Joint Standing Committee on the National Disability Insurance Scheme

Inquiry into Assistive Technology

Hon Kevin Andrews MP Chair Joint Standing Committee on the National Disability Insurance Scheme PO Box 6100 Parliament House Canberra, ACT 2600

dear Mr Andrews

Speech Pathology Australia welcomes the opportunity to provide feedback to the Joint Standing Committee on the National Disability Insurance Scheme’s Inquiry into Assistive Technology. As you are aware Speech Pathology Australia is the national peak body for speech pathologists in Australia, representing more than 8500 members. Speech pathologists are university trained allied health professionals with expertise in the assessment and treatment of communication and swallowing disabilities.

Some people with disability have complex communication needs (CCN) which are difficulties with understanding or the expression of communication, associated with additional physical, cognitive or sensory impairments. Many people with CCN benefit from the provision of alternative or additional methods of communication, including aided Augmentative and Alternative Communication (AAC) such as communication books, boards, speech generating devices and accessible IT for phone and internet based communication. Certain speech pathologists working in disability focus their practice on the assessment and provision of communication aids for people with CCN. This is a specialised area of the NDIS workforce. Speech pathologists working in this specific area of clinical focus typically develop their skills over many years working with people with CCN.

It is Speech Pathology Australia’s opinion that the NDIA is not operating a functional system for participants with CCN to timely access appropriate, evidence based or effective communication devices. While there has been some recent consultation with stakeholders in an effort to make improvements to the current system, there is still a lack of communication and clear process for providers to follow and planners continue to override practitioner’s decisions.

Evidence and feedback from our members working with NDIS participants and their families/carers from all states and territories is presented to illustrate the key issues we feel relate to the Inquiry’s Terms of Reference. We preface this with background information about CCN and AAC Assistive Technology.

As always, we would be very keen to appear before the Committee, to bring together leaders in the speech pathology profession with expertise and ‘real life’ experiences of these issues to provide more detail regarding the particular problems we highlight in our submission and to discuss potential solutions.

Yours faithfully

Gaenor Dixon National President

Introduction ………………………………………………………………………………………………………………………………… 4

About Speech Pathology Australia and speech pathologists ………………………………………………………… 4

About Complex Communication Needs ……………………………………………………………………………………… 4

What is AAC Assistive Technology (ACC AT)? …………………………………………………………………………… 5

How is the need for AAC AT assessed and prescribed? ………………………………………………………………. 6

Abandonment of AAC AT …………………………………………………………………………………………………………. 6

Speech Pathology Australia’s specific comments relating to the Inquiry’s terms of reference ……………….. 8

a. the transition to the NDIS and how this has impacted on speed of equipment provision ………………….. 8

b. whether the estimated demand for equipment to be sourced through the assistive technology process in each roll out area was accurate ……………………………………………………………………………………………. 8

c. whether market based issues impact the accessibility, timeliness, diversity and availability of assistive technology …………………………………………………………………………………………………………………………….. 9

d. the role of the NDIA in approving equipment requests ………………………………………………………………… 9

e. the role of current state and territory programs in the assistive technology process ………………………. 10

f. whether the regulatory frameworks governing assistive technology are fit-for-purpose ………………….. 11

g. any other related matters ………………………………………………………………………………………………………. 11

References ………………………………………………………………………………………………………………………………. 15

Introduction

Speech Pathology Australia welcomes the opportunity to provide feedback to the Joint Standing Committee on the National Disability Insurance Scheme’s Inquiry into Assistive Technology. We have structured our feedback in response to the Terms of Reference and conclude with recommendations that we hope the Commission will find useful. We preface our comments with background information on communication and swallowing disability and the role of speech pathologists in improving outcomes for people with complex communication needs (CCN) who require Augmentative and Alternative Communication Assistive Technology (AAC AT).

About Speech Pathology Australia and speech pathologists

Speech Pathology Australia is the national peak body for speech pathologists in Australia, representing over 8500 members. Speech pathology is a self-regulated health profession through Certified Practising Speech Pathologist (CPSP) membership of Speech Pathology Australia. Speech pathologists are not required to also be registered through the Australian Health Practitioner Regulation Agency (AHRPA).

