ICF Australia Interest Group submission
to the Community Affairs Legislation Committee on the National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Bill 2024
Introduction ……………………………………………………………………………………………… 1
Conclusions: our suggestions …………………………………………………………………….. 1
Definitions and the ICF ……………………………………………………………………………… 2
The ICF as an aid to clarifying some definitions in the Bill ……………………………. 3
The term ‘impairment’ and lack of definition ………………………………………………. 4
Functional capacity ……………………………………………………………………………….. 7
Section 10. Definition of NDIS supports and inclusions …………………………………… 7
Inclusions …………………………………………………………………………………………….. 9
Assessment and Rules ……………………………………………………………………………. 10
Assessment tools ………………………………………………………………………………… 12
Data for monitoring the NDIS, people’s experience and outcomes …………………. 13
Further information about use of the ICF to support the NDIS………………………… 13
Sources ……………………………………………………………………………………………… 14
Appendices: Previous ICF AIG submissions ……………………………………………. 14
May 2024
Introduction
The NDIS is a great achievement of Australia, with Objects and Principles we can be proud of (Part 2 of the Act). It has made positive differences in thousands of lives.
The Review recently completed is similarly excellent. The Review was coherent, with recommendations connected so as to be possible to operationalise.
The NDIS Review wisely said that the International Classification of Functioning, Disability and Health (ICF) should be used to underpin NDIS data structure (Recommendation 23, Action 23.4, P256) and eligibility assessment (NDIS Supporting Analysis, p.242).
This submission aims to help with this work. The submission focusses on specialist aspects of the Bill, related to definition and classification, in line with the expertise of the submitting group, the ICF Australia Interest Group.
Conclusions: our suggestions
Here, we draw together our suggestions arising from analysis and discussion following.
- ‘Impairment’ is a central concept in the Act and the Bill, and should be among the key definitions in the Bill. A draft definition is put forward for consideration, to align it with the ICF definition:
Definition proposed: Impairment, for the purposes of the Act, signifies a problem with body function or structure, associated with a health condition
Impairments, in interaction with environmental factors, may then be described as associated with participation restrictions or limitations in ‘functional capacity’. The term ‘impairment’ should generally be used in the plural to avoid the implication of a simple causal pathway; note especially the new paragraph (aa) to be inserted before paragraph 34(1)(a).
The ICF AIG supports descriptions of disability as the most appropriate method for consideration of entry, and suggests that the concept of impairment alone is inadequate for description of a person’s disability that also includes the concepts of activity limitation and participation restriction.
- Likewise, ‘functional capacity’ is an important concept for eligibility, and its definition is seen as required (NDIS Review Supporting Analysis p.244). A definition is offered:
Functional Capacity Definition: “Functional capacity refers to an individual’s ability to be involved in life situations and to execute tasks or actions, with and without assistance (assistive devices and/or personal assistance). Information regarding impairment(s) and environmental factors, and how they impact the individual’s function is included when assessing functional capacity” (from NDIA
Definitions and the ICF
The NDIS Review and its Supplementary Analysis urged using the ICF as the basis for data structures, definitions and assessment tools (e.g. Review Report p.264; Supporting Analysis p.244). The aim of our submission is to assist in working towards improvements in definitions, measurement and data.
The Explanatory Memorandum for the Bill states that “the Bill does not change the criteria for accessing the NDIS, but rather helps to clarify broad and potentially ambiguous terminology”. These are useful aims in a complex field such as disability, and we try, in this submission, to contribute to this goal.
We support the NDIS Review’s calls to make the access process more equitable (NDIS Review p.38). The Review also identifies the need to clarify definitions in key eligibility criteria for Sections 24 and 25 of the Act. As recognised in the Explanatory memorandum, and consistent with the NDIS Review Supporting Analysis (pp.230, 244, 247) it will be important for the development of these definitions to be informed by consultations with and advice from people with disability, families, representative organisations, functional measurement experts and researchers and health professionals.
The ICF as an aid to clarifying some definitions in the Bill
In this section we outline features of the ICF and how it can be used to clarify NDIS definitions.
