ATSA submission to the Department of Health, Disability and Ageing on the NDIS rules - Public consultation on new framework planning
March 2026
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
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 requires 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.
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Summary of Recommendations
Recommendation 1: Prior to implementation make exposure drafts, end-to-end workflows and guidance materials available for public consultation The NDIA should make exposure drafts of the rules, end-to-end workflow documentation and supporting guidance materials publicly available prior to implementation to ensure stakeholders have sufficient information to provide meaningful feedback on how the framework will operate in practice.
Recommendation 2: Integrate regular evaluation and feedback into roll-out of new framework planning The phased roll-out of New Framework Planning should include ongoing, regular and transparent evaluation. This should include structured opportunities for public consultation and stakeholder feedback and early testing in cases involving complex and interacting needs. To support this, public reporting on the impact of new framework planning on the following should be provided:
- planning and approval timeframes
- impacts on reviews and appeals
- administrative burden on participants and providers
- participant outcomes
- equity impacts for participants with complex needs and intersecting impairments
Recommendation 3: Strengthen assistive technology expertise in assessment and planning To ensure informed decision-making, the NDIA should ensure that:
- NDIA assessors and delegates receive comprehensive training in assistive technology and its role in supporting independence and participation
- ongoing professional development is available to assessors and delegate to maintain competency in AT-related decision-making
Recommendation 4: Co-design targeted assistive technology assessments with the AT sector before rollout Before implementation, the NDIA should work proactively with the assistive technology sector, including ATSA members, relevant allied health bodies and disability sector organisations, to refine targeted assessment pathways for AT and ensure they are fit for purpose. This work should focus on:
- defining what triggers a targeted AT assessment and when it is not required
- clarifying what evidence will be accepted, what is required versus optional, and who can provide it
- recognising appropriate existing reports and evidence to reduce duplication
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- establishing service standards and practical timeframes for AT-related decisions
- testing the assessment pathway using real-world AT scenarios, including thin markets and bespoke equipment
- ensure that New Framework Planning explicitly recognises that assistive technology outcomes depend on wrap-around supports, not only a budget for the item itself
Recommendation 5: Avoid over-reliance on a single “primary disability” New Framework Planning should not rely on participants nominating a single primary disability where multiple impairments interact. Instead, the process should focus on functional needs across contexts, including home, community, employment and transport environments. Assessment processes should explicitly consider how intersecting impairments interact and how this changes assistive technology requirements.
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Introduction
Assistive Technology Suppliers Australia (ATSA) welcomes the opportunity to provide feedback on the proposed rules supporting the National Disability Insurance Scheme (NDIS) New Framework Planning model.
Assistive technology plays a critical role in enabling many NDIS participants to live independently, participate in education and employment, and engage in community life. For participants who rely on assistive technology, timely access to appropriate equipment, together with the wrap-around supports required for its effective use, is essential to achieving the outcomes intended under the NDIS.
ATSA acknowledges the policy objectives underpinning the proposed shift to New Framework Planning, including improving national consistency, transparency and the long-term sustainability of the scheme. However, given the importance and complexity of assistive technology supports, it is critical that the new framework is designed and implemented in a way that supports timely, informed and flexible decision-making for participants who require AT.
This submission outlines several areas where further clarity, consultation and collaboration with the assistive technology sector will be important to ensure the framework operates effectively in practice. ATSA’s recommendations focus on improving transparency in planning processes, strengthening assistive technology expertise within the system, and ensuring that targeted assessment pathways for AT are practical, efficient and fit for purpose.
Ongoing delays in accessing assistive technology under the NDIS
Assistive technology (AT) is a critical support for many NDIS participants. However, ATSA members and other stakeholders continue to report substantial delays in the approval and provision of AT through the scheme. These delays arise from a range of factors including administrative processes, extended plan review timelines, disputes regarding eligibility and inconsistent interpretation of support categories.
These concerns are reflected in available performance data relating to the NDIS Participant Service Guarantees (PSGs). For example, PSG 14, which requires the NDIA to amend a participant’s plan within 28 days of receiving relevant information, was achieved in only 44 per cent of cases nationally in the first and second quarters of 2025–261,2.
Members report that delays in AT provision can have significant consequences for participants, including:
- increased risk of injury or deterioration in functional ability
- avoidable hospitalisation or secondary health complications
- delayed independence, community participation and employment outcomes
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- increased overall costs to the NDIS due to reliance on higher-intensity supports or informal care.
Implications of New Framework Planning for assistive technology
ATSA acknowledges the policy objectives underpinning the proposed shift to a Support Needs Assessment (SNA) model, including improving national consistency, equity of decision-making and the long-term sustainability of the NDIS. However, based on the information currently available, ATSA has several concerns about the potential implications of the proposed framework for participants who require assistive technology.
First, there is limited publicly available information regarding how the assessment and planning process will operate in practice, including the operational steps from initial assessment through to plan approval and implementation. In particular, it remains unclear how targeted assessments for assistive technology will be triggered, what evidence will be accepted, and how decisions will be made where complex AT needs are involved. Therefore, ATSA recommends:
Recommendation 1: Prior to implementation make exposure drafts, end-to-end workflows and guidance materials available for public consultation The NDIA should make exposure drafts of the rules, end-to-end workflow documentation and supporting guidance materials publicly available prior to implementation to ensure stakeholders have sufficient information to provide meaningful feedback on how the framework will operate in practice.
