Submission 23 — Blind Citizens Australia (BCA) — New Framework Planning and NDIS Supports Consultation

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Sz Blind Citizens Australia

Ph 1800 033 660 | E bca@bca.org.au | W bca.org.au | ABN 90 006 985 226

Response to New Framework Planning and NDIS Supports Consultation

Closing date: 14 October 2026

Prepared by: Melanie Chatfield, National Policy Officer

Contact: melanie.chatfield@bca.org.au

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Contents

  1. What questions and feedback do you have about the draft support needs assessment
  • report template?
  1. In what circumstances should a replacement assessment be arranged? Are there
  1. Further information and details about the budget method calculations will be provided
  1. What questions and feedback do you have about the draft participant plan template? 10
  1. What feedback and questions do you have about plan variations and reassessments?
  1. What feedback do you have about changes to NDIS supports for old and new
  1. What impacts may result from removing replacement supports? What items or services
  1. What would help people with disability better understand the NDIS new framework

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About Blind Citizens Australia

Blind Citizens Australia (BCA) is the national disability representative organisation for

people who are blind or vision impaired. BCA brings lived experience and specialist

blindness-sector knowledge to policy development affecting the rights, independence,

safety and participation of people who are blind or vision impaired.

Overarching Position

BCA considers that people with established permanent blindness or vision impairment

should have a streamlined pathway through NDIS planning. Participants should not be

repeatedly required to prove their permanent impairment or re-establish support needs that

remain unchanged. Assessment and reassessment should focus on what genuinely needs

to be determined, including current or changing support needs and circumstances, the

supports that enable independence, and when specialist blindness expertise is required.

Response to Consultation

Support needs assessment rules

  1. What parts of the support needs assessment process need more explanation? Further explanation is needed about how the support needs assessment will accurately

identify the needs of people who are blind or vision impaired. Blindness and vision

impairment are relatively low-prevalence disabilities, and a generalist assessor may not

recognise the specialist skills, technology and supports that enable a person to function

independently. This creates a risk that independence will be mistaken for an absence of

support need. The assessment process must therefore be able to recognise the factors that

enable independence and identify when specialist blindness expertise is needed.

Recognise how variance in circumstances and environments affect support needs

A person who is blind or vision impaired may be independent in a familiar environment such

as their home or workplace but require different support in an unfamiliar, changing or

inaccessible one. For example, a person may independently navigate a familiar public

transport route using orientation and mobility skills, a white cane or dog guide, but require

additional support where routes, infrastructure or accessible information are different.

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The assessment must therefore consider the participant’s actual and variable

circumstances, including accessible transport, pedestrian infrastructure, wayfinding and

information, lighting and glare, and changes to the built environment. It should also account

for progressive or fluctuating vision and reasonably foreseeable changes during the plan

period.

The PECQ could help capture these factors where they are not identified through the core

assessment. Government should explain how PECQ information will affect assessed

support need, assessed support categories and the budget method.

Assess access to information, not just understanding

The assessment should distinguish between a person’s ability to understand and use

information and their ability to independently access that information in a usable format.

A person who is blind or vision impaired may have no difficulty with comprehension or

decision-making but still require disability-related supports to access written, digital or

visually presented information. Depending on the participant, this may involve use of

assistive technology, screen-reading or magnification software, Braille, tactile or audio

information, accessible documents, specialist training or a support worker.

Provide clear pathways to specialist blindness expertise

The consultation paper identifies Vision AT and dog guides as targeted assessment areas.

BCA seeks clear criteria for determining when these and other relevant targeted

assessments are required, including how a generalist assessor will recognise when

specialist blindness expertise is necessary. Government should establish clear triggers for

specialist assessment or advice so that access does not depend solely on a generalist

assessor recognising a need outside their expertise. Participants should also be able to

request specialist input and provide existing specialist evidence where relevant.

Core and vision-related targeted assessments should be designed, tested and reviewed

with people who are blind or vision impaired and practitioners with relevant specialist

expertise. This should include testing whether the assessment reliably identifies blindness

specific support needs.

The assessment should also distinguish between assistance to complete a task and

specialist support that builds or maintains the skills to complete it independently. For

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example, assistance with a journey is different from orientation and mobility training that

enables a person to travel independently.