The ICF is the World Health Organization framework and classification system for organising and documenting information on functioning and disability: the International Classification of Functioning, Disability and Health (ICF). It is an international standard and has underpinned disability data development in Australia for almost 30 years. It represents a biopsychosocial model of disability which recognises the multifactor, interactive nature of disability and its dependence on environment (see Fig 1 in Attachment 1); it represents a great contrast to the linear, causal medical model it displaced. The ICF provides a comprehensive framework and standardised terminology for capturing and relating information on all aspects of functioning and disability, including environmental factors and personal factors that affect functioning. The NDIS Review proposed use of the ICF to underpin data structures for the NDIS (e.g. Review Report p.264). As recognised in the NDIS Review Final Report: Supporting Analysis, the ICF should be used as a basis for developing functional capacity and support needs assessments for the reformed NDIS participant pathway (e.g. p.244). It can also assist with clearly defining key concepts to avoid ambiguity in the NDIS Act and NDIS rules. [Please see Attachment 1: ICF and its potential uses in the National Disability Insurance Scheme (NDIS)].
The ICF is well aligned with the UN Convention on the Rights of Persons with Disabilities (CRPD). According to the CRPD preamble:
(e) Recognizing that disability is an evolving concept and that disability results from the interaction between persons with impairments and attitudinal and environmental barriers that hinders their full and effective participation in society on an equal basis with others,
The two instruments share common concepts and terms, notably environment and barriers as factors in the creation of disability, participation as a desired outcome and right. Key ICF definitions referred to in this submission include:
- Disability - An umbrella term for impairments, activity limitations and participation restrictions. It denotes the negative aspects of the interaction between a person’s health condition(s) and that individual’s contextual factors (environmental and personal factors).
- Impairments - Problems in body function or structure such as a significant deviation or loss.
- Activity - The execution of a task or action by an individual.
- Participation - Involvement in a life situation.
- Environmental factors make up the physical, social and attitudinal environment in which people live and conduct their lives. These are either barriers to or facilitators of the person’s functioning.
Source: WHO 2001, pp. 3,8,10
The scope of each component of the ICF is indicated by the chapter headings following, under which more detailed content is systematically laid out as mutually exclusive hierarchical items.
Table 1: ICF components and chapters
Body Functions:
1. Mental functions
2. Sensory functions and pain
3. Voice and speech functions
4. Functions of the cardiovascular, haematological,
immunological and respiratory systems
5. Functions of the digestive, metabolic, endocrine
systems
6. Genitourinary and reproductive functions
7. Neuromusculoskeletal and movement-related
functions
8. Functions of the skin and related structures
Activities and Participation:
1. Learning and applying knowledge
2. General tasks and demands
3. Communication
4. Mobility
5. Self-care
6. Domestic life
7. Interpersonal interactions and relationships
8. Major life areas
9. Community, social and civic life
Body Structures:
1. Structure of the nervous system
2. The eye, ear and related structures
3. Structures involved in voice and speech
4. Structure of the cardiovascular, immunological
and respiratory systems
5. Structures related to the digestive, metabolic and
endocrine systems
6. Structure related to genitourinary and
reproductive systems
7. Structures related to movement
8. Skin and related structures
Environmental Factors:
1. Products and technology
2. Natural environment and human-made changes to environment
3. Support and relationships
4. Attitudes
5. Services, systems and policies
Source: WHO, 2001, pp. 29-30
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In Section 24 on the ‘disability requirements’ which talks about ‘disability attributable to impairments’ (Section 24(1)(a))
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In Section 24(1)(c) on the ‘disability requirements’:
'the impairment or impairments result in substantially reduced functional capacity to undertake one or more of the following activities' -
In section 25, recognising that ‘impairments’ may fluctuate in effect.
