New Framework Planning & NDIS Supports – OTA Submission – October 2026

Introduction

About Occupational Therapy Australia

OTA is the peak professional body representing occupational therapists nationally.

We empower and elevate over 36,000 occupational therapists who in turn work in partnership with individuals and communities to enable participation in the everyday activities, occupations and life roles that are meaningful to them.

We’re the single, unifying connection point for occupational therapists across the nation, leading the profession through education, support, and advocacy, so every occupational therapist is informed, inspired and fulfilled in their profession.

As one of Australia’s largest allied health workforces, occupational therapists provide essential supports across health, primary care, aged care, disability, mental health, veteran care and more.

About Occupational Therapy

Occupational therapy is a person-centred allied health profession concerned with promoting health, wellbeing and participation through engagement in meaningful and necessary occupations. Occupational therapists understand that a person’s ability to participate is shaped by the interaction between their individual capabilities, the tasks they want to do, their physical and social environment, and the supports available to them.

This way of understanding function sits at the centre of clinical practice. Occupational therapists are trained to assess what a person can do in the context of their actual daily life, at home, at school, at work and in the community. That means looking beyond whether a task can be performed once, in a controlled setting, to whether it can be performed safely, repeatedly and reliably over time, and to what a person needs by way of assistive technology, modification, informal support or the removal of a barrier to do so.

It also means recognising that capacity can fluctuate, that a single presentation on a single day does not always reflect a person’s typical function, and that diverse support needs, communication needs, cultural context and multiple and interacting needs all shape what a good assessment needs to capture.

Capacity building sits at the core of occupational therapy, with occupational therapists working alongside people to build skills, strategies and habits, and create enabling environments that strengthen participation and autonomy, and reduce reliance on ongoing support over time.

Occupational therapists are already embedded across the NDIS, conducting functional capacity assessments, recommending assistive technology and environmental modifications, and delivering capacity-building supports that strengthen people’s skills, confidence, routines and environments to enable greater choice, participation and agency in everyday life.

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Recommendations

Support needs assessment rules

The modified I-CAN v6 tool should be amended to score support type and potential for change as well as support intensity, so a scored need can be attributed to allied health input where appropriate.
Allied health professionals, including occupational therapists, should be directly involved in developing and validating the modified tool.
The modified tool and its scoring methodology should be released for sector review before finalisation, given how directly this scoring now informs funding across multiple categories.
A therapy targeted assessment module should be added to the support needs assessment, triggered when the core assessment identifies set criteria, so therapy need is assessed directly and consistently, and funding is directed to supports that reduce long-term need.
The rules should specify how clinical evidence from treating professionals contributes to the funding calculation, when they are brought into the assessment process, the referral pathway, how their input is funded, and its expected scope.

Support needs assessment report

Participants (or their nominee) should have an explicit right to request a targeted assessment or submit existing allied health evidence at any stage.
A treating professional should have a defined opportunity to respond or supply further evidence before a report is finalised, particularly where a recommendation will not be accepted.
A clinical disagreement between evidence from a treating professional and the assessor’s report should be a named trigger for a reassessment, with a set response timeframe.
Each core domain should include a structured field asking whether therapeutic supports have been considered as a way of meeting the identified need, so the NDIA can match support type to need and track outcomes over time.
The report should require documented evidence sourcing for all stated needs, including the assessment tools used and sources of collateral information, consistent with existing reporting standards under old framework planning.
Rejection outcomes should specify which requirement was not met, what information was missing, and what the participant would need to provide to progress the request.
Each report should record the assessor’s full name or unique identifier and contact details.

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The report and plan should include a plain-language executive summary and an embedded glossary, be available in accessible formats, and be tested with participants for readability on mobile devices.

Budget method rules

The methodology for combining functional, DRHS, AT and assessment therapy inputs into a single therapy funding level should be released for consultation before finalisation.
The therapy funding figure should be accompanied by a plain-language explanation in the plan itself, showing which assessment inputs and settings produced it, so the decision is contestable at internal review and at the ART.
The adjustment mechanism for all categories, including therapy, should explicitly include complexity of support needs as a documented basis for departing from a set funding level.
The plan implementation meeting should be opt-out rather than opt-in, with an explicit right for a treating professional or support coordinator to attend.
The NDIA should give participants advance written notice of the purpose of any meeting that may inform their plan, with enough time to prepare and invite support.

Participant plan template

Participants should be able to restrict flexible therapy funding on the basis of therapeutic need evidenced by a treating professional, alongside the existing safety risk basis.
The NDIA should clarify how therapy funding will be displayed in a participant’s plan and support needs assessment report.
The NDIA should define ‘daily supports’ and reconcile it with the 18-category structure, with written confirmation of whether it includes therapy supports and under what conditions.

Plan variation and reassessment rules

A scheduled mid-plan review point should be introduced for plans of three years or longer.
Updated clinical evidence from a treating professional, including evidence of therapeutic progress, should be able to trigger a plan variation for moderate functional change, without requiring an emergency framing or a full reassessment.