Evidence should come from a practitioner with expertise relevant to the support need being

assessed. For example, an ophthalmologist or optometrist can provide evidence about

vision impairment and prognosis, while an orientation and mobility specialist can assess

travel needs. The rules should not require an allied-health report where another

appropriately qualified specialist is better placed to provide the necessary evidence.

Use existing evidence and avoid unnecessary reassessment

Relevant existing evidence should be used wherever it provides the required information,

without requiring a duplicative assessment simply because it is not provided on a particular

template. Government should clarify when existing participant or specialist evidence can

satisfy a targeted assessment.

Where permanent blindness or vision impairment has already been established, existing

evidence of permanence should be accepted. Further assessment should focus on current

or changing disability-related support needs and circumstances.

Where a participant has an established disability-related need for a type of assistive

technology, replacement or updating of technology serving substantially the same function

should not routinely require a new specialist assessment or report. Further assessment

should only be required where there is a material change in the participant’s needs, the

function being funded or other relevant circumstances.

  1. What questions and feedback do you have about the draft support needs assessment report template?

BCA supports participants receiving a support needs assessment report before it is used to

inform their budget. The report should contain enough information for a participant to

understand and check whether their support needs, enabling factors and circumstances

have been accurately recorded.

This is important because an omission or misunderstanding at assessment can flow through

to the assessed support categories, budget calculation and final plan. Participants should

have a meaningful opportunity to identify material errors before those errors affect later

decisions.

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Make the basis for assessment ratings clear

For people who are blind or vision impaired, a rating of independence may not tell the whole

story. A participant may undertake an activity independently due to established skills,

assistive technology, supports, or familiarity with their environment. Where these factors are

material to understanding the participant’s support needs, they should be documented

alongside the relevant assessment information. Otherwise, a report may indicate

independence without identifying what enables that independence or what may be required

to maintain it.

Make relevant evidence and targeted-assessment decisions transparent

The report should provide sufficient information to identify:

  • the material evidence used in reaching the assessment outcome;

  • the material skills, technology, supports or environmental factors that enable the participant’s independence;

  • the outcomes of targeted assessments undertaken;

  • where a potentially relevant targeted assessment was considered but not undertaken, the basis for that decision; and

  • where material participant or specialist evidence is inconsistent with the assessment outcome, how that evidence was considered and the reason for the different

conclusion.

  1. In what circumstances should a replacement assessment be arranged? Are there additional circumstances that should be considered?

A replacement assessment should be arranged where a material problem means the

original assessment is no longer a reliable basis for determining support needs and cannot

be adequately addressed by correcting the report or obtaining supplementary information.

Relevant circumstances could include:

 material errors or omissions that cannot reliably be corrected;

 failure to consider material participant or specialist evidence;

 failure to obtain a targeted assessment or specialist input necessary to properly

identify a material support need; or

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 an accessibility, communication or other procedural problem that materially affected

the participant’s participation or the reliability of the assessment.

For example, if assessment questions or information are not communicated in a format the

participant can access and this results in support needs being materially misunderstood or

omitted, a replacement assessment may be necessary.

Where a replacement assessment is refused, the participant should receive clear reasons

for that decision and information in their preferred format about any available mechanism to

challenge it.

Budget method rules

  1. Further information and details about the budget method calculations will be provided later in 2026 after more testing is done. What information would help participants understand how a budget is calculated?

Participants should be able to understand how their assessed support needs translate into

funding. This requires public information about how the budget method works and

participant-specific information explaining the factors that affected their individual budget.

Show participants how their budget was calculated

A participant should be able to identify:

  • the assessed support need and relevant support category;

  • any material skills, technology, existing supports or environmental factors taken into account;

  • the calculation method applied;

  • the material information used in that calculation;

  • any standard amounts, assumptions or adjustments that had a significant effect on their budget, including anything that increased or reduced the amount of funding; and

  • how the final amount relates to their assessed support needs. Explain default amounts and individual circumstances

BCA seeks further information about the proposed default amount for community supports

including how it will be determined, the assumptions underpinning it and how the calculation

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will respond where a participant’s assessed support needs differ materially from those

assumptions.