The CPSP credential is recognised as a requirement for approved provider status under a range of government funding programs including the NDIS.

Speech pathologists are the university trained allied health professionals who specialise in treating speech, language, communication and swallowing problems. Speech pathologists work across the life span with infants, children, adolescents, adults and the elderly with communication and swallowing problems. Difficulties in speech, language, fluency, voice, social communication and swallowing can occur in isolation or the person may have difficulties in more than one area.

Certain speech pathologists working in disability focus their practice on assessment and provision of communication aids for people with CCN. This is a specialised area of the NDIS workforce. Speech pathologists working in this specific area of clinical focus typically develop their skills over many years of experience working with people with CCN.

The clinical protocols for speech pathology treatment are evidence based and backed by strong multidisciplinary scientific evidence for efficacy. Clinical protocols for the assessment and provision of AAC (in terms of type, design, method of access, and complexity etc.) differ depending on the clinical presentation and diagnosis of the participant, and aim to maximise their access, participation, and communication.

About Complex Communication Needs

Complex communication needs are difficulties with understanding or the expression of communication, associated with additional physical, cognitive or sensory impairments. People with CCN may have little or no expressive speech, or their speech may be unintelligible to some communication partners, or in some contexts. Complex communication needs can arise from lifelong disabilities, such as cerebral palsy, Autism Spectrum Disorder and other developmental disabilities such as Down Syndrome, Angelman’s Syndrome, Rett Syndrome and developmental apraxia of speech. Complex communication needs might also arise from acquired disability such as Motor Neurone Disease, Multiple Sclerosis, cerebral vascular accident (stroke), spinal injury or from traumatic brain injury.

While people with CCN have shared experience of many of the barriers to their communicative participation such as people directing their conversation and questions to carers, or avoiding interactions

Communication Needs

out of embarrassment, and may benefit from similar supports and strategies, in many other ways, they are a highly heterogeneous group. Their functional needs, individual difficulties, barriers to communication participation, and desired goals for participation will be different. For people with CCN the need for specialist assessments and intervention by speech pathologists is crucial.

Many people with CCN benefit from the provision of alternative or additional methods of communication, termed Augmentative and Alternative Communication (AAC) this enables them to meet their various communication needs as intelligibly, efficiently, independently (or autonomously) and in a way that is socially valued, to understand others and to be understood. Aided AAC may be electronic, or it may be non-electronic. Both electronic and non-electronic aided AAC can be complex to design, and require users to learn additional skills in order to be able to use it functionally.

According to the 2015 Survey of Disability, Ageing and Carers (SDAC), ‘the majority (81.6% or 850,500) of Australians with communication disability (living in households) use aids or equipment to assist them with their disability. Almost two-thirds (63.6%) of people with communication disability had a hearing aid, while others used low technology reading or writing aids (4.4%), high technology reading or writing aids (4.3%) and low technology speaking aids (1.8%). Other forms of aids used include email or internet (6.2%), cochlear implants (1.1%) and high technology speaking aids (1.0%).’i

What is AAC Assistive Technology (ACC AT)?

Additional or alternative methods of communication include symbol and text based boards, electronic tablets and Apps, and access supports such as mounting and switches.

                       Some examples of aided AAC include multi-level communication
                             books or boards, such as the Pragmatically Organised Dynamic
                                 Display system (PODD), or dedicated speech generating devices
                                         (typically micro-computers) – which offer a variety of different
                                symbolic systems, and accessing systems (such as head pointer
                            mouse, or track ball, or switch, or eye-gaze), or software systems
                              which can be used with laptops or other computers or tablets with
                      AAC Apps. Additional ‘accessories’, such as mounting arms,
                                  switches, keyguards, timing devices etc are also often required.