NDIS supports rules

The NDIA should introduce a mechanism to fund clinically recommended items that do not precisely match a category description, before replacement supports are withdrawn for old framework plans.

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Any blanket exclusion should retain a pathway for clinically justified, individually assessed exceptions.
A targeted occupational therapy driver assessment should be required before NDIS funding is allocated for specialised driver training, with Occupational Therapy Driver Assessor (OTDA) input into assessment, funding amounts and guidance for driving instructors.
The rules should specify a threshold or item list that distinguishes supports safely purchased at retail without professional input from those that require documented allied health assessment and prescription, regardless of purchase channel, and clarify who holds responsibility for purchasing decisions.
The carve-out structure already used for animal-assisted therapy should be replicated: exclude headphones generally, but permit funding where an appropriately qualified allied health professional prescribes them as part of a therapeutic intervention in line with reasonable and necessary criteria.

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Response to Consultation Questions

Occupational Therapy Australia (OTA) welcomes the opportunity to respond to the Department of Health, Disability and Ageing’s (the Department’s) consultation on new framework planning and NDIS supports.

OTA supports the goals for new framework planning - a fairer, more consistent and more sustainable NDIS. We also welcome the move toward consistent assessment, clearer rules and more transparent budgets. With this in mind, we see a clear opportunity to strengthen new framework planning by directly assessing and transparently costing therapeutic need.

Getting this right matters well beyond the occupational therapy profession. Capacity-building therapy is a critical investment in improving participant outcomes and supporting the long-term sustainability of the Scheme. It strengthens functional capacity, participation, choice and agency - enabling participants to engage more fully in everyday life and, where possible, reducing reliance on more intensive paid supports over time.

Evidence demonstrates these interventions lead to improvements in functional ability, quality of life, and reduced ongoing service use, reinforcing the value of investing in capacity-building approaches. 1 This reflects the insurance-based approach at the heart of the NDIS - investing early in effective supports that improve outcomes while supporting the sustainability of a participant’s support needs over their lifetime. It may also reduce avoidable administrative activity associated with reviews, reassessments and applications to the Administrative Review Tribunal (ART).

OTA’s feedback therefore focuses on whether the new rules direct funding to the supports most likely to improve outcomes and reduce long-term need. Our recommendations aim to make therapeutic need visible, measurable and protected within the framework. Rules that do this will strengthen the Scheme’s sustainability, support fairer and more consistent decisions, ease pressure on the support workforce, and give the NDIA better data on which supports are effective.

OTA would welcome access to several materials that would allow a fuller assessment of the framework. This includes the modified I-CAN v6 tool and its scoring methodology, the personal and environmental circumstances questionnaire (PECQ), the detailed budget calculation methodology, exposure drafts of the rule text and a worked example showing therapy supports funded and displayed in a participant’s plan.

Our analysis and feedback are based on the consultation papers and sample documents provided. Where the Department holds information that clarifies or resolves any issue raised, OTA welcomes that clarification. We would be glad to work with the Department on the modified assessment tool, the therapy funding methodology and the design of targeted assessment modules.

1 Bennett, C., Allen, F., Hodge, S., & Logan, P. (2022). An investigation of reablement or restorative homecare interventions and outcome effects: A systematic review of randomised control trials. Health & Social Care in the Community, 30(6), e6586–e6600. https://doi.org/10.1111/hsc.14108

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Support needs assessment rules

What parts of the support needs assessment process need more explanation?

The modified I-CAN v6 tool

OTA recognises the Department’s work to modify the I-CAN v6 tool and would value more detail before it is used to determine support needs. OTA retains concerns about this tool - put simply, it was not designed to assess therapeutic need, and has not been validated for the purpose of setting funding across multiple support categories.

The Department has confirmed it is working with the Centre for Disability Studies and the University of Melbourne to modify the tool, but this modified version has not been released. Without this detail, the sector cannot assess whether the tool can inform a support needs assessment accurately.

Two changes would strengthen the tool’s ability to capture therapeutic need.

First, I-CAN measures a person’s abilities and the intensity of support required, not the type of support or the cost of delivering it. An hour of support scores the same whether an occupational therapist, a support worker or a family member provides it. Yet the cost, purpose and outcome of that hour differ substantially.

Second, I-CAN captures a participant’s current need at a single point in time. It does not measure potential for change. Identifying whether a participant could improve their daily function therefore falls to the individual assessor, making access to therapy funding dependent on their judgement alone. Nothing in the proposed process then asks whether need could reduce following capacity building. The budget is set as if today’s need will stay the same.

Together, these limitations prevent funding being directed to the support most likely to reduce need over time. Across the participant population, this risks locking in ongoing support costs that targeted therapy could have reduced.

Consider a participant working toward independent toileting. The tool could score the same number of hours whether a support worker or an occupational therapist delivers them, and it would record that need as fixed. A support worker provides hands-on assistance, prompting or supervision so the participant can complete toileting safely each day, maintaining their current level of participation. However, only the occupational therapist is working toward the participant’s underlying goal: safe, independent toileting.

