Australian Ethical Health Alliance.

Summary of Recommendations

Recommendation 1: Recognise the higher costs of AT provision in remote communities

The NDIS should recognise that higher service delivery costs are inherent to remote AT provision and ensure funding meets these realities. AT supplied in remote areas often requires enhanced durability and specialised features suitable for harsh terrain. Freight and travel costs are substantial and unavoidable. Pricing and funding decisions should transparently incorporate these factors rather than absorbing them into equipment prices, which obscures true cost drivers and complicates planning.

Recommendation 2: Improve efficiency through flexible funding and streamlined approvals

Flexibility is essential to efficiency in remote service delivery. Providers must be able to:

claim for repairs and servicing undertaken during community visits
carry out urgent safety-related work without prior approval
provide interim low-cost equipment where appropriate
receive rapid approvals to avoid repeat travel and prolonged equipment downtime

These measures ensure safety, reduce costs and better align with the realities of remote community dynamics.

Recommendation 3: Fund ‘full service package’ visits to remote communities

A bundled model should support multidisciplinary visits by occupational therapists, AT suppliers and technicians. Funding should cover travel time, vehicle costs, freight of equipment and spare parts, and unforeseen repairs. This approach increases efficiency, reduces administrative burden and ensures participants receive comprehensive support during limited service windows.

Recommendation 4: Adopt community-specific approaches rather than one-size-fits-all policies and processes

Remote First Nations communities vary significantly in culture, geography, mobility and service infrastructure. Policy settings must enable bespoke approaches that respond to local conditions. This includes supporting trusted community connectors, ensuring continuity of relationships and avoiding rigid block funding arrangements that unintentionally exclude experienced providers or limit culturally appropriate engagement.

Recommendation 5: Invest in training and building a local AT maintenance workforce

A ‘light-touch’ version of ATSA’s AT technician training for community members would enable basic troubleshooting, minor repairs and information gathering. Tools and common spare parts should be stored locally. Remote troubleshooting via video calls should be supported.

Introduction

Safe, functional and culturally appropriate assistive technology (AT) is essential for many First Nations NDIS participants, particularly those living in remote communities. ATSA members deliver a wide range of AT across Australia, including in regional, rural and remote areas. Providing AT and related supports (such as regular servicing, repairs, set up and adjustments) in these contexts requires approaches that differ substantially from mainstream metropolitan service models. Without such adaptations, First Nations participants experience significant barriers to equitable AT access.

This submission focuses on the complexities, costs and systemic challenges involved in supplying AT to remote First Nations communities. In particular, it responds to the following questions posed in the NDIS First Nations market and sector discussion paper:

What NDIS policy and process changes would help providers deliver sustainable and culturally safe supports to First Nations participants?
How can NDIS pricing better reflect the realities of providing supports in First Nations communities?
What solutions are needed to address thin markets in regional and remote areas?

This paper draws on consultation with AT suppliers, manufacturers and occupational therapists experienced in remote service delivery in First Nations communities. This submission and its recommendations have been endorsed by Occupational Therapy Australia (see attached letter of endorsement).

Supplying complex AT to remote First Nations communities

Provision of intermediate to complex assistive technology (AT) in remote First Nations communities involves a level of complexity not encountered in urban contexts. Ensuring a safe and appropriate match between the user, the environment and the equipment requires careful, context-sensitive assessment. The World Health Organization’s four-step model for AT provision (assessment, fitting, training and follow up) highlights the need for a holistic, iterative approach, and each of these stages becomes more challenging where geography, climate and community structures shape service delivery1.

Who is involved

Effective AT provision in remote communities depends on multidisciplinary collaboration. Occupational therapists with advanced technical AT expertise, AT suppliers, equipment manufacturers and trusted local community connectors all play critical roles. Community connectors are often central to successful engagement, providing cultural brokerage, facilitating appointments, assisting with communication and supporting onsite problem solving. Their involvement is essential for building trust, enabling continuity and ensuring that AT provision aligns with community rhythms and cultural expectations.

The challenges of a thin market for AT provision

Remote First Nations communities constitute extremely thin markets for intermediate to complex AT. At any given time, there may be only one or two NDIS participants requiring advanced equipment, which significantly limits economies of scale. The small number of participants does not diminish the complexity of the need, yet the cost of delivering services increases substantially.