                                      In some cases, aided AAC is provided as part of an ‘integrated’
                       AT system i.e. along with a means to drive an electronic
                                  wheelchair, operate environmental control systems, and access     An example of an electronic
                                        IT, including mobile     speech generating device
                           phone and computer.

Information technology access is an increasingly important component of providing independent communication.

People with CCN often require more than one system to allow them to meet all of their communication needs, and a non- electronic system is almost always needed, to provide access to communication when their electronic system is unavailable.

                                             A PODD (non- electronic)
                                                                               5

How is the need for AAC AT assessed and prescribed?

All AAC methods need to be tailored to the specific needs of the participant. The tailoring of an AAC device to reflect an individual’s communication needs and interests, and to provide for efficient and independent communication, is typically managed by a speech pathologist in collaboration with the individual and their family/carers. Other supports for successful introduction and functional use of an AAC system include setting up and programming electronic devices, and training the individual and family/carers in the use of the device in different communicative contexts. The AAC system will need to be reviewed on an ongoing basis to ensure that use of the device continues to meet the needs of the individual.

Assessment and trialling of anAAC system may also require the collaboration of multiple allied health workers (speech pathologists, occupational therapists etc) depending upon the physical and sensory capacity of the individual. For example, communication devices may need to be fitted to wheelchair equipment to maximise a person’s ability to physically use the device. Aided AAC may need to be designed in such a way as to allow for visual tracking or visual field difficulties etc.

Assessment, trialling and prescription of AAC is dynamic (nonlinear) and frequently requires opportunities for extended trialling of a method by an individual to determine if it will meet their needs on an ongoing basis. This trialling is essential to ensure the AAC is ‘fit for purpose’ and will assist the person to achieve both their short and longer term goals.

Provision of AAC AT, both electronic and non-electronic, is a complex process. Individuals have differing needs and abilities which need to be considered for example:

learning to use AAC often requires the development of different and additional skills, which can vary for each type of AAC set up e.g. different symbol sets, different ‘navigation’ within the device, different operation (i.e. programming, or back up, or design access to vocabulary), depending upon the AAC selected.
new items and new versions of AAC devices are consistently coming on to the market (which can lead to issues with compatibility between the program and the system). For example, for the same device such as an electronic tablet, a large number of communication apps exist, each with different features which act like a completely different device. This is comparable to having to learn to use a Mac vs Android operating system. To know and understand the features each item offers, and to be able to match these with a participant’s abilities and requirements, requires the considerable expertise and knowledge of a speech pathologist.

Due to this complexity, it is common for speech pathologists (and other professionals) to work primarily and specifically in the AAC field over long periods of time. Practitioners with particular skills in AAC assessment and provision are a small but critical component of the NDIS provider market and there is no alternative provider market that participants with AAC AT needs can access.

Abandonment of AAC AT

It is unclear what the exact rates of AT ‘abandonment’ of AAC are at this point of the roll out of the NDIS. The 2015 NDIS Assistive Technology Strategy states that ‘research suggests a 30% abandonment rate for AT when the user has had little opportunity to exercise choice and control.’ii Whatever the figure, it is essential to consider and address the following factors that may lead to this lack of choice and control and subsequent AT abandonment on the part of the AAC useriii:

frustration due to lack of AAC knowledge on the part of the professional
equipment breakdowns
lack of relevant vocabulary
lack of support for device use on the part of caregivers, and
belief that they can communicate effectively without the device.

Leaders in the field of AAC, including many of our members, predict that the rates of equipment abandonment will be exacerbated given the myriad of problems associated with AAC assessment and access under the NDS being experienced. This has serious repercussions in regardsto the ‘value for money’ of particular AAC devices. No device is value for money if it is not able to be used to assist a participant to meet their current functional needs and support them to develop their communication skills and participation.