If assessed solely on current support intensity, this need could translate into ongoing support worker hours without sufficient consideration of the person’s capacity-building potential. Targeted occupational therapy can strengthen skills, routines and environmental supports, which may reduce the level or intensity of paid assistance required over time. Support workers can then play an important role in reinforcing the strategies, assistive technology and routines established through occupational therapy. This strengthens the participant’s capacity, choice, agency and participation in everyday life, while supporting more sustainable use of funded supports.

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Until the modified tool and its scoring methodology are released, there is no way to confirm whether it can distinguish “this person needs three hours of support a week” from “this person needs three hours of therapy a week to reduce ongoing support”. These needs produce different budgets and different long-term outcomes.

Scoring support type and potential for change would also give the NDIA better data. The Scheme could track which supports reduce need over time and use that evidence to guide future planning and pricing decisions.

Recommendation 1 - OTA recommends the modified I-CAN v6 tool be amended to score support type and potential for change as well as support intensity, so a scored need can be attributed to allied health input where appropriate.

Recommendation 2 - OTA recommends allied health professionals, including occupational therapists, be directly involved in developing and validating the modified tool.

Recommendation 3 - OTA recommends the modified tool and its scoring methodology be released for sector review before finalisation, given how directly this scoring now informs funding across multiple categories.

The structure of the assessment

The assessment structure would also benefit from further explanation. Every other major support type has its own targeted assessment module, including assistive technology (AT), home modifications, disability-related health supports (DRHS) and behaviour support. Therapy has no equivalent. It is assessed only through the generalist assessor’s scoring in the core needs assessment, drawn from a single conversation.

As a result, an assessment has no structured way to ask whether a participant needs therapy to meet their goals. Therapeutic need instead surfaces indirectly, as a byproduct of AT, DRHS or home modification assessments.

A therapy targeted assessment module would ensure participants whose goals are best met through capacity building are identified. Like the existing AT, home modifications and DRHS modules, it would be activated only when the core assessment identifies a likely therapeutic need. This would improve consistency.

At present, whether therapy need is identified depends largely on an individual assessor’s judgement. A structured module would apply the same questions to every participant who meets the criteria, supporting the fair and consistent decisions new framework planning is designed to deliver.

Clear guidance on when and how treating professionals contribute would also strengthen the assessment process. As currently articulated, the proposed rules do not set out the referral pathway, how this input would be funded, or its expected scope.

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Recommendation 4 - OTA recommends a therapy targeted assessment module be added to the support needs assessment, triggered when the core assessment identifies set criteria, so therapy need is assessed directly and consistently, and funding is directed to supports that reduce long-term need.

Recommendation 5 - OTA recommends the rules specify how clinical evidence from treating professionals contributes to the funding calculation, when they are brought into the assessment process, the referral pathway, how their input is funded, and its expected scope.

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

Clinical input before the report is finalised

Under old framework planning, evidence of therapeutic need usually comes directly from the treating professional. For occupational therapists, that evidence draws on structured, validated tools and direct observation across real environments, typically via a functional capacity assessment.

Under new framework planning, a trained and accredited NDIA assessor conducts the core needs assessment and the PECQ in a single guided conversation. The budget method table states therapy funding levels are then set by “assessed need for one or more of functional, DRHS, AT or assessment therapy”. The same generalist assessor also decides whether a participant has “relevant reports from a medical or allied health professional”, and whether a targeted assessment is needed.

The support needs assessment report would benefit from a defined point for clinical input. At present, where a participant already has a treating professional and that professional’s recommendation is not accepted (through the “outcome - no evidence” pathway), that professional has no opportunity to respond or supply further evidence. The only recourse is the participant’s right to flag errors after the report has been issued. This creates avoidable rework for the NDIA and avoidable delay for the participant.

Clinical input is most valuable, and least costly, before a report is finalised. Getting the assessment right the first time reduces the need for replacement assessments and reviews, and gives participants confidence in the process.

Recommendation 6 - OTA recommends participants (or their nominee) have an explicit right to request a targeted assessment or submit existing allied health evidence at any stage.

Recommendation 7 - OTA recommends a treating professional have a defined opportunity to respond or supply further evidence before a report is finalised, particularly where a recommendation will not be accepted.

Recommendation 8 - OTA recommends clinical disagreement between evidence from a treating professional and the assessor’s report be a named trigger for a reassessment, with a set response timeframe.

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Support type in the core domains

The 12 core assessment domains record the frequency and level of support a participant needs. They do not record what kind of input would best meet that need. Each domain should consider both the type and the intensity of support.

For example, a generalist assessor may identify that a participant requires “moderate support with cooking”. However, this describes the current level of assistance without necessarily identifying whether the person’s capacity could be strengthened, or whether changes to their environment could better enable participation.

Occupational therapy can explore the interaction between the person, the activity and their environment, identifying opportunities to build skills and routines alongside strategies such as assistive technology, environmental modifications, task adaptation and changes to the way support is provided. Therapy may enable greater participation, choice and agency while supporting more sustainable use of funded supports over time.

