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
- What questions and feedback do you have about the draft support needs assessment
- report template?
- In what circumstances should a replacement assessment be arranged? Are there
- Further information and details about the budget method calculations will be provided
- What questions and feedback do you have about the draft participant plan template? 10
- What feedback and questions do you have about plan variations and reassessments?
- What feedback do you have about changes to NDIS supports for old and new
- What impacts may result from removing replacement supports? What items or services
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may no longer be available?
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- What questions do you still have?
- What would help people with disability better understand the NDIS new framework
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12. What communication formats would make the information more accessible?
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13. What should Government focus on in future communication products?
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Recommendations
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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
- 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.
- 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:
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the material evidence used in reaching the assessment outcome;
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the material skills, technology, supports or environmental factors that enable the participant’s independence;
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the outcomes of targeted assessments undertaken;
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where a potentially relevant targeted assessment was considered but not undertaken, the basis for that decision; and
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where material participant or specialist evidence is inconsistent with the assessment outcome, how that evidence was considered and the reason for the different
conclusion.
- 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
- 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:
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the assessed support need and relevant support category;
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any material skills, technology, existing supports or environmental factors taken into account;
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the calculation method applied;
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the material information used in that calculation;
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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
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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.
- 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:
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distinguish flexible, restricted flexible and stated funding and explain what each means in practice;
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explain material restrictions or requirements, why they apply and their practical effect;
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show funding across support categories and funding periods;
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show how identified support needs are reflected in the funding provided; and
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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
- 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:
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failure, repair, replacement or reasonable updating of established vision assistive technology;
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eligible unexpected or replacement costs associated with a dog guide;
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relocation requiring additional orientation and mobility support;
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changes in employment, education or informal support that affect disability-related support needs; and
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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
- 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.
- 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
- 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.
- 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?
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What criteria will require or trigger specialist evidence or targeted assessment where a generalist assessment does not adequately identify a blindness-specific support need?
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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
- 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.
- 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.
- 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
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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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