Second, there is concern that the coordination of various assessment stages, including targeted assessments for assistive technology, may increase the time required to finalise plans or approve requests for assistive technology, particularly where specialised equipment or customised solutions are involved. Given the scale of the proposed changes, it will be important that New Framework Planning is introduced in a way that allows the NDIA to identify and address unintended consequences early. In particular, the framework should be tested in situations involving complex and interacting support needs, including participants who require complex assistive technology. Experience in other sectors, including the current roll-out to Support at Home in aged care, demonstrates that structured assessment tools and algorithm-informed funding approaches can struggle to capture complexity without careful testing and refinement. A phased rollout that incorporates early trials, ongoing evaluation and opportunities for stakeholder feedback would help ensure that the framework is robust, responsive and fit for purpose before full implementation. To this end, ATSA makes the following recommendation:
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Recommendation 2: Integrate regular evaluation and feedback into roll-out of new framework planning The phased roll-out of New Framework Planning should include ongoing, regular and transparent evaluation. This should include structured opportunities for public consultation and stakeholder feedback and early testing in cases involving complex and interacting needs. To support this, public reporting on the impact of new framework planning on the following should be provided:
- planning and approval timeframes
- impacts on reviews and appeals
- administrative burden on participants and providers
- participant outcomes
- equity impacts for participants with complex needs and intersecting impairments
Also, there is a risk that assessors or NDIA delegates without sufficient knowledge of assistive technology may inadvertently contribute to delays, including through unnecessary plan reviews or disputes arising from uncertainty about appropriate AT supports. Therefore, ATSA recommends:
Recommendation 3: Strengthen assistive technology expertise in assessment and planning To ensure informed decision-making, the NDIA should ensure that:
- NDIA assessors and delegates receive comprehensive training in assistive technology and its role in supporting independence and participation
- ongoing professional development is available to assessors and delegate to maintain competency in AT-related decision-making
ATSA is also concerned that the individual needs of people requiring assistive technology may not be fully captured and incorporated into their plan under New Framework Planning. For instance, we are concerned that assessment tools and algorithm-informed funding may not fully capture the types of wrap-around supports required for safe and effective use of assistive technology. These supports include:
- assessment and clinical prescription
- trials and equipment selection
- fitting, configuration and set-up
- user training and education
- follow-up adjustments and modifications
- maintenance, servicing and repairs.
We are also concerned that New Framework Planning may not capture the needs of participants with multiple and intersecting impairments. Many participants experience more than one disability, and the interaction between these impairments can significantly influence AT requirements. Participants should not be required to nominate a single “primary” disability where their needs arise from the interaction of
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multiple impairments. Without mechanisms to capture these complexities, there is a risk that the new planning framework may produce assessments or funding outcomes that do not accurately reflect participants’ real support needs. Therefore, ATSA recommends the following:
Recommendation 4: Co-design targeted assistive technology assessments with the AT sector before rollout Before implementation, the NDIA should work proactively with the assistive technology sector, including ATSA members, relevant allied health bodies and disability sector organisations, to refine targeted assessment pathways for AT and ensure they are fit for purpose. This work should focus on:
- defining what triggers a targeted AT assessment and when it is not required
- clarifying what evidence will be accepted, what is ‘required’ versus ‘optional’, and who can provide it
- recognising appropriate existing reports and evidence to reduce duplication
- establishing service standards and practical timeframes specifically for AT-related decisions
- testing the assessment pathway using real-world AT scenarios, including thin markets and bespoke equipment
- ensure that New Framework Planning explicitly recognises that assistive technology outcomes depend on wrap-around supports, not only a budget for the item itself
Recommendation 5: Avoid over-reliance on a single “primary disability” New Framework Planning should not rely on participants nominating a single primary disability where multiple impairments interact. Instead, the process should focus on functional needs across contexts, including home, community, employment and transport environments. Assessment processes should explicitly consider how intersecting impairments interact and how this changes assistive technology requirements.
Closing
ATSA supports reforms that aim to improve the fairness, transparency and long-term sustainability of the NDIS. However, it is essential that the implementation of New Framework Planning does not inadvertently increase delays or create new barriers to accessing assistive technology and the wrap-around supports required for its effective use.
Greater transparency regarding how the planning process will operate in practice, together with opportunities for stakeholders to provide feedback as the framework is implemented, will be critical to its success. ATSA therefore encourages meaningful collaboration with the assistive technology sector in the design of targeted AT assessments, along with ongoing evaluation and refinement of the framework as it is rolled out.
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ATSA appreciates the opportunity to contribute to this consultation and would welcome continued engagement with government and the NDIA as the New Framework Planning model is further developed and implemented.
References
- NDIS 2025, Quarterly Report Q1 2025–26. Available at: https://www.ndis.gov.au/publications/quarterly-reports
- NDIS 2025, Quarterly Report Q2 2025-26. Available at: https://www.ndis.gov.au/publications/quarterly-reports
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