Defaulting to additional support worker hours risks overlooking opportunities to build both individual capacity and the capability of the environment around the person. Where occupational therapy can strengthen skills, adapt environments and equip the people providing support with effective strategies, support workers can reinforce these approaches rather than simply completing activities on the participant’s behalf. This creates a more enabling model of support, maximising participation and capacity over time, while making more effective use of both the therapy and support workforces.

Recommendation 9 - OTA recommends each core domain include a structured field asking whether therapeutic supports have been considered as a way of meeting the identified need, so the NDIA can match support type to need and track outcomes over time.

Evidence, accountability and accessibility

Stronger evidence sourcing, accountability and accessibility would protect participants and build confidence in new framework planning.

As currently presented, the sample report records a participant’s needs without reference to supporting evidence. It does not show how a need was identified, who identified it, or what information informed the finding. This contrasts with the evidence produced under old framework planning, which drew on standardised assessments, clinical observation, functional history and input from participants, families and other treating professionals.

Clear evidence sourcing would let participants check that their needs have been captured accurately and completely. It would also give funding decisions a stronger foundation and make them easier to review.

Specific reasons for rejections would give participants a clear path forward. The sample documentation logs rejections for prosthetics and orthotics simply as not meeting requirements. Stating which requirement was not met, what information was missing, and how the participant could address the gap,

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would help participants submit a complete application. Participants with a clear path forward are less likely to resubmit requests without knowing what to change, or to seek review.

Clear decisions also support participant safety. Timely access to essential equipment prevents falls, protects mobility and supports autonomy and choice. It also costs far less than a single fall that results in a hospital admission, with costs falling on the public health system and on the NDIS, which may then need to fund AT or home modifications for a safe discharge home. Timely provision supports the Government’s aim of a stronger interface between the NDIS and mainstream services.

Clear findings and explained decisions would reduce requests for internal review and applications to the ART. This would lower costs for the NDIA and support the consistency new framework planning is designed to deliver.

Clear assessor identification would strengthen accountability. The sample report records no assessor identifier beyond a first name and provides no contact details. Including a unique identifier and contact details would allow participants and treating professionals to clarify findings, correct errors and supply further information.

An executive summary and glossary would help participants understand and use their plan. The report and plan are long and complex, and introduce new terms such as ‘flexible-unrestricted’, ‘flexible-restricted’ and ‘stated supports’. These terms directly affect how a participant can use their funding, so clear explanations are essential.

Mobile-friendly formatting would further improve access, as many participants will view their documents on a phone. Accessible documents allow all participants, including those with cognitive disability, diverse literacy or vision needs, and those from culturally and linguistically diverse backgrounds, to use their plan with confidence.

Recommendation 10 - OTA recommends the report require documented evidence sourcing for all stated needs, including the assessment tools used and sources of collateral information, consistent with existing reporting standards under old framework planning.

Recommendation 11 - OTA recommends rejection outcomes specify which requirement was not met, what information was missing, and what the participant would need to provide to progress the request.

Recommendation 12 - OTA recommends each report record the assessor’s full name or unique identifier and contact details.

Recommendation 13 - OTA recommends the report and plan include a plain-language executive summary and an embedded glossary, be available in accessible formats, and be tested with participants for readability on mobile devices.

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Budget method rules

Transparency of the therapy funding formula

Publishing the method used to determine therapy funding would make allocations transparent and contestable. The rules state that funding draws on “assessed need for one or more of functional, disability-related health supports, assistive technology or assessment therapy”, but they do not explain how these inputs are weighted or combined into a dollar figure.

This differs from AT and home modifications, which use quotes or benchmarking tied to a specific prescribed item. Therapy funding is instead a figure produced by a formula not yet published and applied by a generalist assessor. Knowing how a budget was calculated would allow participants and treating professionals to interpret, question and plan around it. Amending this would help new framework planning deliver on the Government’s stated goal of more transparent and consistent planning decisions.

The most consequential decision is how many therapy hours a participant needs to reach a goal, and this requires clinical expertise a generalist assessor is not trained to provide. For example, assessing, trialling and setting up a powered wheelchair typically takes several sessions, as does teaching a person to shower independently. Estimating these hours becomes more complex when a participant has several concurrent goals. Clinical input into these estimates would ensure therapy budgets are sufficient for participants to reach their goals, reducing unmet need and avoidable review requests.

OTA supports the use of structured tools to facilitate administrative processes, with the resulting decisions made by people. We oppose any approach that uses fully automated processes to determine support needs or associated budgets. Any partially automated decision should include mandatory human oversight and a clear power to override the calculated outcome. This ensures each budget reflects the participant’s circumstances, including complexity of support needs and evidence from treating professionals.

Transparency also supports a well-functioning market. When participants and providers understand how therapy funding is set, they can plan services over the life of a plan, reducing disruption and the risk of underspending or overspending.