Community support needs for people who are blind or vision impaired can vary depending

on factors such as geographic location, accessibility of transport and the built environment,

familiarity with environments, employment or education requirements, availability of

specialist services and interaction with other disabilities.

Provide a funding pathway for foreseeable high-cost supports

Where a high-value assistive technology replacement or other significant support need is

reasonably foreseeable during the plan period, the budget method should provide a

practical way to fund it when required. A support need should not be recognised in the

assessment without a corresponding pathway to funding.

Fund supports that build and maintain independence

The budget method should recognise specialist supports that build or maintain

independence. A participant’s existing independence should not be treated as evidence that

further specialist support is unnecessary where training or support is needed to maintain

skills, adapt to changing circumstances or develop new skills.

Only count mainstream and community services that can be used

Where the budget method takes account of mainstream or community services, availability

should mean reasonably available and usable by the participant in their actual

circumstances. The methodology should not assume a service is available, accessible and

useable merely because it exists.

For people who are blind or vision impaired, a service may exist but may not be usable

because of inaccessible booking or information systems, wayfinding barriers, lighting

conditions, transport barriers or reliance on visual information without an accessible

alternative.

Do not assume informal supports

BCA is concerned about any budget method that assumes family, friends or others will

provide unpaid disability-related support. The presence of family, friends or housemates

does not mean they are willing, able or appropriate people to provide ongoing support, and

help provided in the past should not create an expectation that it will continue.

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The concept of informal supports can also be poorly understood and applied in practice. A

BCA member reported that their Rotary Club had been incorrectly listed in their NDIS plan

as an informal support, despite not providing disability-related support. It took several plan

updates to correct this and other inaccurate assumptions about their personal

circumstances.

It is our view that a participant’s budget should be based on their disability-related support

needs, not an assumption that personal relationships will substitute for funded support.

Participants should retain choice about whether and when they seek help from family or

friends. This is important to support independence and avoid creating dependence or

placing pressure on personal relationships. If informal supports are to affect budget

calculations, Government should clearly define what counts as informal support, how it will

be assessed and quantified, and how any resulting reduction in funding will be explained to

the participant.

Clarify private vehicle transport

BCA seeks clarification about how eligibility and set funding levels for private vehicle

transport will operate for participants who can independently use public transport for some,

but not all, journeys.

A person who is blind or vision impaired may independently undertake a familiar public

transport journey but be unable to safely, reliably or reasonably complete another journey

because of inaccessible transport information, an inaccessible interchange or destination,

lack of an accessible route to or from the service, or other disability-related barriers. Ability

to use public transport for some journeys should not, by itself, establish that disability

related transport support is unnecessary.

Require transparency and human oversight in automated or algorithmic processes

If automated or algorithmic processes are used to materially inform support needs

assessment or individual budget calculations, their role should be transparent and subject to

effective human oversight. Participants should be able to understand and challenge material

outcomes, and a responsible NDIA decision-maker should be able to scrutinise, correct or

depart from an automated output where it does not accurately reflect the participant’s

support needs and circumstances.

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Publish the budget methodology

Government should publish sufficient information about calculation methodologies,

benchmarks, defaults, adjustments and offsets so participants, advocates and Disability

Representative Organisations can understand how the system operates and identify

potential systemic problems.

Safeguard participants where funding materially changes

Where the new assessment and budget methodology results in a material reduction in

support, participants should receive clear reasons in their preferred accessible format

explaining the basis for the change, appropriate transition arrangements where required,

and straightforward information about review and appeal rights.

  1. What questions and feedback do you have about the draft participant plan template? BCA is concerned that the draft participant plan is complex and difficult to navigate.

Participants should be able to readily understand their funding, how it can be used, any

restrictions or requirements, and what they can do if they disagree with the outcome.

Key terms should be explained within the plan wherever possible, supported by an

integrated glossary rather than requiring participants to move between documents or

external resources.

The plan should clearly:

  • distinguish flexible, restricted flexible and stated funding and explain what each means in practice;

  • explain material restrictions or requirements, why they apply and their practical effect;

  • show funding across support categories and funding periods;

  • show how identified support needs are reflected in the funding provided; and

  • explain what participants can do if they believe their plan does not reflect their assessed support needs.

