Administrative barriers to access of assistive technology and home modifications for NDIS participants

Australian Rehabilitation and Assistive Technology Association (ARATA) Submission to the Joint Committee of Public Accounts and Audit

30 January 2026

redacted redacted

ARATA would like to acknowledge and thank the many ARATA members who contributed their knowledge, experiences, and expertise to inform this response.

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Executive Summary

ARATA welcomes the opportunity to make a submission to the Inquiry to the Administration of the NDIS, as convened by the Joint Committee on Public Accounts and Audit (hereafter called the Committee). This submission addresses systemic weaknesses in the administration of the National Disability Insurance Scheme (NDIS) that directly affect participant access to assistive technology (AT) and home modifications. ARATA’s evidence highlights persistent challenges in performance monitoring, decision-making consistency, and application of legislative and policy frameworks - particularly Sections 10 and 33 of the NDIS Amendment Act 2024 and the Support Lists.

These administrative issues undermine Scheme objectives by delaying or denying cost-effective, evidence-based supports essential for participant independence, safety, and social and economic participation. The issues raised fall within the Committee’s terms of reference, including governance, administrative efficiency, value for money, transparency, and accountability.

As the NDIS transitions to new planning and assessment frameworks, ARATA emphasises the importance of learning from past administrative challenges to ensure reforms improve, rather than restrict, access to essential AT and home modifications.

Key Recommendations

1. Require public reporting against the Participant Service Guarantee (PSG), with an expanded scope to include timeframes for complex plan variations (e.g. high-cost assistive technology).
2. Establish AT–specific performance benchmarks covering approval, repair, replacement, and continuity of AT supports.
3. Mandate public reporting of AT performance outcomes, including accessible data by AT type, complexity, and funding model.
4. Ensure administrative controls affecting AT are proportionate and risk-based, informed by performance data and participant outcomes.
5. Improve consistency and transparency in the application of Section 10 and the Support Lists, including safeguards against inappropriate exclusion of cost-effective AT solutions.
6. Prevent AT denials arising from administrative errors including removal or “end-dating” of recognised impairments without participant notification or due process.
7. Ensure new framework planning and assessment processes can identify AT and home modification needs, supported by a skilled assessor workforce and co-design with participants and peak bodies.
8. Simplify replacement support processes for low-risk or mainstream items with clear functional benefit, reducing unnecessary administrative burden.

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1. About ARATA

The Australian Rehabilitation and Assistive Technology Association (ARATA) is the national non-profit peak body representing assistive technology stakeholders. ARATA works to advance access to rehabilitation and assistive technologies and promote practices that ensure positive outcomes from their use for people of all abilities. ARATA includes a membership of both National Disability Insurance Scheme (NDIS) participants and NDIS providers, as well as other assistive technology (AT) stakeholders across all experiences of individual AT use, the provision of AT advice (e.g. via health professionals), AT supply, product development, and AT research and education in Australia and internationally.

ARATA provides a national forum for information sharing and liaison between people who are involved with the use, selection, customisation, supply, research and ongoing support of rehabilitation and assistive technologies. Our Association promotes, develops, and supports the national rehabilitation and AT community of practice as well as contributing as a founding organisation to the Global Alliance of Assistive Technology Organizations (GAATO).1

Through its membership, ARATA represents the interests and opinions of the full range of AT stakeholders in Australia. ARATA maintains that roles for all AT stakeholders must be considered, centred around the goals and needs of people who use AT in their own lives, and their informal supporters , including family members and carers, who may engage with the NDIS.

2. The Role of Assistive Technology in the NDIS

The World Health Organization (WHO) defines AT as an umbrella term encompassing assistive products, assistive systems, and assistive services.2 Assistive technology range from physical devices such as wheelchairs, glasses, and prosthetic limbs, to digital solutions including speech recognition software, captioning services, navigation tools, and time-management applications.

The WHO recognises that AT supports participation across all life domains, including education, employment, leisure, self-care, and everyday activities such as cooking. Effective access to AT delivers benefits not only for individuals, but also for families, carers, and the broader economy through improved independence, reduced reliance on paid supports, and better health and wellbeing outcomes.

Under the NDIS, AT and home modifications are fundamental supports, not optional extras, and are essential to achieving Scheme objectives.

1 History | GAATO 2 Assistive technology

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3. Declining Access to Assistive Technology Following Legislative Change

ARATA supports broad reform to ensure the NDIS is financially sustainable while effectively identifying and meeting the support needs of people with significant disability. However, evidence indicates that recent (2024) legislative and administrative changes are having unintended consequences for access to AT and home modifications redacted.