Recommendation 14 - OTA recommends the methodology for combining functional, DRHS, AT and assessment therapy inputs into a single therapy funding level be released for consultation before finalisation.

Review rights

Under old framework planning, funding is tied to a specific professional recommendation, giving participants a concrete basis for review. Under the proposed budget method, no document states how much therapeutic support a participant needs or why. If a participant disagrees with their therapy allocation, there is no single piece of evidence to point to or contest. That evidence is required to ensure the efficacy of a review.

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The draft plan clearly sets out the 28-day timeframe to apply to the ART after an internal review outcome. Stating how much weight evidence from treating professionals and other allied health practitioners carries at each review stage would ensure reviewers have the complete picture to make a fully informed decision.

Recommendation 15 - OTA recommends the therapy funding figure be accompanied by a plain-language explanation in the plan itself, showing which assessment inputs and settings produced it, so the decision is contestable at internal review and at the ART.

Complexity of support needs

Funding decisions also need to account for complexity of support needs, which is currently unaddressed in the budget method rules. Every support category, including therapy, is adjusted only for remoteness and category-specific offsets - no other adjustments are available. This contrasts with old framework planning, where complexity of support needs was frequently used to justify funding above a standard level.

Consider a participant with goals across daily routines, meal preparation, finding employment and learning to drive, alongside cognitive or communication factors that affect how they learn and apply new skills. Each goal may call for a different form of occupational therapy. An occupational therapist may support daily routines, meal preparation and employment, while an occupational therapist with driver assessment expertise addresses the driving goal. Some goals may also need to be worked on sequentially to avoid overload. A standard allocation of therapy hours cannot reflect the intensity, expertise and sequencing this combination of needs requires.

The same issue applies to multiple and interacting support needs. A frequency and level score in each domain captures severity within that domain. It does not capture how these needs interact. For example, a participant with cognitive impairment may find their mobility needs harder to manage than either need alone would suggest.

Complexity also changes over time. For example, a participant with Motor Neurone Disease or multiple sclerosis may have needs that shift substantially within a single plan. A fixed funding level without a complexity adjustment cannot respond to that change.

Funding complexity of support needs early ensures supports stay proactive and proportionate, avoiding more intensive and expensive responses later. A documented complexity adjustment would also improve the accuracy of budget setting across the entire Scheme.

Recommendation 16 - OTA recommends the adjustment mechanism for all categories, including therapy, explicitly include complexity of support needs as a documented basis for departing from a set funding level.

The plan implementation meeting

Understanding a budget depends on being able to discuss it. The consultation paper and draft report both describe the plan implementation meeting as something a participant “can choose” to have, not as an automatic step.

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The participants least likely to request this meeting are often those who need it most. This includes people who are new to the Scheme or unfamiliar with its terms, and participants with cognitive or psychosocial disability. An opt-in meeting is a weaker safeguard than the built-in planning conversation participants have under old framework planning.

Participants who understand their plan are more likely to use their funding as intended. A default meeting would support better plan use, reduce avoidable variation requests and help participants direct funding toward their goals from the start.

Participants also need to know when a conversation with the NDIA will inform their plan. Occupational therapists have reported that some participants are receiving informal ‘check-in’ calls from the NDIA without being told the call is a planning meeting. Without notice, participants cannot prepare, gather evidence or arrange for a nominee, treating professional or support coordinator to join. Clear advance notice of a meeting’s purpose would help participants take part fully and give the NDIA more complete information to base decisions on.

Recommendation 17 - OTA recommends the plan implementation meeting be opt-out rather than opt-in, with an explicit right for a treating professional or support coordinator to attend.

Recommendation 18 - OTA recommends the NDIA give participants advance written notice of the purpose of any meeting that may inform their plan, with enough time to prepare and invite support.

What questions and feedback do you have about the draft participant plan template?

Protecting therapy funding

The plan template would benefit from a clear way to protect therapy funding once it has been assessed and allocated. Therapy currently sits within the flexible-unrestricted budget, alongside in-home and community supports, low-cost AT and consumables. Each of these supports serves a different purpose. Over a plan of up to five years, spending on one support could unintentionally reduce the funding available for therapy that has been assessed as necessary for the participant to achieve their goals.

Consider a participant with an assessed need for occupational therapy to build skills and strategies for their morning routine and reduce the assistance they need from support workers. Over the plan, they use more of their flexible budget on support worker help with that routine. This is a legitimate use of their funding, but it gradually draws down the funding available for therapy. The therapy allocation runs out before the intervention is complete, and the participant continues to need the same level of support worker assistance.

Protecting assessed therapy funding preserves the participant’s ability to achieve their plan outcomes. When therapy stops early, the capacity-building gains that would lower future support needs are lost, and ongoing support costs rise.

That outcome runs counter to the insurance-based approach at the heart of the NDIS. The Scheme is designed to invest early in supports that reduce a participant’s lifetime needs and costs. Capacity-building

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therapy is one of the clearest examples of that investment. Protecting it within the plan is a practical way to put the Scheme’s insurance principle into effect.

