arata The Australian Rehabilitation and Assistive Technology Association (ARATA) Submission to the Joint Standing Committee inquiry into the integrity of the National Disability Insurance Scheme
24 April 2026
For further information, please contact redacted or redacted
ARATA would like to acknowledge and thank the many ARATA members who contributed their knowledge and expertise to inform this submission.
arata Executive Summary
ARATA welcomes the opportunity to provide feedback to the Joint Standing Committee inquiry into the integrity of the National Disability Insurance Scheme (NDIS). This submission draws on evidence from ARATA members, reflecting consistent, system-level issues affecting the integrity of the Scheme, particularly in relation to assistive technology (AT) and home modifications (HM).
Assistive technology and home modifications are foundational supports within the NDIS. When delivered appropriately and in a timely manner, they enhance safety, independence, and participation, while reducing downstream costs to the Scheme and broader service systems. Conversely, delays, poor-quality decision-making, or restricted access can result in avoidable harm, increased reliance on high-cost supports, and pressure on informal carers and state-based systems.
A central theme of this submission is that planning and assessment decisions are the primary safeguard of Scheme integrity. However, current and proposed reforms risk undermining this safeguard by potentially insufficiently recognising the role of high-quality AT advisor evidence. There is a disproportionate policy focus on downstream compliance, audit, and enforcement, rather than strengthening the quality, consistency, and evidentiary integrity of decisions at the points of access, assessment, and planning.
ARATA member survey findings also highlight systemic issues in service agreements, complaints pathways, regulatory oversight, and home and living arrangements. While most providers act in good faith, a minority engage in sharp practices that can significantly impact participants and families. Current safeguards are often reactive, inconsistent, and difficult to avigate, limiting their effectiveness in preventing harm.
ARATA submits that strengthening Scheme integrity requires a rebalancing toward preventative safeguards, including improved planning processes, clearer standards for documentation and service agreements, more proactive regulatory oversight, and stronger protections for participants - particularly in complex areas such as home and living supports.
arata Recommendations
- Strengthen planning and assessment as core integrity mechanisms
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Ensure planning processes are evidence-based, transparent, and capable of capturing functional, environmental, and support complexity
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Clarify how Support Needs Assessments will incorporate AT and HM needs and allied health evidence
- Recognise and operationalise the preventative role of AT advisor evidence
- Establish clear standards and expectations for AT advisor documentation
- Embed allied health expertise at key decision points within access, assessment, and planning
- Improve service agreement consistency and safeguards
- Develop standardised guidance and minimum requirements for service agreements
- Ensure agreements are accessible, transparent, and support informed participant decision-making
- Strengthen oversight of how service agreements are used in practice
- Strengthen safeguards against sharp practices
- Introduce measures to reduce conflicts of interest, including in the trial and supply of assistive technology, and in home and living arrangements.
- Support independent advice and informed decision-making for participants
- Reform complaints and review pathways
- Improve accessibility, timeliness, and usability of complaints systems
- Provide greater support for participants navigating complaints and reviews
- Ensure complaints processes lead to consistent and meaningful outcomes
- Shift regulatory oversight toward proactive monitoring
- Increase early identification of risks through data and monitoring
- Strengthen preventative regulatory approaches rather than relying on post-harm responses
- Ensure accountability mechanisms are effective and proportionate
- Strengthen safeguards in assistive technology supply, home and living, including SDA
- Ensure clear separation between advising on and the supply of assistive technology, and between housing and support provision
- Improve transparency and consistency across leases, service agreements, and SDA agreements
- Clarify pathways and responsibilities for accessing AT and HM within home arata and living arrangements
- Strengthen protections to uphold participant choice, control, and rights
About The Australian Rehabilitation and Assistive Technology Association (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 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 is run by a voluntary Board of Management that includes both NDIS participants and NDIS providers. For details, including our constitution, see www.arata.orq.au/about-ARATA/mission/
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 assistive technology 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 assistive technology stakeholders in Australia.
- Introduction The Australian Rehabilitation and Assistive Technology Association (ARATA) welcomes the opportunity to contribute to the Joint Standing Committee inquiry into the integrity of the National Disability Insurance Scheme (NDIS).
This submission reflects key feedback from ARATA members, compiled based on findings from a purpose-designed member survey, on member experience with the NDIS. The evidence reflects systemic patterns rather than isolated incidents, with verbatim quotes included where they illustrate key themes. We share the collective insights of our members, as they relate to the integrity of the NDIS, and access to assistive technology and home modifications.
ARATA stands committed to the integrity of the NDIS. ARATA has contributed to the NDIS (Integrity and Safeguarding) Bill Inquiry and the final report noted ARATA input2.