Since the legislative amendments took effect in late 2024, the proportion of NDIS participants accessing AT has fallen by approximately 10 per cent between October 2024 and June 2025, accelerating a downward trend evident since 2021–223. These findings align with anecdotal evidence reported by ARATA members regarding reduced access to AT and home modifications following the changes.

Available data also demonstrates inequities across groups, with First Nations participants and those living in remote or very remote areas experiencing significantly lower access to AT and home modifications. These disparities raise serious concerns about the administrative equity of the Scheme, which appears to have been impacted by the implementation of recent legislative change.

4. Assistive Technology Delays and Weaknesses in Performance Monitoring

ARATA members consistently report prolonged delays in participant access to essential AT and home modifications. These delays are reflected in Participant Service Guarantee (PSG) data4, which shows sustained underperformance in plan variation timeframes that frequently underpin AT approvals.

For example, PSG 14 (28 days for certain plan variation decisions) has been met in fewer than half of cases nationally in recent reporting periods. While the NDIA has also committed to a 50-day timeframe for more complex decisions - often relevant to higher-cost AT - performance against this benchmark is not publicly reported, preventing meaningful scrutiny.

Delays in AT and home modification access have serious consequences, including:

• increased risk of injury and deterioration in function;

• avoidable hospital admissions;

• reduced independence and participation; and

• higher Scheme costs due to reliance on substitute or crisis supports.

Existing PSGs do not capture the participant’s end-to-end experience of obtaining AT. There are no published benchmarks addressing:

3 NDIS participants use of assistive technology - Personal and community support - Australian Institute of Health and Welfare 4 Participant Service Guarantee | NDIS

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• time from identification of AT need to approval;

• approval of repairs or replacements;

• periods during which participants are without essential equipment and/or safe environments; or

• repeated delays experienced by participants with complex or evolving needs.

As a result, significant administrative failures likely remain hidden within detailed performance data.

5. Opportunities to enhance Transparency and Accountability in Performance Reporting

NDIS quarterly performance reports typically acknowledge when PSG targets are missed but provide limited insight into underlying causes or remedial actions. Commentary is often generic, referring to demand pressures or reform activity, without clearly identifying:

• root causes of delays;

• impacts on specific support types, including AT and home modifications redacted; or

• whether corrective measures are effective.

This approach mirrors concerns raised in multiple Australia National Audit Office (ANAO) audits. Auditor-General Report No. 25 found that performance information across Commonwealth entities often lacked sufficient explanation and linkage to service improvement. Furthermore, Auditor- General Report No. 41 identified weaknesses in NDIA performance reporting to the Board, including reliance on aggregated data and limited analysis of persistent underperformance.

In the context of AT and home modifications, these shortcomings allow repeated delays and poor decisions to persist without escalation or targeted intervention.

6. Administrative Issues Arising from the Implementation of Section 10 (Support Lists)

ARATA members report that the implementation of Section 10 since October 2024 has created significant administrative barriers and inequities, particularly in relation to access to AT and home modifications. The framework has resulted in reduced access to reasonable and necessary capital supports, constrained participant choice and control, stifled innovation and problem-solving, and increased the cost of supports due to the additional advisory, reassessment, and compliance requirements imposed by rigid categorisation and replacement processes. Participants and providers report uncertainty and fear of misinterpretation of unclear rules, which acts as a deterrent to pursuing AT and home modification solutions that could otherwise improve functional outcomes and independence.

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A central administrative issue arises from the binary categorisation of supports into “in” and “out” lists. This approach undermines the foundational NDIS principle that reasonable and necessary supports must be determined on an individualised basis. In practice, the lack of transparency and clarity regarding inclusions, exclusions, and decision-making thresholds has led to inconsistent and inequitable outcomes across participants, planners, and delegates. Decisions are frequently driven by categorical exclusion rather than functional need, evidence, or value for money.

ARATA members report persistent misalignment between functional outcomes and item categorisation under Section 10. Low-cost mainstream items, such as tablets, communication apps, kitchen aids, smart devices, and environmental controls, are routinely excluded despite delivering critical functional benefits and often representing a more cost-effective alternative to specialised disability-specific equipment. This approach is inconsistent with the long-standing policy intent to prioritise functional impact over the commercial classification of an item.

The administrative burden associated with accessing replacement supports has also increased substantially. Participants are frequently required to undergo reassessment and provide extensive new justification to replace clearly worn, unsafe, or no-longer-fit-for-purpose equipment, including low-risk and universally available items. This creates delays, increases plan management and allied health costs, and disproportionately affects participants with limited plan funding or capacity to navigate complex administrative processes. A risk-proportionate and streamlined replacement pathway is urgently required.

ARATA members report widespread inconsistency in how Section 10 is applied to everyday and mainstream items, even where clear evidence of disability-related functional benefit exists. Examples include:

• Environmental control supports (e.g. smart speakers enabling home automation for a person with spinal cord injury) being misclassified and excluded.