The draft rules make this protection difficult to secure. Placing therapy funding in the flexible-restricted category would protect it, but the only worked example in the draft plan that justifies restricted funding rests on safety risk alone. Evidenced therapeutic need is not recognised in the draft plan.

OTA supports choice and control as a founding principle of the NDIS. Participants should decide how their funding is used, and that choice should include the option to protect funding for therapy. The decision to restrict therapy funding should sit with the participant, informed by evidence from their treating allied health professionals about the therapy needed to reach their goals.

Recommendation 19 - OTA recommends participants be able to restrict flexible therapy funding on the basis of therapeutic need evidenced by a treating professional, alongside the existing safety risk basis.

How therapy appears in plans and reports

The Department’s own sample documents show the gap between documented therapeutic need and assigned funding is already occurring. This presents a valuable early opportunity to better align budgets with support needs under new framework planning.

On page 10, Ishaan’s draft plan states that he sees an occupational therapist and receives speech therapy. This is a documented, current service, not an inferred need. Yet his plan lists five named categories his flexible funding can be spent on, and none is therapy supports. Either his occupational therapy is expected to be self-funded, or it has no clear, protected funding source. In the second case, it would have to draw on other category funding not designed for it. Either way, Ishaan cannot tell how his existing occupational therapy will continue to be funded.

John’s support needs assessment report shows a related problem. His core needs, as scored, align closely with occupational therapy supports. They include moderate support with cooking and cleaning and extensive support with household maintenance. Yet his final list of “assessed supports” contains five items, and none is therapy supports.

One of the items that does appear, “daily supports (flexible)”, is not defined anywhere in the report. It does not match any of the 18 named categories in the NDIS supports paper. The material provided does not make clear whether this is a broader grouping that can be spent on therapy or something else entirely.

Each sample document provided by the Department uses a different term for describing where therapy funding may sit:

A named category (‘therapy supports’ in the new framework planning paper)
An incomplete list of categories (Ishaan’s plan)
An undefined higher-level grouping (‘daily supports (flexible)’ in John’s report).

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None shows, from start to finish, how a clearly identified therapy need becomes a funded, visible line in a participant’s plan. If the Department’s own examples cannot show this clearly and consistently, participants, providers and plan managers will struggle to do so.

Sample documentation that traces a clearly identified therapy need through to a funded, visible line in a participant’s plan would be a valuable addition to new framework planning. Clear, consistent examples from the Department would give participants, providers and plan managers a reliable model to follow, and build confidence in the process. It would support Scheme stewardship and allow the NDIA to track how therapy funding is allocated and used, and to measure its effect on participant outcomes and long-term costs.

Recommendation 20 - OTA recommends the NDIA clarify how therapy funding will be displayed in a participant’s plan and support needs assessment report.

Recommendation 21 - OTA recommends the NDIA define ‘daily supports’ and reconcile it with the 18-category structure, with written confirmation of whether it includes therapy supports and under what conditions.

Plan variation and reassessment rules

What feedback and questions do you have about plan variations and reassessments?

A pathway for moderate change

Under new framework planning, there is no longer a clear pathway for moderate, clinically documented change in need over a long plan. The consultation paper’s examples of plan variations include management type changes, urgent crisis funding, repairs and replacements, and small increases in hours. These cover minor changes or urgent needs. They do not clearly cover a moderate, documented shift in functional or therapeutic need.

This gap will affect many participants, such as:

a child whose developmental growth creates new therapy and equipment needs
a person with a progressive condition whose support needs change gradually over several years
a person discharged from hospital after a fall, whose needs have changed but are not urgent.

Each needs a change that is neither urgent nor small, and none warrants an entirely new support needs assessment.

A pathway for moderate change would let participants access support when their needs first shift. A timely variation based on clinical evidence costs less than waiting for a situation to become urgent or completing a full reassessment. Early variation also reduces the risk (and associated cost) of falls and hospital admissions, and allows therapy to help participants maintain their skills.

This pathway becomes more valuable as plans lengthen. In a plan of up to five years, significant change becomes more likely. A clinically informed variation pathway would allow the Scheme to respond early,

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when changes in need are easier and less costly to address. Responding early would also reduce demand for full reassessments, easing pressure on NDIA assessment capacity as the new framework rolls out.

Recommendation 22 - OTA recommends a scheduled mid-plan review point be introduced for plans of three years or longer.

Recommendation 23 - OTA recommends updated clinical evidence from a treating professional, including evidence of therapeutic progress, be able to trigger a plan variation for moderate functional change, without requiring an emergency framing or a full reassessment.

NDIS supports rules

What impacts do you think will be experienced as a result of removing replacement supports? What items or services will no longer be available?

OTA welcomes the intent to simplify the replacement supports process, which many participants and providers have found confusing. Balancing simplification against any new risks would help the Department realise the full benefits of the reform.

Only tablets, accessibility apps, smartwatches and smartphones are proposed to become stated items within the replacement supports pathway. The paper states that no other items, including standard commercially available household items, would be available through a replacement supports process.