‘Impairment’ in the legislation is an imprecise term, in terms of both the ICF definitions and the CRPD approach. When used as in 24(1)(c): there is an implication of a linear causal (results from’) and medical model of disability, rather than the interactive processes recognised in the ICF and CRPD. The use of ‘attributable to’ in Section 24(1)(a) appears similar to the CRPD approach, perhaps leaving open the idea that there may be other factors in operation as well (environment). Sometimes it is used in the singular (‘an impairment’) and sometimes indicating the possibility of more than one impairment (‘impairment or impairments’); the former phrase is more likely to imply the medical model of direct causation. The fact that the Review recommends “removing automatic access to the NDIS under diagnostic Access Lists” is a welcome step away from the unscientific medical model (NDIS Review Supporting Analysis p.238.)
The difficulty of using this language in the field of disability is indicated in examples in the Explanatory Memorandum. The example on page 17 indicates the importance of the whole-person approach, and uses more common and logical language of disability: “Kirra’s support needs assessment will not require her to repeatedly prove that she meets the disability requirements or the early intervention requirements or both. It will have a whole-of-person focus with the objective of identifying the impacts of Kirra’s disabilities.”
This variation in meaning and usage is a problem for the legislation which can perhaps be solved by including a definition in the legislation, referring to both the ICF and the CRPD, setting out a meaning of ‘impairment, for the purposes of the Act’. A suggestion is made here:
Definition proposed: Impairment, for the purposes of the Act,
signifies a problem with body function or structure, associated with
a health condition.
It is suggested that consideration be given to inclusion of this definition in the NDIS
Act. It should be understood that impairments, as defined in ICF, may relate to a
broad range of disabilities. The ICF includes the full spectrum of impairments, including psychosocial, cognitive and physical, as well as activities and participation across all areas of life (see Table 1).
Impairments, in interaction with environmental factors, may then be associated with participation restrictions or limitations in ‘functional capacity’.
Using the word ‘impairment’ in the singular appears problematic at times. For example, there is a new paragraph (aa) inserted before paragraph 34(1)(a),
apparently focussing on a single impairment as the cause of a possible array of difficulties meeting the disability requirements.
(aa) the support is necessary to address needs of the participant arising from an impairment in relation to which the participant meets the disability requirements (see section 24) or the early intervention requirements (see section 25);
In the case of (aa) there may be a drafting error as well as a scientific error, which may be ameliorated by using the more usual phrase ‘impairment or impairments’, or better ‘associated with an impairment or impairments’.
If this is not a drafting error and the text is intentional, there are problems with the wording of this paragraph. It implies an outdated, medical model view of disability that assumes a linear, causal relationship between a person’s impairment and their disability-related support needs. Rather, disability and related support needs should be understood in terms of the dynamic interaction between a person’s health conditions, as in the ICF, and also relevant environmental and personal factors. Supports can be understood as environmental factors that help to facilitate a person’s functioning. In assessing a person’s support needs as part of the NDIS planning process, their disability should be viewed holistically (see e.g. Explanatory Memorandum, p.12). The Review Report’s Supplementary Analysis (Page 260) makes the point:
‘The NDIA appears to take the view that a participant’s disability is the specific diagnosis or impairment that access to the NDIS was granted for. This is confusing for participants with multiple disabilities who justifiably understand their needs more holistically and expect the same from the NDIS.’
For these reasons we believe that the requirement in the proposed paragraph (aa) is not workable in practice and its insertion into the NDIS Act could result in negative outcomes for individual participants. It would also be at odds with the NDIS Review Final Report, which emphasises the need to move away from viewing participants in terms of a ‘primary disability’ diagnosis (NDIS Review Supporting Analysis, pp. 260,299).
As the aim of the NDIS is to facilitate participants’ social and economic participation, it is appropriate to consider participants’ support needs in terms of their disability- related activity limitations and participation restrictions, rather than specific impairments.
Section 32 also seems to imply that the assessment of NDIS supports requires some kind of one-to-one relationship between a support and a specific, causal impairment:
32L(3) The assessment must assess the participant’s need for supports only in respect of impairments in respect of which the participant meets the disability requirements or the early intervention requirements.
Overall, the ICF AIG supports descriptions of disability as the most appropriate method for consideration of entry, and suggests that the concept of impairment alone
ICF Australia Interest Group submission to the Community Affairs Legislation Committee 6
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is inadequate for description of a person’s disability that also includes the concepts of activity limitation and participation restriction.