• Smart glasses for a young person with rapid-onset blindness declined on the basis that they are “not disability-specific.”

• Noise-cancelling headphones denied for sensory regulation for autistic participants.

• Window tinting excluded as an “everyday expense” despite demonstrable psychosocial safety benefits.

• Tablets and text-to-speech software removed from funding, forcing reliance on more expensive disability-specific alternatives.

• Smartwatch fall-alert technology declined as an “everyday item,” increasing reliance on paid supports and reducing participant safety.

Additional examples include the exclusion of therapeutic and functional AT such as active-passive trainers, despite evidence of health and functional improvement, and the exclusion of assistive technology supporting sexual expression under broad categorical exclusions, without regard to disability-related function.

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One ARATA member described the following case, which illustrates the cumulative administrative impacts of Section 10 implementation:

“I have been navigating everyday items with a plan manager for a new NDIS participant. Since there are no funds for low-cost AT in the PACE plan, we will have to go back to the NDIS because the items are not within the designated list of eligible replacement supports (smart watches, tablets, smart phones, accessibility/communication apps). My participant is a new T4 (ASIA D) spinal injury sole parent of three children with significant neuropathic pain, seeking an adapted office chair, low clothesline, and kitchen stool to support self-management. Only three hours of occupational therapy funding has been allocated for AT prescription, which is vastly inadequate.”

Collectively, these issues demonstrate that the current administration of Section 10 prioritises rigid categorisation over functional outcomes, increases administrative complexity and cost, and undermines equitable access to reasonable and necessary supports. Without substantive reform to the operation of the Support Lists and replacement processes, these administrative failures will continue to adversely affect participants, providers, and ultimately the sustainability of the Scheme.

7. Administrative Errors and “End-Dating” of Recognised Impairments

ARATA remains concerned by evidence of systemic data integrity and administrative failures within NDIA systems, which have, for example, resulted redacted in participants’ impairments being effectively removed redacted without notice.

As raised by ARATA in our evidence to the NDIS Joint Standing Committee5 in October 2025, members have reported cases where AT redacted access has been denied not due to changes in functional need, but because impairment records have been altered or lost administratively. This has created significant barriers to essential supports. Case examples include a participant with Autism and Ehlers–Danlos Syndrome being denied wheelchair access and instructed to reapply for the NDIS; a participant with psychosocial disability and spinal injury having previously funded physical supports withdrawn; and a participant with cerebral palsy having their impairment end-dated, resulting in seating and bedding supports being refused without any notification or review process.

These incidents raise concerns regarding procedural fairness, transparency, and system reliability, particularly in the context of increasing reliance on impairment data to determine access to supports under the evolving NDIS framework.

5 P.6 in document listed no. 5. ARATA response to Questions on Notice to the NDIS Joint Standing Committee - Additional Documents – Parliament of Australia

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8.The need for reliable systems that embed consideration of AT and home modification Evidence in NDIS Decision-Making

Meaningful consideration of participant-provided allied health and AT and home modifications evidence is essential to the integrity of NDIS decision-making. Ignoring or inadequately weighing such evidence presents significant safeguarding risks. When decisions are made without due regard to professional assessments from trusted and registered allied health providers, the likelihood of adverse outcomes increases, including implementation of inappropriate or unsafe AT and home modifications redacted arrangements; incorrect funding levels, whether under- or over-provisioned; and deterioration in participant health, independence, and wellbeing.

Administrative settings that restrict NDIS delegate access to documented AT and home modifications prescriber evidence, override the recommendations of professional reports, or substitute individualised clinical judgement with standardised tools or algorithmic processes fundamentally compromise the NDIS’s safeguarding objectives. This risk is especially pronounced for participants with complex needs. Delays or the inability to record documentation within NDIS administrative systems, can lead to predictable and avoidable risk. The NDIS must prioritise establishing strong administrative systems with capacity to efficiently acquire, store, and respond to evidence of AT and home modification need, to ensure safe, appropriate, and effective AT and home modification decision-making.

9. Conclusion

Meaningful NDIS reform, including the implementation of new Framework planning, presents a vital opportunity to ensure all participants can access the AT and home modifications they need to live safely, independently, and with dignity. To achieve this, the Scheme must be underpinned by robust and transparent accountability systems that enable effective monitoring of administrative performance. Further, robust administration systems are fundamental to effective NDIS decision- making. They play a critical role in preventing inequities, fostering innovation, safeguarding participant wellbeing, and supporting overall Scheme sustainability, thereby enabling the NDIS to uphold its commitment to choice, control, and equitable access to reasonable and necessary supports for every participant.

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