Speech Pathology Australia’s specific comments relating to the

Inquiry’s terms of reference

a. the transition to the NDIS and how this has impacted on speed of equipment provision

The transition to the NDIS has resulted in inconsistent and inappropriate arrangements for the funding and provision of communication devices for NDIS participants. The main issues include:

significant delays, in some cases of many months, for a participant to access an effective communication device

“I prescribed Proloquo for a child in December last year, the family were told it was approved but it never turned up. We followed up and got a rejection as the child already has an iPad (but not the prolo App) so on parent request we made a formal complaint in April, received a response stating it would be dealt with within three days - still haven’t heard back! Mum is ringing every week now but still nothing”. Member Nov 2017

confusion about the relationship between the jurisdictional schemes and the NDIS
lack of information for participants, providers (and apparently within the NDIS) about the processes of equipment provision. No information about where to send requests, no ‘return reply’ to confirm that requests have been received
poor, and in some instances no, communication from the NDIS regarding where in the process different orders/requests for equipment currently stand
incredible delays with getting funds into plans because of the requirement to undertake a full review if there is a need for funding/supports to be added to the plan
due to a lack of understanding by planners, providers are unable to claim for payment because the funds/supports have been allocated to a support category or item which they are unable to claim against or are not registered for
providers experience delays in the provision of equipment while awaiting a decision from the Technical Advisory Team (TAT), or because request paperwork has been lost
examples of inappropriate decisions from the TAT (e.g. recommending modifications which were technologically incompatible)
concern regarding the application of the same models for provision of AAC AT as for other types of AT when the needs are, and the processes should be, significantly different (e.g. the same process must be followed for the provision of a commode shower chair, as for a communication device).

b. whether the estimated demand for equipment to be sourced through the assistive technology process in each roll out area was accurate

While Speech Pathology Australia is not privy to the details of the demand estimates versus actual demand for assistive technology in the roll out areas, we would not be surprised to learn that actual demand for AAC AT was higher than anticipated, particularly for iPads and Apps. This expectation is

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c. whether market based issues impact the accessibility, timeliness, diversity and availability of assistive technology

The processes for procurement of AT, and the frequent, unpredictable and often poorly communicated changes in these processes have had implications for suppliers/providers. For example, the loss of State based ‘libraries’ of electronic aided AAC AT which could be borrowed and used as part of an assessment, trial, or allocated permanently, has created significant demand upon suppliers of AAC AT to provide electronic aided AAC systems for short term loan. The newly developed processes for provision of AAC AT through the NDIS are likely to drive a requirement for suppliers to offer electronic aided systems for medium to long term lease. This will enable people with disabilities to retain a device following a successful trial, while waiting for their next allocation of funds in their plan allocated to allow for purchase for long term use.

Participants need to be able to borrow or lease (using their NDIS funds) from an organisation which is able to offer a ‘library’ of devices for trial. To expect that primary providers and/or AT Advisors purchase (or even lease on a long term basis) the full range of electronic aided AAC that they need to have access to in order to support the provision of advice and support to participants is unrealistic. It will also likely have a flow-on effect of creating delays to the provision of the best solutions for participants because they will be on a waiting list to access the devices.

The reduced predictability of demand may lead to delays in provision where equipment is being ordered and shipped from overseas, particularly when it is expensive, as they are not readily stocked.

d. the role of the NDIA in approving equipment requests

There are constant and repeated requests for additional information about the clinical reasoning behind the AAC recommendations made by providers. These often require providers to produce lengthy feedback, outlining the entire process of assessment, trial and decision making which led to a recommendation, in order for planners to be able to make their determination of what is ‘reasonable and necessary’.

Planners are not adequately trained, and/or are without the necessary competencies, to understand and apply the NDIS guidelines in relation to aided AAC AT. For example, planners are reporting to participants that the NDIS does not purchase iPads because they are considered mainstream technology. This has led to providers making recommendations for the purchase of (often much more costly) dedicated electronic AAC devices, because the family or participant are not able to purchase an iPad (which will ONLY be used to support communication and participation) in addition to a specific communication app. This in affect means that planners are making decisions which are completely contrary to the NDIS principle of value for money.