Occupational therapists regularly recommend modified or adapted mainstream products. These may sit outside the ‘assistive technology - assets’ definition. Retaining a mechanism for clinically justified replacement supports as a safety valve would ensure participants have access to recommended items that fall between category definitions.

In this context, ‘clinically justified’ should mean that the recommendation is based on an assessment of the participant’s disability-related needs, is linked to their goals and participation, and meets the reasonable and necessary criteria. This provides a clear basis for professional recommendations while retaining appropriate safeguards.

Individual clinical justification also allows supports to reflect each participant’s needs. Professionals working with a participant are well placed to make a clinically sound recommendation. For example, a participant with rheumatoid arthritis may have reduced grip strength that affects their ability to dry their hair independently. An occupational therapist may identify a lightweight hairdryer as an appropriate, low-cost solution, which the participant can trial and buy from a mainstream retailer. This one-off purchase enables independent self-care and removes the need for a support worker to complete the task.

These items also offer strong value, in that a one-off, low-cost item can replace recurring support. For example, a jar opener may reduce or remove the need for meal preparation support for a participant with limited hand function. Over a plan of up to five years, the item would cost far less than the recurring support it replaces.

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An individual, clinically justified pathway weighs the cost of an item against the cost of the support it replaces. This allows the Scheme to fund the option that delivers the best value and outcome for each participant.

Recommendation 24 - OTA recommends the NDIA introduce a mechanism to fund clinically recommended items that do not precisely match a category description, before replacement supports are withdrawn for old framework plans.

Recommendation 25 - OTA recommends any blanket exclusion retain a pathway for clinically justified, individually assessed exceptions.

Are there particular support types where more guidance may be needed?

Specialised driver training

OTA welcomes the recognition of specialised driver training as a separate support category. However, this needs further guidance, as no targeted assessment is attached to it. This risks funding amounts and guidance for driving instructors being set without any allied health input.

Safe, effective use of driver training funding depends first on establishing whether a participant can drive safely. Under old framework planning, participants may receive funding for driving lessons before anyone has assessed their capacity and suitability to drive. Some participants complete lessons, then undertake a driver assessment that identifies significant safety concerns or finds driving is not appropriate. This exposes participants and the public to avoidable risk and directs Scheme funds to training that cannot lead to a licence.

Occupational therapy driver assessment is a specialised area of practice that requires postgraduate training. Occupational therapy driver assessors evaluate whether a person can drive safely, identify the vehicle modifications they need and recommend the type and amount of training required. State and territory licensing authorities rely on these assessments to make licensing decisions.

Assessment before funding supports public safety and sound funding decisions. It ensures training is the right type and amount for the participant’s needs and well matched to any vehicle modifications. This helps participants reach licensing standards effectively and drive with the right supports in place. Where driving is not achievable, early assessment allows participants to redirect funding toward other supports that better align with their capacity, goals and circumstances.

For many participants, driving strengthens community participation, choice, and agency. It is often key to getting and keeping a job, which supports the Government’s goal of increasing economic participation for people with disability.

Recommendation 26 - OTA recommends a targeted occupational therapy driver assessment be required before NDIS funding is allocated for specialised driver training, with Occupational Therapy Driver Assessor (OTDA) input into funding amounts and guidance for driving instructors.

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Are there any practical issues, or unintended impacts that need to be considered?

The retail purchase pathway

OTA broadly welcomes the retail purchase pathway to streamline procurement of assistive technology. This is reasonable for mainstream, low-risk items. However, the guidance leaves “where appropriate” undefined. This gives support coordinators and plan managers no guidance on when professional advice is needed before purchase. It also leaves unclear who holds responsibility if an unsuitable item is purchased and causes harm. Clear guidance would protect participants and give everyone involved in a purchase confidence about their role.

Additionally, many items in the ‘assistive technology - other’ category need professional assessment to select safely and effectively. These include postural supports, modified seating and positioning products. The wrong product can cause harm - an unsuitable cushion can contribute to pressure injuries, and poorly matched seating can increase the risk of falls.

Successful AT outcomes rely on well-established, evidence-informed steps: goal setting, assessment, trial, AT matching, reporting and documentation, delivery and set-up, fitting and customisation, implementation, training, review, maintenance and repair. These steps apply whatever the purchase pathway. OTA’s Assistive Technology Capability Framework sets out this best practice. Allied health professionals, including occupational therapists, are well placed to apply proportionate assessment, decision-making support and implementation, matching the level of input to the item and the participant’s needs.

Well-matched items also deliver savings beyond the NDIS. The right cushion or seating helps prevent pressure injuries and falls, reducing demand on the health system and the need to replace unsuitable items. Targeted professional input for higher-risk items protects participants and keeps costs contained within a single, well-chosen support.

Recommendation 27 - OTA recommends the rules specify a threshold or item list that distinguishes supports safely purchased at retail without professional input from those that require documented allied health assessment and prescription, regardless of purchase channel, and clarify who holds responsibility for purchasing decisions.

