Submission to Department of Social Services: Ensuring the NDIS Supports Rules Support Timely Access to Assistive Technology
25 July 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
The problem: Assistive technology approval delays, inconsistent decision making and poor
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plan utilisation
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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 disabilities 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 The NDIA must ensure the content of the final Supports Rules and accompanying operational guidelines:
- Reinforce the need for nationally consistent decision-making on AT approvals;
- Provide clear criteria for decisions on AT, without the need for extensive FAQs;
- Reduce unnecessary administrative barriers by clearly distinguishing between low, mid, and high-cost AT and their associated approval pathways, in alignment with the AT Risk Table;
- Mandate transparency and communication on decisions, including reasons for delays, requests for additional evidence, or changes in funding outcomes;
Recommendation 2 The NDIA must facilitate the practical implementation of the final Supports Rules and accompanying operational guidelines by:
- Ensuring they are delivered as a cohesive and integrated package;
- Ensuring all stakeholders (Participants, NDIA staff, Plan Managers, Support Coordinators and AT suppliers) have access to the same guidance material and decision-making criteria on AT to reduce unnecessary frustrations and delays in access; and
- Ensuring the updated rules and accompanying operational guidelines are supported by mandatory training on AT for all NDIA planners, Plan Managers and Support Coordinators.
Recommendation 3 The NDIA must incorporate distinct AT-specific service indicators into the NDIS Participant Service Charter and Participant Service Guarantee. These indicators must be routinely reported on in the NDIA’s quarterly reports to enable public accountability and the monitoring of progress in improving AT service delivery.
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Introduction
Assistive Technology Suppliers Australia (ATSA) welcomes the opportunity to contribute to the consultation on the NDIS Supports Rules. Many ATSA members have responded positively to the interim support lists, valuing the increased clarity around the types of assistive technology (AT) supports eligible for funding under the NDIS. However, despite this progress, persistent issues with inconsistent decision making and delays in AT approval remain. This submission highlights these ongoing challenges and offers recommendations to support the effective implementation of the final support lists and associated guidelines. Our goal is to ensure more equitable, timely and transparent access to AT for all NDIS participants.
The problem: Assistive technology approval delays, inconsistent decision making and poor plan utilisation
Many NDIS participants face significant challenges accessing the assistive technology (AT) they are entitled to, and in a timely manner. According to the latest NDIS data (Quarter 3, 2024–25), average plan utilisation for mid/high-cost AT is only at 68%, with some groups experiencing even lower rates1. For example, participants whose primary disability is recorded as hearing impairment used just 52% of their committed mid/high-cost AT funding and only 37% of their low-cost AT (consumables) funding on average1.
Delays in AT approvals continue to be a major issue. The most recent data shows that only 39% of plan variation decisions (the target for low/mid cost AT) met the Participant Service Guarantee timeframe of 28 days2. There is no publicly available data on whether complex plan variations met the 50-day target (the target for high-cost AT). However, anecdotally we continue to receive feedback from ATSA members and other stakeholders that the wait for decisions on AT, particularly high cost AT is extensive, sometimes up to 2 years.
Feedback from members indicates that timely access to AT is frequently impeded by:
- Unjustified variation in decisions on similar AT items, even when aligned with the NDIS Assistive Technology Product Risk Table or interim support lists.
- Inconsistent interpretation of NDIS supports rules by NDIA planners, Plan Managers, Support Coordinators and Local Area Coordinators.
- Varied application of requirements for quotes, assessments, or trials, even for low-risk, low-cost items
- Delays in approval for all AT, often without clear communication or reasoning.
These delays have real-world consequences for participants. We often receive feedback that while waiting for their AT participants have reduced independence and mobility, continue to rely on expensive alternative supports and are at higher risk of injury and hospitalisation.
Participant Case Study: Nihal
In February 2024, Nihal’s orthotist identified that her prosthetic socket was loose and unsafe, causing pain and increasing her risk of falls. While temporary adjustments were made, a new socket was urgently required.