The following is a case study based upon dialogue between the Association and a parent in NSW:

The child has moderate intellectual disability, severe apraxia and a diagnosis of Autism Spectrum Disorder who is non-verbal. The child uses Proloque2go (a speech generating App) on an iPad, and also

The Role of Current State and Territory Programs in Assistive Technology Process

During transition, the role of the state and territory programs has been unclear and poorly communicated. There is ongoing failure to recognise that the service delivery landscape has been transformed, with the requirement to engage and communicate with a new set of stakeholders in addition to the previous group. This has contributed to delays and increased costs for participants and/or for providers.

Speech Pathology Australia holds grave concerns about the potential impacts on the sector of the loss of the state based programmes, in particular their role in providing consultative advice to providers. This helped to build capacity in the community through a transfer of knowledge and skills, thereby enabling them to take a greater role in further processes to identify the best solutions for participants.

e. “My issue with rural services is that, as the only speech pathologist in my area, I am getting referrals for much more complex children than I used to. I am having to quickly skill myself up in AAC that is more than an iPad and ProLoQuo2Go. Once upon a time I could have called on the assistance of an ADHC NSW therapist, but now they are my competition. Now I am trying to provide the service in consultation with suppliers who really want to sell you their product” – Rural NSW speech pathologist

f. whether the regulatory frameworks governing assistive technology

are fit-for-purpose

Speech pathologists who are leaders on the field of AAC provision are expressing dismay at the current situation of AAC AT provision through the NDIS. They believe it is an erosion of the quality evidence based services that previously existed in many states and territories, and is undermining the benefits of the NDIS to participants who have CCN. The current regulatory framework governing AT is inconsistent, wieldy and too slow with reports of delays of many months, and in some cases even years, for a participant to access an effective and appropriate communication device.

“Participants are needing to appeal all the time on ridiculous decisions made by the NDIS in relation to AT and support needs that have been recommended by specialists. Why does the NDIS ask for or accept reports from therapists with years of experience only to decline their recommendations especially when there is evidence of it working? The appeals process and then tribunal where many end up is such a waste of valuable money and energy for families. The decision making process needs to be improved immediately to stop the system failing the participants.”

These delays not only preclude these individuals from participating in the ‘choice and control’ tenets of the NDIS but in extreme cases – such as the case of Mr Tim Rubenach who died waiting for a tilt bed that never arrivediv – such delays may have dire consequences.

In addition to the issues highlighted above Speech Pathology Australia members have also reported the following:

A recommendation made by an experienced speech pathologist has been denied outright for the participant or the ‘type’ of AAC has been denied and an alternative approved without input from the speech pathologist as to its appropriateness for the individual participant.

“I’ve had a client knocked back for a LAMP app (which he uses functionally to communicate). I didn’t apply for a dedicated device because all those requests were getting knocked back so I tried to help NDIS and suggest a cheaper option. The reason the planner gave her was “children under six shouldn’t be using that sort of technology to Communicate, they are too young”. Who are these people? What is their background in AAC? I’m a disability clinician, but I am starting to think this is all too hard basket now that NDIS is in town.”
Seemingly arbitrary ‘caps’ placed on the amount that can be spent on AAC. A ‘cap’ of $1000 is common and is seen to reflect an erroneous presumption by planners that any participant with a communication need can have their needs met through the provision of an ‘iPad’ with Apps (equating to approximately $1000). There are multiple problems with this, the least of which is that participants with physical limitations may be unable to physically use an iPad.

“high frustration around the length of time families are waiting for an early intervention plan (up to 1 year) - very frustrated by the time children are waiting for NECESSARY equipment (seating for mealtimes, communication devices). Planners refusing AT due to ‘doubling up’ of services, but often our children need more than one communication system (e.g. Auslan, communication system and

therapy). Planners thinking that mainstream devices (iPads) will suffice as communication systems when an alternate specific AT device has been trialled and recommended
Planners refusing to fund the purchase of a tablet/iPad, and only approving the cost of the communication App within the Plan.
Lengthy and administratively burdensome processes for speech pathologists to support participants to appeal decisions made to deny funding for a particular AAC device. Speech pathologists are not funded to participate in appeals processes on behalf of participants, and this can be a lengthy and complex process.
The listing of an AAC device in a participant’s plan occurs during the plan development stage, in isolation from any recommendations from experts in AAC provision, and is therefore not informed by expert advice. Due to the current problems in reviewing plans mid-cycle, there is a significant delay if the AAC device in the plan needs to be altered based upon an assessment by a speech pathologist.