Higher costs arise from multiple sources, including long-distance travel, freight and the need for equipment robust enough to withstand harsh terrain and climatic conditions. While funding participants to travel to urban centres for assessment may appear cost-effective, this approach frequently proves more expensive and far less appropriate. Assessments conducted away from the home environment risk prescribing equipment that is ill suited to local housing, terrain and community life. Community-based assessments remain the most effective and ethical approach, despite higher upfront provider costs.

Regular servicing and repairs: difficult or impossible

Access to timely servicing and repairs is a significant challenge. Travelling to remote communities often requires a four-wheel drive and may involve several hours of driving on unsealed roads. Safety protocols typically require two staff to travel together, compounding costs. Seasonal factors such as flooding or road closures can make communities inaccessible for extended periods.

In practice, many AT items remain unserviced for prolonged periods, increasing safety risks and reducing the lifespan of equipment. The inability to conduct routine maintenance further contributes to the higher cost of AT provision in remote communities, as equipment failures may necessitate full replacement rather than repair.

Relationship building is essential yet fragile

Relationship building and local community connections are foundational to culturally safe and effective AT provision in remote First Nations communities. However, these relationships are often fragile due to workforce turnover across suppliers, therapists and support coordinators. Many providers are new not only to the NDIS but also to the cultural and logistical realities of specific communities. At the same time, First Nations communities can be highly mobile, which disrupts continuity of care and informal support networks.

Community dynamics are fluid, with visits sometimes cancelled at short notice due to community business and sometimes unrest. These factors make itinerary planning challenging and create financial uncertainty for providers attempting to deliver consistent, reliable services.

Alternative funding models have not been sustained

While remote loadings are conceptually helpful, their application remains inconsistent, and freight charges are often absorbed into the cost of equipment. This blurs the distinction between the price of the device and the logistical expense of

delivering it, contributing to apparent price inflation and misunderstandings about true cost drivers.

Attempts to trial alternative approaches have had mixed success. The NDIA-funded ‘Fix It on Community’ program, delivered through Keep Moving, demonstrated an effective method for building local capacity in basic AT maintenance, repairs, set up and general troubleshooting. Despite positive outcomes, the program has not been scaled or sustained. Similarly, the feasibility study undertaken by AT Lab and the MJD Foundation on Groote Eylandt concluded that the demand for complex AT was too low to support a standalone localised service model2. This reflects a broader structural issue: while needs are significant, the volume of demand does not align with market-based service expectations.

These experiences illustrate the limitations of relying solely on market mechanisms or short-term pilots. Sustained, place-based investment and flexible funding arrangements are required to overcome the structural barriers inherent in remote AT provision.

Responses to Consultation Questions

1. What NDIS policy and process changes would help providers deliver sustainable and culturally safe support to First Nations participants?

More flexible and culturally responsive policies and processes are critical to support safe and effective AT provision in remote First Nations communities. Providers require the ability to adapt service delivery to local contexts, community dynamics and the logistical realities of remote work. This includes flexible funding arrangements that allow assessment, supply, repair and follow up to occur opportunistically when participants, equipment and clinicians are all available at the same time. Rigid pre-approval requirements for repairs or servicing are often unworkable in remote contexts, where urgent work must be completed onsite and delays pose significant safety risks.

The NDIS should also formally recognise and sustainably fund the role of local community connectors. These individuals are essential for culturally safe engagement, effective communication, appointment coordination and the navigation of community protocols. Their work is currently undervalued and inconsistently supported, despite being fundamental to establishing trust and ensuring continuity in communities where visiting providers may be new or unfamiliar.

2. How can NDIS pricing better reflect the context and nature of NDIS supports for First Nations participants?

NDIS pricing models must more accurately reflect the genuine costs of delivering AT in remote and very remote regions. Much of the equipment used in these environments must be more durable and versatile to withstand harsh terrain and climatic conditions, which increases base costs. Freight charges are significant and often unpredictable, particularly when transport depends on seasonal access. Travel

time is unavoidable and frequently substantial, and workforce safety requirements generally necessitate two-person travel.

A bundled pricing approach for remote AT visits would provide a more realistic framework for providers and improve the sustainability of service delivery. Such a model should encompass travel time, vehicle wear and running costs, freight for equipment and spare parts, and provision for unplanned work such as onsite repairs that cannot be quoted in advance. A bundled approach would also reduce administrative burden and mitigate the inefficiencies created by multiple claim types, fragmented approvals and short service windows.

Therefore, ATSA makes the following recommendation:

Recommendation 1: Recognise the higher costs of AT provision in remote communities

3. What are the best solutions to thin markets in regional and remote areas for First Nations participants?

Thin markets in remote First Nations communities require structural solutions that extend beyond conventional market-driven approaches. Demand for complex AT is small in absolute numbers, yet the complexity of need is high and the cost of service delivery is significant. Effective solutions must therefore strengthen coordination, create efficiencies and build local capability.

