Measuring what matters: NDIS performance, participant

service guarantees and the timely supply of assistive technology

ATSA submission to the Joint Committee of Public Accounts and Audit Inquiry into the administration of the National Disability Insurance Scheme

              January 2026

               Assistive Technology Suppliers Australia
                  Suite 302, Level 3 Lawson Place
            165 -167 Phillip St Sydney NSW 2000

                     02 8006 7357
                       www.atsa.org.au

                            Drafted by:
                   Karen Larsen-Truong
                       Policy Officer

                      Approved by:
                      Serena Ovens
                Chief Executive Officer

redacted

Contents

Summary of Recommendations ……………………………………………………………………… 4

Introduction …………………………………………………………………………………………………. 5

Stated commitments on AT decisions are not supported by AT-specific performance targets ……………………………………………………………………………………… 5
Reporting does not explain why targets are missed or what should be done ……… 7
Administrative controls and processes contributing to delays in AT supply ………… 8

Closing ………………………………………………………………………………………………….. 9

References ………………………………………………………………………………………………… 10

About Assistive Technology Suppliers Australia (ATSA)

Assistive Technology Suppliers Australia (ATSA) is Australia’s national peak body representing the needs of assistive technology suppliers, distributers, manufacturers and technicians. We also work closely with the allied health sector, with allied health professionals being eligible for affiliate membership.

ATSA require our members to adhere to a comprehensive Code of Practice on the provision, sales and servicing of assistive technology (AT).

We are a registered not-for-profit organisation with charitable status, ensuring we advocate for the rights of people with disability and older persons to access the most appropriate assistive technology to provide for their ongoing independence and individual needs.

Our Purpose is to support the assistive technology industry to enhance the lives of Australians with disability by:

Ensuring the provision of quality equipment
Upholding ethical business practices
Conducting research
Promoting education
Cultivating partnerships
Advocating for positive change with government and other stakeholders

We are also a member of the Australian Ethical Health Alliance.

Summary of Recommendations

Recommendation 1: Publicly report on the PSG for complex plan variations (50 days)

ATSA recommends that quarterly reporting on PSGs include performance against the 50 day target for complex plan variations, which relates to the stated commitment for decisions on high-cost AT.

Recommendation 2: Establish AT–specific performance targets

The NDIA should establish clear, AT-specific performance targets that measure the timeliness and continuity of assistive technology provision under the NDIS. Without AT-specific metrics it is impossible to measure progress or target reforms that will reduce unnecessary delays.

Recommendation 3: Publicly report AT-specific performance outcomes

ATSA recommends that AT-specific performance targets and results be reported publicly, including through NDIS quarterly reports to disability ministers and NDIA annual performance statements. Public reporting would strengthen transparency, accountability and confidence that delays affecting essential supports are being monitored and addressed.

Recommendation 4: Disaggregate AT performance data to support oversight

AT performance targets and results should be disaggregated to enable meaningful oversight, including by:

AT type (e.g. manual wheelchairs, power wheelchairs, vehicle modifications)
AT cost (e.g. low, medium or high cost AT); and
Rental vs purchase

Disaggregated reporting would support the NDIA Board and the Parliament to identify systemic bottlenecks and recurring issues that are not visible in aggregated performance data.

Recommendation 5: Link AT performance results to remedial action

Consistent with ANAO expectations for meaningful performance reporting, the NDIA should be required to:

explain variances where AT performance targets are not met; and
clearly identify remedial actions, timeframes and accountability for addressing underperformance.

Recommendation 6: Adopt proportional, risk-based controls informed by performance data

ATSA considers that ANAO findings point to the need for more proportionate, risk- based administrative controls, supported by performance data that clearly shows where delays are occurring and why. Stronger linkage between administrative processes, PSG performance and participant outcomes would enable the NDIA Board and the Parliament to assess whether controls are achieving their intended purpose without undermining access to essential supports.