“We continue to have concerns here in Victoria regarding the negative impact (of the NDIS) on people with complex communication needs. We continue to experience: - lengthy delays in delegate decisions - poor communication and poor stakeholder engagement - applications for stand-alone speech generating devices declined contrary to recommendation of the prescribing speech pathologist and clinical reviewer - lack of consideration of specialist/expert opinion - lack of responsiveness in urgent cases such as device repairs and applications for communication technology for participants with Motor Neurone Disease and other progressive neurological conditions High level advocacy from exec managers in our organisation appears to be falling on deaf ears”

An insistence that only one AAC device will be funded through the NDIS. This presumes that a person’s communication needs will be met in all circumstances by one device. It is common for an individual to have a range of solutions that are part of their overall communication system. For example a person may have two electronic speech generating devices with a more complex system for in-depth conversation with family, along with a simpler system such as a single switch device with some ‘quick’ messages, to use when at a café, or catching public transport.
This ‘one item for the same purpose’ principle has also meant that participants who require both a non-electronic and an electronic aid are required to choose only one of these. This is at odds with best practice principles and can mean that participants may be left without a voice – for example, when their electronic system ‘fails’, or when it is not appropriate to use (for example, when camping with their family or while at the pool).
The variation in length of time to approve the release of funds to purchase an AAC device can be considerable. In some cases, approval has taken many months. This is unacceptable for participants who have no other form of functional communication.

“AT Requests are taking too long to be processed - they do not appear to be even looked at before 10 months without a client ringing and asking what is happening, and only then it gets escalate. AT Requests being denied by planners with little to no experience with AAC - do not accept the recommendations provided by Speech Pathology - inconsistency in plans - appears to be completely dependent upon what planner you get.”

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discriminatory to restrict a child from using their AAC device, simply because it happens to be within an educational setting. This is equivalent to not allowing a child with mobility issues to use their wheelchair at school.

An incongruence between placing the burden of the full cost for an AAC device within a single annual plan, without considering the lifespan of the device. For example, an appropriate but expensive AAC device might be funded in the plan for 2017 but may ‘last’ over ten years for that participant. There appears to be no mechanism for spreading the cost of the item over multiple NDIS plans.

People in the disability sector with expertise or lived experience of communication disability are clear that these issues demonstrate a lack of understanding by the NDIS.

Participants cannot communicate their complaint to the NDIS if they have not been provided with an appropriate communication device but more importantly, they are unable to truly build their capacity and take the opportunities to exercise their choice and control across all aspects of their lives. Speech Pathology Australia contends that it is highly likely that participants with CCN who require AAC AT are disproportionately included in the group of NDIS participants who are described in the Final Report of the Evaluation of the NDIS as those participants who are ’not experiencing improved outcomes as they are unable to effectively advocate on their own behalf.’v

Many of these problems are exacerbated by the turnover of planners within the NDIS and the communication issues that have been identified and acknowledged through the Productivity Commission’s recent report into the NDIS Costsvi.

In addition to the immense and in some cases extremely detrimental effect on participants, these delays and system failures also have a practical and emotional toll on providers. Speech pathologists find themselves spending many extra (unpaid) hours of work advocating on behalf of their client. This also has associated emotional stress which when combined with the practical frustrations, has the potential to become so great that providers will de-register from the scheme.

“I’m concerned that good people will leave our field due to this kind of stress and our clients will be stuck with clinicians who just toe the line and settle for the inappropriate solutions because they are cheaper or because it’s easier just to accept what is being offered. The NDIS was not set up to create this type of situation and I hope it doesn’t come to this. Each time we call, email or correspond with them, time goes by and weeks and months pass that is valuable learning time for our clients to develop skills with their systems. Money gets spent on documentation and additional time to assess and respond to all of the concerns of the NDIS and families get more frustrated and are left with a sense of having to feel grateful for anything they get rather than excited to support their child to achieve their potential.”