Noise-cancelling headphones

The proposed blanket exclusion of electronic noise-cancelling headphones is too broad. Occupational therapists frequently prescribe them as part of sensory regulation strategies for autistic participants and others with sensory processing needs.

For these participants, headphones can support regulation, wellbeing and participation in school, work and the community. Without them, some participants may need more behaviour support or support worker hours. Those supports would cost more than the headphones and deliver less choice, autonomy, and control.

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A targeted carve-out allows the Scheme to fund the lower-cost, higher-value option where it is clinically justified.

Recommendation 28 - OTA recommends the carve-out structure already used for animal-assisted therapy be replicated: exclude headphones generally, but permit funding where an appropriately qualified allied health professional prescribes them as part of a therapeutic intervention in line with reasonable and necessary criteria.

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How our recommendations benefit the Scheme

OTA’s recommendations support the Government’s objectives for a fairer, more consistent and more sustainable NDIS. Adopting them would deliver better outcomes across six areas.

✓ Improved sustainability and lower lifetime costs Directly assessing and protecting therapeutic need puts the Scheme’s insurance principle into practice. Capacity-building therapy enables participation, builds choice and agency, and reduces reliance on ongoing paid support, lowering each participant’s lifetime costs. Low-cost, clinically justified items can replace recurring supports over a plan of up to five years. A pathway for moderate change lets the Scheme respond early, when changes in need are easier and less costly to address.
✓ Fairer, more consistent and transparent decisions A therapy targeted assessment module would ensure therapy need is identified consistently across the Scheme. Documented evidence sourcing, a published therapy funding methodology, and an adjustment for complexity of support needs would ground each budget in clear evidence. When participants and providers understand how funding is set, they can plan services over the life of a plan, supporting a stable, well-functioning market. These measures deliver on the Government’s commitment to transparent and consistent planning decisions.
✓ Lower administrative and review costs Getting the assessment right the first time reduces rework for the NDIA. Clinical input before a report is finalised, specific reasons for rejections and a plain-language explanation of therapy funding would reduce replacement assessments, internal reviews and applications to the ART. A moderate change pathway and a mid-plan review point would reduce demand for full reassessments, easing pressure on NDIA assessment capacity as the new framework rolls out.
✓ Stronger interface with mainstream services Timely access to well-matched equipment and clinically informed supports prevents falls, pressure injuries and hospital admissions. This reduces pressure on the public health system and supports the Government’s aim of a stronger interface between the NDIS and mainstream services.
✓ Improved workforce capacity and data Aligning support type with need directs support worker hours to participants who require ongoing assistance. Where therapy builds a participant’s own capacity, it eases demand on a workforce already under strain. Scoring support type and potential for change, and showing therapy funding as a visible line in each plan, would allow the NDIA to track which supports reduce need over time. This evidence would guide future planning and pricing decisions and strengthen Scheme stewardship.
✓ Increased participant confidence, safety and choice Clear evidence, accessible documents and a default plan implementation meeting would help participants understand their plans and use their funding as intended. Allowing participants to protect therapy funding on the basis of evidenced therapeutic need strengthens choice and control. Clinically informed driver training and AT prescription protect participant and public safety. Driving also supports the Government’s goal of increasing economic participation for people with disability.

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Conclusion

OTA wants new framework planning to succeed, and this submission has been written in that spirit.

We share the Government’s goals for a fairer, more consistent and more sustainable NDIS. Consistent assessment, clearer rules, and transparent budgets can improve outcomes for participants and strengthen confidence in the Scheme.

Achieving these goals depends on whether the framework can identify and direct funding to the supports most likely to build capacity, strengthen participation and reduce long-term reliance on ongoing paid support.

Therapy delivers on all three outcomes. As currently drafted, however, new framework planning does not directly assess or transparently cost therapeutic need at any stage, from assessment through to plan implementation and variation.

Getting this right would deliver benefits across the system:

Participants would build the skills, choice and autonomy that lower their lifetime support needs.
The support workforce would have more capacity for participants who need ongoing assistance.
The health system and other mainstream services would face less cost shifting and pressure.
The NDIA and the ART would manage fewer reviews, reassessments and appeals.
The Scheme would gain the data it needs to understand which supports are most effective.

OTA’s recommendations put these benefits within reach. Together, they would make therapeutic need visible, measurable and protected within the framework.

This would support fairer and more consistent decisions, ease pressure on the support workforce and strengthen the interface between the NDIS and mainstream services.

Occupational therapists bring unique expertise in functional capacity assessment and in translating what a person can do, and needs or wants to do, into the supports that enable meaningful participation in everyday life. This expertise is already embedded across the Scheme.

OTA is ready to put that expertise to work, partnering with the Department to build new framework planning that best serves participants, providers and the Government alike.

OTA would be glad to discuss this submission further and can be reached at policy@otaus.com.au

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Section Heading here

This Guideline sets out the actions needed to develop and approve an OTA Position Statement. It also provides a framework for the Position Statement document to ensure comprehensiveness and clarity.

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