Flexible funding arrangements

Flexible funding is central to overcoming the constraints of thin markets. Providers need the capacity to undertake opportunistic servicing, repairs and assessments when conditions allow. This includes the ability to claim for work completed during community visits, even when pre-approval is impractical. Flexibility reduces the need for repeated travel, ensures participants are not left with unsafe or unusable equipment and makes better use of scarce clinical resources.

Therefore, ATSA recommends:

Recommendation 2: Improve efficiency through flexible funding and streamlined approvals

Flexibility is essential in remote service delivery. Providers must be able to:

claim for repairs and servicing undertaken during community visits
carry out urgent safety-related work without prior approval
provide interim low-cost equipment where appropriate

receive rapid approvals to avoid repeat travel and prolonged equipment downtime.

These measures ensure safety, reduce costs and better align with the realities of remote community dynamics.

Improving efficiency through multidisciplinary visits and coordinated service delivery

Coordinated visits involving occupational therapists, AT suppliers and technicians can significantly increase efficiency and reduce overall costs. This model allows multiple participants to be seen in a single trip and enables collaborative problem solving onsite. Programs such as the Fix It on Community initiative demonstrated the value of pairing therapists with technicians to complete repairs, set ups and basic maintenance efficiently. However, such initiatives require consistent funding to be sustained and scaled. ATSA makes the following recommendation:

Recommendation 3: Fund “full service package” visits to remote communities

Recognition of community-specific dynamics and the need for bespoke approaches

Remote First Nations communities vary widely in geography, culture, mobility patterns and service infrastructure. A one-size-fits-all model is unlikely to succeed. Providers must be supported to adapt their approach for each community, including working through local organisations, engaging cultural leaders, and planning for cancellations, mobility and seasonal access challenges. Solutions must prioritise flexibility, cultural safety and deep community engagement.

Therefore, ATSA recommends:

Recommendation 4: Adopt community-specific approaches rather than one-size-fits-all policies and processes

Investment in local AT maintenance, repair and set up capability

A strengthened approach to building local capability is vital in thin markets where specialist visits are infrequent. Developing a community-based AT maintenance workforce can significantly reduce equipment downtime, improve safety and provide greater autonomy for participants.

ATSA proposes the development of a light AT technician training program tailored to remote First Nations communities. This program would draw on selected components of ATSA’s existing AT Technician Training and adapt them for delivery in remote contexts. Training would be provided in partnership with AT suppliers who can bring equipment, tools and technical expertise, ensuring the content is practical, hands on and aligned with industry standards.

Local organisations, including Indigenous-led councils, community-controlled health services and aged care centres, would play an essential role in hosting, supporting and embedding the training. Meaningful engagement with these organisations ensures cultural appropriateness, strengthens community ownership and aligns the training with local structures and priorities.

Given the transient nature of remote communities and turnover among local workers, the program would require ongoing funding and intermittent delivery. This approach enables new participants to be trained as they enter community roles and maintains capability even as staff move in and out of the region.

The curriculum would equip trainees with skills in servicing and maintaining equipment, performing minor repairs, adjusting and safely setting up devices, identifying early signs of equipment malfunction and using video support for troubleshooting with external technicians. Tools and commonly used spare parts should be stored locally to enable immediate response when issues arise.

Developing this workforce is a practical, culturally grounded and community-strengthening solution to thin markets. ATSA is eager to work with the NDIA to co-design the program, ensuring it aligns with broader agency objectives for remote service delivery and creates a sustainable foundation for AT provision in remote First Nations communities.

Recommendation 5: Invest in training and building a local AT maintenance workforce

Closing

Ensuring access to safe, culturally appropriate and durable assistive technology is essential to enabling independence and wellbeing for First Nations NDIS participants living in remote communities. The challenges outlined in this submission reflect long standing structural barriers that require flexible, place based and culturally informed reforms. ATSA welcomes continued collaboration with the NDIA to progress these reforms.

References

World Health Organization. (2018). WHO standards for wheelchair provision. Accessed 09/12/2025, available from: https://www.who.int/publications/i/item/9789240074521
MJD Foundation and AT Lab. (2023). Groote Eylandt Assistive Technology Feasibility Study. Accessed 09/12/2025, available from https://mjd.org.au/entries/mjdf-assistive-technology-feasibility-study-groote-eylandt/.