The plan and accompanying reasons should be provided in the participant’s preferred

accessible format. Accessibility should extend beyond technical compatibility with assistive

technology: information should also be logically structured, easy to navigate and written in

plain language so participants can independently understand their own plan.

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Plan variations and reassessments

  1. What feedback and questions do you have about plan variations and reassessments? BCA supports using plan variations for discrete changes in support needs. A change in one

area should not unnecessarily trigger reassessment of otherwise stable parts of a

participant’s plan or discourage participants from reporting genuine changes in need.

For people who are blind or vision impaired, variations should be able to respond promptly

to changes such as:

  • failure, repair, replacement or reasonable updating of established vision assistive technology;

  • eligible unexpected or replacement costs associated with a dog guide;

  • relocation requiring additional orientation and mobility support;

  • changes in employment, education or informal support that affect disability-related support needs; and

  • changes in technology or the accessibility of systems or environments that create a new disability-related support need.

Clear decision timeframes should apply where delay could leave a participant without an

essential support or materially affect their independence or safety. Where appropriate,

continuity arrangements should prevent avoidable gaps in essential supports while a

variation is being decided.

The framework should also respond to progressive vision loss where timely capacity

building, orientation and mobility or assistive technology support is needed as vision

changes. Participants should not have to wait until a foreseeable change results in loss of

independence or safety before relevant support needs can be addressed.

The rules should clearly distinguish when a variation or reassessment is required. Where

the NDIA determines that a reassessment is necessary instead of a requested variation, the

participant should be told why and the scope of reassessment should be proportionate to

the change in circumstances.

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NDIS supports rules

  1. What feedback do you have about changes to NDIS supports for old and new framework planning?

BCA’s principal concern is that the new support categories must not make established

specialist blindness supports harder to access. There should be a clear pathway to supports

including orientation and mobility, independent living skills, specialist vision rehabilitation,

vision assistive technology and dog guide services, with participants able to understand

where these supports are funded, what evidence is required and how the funding can be

used.

Recognise specialist blindness practitioners

Some specialist blindness supports are delivered by appropriately qualified practitioners

who do not fall within conventional allied-health classifications. The rules should recognise

practitioners based on the expertise and competence required to deliver the support, while

retaining appropriate qualification and safeguarding requirements.

Retain choice and flexibility for accessibility technology

The support rules should recognise the disability-related function performed by technology

and retain appropriate choice and flexibility for eligible accessibility technology. Any

requirements should be proportionate to risk and sufficiently flexible to respond to changing

technology and individual accessibility needs.

Recognise disability-related information access

Support descriptions should recognise disability-related information access needs where

they meet NDIS funding requirements, including relevant assistive technology, Braille and

tactile solutions and specialist training that enables people who are blind or vision impaired

to independently access and use information.

  1. What impacts may result from removing replacement supports? What items or services may no longer be available?

BCA’s concern is that the new arrangements must continue to provide a clear and timely

pathway to eligible accessibility technology, including mainstream technology that performs

a disability-related function.

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For people who are blind or vision impaired, mainstream devices and applications can

provide essential functions such as navigation, optical character recognition, object

identification, and accessible communication. The rules should clearly explain how this

technology can qualify and be funded, including necessary accessories, configuration,

specialist assessment or training, repair and replacement.

Where a participant’s disability-related need and the function of their assistive technology

are already established, replacing or updating technology that serves substantially the same

function should not routinely require a new specialist assessment or report.

General questions

  1. What information was most useful? The identification of Vision AT and dog guides as targeted assessment modules is useful

because it provides some clarity about how particular blindness-specific support needs may

be considered within the support needs assessment. Further detail is needed about the

criteria for triggering these targeted assessments, how their findings will inform assessed

support needs and support categories, and how those needs will translate into budget

calculations.

  1. What questions do you still have? BCA continues to have the following questions:
  • How will Government monitor outcomes by disability cohort during rollout, including assessment and funding outcomes, access to specialist disability supports and any

unintended effects on the availability of specialist services?

  • What assessment and budget methodologies, benchmarks, defaults and other material calculation information will be published before implementation so participants and

Disability Representative Organisations can understand and scrutinise how the new

framework operates?

  • What criteria will require or trigger specialist evidence or targeted assessment where a generalist assessment does not adequately identify a blindness-specific support need?