1 History I GAATO 2 National Disability Insurance Scheme Amendment /Integrity and Safeguarding) Bill 2025 - Parliament of Australia
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- The Role of Assistive Technology in the NDIS The World Health Organization (WHO) defines assistive technology (AT) as an umbrella term encompassing assistive products, assistive systems, and assistive services.3 Assistive technologies 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.
AT and home modifications (HM) have a direct and often immediate impact on a person’s safety, independence and quality of life. They play a critical role in maintaining personal safety, including pressure care, falls prevention and safe transfers. They also enable access to essential daily activities such as toileting, showering and cooking, and support communication, social connection, community participation and employment. Importantly, these supports contribute significantly to the sustainability of informal care arrangements, helping families and carers to continue in their roles safely and effectively.
In many cases, AT and HM are preventative supports. When provided in a timely way, they can reduce hospital admissions, prevent functional decline, minimise secondary complications and ultimately reduce long-term costs to the Scheme. Conversely, delays or restrictions in access can lead to avoidable harm, carer burnout and increased reliance on more intensive and higher-cost supports over time.
Under the NDIS, AT and HM are fundamental supports and are essential to achieving Scheme objectives. The New Framework Planning (NFP) Rules, currently under development, must support optimal provision of AT and HM for this objective to be achieved. Safeguarding measures must be strengthened to enable both scheme integrity and sustainability.
- The Central Role of Planning Decisions in Safeguarding NDIS Integrity
AT and HM are fundamental supports under the NDIS, underpinning participant safety, independence, and participation, as well as the sustainability of informal care. When delivered in a timely, evidence-based manner, they reduce downstream costs by preventing hospitalisation, functional decline, carer burnout, and reliance on higher-cost supports.
Within this context, planning decisions are a critical safeguard and central to the integrity of the NDIS. Effective planning ensures that supports are reasonable, necessary, and
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appropriately targeted, while also protecting against both under-support and inefficient allocation of public resources. This requires planning processes that can accurately capture the interaction between functional capacity, environmental context, and evolving support needs.
ARATA acknowledges the objectives of the proposed Support Needs Assessment (SNA) model, including improved consistency, equity, and sustainability. However, the current consultation materials lack sufficient operational detail to assess how the framework will function in practice, particularly in relation to how assessment outcomes translate into funding, how support needs such as AT and HM will be identified, and how allied health evidence and specialist assessments will be incorporated and safeguarded.
ARATA is concerned about reliance on structured tools such as I-CAN as primary determinants of support needs, and how they will identify or screen for AT and HM needs. While these tools may support efficiency objectives, they cannot replace comprehensive functional and environmental assessments, particularly for complex AT and HM. A timelimited interview is unlikely to capture fluctuating conditions, cumulative fatigue, environmental barriers, or the interaction of multiple impairments, factors that are essential to sound planning decisions. ARATA also has concerns about the limitations on plan reassessments being proposed at the current time. Significant needs can change between SNAs and the Scheme needs to be responsive to these changes in need to prevent loss of independence, admission to hospital, or a loss of independence in communication, mobility, and other functional domains.
Given the scale of the proposed reform, further operational detail and transparency are necessary to maintain confidence in planning processes as a core integrity mechanism. ARATA remains committed to contributing its expertise to the development of a planning framework that is evidence-based, safe, and responsive to participant needs. ARATA welcomes the announcement that SNAs will be delayed until April 2027, pending development of a more robust assessment process4.
- Service Agreements, and AT Advisor Evidence
Service agreements could be a valuable tool to support integrity and safeguarding within the NDIS, and this emerged as a clear theme from ARATA’s survey. However, there is currently significant inconsistency in how service agreements are developed and implemented, limiting their effectiveness in protecting participants.
As one respondent noted, “Service agreements are often generic and do not protect participants.”
This is compounded by issues of accessibility and understanding, with another observing that “Participants don’t always understand what they are agreeing to.”
These findings point to the need for stronger guidance and standard-setting focused specifically on service agreement processes to ensure they genuinely support informed decision-making and participant safeguards.
These challenges sit alongside broader concerns regarding the use of AT advisor arata evidence. This submission’s central position is that successive policy approaches to integrity have not adequately recognised or operationalised the preventative role of AT advisor evidence. Instead, reforms have disproportionately focused on downstream compliance, audit, and enforcement mechanisms, with insufficient attention given to strengthening the quality, consistency, and evidentiary integrity of decisions made at the points of access, assessment, and planning.
As highlighted in the survey, “High-quality reports can support good decisions, but poor ones are not challenged.”
ARATA members report that high-quality reports are not used to underpin decisions, and sometimes this results in inappropriate decision-making by planners. Clarifying the role and expectations of AT advisor documentation is therefore critical to ensuring it continues to function as an effective, preventative safeguard within the Scheme.