Introduction

Over recent years ATSA members and other stakeholders have repeatedly reported long waits for participants to receive essential assistive technology (AT) under the National Disability Insurance Scheme (NDIS). That concern is reflected in official performance data on NDIS Participant Service Guarantees (PSGs). For example, PSG 14, which requires an amendment to a participant’s plan within 28 days of receipt of information, was met in only 44 per cent of cases nationally in Q1 2025– 261, and performance against this guarantee has remained well below target in recent quarters, underscoring the scale of the timeliness problem for AT decisions.

Importantly, our members report that delays in AT provision can lead to:

increased risk of injury or deterioration in function;
avoidable hospitalisation;
delayed independence, social and workforce participation; and
increased costs to the NDIS due to reliance on other more expensive forms of care.

Finding the causes and practical fixes for delayed access to AT is made harder by insufficient AT-specific data and a lack of AT-specific performance targets. The reports supplied by the Australian National Audit Office (ANAO) also identify a set of recurring weaknesses in how the NDIA monitors and explains performance and other operational weaknesses that can contribute to delays. The purpose of this submission is to outline these shortcomings, describe their implications and recommend practical ways to improve monitoring, measurement and reporting to support more timely AT supply. Each section below explains a particular aspect of the problem and sets out practical recommendations for clearer monitoring, measurement and reporting.

1. Stated commitments on AT decisions are not supported by AT-specific performance targets

Referencing the Participant Service Guarantee, the NDIA has made the following commitments around decisions on AT:

“For your current plan we’re required to make a decision about low and mid cost assistive technology within 28 days. We’re required to make a decision within 50 days if it’s high cost.”2

However, these commitments do not refer to AT-specific targets but instead refer to general PSG targets for all plan variations, as described below.

Commitment 1: decision on low and mid cost AT within 28 days The first commitment refers to PSG 14 ‘Decide whether to vary a plan, after the NDIA informs a participant that more time is required’ (28 days) and is referenced in both the Participant Service Charter and Participant Service Guarantee. Performance against this target is reported in NDIS quarterly reports to disability ministers.
Commitment 2: decision on high cost AT within 50 days The second is not referenced in the Participant Service Guarantee or given a number, but can be found in the Participant Service Charter under Plan Variations3. It refers to the guarantee: ‘For more complex situations, decide
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whether to vary a plan, after the NDIA informs a participant that more time is required’ (50 days). Performance against this target is not publicly reported, making it impossible to monitor performance.

In both cases, the commitments for decisions on AT have the following shortcomings:

Not AT-specific. They both refer to performance targets for plan variations in aggregate, not to AT decisions.
Only partially reported on in NDIS quarterly reports to disability ministers (50 day target for complex plan variations is not reported).
Do not provide performance targets or data on the actual time taken for NDIS participants to receive the AT they need.

More generally, AT decisions are made through several pathways (initial plan development, plan reassessment, plan variation, internal review) and are impacted by a range of administrative processes not fully captured in current PSGs. For example, there are no published targets for:

time taken from identification of AT need to AT approval;
time taken to approve repairs or replacements of existing AT;
duration participants are without essential equipment due to administrative processes; or
repeated delays experienced by participants with complex or changing AT needs.

In the absence of AT-specific targets, delays in AT supply can remain hidden within aggregated reporting, even where they have significant functional and safety consequences for participants.

Recommendation 1: Publicly report on the PSG for complex plan variations (50 days)

ATSA recommends that quarterly reporting on PSGs include performance against the 50 day target for complex plan variations, which relates to the stated commitment for decisions on high-cost AT.

Recommendation 2: Establish AT–specific performance targets

Recommendation 3: Publicly report AT-specific performance outcomes

2. Reporting does not explain why targets are missed or what should be done

Across multiple quarters, NDIS quarterly reports to disability ministers acknowledge that certain PSGs are not being met but provide limited explanation of underlying causes. Commentary typically references increased demand, workforce pressures, or reform activity, without clearly identifying:

root causes of delay;
whether delays disproportionately affect particular cohorts or support types; or
what corrective actions are being taken and whether they are effective.