Recommendations

Speech Pathology Australia recommends that the process for provision of AAC AT (electronic and non- electronic) under NDIS:

recognises that the provision of AAC AT is different to the provision of other AT and therefore requires the inclusion of different and additional system components.
enables a group of providers to develop and maintain more specialised knowledge and skills regarding a range of AAC AT options that are available, their features, and how these interact with and match to a participant’s abilities and needs. These ‘specialist’ providers can then in turn act as AT Assessors and/or as AT Advisors to participants and/or primary providers to expand their competencies and therefore their role in supporting participants to identify the best AAC AT solutions. This role is essential to continually and sustainably build capacity in the sector, and therefore should not be funded through individual plans, or provided as a one off Linkages and Capacity Building Grant.
funds access to AAC AT for use by providers to enable them to trial the full range of potential solutions and truly provide for participant ‘choice and control’.
includes efficient and effective mechanisms to support participants and those in their environment to learn about the operational aspects of their AAC AT system and provides access to ‘troubleshooting’ supports for their electronic AAC AT.
provides timely access to replacement systems when participant’s electronic AAC AT requires repair or maintenance
funds individuals to access non-electronic as well as electronic AAC systems and more than one piece of electronic aided AAC AT to enable them to meet their diverse communication needs across different contexts.
recognises that access to ICT is an increasingly important component of communication for all Australians, including those with a disability and therefore improves the accessibility of the NDIS website, and MyPlace participant portal to allow people with disabilities, including communication disability, to be able to access the portal, and potentially manage their own supports.
addresses the factors that lead to abandonment of AT
recognises people with CCN as a discrete community of people with disability in their own right, who experience specific and additional barriers to participation, and with specific needs, who require access to a specific and shared group of supports, that should be funded out of the ILC funding on an ongoing basis.

Finally, we would add that the development of the new system should be informed by work that has already been done in Australia such as the State Wide Complex Communication Project in South Australia and internationally, for example the evidence based research report from Communication Matters in the UKvii.

References

i Australian Bureau of Statistics (2017) Australians living with communication disability, http://www.abs.gov.au/ausstats/abs@.nsf/Latestproducts/4430.0Main%20Features872015?opendocume t&tabname=Summary&prodno=4430.0&issue=2015&num=&view

ii NDIA (2015) NDIS Assistive Technology Strategy, https://www.ndis.gov.au/html/sites/default/files/AT-Paper_0.pdf See: Strong, J. G., Jutai, J. W., Plotkin, A. D. and Bevers, P. (2008) ‘Competitive Enablement: A Consumer-Oriented Approach to Device Selection in Device assisted Vision Rehabilitation’ in Mann, W. C., ed. Assistive Technology Research Series, Volume 22: Aging, Disability and Independence, Amsterdam: IOS Press, 175-195)

iii Moore, K. (2008) AAC Project Independent Living Centre WA Mapping Best Practice https://docplayer.net/33194464-Aac-project-independent-living-centre-wa-inc-disability-industry-plan-seed-grant-mapping-best-practice.html

iv http://www.abc.net.au/news/2018-06-01/tas-ndis-apology-after-tim-rubenach-ordeal/9824450

v Mavromaras, K. et al (2018) Evaluation of the NDIS Final Report, Flinders University Adelaide.https://www.dss.gov.au/sites/default/files/documents/04_2018/ndis_evaluation_consolidated_re port_april_2018.pdf

vi https://www.pc.gov.au/inquiries/completed/ndis-costs/report/ndis-costs.pdf

vii Communication Matters Research Matters (2013) an AAC Evidence Base research project – final report: Shining a light on Augmentative and Alternative Communication https://www.communicationmatters.org.uk/page/evidence-base

Assistive Technology for People with Complex Communication Needs