  • How will Government test whether needs identified in the support needs assessment are accurately carried through to assessed support categories, budget calculations and

final plans? Page 13 of 16

  1. What would help people with disability better understand the NDIS new framework planning rules?

Government should explain new framework planning through the participant journey rather

than requiring participants to understand how separate rules interact.

Participants need a clear, plain-language explanation of each stage: what happens, what

information is considered, who makes decisions, how those decisions affect funding, what

information the participant will receive, how errors can be corrected and what they can do if

they disagree with a decision.

Worked examples would help demonstrate how the framework operates in practice. These

should cover different disabilities and circumstances, including a person who is blind or

vision impaired, and show how information moves from assessment through to support

categories, budget calculation and the final plan.

  1. What communication formats would make the information more accessible? For people who are blind or vision impaired, information should be available in accessible

HTML and properly structured accessible electronic documents compatible with screen

readers and magnification. Braille, large print and audio should also be available where

requested.

Accessibility should apply throughout the participant journey, including assessment

information and reports, plans, reasons and notices, review information, forms and digital

portals. Electronic documents should be properly structured and navigable, with meaningful

headings, links and document structure.

Participants should not have to rely on another person to read or navigate information about

their own NDIS plan or experience avoidable delay because information has not been

provided in an accessible format. Accessible formats should be provided at the same time

as equivalent information is provided to other participants wherever practicable.

  1. What should Government focus on in future communication products? Future communication products should focus on what participants need to understand and

act on, including:

  • What will change at each stage of assessment, budgeting and planning; Page 14 of 16
  • What information and evidence participants may need to provide;
  • How assessment outcomes affect funding and how funding can be used;
  • When a plan can be varied or reassessed;
  • How to correct errors, raise concerns and exercise review and appeal rights; and
  • What has been decided, what is proposed and what is still being developed. Information should use practical examples, including examples relevant to people who are

blind or vision impaired, and should be timely and available in accessible formats before

participants are required to make decisions or participate in a new process.

Final rules, operational guidance and accessible participant information should be available

early enough for the new processes, systems and communications to be properly tested

before implementation.

Recommendations

  1. Provide a streamlined planning pathway for established permanent blindness or vision impairment. Participants should not be repeatedly required to prove

permanent impairment or re-establish support needs that have not changed.

Assessment and reassessment should focus on current or changing support needs

and circumstances.

  1. Ensure assessment recognises what enables independence. Assessment should recognise the assistive technology, orientation and mobility skills, white cane or dog

guide, learned techniques and environmental familiarity that enable independence.

Independence achieved through these supports should not be treated as evidence

that disability-related support is unnecessary.

  1. Give participants a clear pathway to specialist blindness assessment. Establish clear triggers for specialist input, allow participants to request a specialist

assessment, and accept evidence from appropriately qualified practitioners with

expertise relevant to the support need. Vision-related assessment tools should be

tested with people who are blind or vision impaired and specialist practitioners.

  1. Protect access to specialist blindness supports. The new support categories should provide a clear pathway to orientation and mobility, independent living skills,

specialist vision rehabilitation, vision assistive technology and dog guide services.

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Participants should be able to identify where these supports are funded, what

evidence is required and how the funding can be used.

  1. Make the pathway from assessed need to funding transparent. Participants should be able to understand how their assessed needs translate into support

categories and funding, including any defaults, assumptions or adjustments that

materially affect the amount. An identified support need should have a practical

pathway to funding, including foreseeable high-value assistive technology needs.

  1. Do not assume family or friends will provide unpaid disability support. A participant’s budget should be based on their disability-related support needs, not an

assumption that family, friends or community connections will substitute for funded

support. Participants should retain choice about whether and when they rely on

informal assistance.

  1. Use plan variations for discrete changes without reopening stable support needs. Changes such as assistive technology replacement, dog guide needs,

relocation or changes in employment or education should be addressed promptly

through plan variation where appropriate. A change in one area should not

unnecessarily trigger reassessment of otherwise stable support needs.

  1. Provide a simple pathway to replace and update established accessibility technology. Mainstream and specialist technology that performs an eligible

disability-related function should remain accessible. Where the participant’s need and

the function of the technology are already established, replacement or updating of

technology serving substantially the same function should not routinely require

another specialist assessment or report.

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