More broadly, although the PSG framework is intended to reflect participant experience, quarterly reporting primarily presents:

aggregate percentages of matters completed within statutory timeframes;
high-level commentary on improvements or pressures; and
Incomplete reporting for all PSGs

Reports do not provide sufficient disaggregation to show:

the impact of delays on specific support types, including AT;
whether delays relate to urgent, safety-critical or complex supports; or
how long participants wait beyond the PSG timeframe when guarantees are not met.

As a result, PSG compliance does not reliably indicate whether participants receive timely access to essential AT, particularly where delays occur after plan approval or during administrative processing.

This mirrors findings in ANAO reports that performance reporting lacks sufficient analysis to support governance and improvement, and allows persistent PSG underperformance to be reported without resolution. For instance, Auditor-General Report No. 41, Effectiveness of the Board of the National Disability Insurance Agency, identifies significant weaknesses in how the NDIA monitors, analyses and reports performance information to its Board, including performance against Participant Service Guarantees (PSGs)4. Report No. 41 found that while the NDIA Board received regular performance reports, reporting tended to focus on high-level, aggregated results, with limited disaggregation or trend analysis. Reporting did not consistently identify causes, risks or corrective actions, limiting the Board’s ability to understand why delays were occurring or how they could be resolved. The report also highlights that performance reporting was insufficiently linked to risk and improvement frameworks. The audit further noted that the Board did not consistently seek further information or assurance from management when performance results were below target, meaning that repeated PSG failures could be reported without triggering escalation or targeted intervention.

These findings align with the conclusions of Auditor-General Report No. 25 (2024– 25), Performance Statements Auditing in the Commonwealth — Outcomes from the 2023–24 Audit Program5. That report found that across entities (including the NDIA), performance information often lacked completeness, usefulness and sufficient analysis to support accountability and improvement.

Report No. 25 identified recurring issues where:

performance measures were not sufficiently informative for decision-making;
results were reported without adequate narrative explaining variances; and
entities could not always demonstrate how performance information was being used to improve service delivery.

To support more transparent and improvement focused monitoring of AT supply under NDIS, ATSA makes the following recommendations:

Recommendation 4: Disaggregate AT performance data to support oversight

AT performance targets and results should be disaggregated to enable meaningful oversight, including by:

AT type (e.g. manual wheelchairs, power wheelchairs, vehicle modifications)
AT cost (e.g. low, medium or high cost AT); and
Rental vs purchase

Disaggregated reporting would support the NDIA Board and the Parliament to identify systemic bottlenecks and recurring issues that are not visible in aggregated performance data.

Recommendation 5: Link AT performance results to remedial action

Consistent with ANAO expectations for meaningful performance reporting, the NDIA should be required to:

explain variances where AT performance targets are not met; and
clearly identify remedial actions, timeframes and accountability for addressing underperformance.

3. Administrative controls and processes contributing to delays in AT supply

ATSA is concerned that findings of the ANOA reports indicate that NDIS administrative controls may be contributing to avoidable delays in the supply, repair and replacement of AT. In particular, the audits indicate that the NDIA has increasingly strengthened administrative controls to manage financial risk, compliance and scheme sustainability. While appropriate controls are necessary, their implementation has not been consistently balanced against the need for timely access to supports, including AT.

Auditor-General Report No. 48, National Disability Insurance Agency’s Management of Claimant Compliance with National Disability Insurance Scheme Claim Requirements National Disability Insurance Agency, found that the NDIA’s approach to claimant compliance and payment assurance has been evolving, with additional checks, reviews and validation processes introduced over time6. The audit noted that these controls are partly effective but remain under development, with frequent changes to processes and reporting arrangements. Importantly, the report highlighted that controls were often implemented before being fully embedded or supported by mature systems, increasing administrative complexity and processing time.