- The Occurrence, and Prevention, of Sharp Practices
ARATA recognises that the vast majority of providers in the AT sector act in good faith and are committed to delivering high-quality, participant-centred outcomes. However, survey feedback indicates that a small number of providers engage in practices that may be characterised as “sharp practices.” While not always unlawful, these behaviours can have significant adverse impacts on participants and their families. ARATA acknowledges the seriousness of these impacts and emphasises that strengthening preventative safeguards, alongside better support for informed, independent decision-making, will be critical to reducing the occurrence of such practices.
Survey responses that these practices can lead to poor outcomes, where “Participants end up with equipment that doesn’t meet their needs,” and in some cases, “Inappropriate prescriptions can actually reduce independence.”
The complexity of the system further compounds these risks, with respondents noting that “The system is confusing and overwhelming for families,” and that “Participants often don’t realise they are being taken advantage of.”
Beyond individual impacts, these behaviours have broader consequences for the integrity of the Scheme, as “Trust in providers and the Scheme is being undermined,” and “Good providers are being tainted by the behaviour of others.”
Together, these findings reinforce the need for stronger upstream safeguards and clearer supports to ensure participants are equipped to make informed decisions, and that ethical providers are supported to deliver high-quality care.
- Complaints, Regulatory Oversight, and Participant Safeguards
Feedback from ARATA’s survey indicates that current complaints and review pathways within the NDIS are not functioning effectively as safeguards for participants.
Respondents consistently described these mechanisms as difficult to access and arata limited in their ability to deliver timely and meaningful outcomes. As one participant noted, “The complaints process is slow and difficult to navigate,” with another observing that “Participants rarely pursue complaints due to complexity and fatigue.”
Even where complaints are made, there are concerns about effectiveness and resolution, with feedback that “Outcomes are inconsistent and do not always address the underlying issue.” These findings suggest that, in their current form, complaints pathways are not providing a reliable or accessible avenue for addressing harm or preventing its recurrence.
These challenges are compounded by broader concerns regarding regulatory oversight. Survey respondents described a system that is largely reactive, rather than preventative, with one noting that “Regulation tends to respond after harm has occurred,” and another highlighting that “There is limited monitoring of provider behaviour before issues escalate.”
This reactive posture limits the system’s ability to identify and address risks early, allowing poor practices to persist. Strengthening participant safeguards must therefore include both more proactive regulatory approaches and improved support for individuals navigating the system. This includes making complaints processes more accessible and usable, as well as ensuring participants are better equipped to make informed decisions.
As reflected in the survey, “Participants need more protection and clearer information.”
Together, these reforms are critical to ensuring that safeguards operate effectively to prevent harm, rather than responding only after it has occurred.
- Home modifications; and Home and Living Supports, including Specialist Disability Accommodation (SDA)
A number of ARATA members described a need for greater transparency in decision-making processes relating to home and living supports, including Specialist Disability Accommodation (SDA). These areas were identified as particularly vulnerable to sharp practices, given the complexity of arrangements and the intersection of housing, supports, and funding streams. Respondents highlighted that, without clear and consistent safeguards, there is a risk that some accommodation providers, including SDA providers, may exert undue influence over participant decisions or operate in ways that are not aligned with participant interests.
Strengthening protections in this area must include a clearer separation between housing and support provision, to reduce conflicts of interest and uphold participant choice and control. Where multiple agreements are in place, such as leases, service agreements, and SDA agreements, there must be greater transparency, consistency, and enforceable protections to ensure participants fully understand their rights and obligations. This includes ensuring that access to AT and HM is not constrained by accommodation arrangements, and that pathways, responsibilities, and funding interfaces are clearly defined.
As one respondent starkly observed, “The system is rorting itself, because of the inability to function efficiently.”
This underscores the urgency of reform to ensure that home and living supports operate with integrity, clarity, and a strong focus on participant outcomes.
arata 8. Conclusion
The NDIS is a transformative reform that has delivered significant benefits to people with disability and the broader community. Maintaining its integrity and sustainability, however, requires a shift in focus.
Evidence from ARATA members indicates that current approaches rely too heavily on downstream compliance and enforcement, while insufficient attention is given to strengthening decision-making at the front end of the Scheme. This limits the effectiveness of safeguards and allows risks to persist.
Strengthening Scheme integrity will require greater emphasis on preventative measures, including robust planning processes, high-quality AT advisor evidence, consistent service agreements, accessible complaints pathways, and more proactive regulatory oversight.
ARATA remains committed to supporting an NDIS that is equitable, evidence-based, and capable of delivering safe and effective outcomes for participants.
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