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A request for replacement was submitted that same month. By late March, the NDIA confirmed receipt of the quotes and documentation, but no further updates followed. With her condition worsening, Nihal was forced to rely on a wheelchair.
In July 2024, she was hospitalised after a suspected stroke and a blood clot developed in her remaining functional leg—complications linked to prolonged immobility. The delay in receiving her prosthesis led to serious health consequences and higher costs for both the NDIS and the health system due to additional hospital care and rehabilitation.
Support lists are still open to interpretation
The NDIS Supports Rules are a vital mechanism to clarify eligibility, scope and administrative requirements for funded supports. While the lists have been reassuring for many of our members, without consistent national interpretation and application, even well-drafted rules can contribute to further confusion and delay.
Feedback received from our members indicates that:
- Despite the clarity provided by the lists, approvals for AT are often disputed, requiring extensive and time-consuming justification;
- Clarifications (if they exist) are helpful, but are often buried under extensive lists of FAQs and are therefore difficult to find and difficult to share; and
- Many of our members report that some LACs, NDIA Planners and Plan Managers are lacking in appropriate AT knowledge, contributing to inconsistency and delays in accessing AT.
Therefore, ATSA makes the following recommendations.
Recommendation 1 The NDIA ensures that the content of the final Supports Rules and accompanying operational guidelines:
- Reinforce the need for nationally consistent decision-making on AT approvals;
- Provide clear criteria for decisions on AT, without the need for extensive FAQs;
- Reduce unnecessary administrative barriers by clearly distinguishing between low, mid, and high-cost AT and their associated approval pathways, in alignment with the AT Risk Table;
- Mandate transparency and communication on decisions, including reasons for delays, requests for additional evidence, or changes in funding outcomes;
Recommendation 2 The NDIA must facilitate the practical implementation of the final Supports Rules and accompanying operational guidelines by:
- Ensuring they are delivered as a cohesive and integrated package;
- Ensuring all stakeholders (Participants, NDIA staff, Plan Managers, Support Coordinators and AT suppliers) have access to the same guidance material and
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decision-making criteria on AT to reduce unnecessary frustrations and delays in access; and
- Ensuring the updated rules and accompanying operational guidelines are supported by mandatory training on AT for all NDIA planners, Plan Managers and Support Coordinators.
Addressing the lack of performance transparency on AT
The lack of publicly available performance targets and data on AT provision under the NDIS makes it difficult to assess how well the scheme and the AT sector are performing.
While the NDIA is required to make a decision about approving AT in someone’s current plan within 28 days (low and mid cost) and 50 days (high cost) (How can you get assistive technology in your plan? | NDIS), there is currently no publicly available data reporting on performance against these targets. Instead, performance on AT-related decisions is grouped under the broader plan variation participant service guarantees. This makes it impossible to see how the scheme is performing specific to AT approvals.
Recommendation 3
The NDIA must incorporate distinct AT-specific service indicators in the NDIS Participant Service Charter and Participant Service Guarantee. These indicators must be routinely reported upon in the NDIA’s quarterly reports to enable public accountability and the monitoring of progress in improving AT service delivery.
Concluding comments
The NDIS cannot deliver on its promise of empowering participants without addressing the long-standing barriers to timely and equitable access to assistive technology. The revised Supports Rules represent an important opportunity to fix the inconsistencies and delays that are undermining participant outcomes and increasing system costs.
We urge the NDIA and government stakeholders to ensure that the final version of the Support Rules includes clear, nationally consistent provisions that enable timely, fair and transparent access to AT for all participants.
ATSA stands ready to support further consultation and to contribute industry expertise to the implementation of these reforms. For further information about any of the matters raised throughout this submission, please contact ATSA’s Policy Officer, Karen Larson-Truong. Karen can be contacted by phone on 0415 543 116, or by email at karen-truong@atsa.org.au.
1 NDIS Explore Data. Available at https://dataresearch.ndis.gov.au/explore-data, accessed 23/07/2025.
2 NDIS Quarterly Report Q3 2024-25. Available at https://www.ndis.gov.au/publications/quarterly-reports, accessed 23/07/2025.
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