Auditor-General Report No. 25 identified broader weaknesses in performance information across Commonwealth entities, including insufficient explanation of variances and weak linkage between performance results and remedial action5. In the NDIA context, this contributes to administrative rework, where decisions are revisited, additional documentation is requested, or approvals are escalated without clear criteria.

In practice, ATSA members report that these controls may be contributing to:

unexplained delays in processing requests for AT;
delays in approving repairs;
repeated requests for additional evidence to occupational therapists where functional need is already well established; and
re-assessment of low-risk AT items through high-burden approval pathways.

Unlike some supports, delays in AT provision often cannot be mitigated through interim measures. Where equipment is broken, unsafe, outgrown or no longer fit for purpose, participants may be left without essential mobility, communication or daily living supports while administrative processes are completed. Therefore, ATSA makes the following recommendation:

Recommendation 6: Adopt proportional, risk-based administrative controls informed by performance data

Closing

This submission highlights that delays in access to AT under the NDIS are closely linked to gaps in performance measurement and reporting. While the NDIA has articulated commitments on decision timeframes, the absence of AT-specific targets, incomplete PSG reporting and limited explanation of underperformance make it difficult to understand where delays occur and how they might be addressed. Consistent with ANAO findings, ATSA considers that clearer, more targeted monitoring and reporting would support better oversight and help improve the timeliness of assistive technology provision for participants.

References

NDIS 2025, Quarterly Report Q1 2025–26. Available at: https://www.ndis.gov.au/publications/quarterly-reports
NDIS 2023, How can you get assistive technology in your plan? Available at: https://ndis.gov.au/our-guidelines
NDIS 2022, Participant Service Charter, Accessed 20/01/2026, Available from: https://www.ndis.gov.au/about-us/service-charter#participant-service-guarantee
Australian National Audit Office 2025, Auditor-General Report No. 41 (2024-25), Effectiveness of the Board of the National Disability Insurance Agency. Available at: https://www.anao.gov.au/sites/default/files/2025-06/Auditor-GeneralReport2024-2541.pdf
Australian National Audit Office 2025, Auditor-General Report No. 25 (2024-25), Performance Statements Auditing in the Commonwealth - Outcomes from the 2023– 24 Audit Program. Available at: https://www.anao.gov.au/sites/default/files/2025-03/Auditor-GeneralReport2024-2525.pdf
Australian National Audit Office 2025, Auditor-General Report No. 48 (2024-25), National Disability Insurance Agency’s Management of Claimant Compliance with National Disability Insurance Scheme Claim Requirements National Disability Insurance Agency. Available at: https://www.anao.gov.au/sites/default/files/2025-06/Auditor-GeneralReport2024-2548.pdf
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ATSA submission on monitoring and reporting for assistive technology supply under the NDIS

Measuring what matters: NDIS performance, participant

About Assistive Technology Suppliers Australia (ATSA)

Summary of Recommendations

Recommendation 1: Publicly report on the PSG for complex plan variations (50 days)

Recommendation 2: Establish AT–specific performance targets

Recommendation 3: Publicly report AT-specific performance outcomes

Recommendation 4: Disaggregate AT performance data to support oversight

Recommendation 5: Link AT performance results to remedial action

Recommendation 6: Adopt proportional, risk-based controls informed by performance data

Introduction

1. Stated commitments on AT decisions are not supported by AT-specific performance targets

Recommendation 1: Publicly report on the PSG for complex plan variations (50 days)

Recommendation 2: Establish AT–specific performance targets

Recommendation 3: Publicly report AT-specific performance outcomes

2. Reporting does not explain why targets are missed or what should be done

Recommendation 4: Disaggregate AT performance data to support oversight

Recommendation 5: Link AT performance results to remedial action

3. Administrative controls and processes contributing to delays in AT supply

Recommendation 6: Adopt proportional, risk-based administrative controls informed by performance data

Closing

References