Functional capacity
The reference to ‘substantially reduced functional capacity’ in Section 24(1)(c), and the foregoing discussion about ‘impairments’ also indicate that attention should be paid to possible definitions of ‘functional capacity’. This seems to be the area of the legislation that gives effect to the Minister’s description of the Scheme’s being for people with ‘significant disability’ (in his Second Reading speech).
The term ‘capacity’, in the ICF, refers to a person’s highest level of achievable performance, measured in an optimal or a ‘standard’ environment, while the term ‘performance’ refers to what a person does in their usual environment. Both concepts relate to Activities and Participation in ICF terms.
In Section 24 (1) (c) on ‘disability requirements’, it appears that ‘functional capacity’ is referring to the ‘performance’ of a person in their usual environment (including the current level of personal assistance and assistive devices). There is, then, some similarity, between ‘functional capacity’ as used in the legislation, and ‘functioning and disability’ in the ICF.
This apparent challenge was faced in work by the NDIA in 2020, attempting to clarify the relationship and proposing a definition of ‘functional capacity’ using some ICF concepts:
- Functional Capacity Definition: “Functional capacity refers to an individual’s ability to be involved in life situations and to execute tasks or actions, with and without assistance (assistive devices and/or personal assistance). Information regarding impairment(s) and environmental factors, and how they impact the individual’s function is included when assessing functional capacity.” (from NDIA 2020 paper ’Assessment of Functional Capacity for NIDS – Development and Framework).
It is suggested that consideration be given to inclusion of this definition in the NDIS Act.
Section 10. Definition of NDIS supports and
inclusions
The explanatory memorandum (pages 2 and 3) explains section 10, defining NDIS supports:
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This item inserts proposed new section 10 which provides a definition for NDIS support. The definition serves two purposes.
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First, it provides a constitutional underpinning for the new planning framework (see item 36) by setting out the kinds of supports that the Commonwealth is constitutionally capable of funding. This is
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primarily accomplished by engaging with Australia’s obligations under the Convention on the Rights of Persons with Disabilities (CRPD). The definition also relies on the relevant aspects of the social welfare power under the Constitution.
Second, proposed paragraphs (b) and (c) will allow NDIS rules to be made that narrow the scope of these constitutionally valid supports to those that are appropriately funded by the NDIS.
And:
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NDIS rules made (or changed) for the purposes of proposed new paragraphs 10(b) and 10(c) will be Category A rules requiring the unanimous agreement of all States and Territories before they can be made (see item 115).
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Proposed paragraphs (b) and (c) will allow NDIS rules to be made that narrow the scope of these constitutionally valid supports to those that are appropriately funded by the NDIS.(Explanatory memorandum page 3)
According to Section 10:
A support is an NDIS support for a person who is a participant or prospective participant if:
(a) the support:
(i) is necessary to support the person to live and be included in the community, and to prevent isolation or segregation of the person from the community; or
(ii) will facilitate personal mobility of the person in the manner and at the time of the person’s choice; or
(iii) is a mobility aid or device, or assistive technology, live assistance or intermediaries that will facilitate personal mobility of the person; or
(iv) is a health service that the person needs because of the person’s impairment or because of the interaction of the person’s impairment with various barriers; or
(v) is a habilitation or rehabilitation service; or
(vi) is a service that will assist the person to access a support covered by subparagraph (iv) or (v); or
(vii) will minimise the prospects of the person acquiring a further impairment or prevent the person from acquiring a further impairment;
ICF Australia Interest Group submission to the Community Affairs Legislation Committee 8
(b) the support is declared by National Disability Insurance Scheme rules made for the purposes of this paragraph to be a support that is appropriately funded or provided through the National Disability Insurance Scheme:
(i) for participants or prospective participants generally; or
(ii) for a class of participants or prospective participants that includes the person; and
(c) the support is not a support declared by National Disability Insurance Scheme rules made for the purposes of this paragraph to be a support that is not appropriately funded or provided through the National Disability Insurance Scheme:
(i) for participants or prospective participants generally; or
(ii) for a class of participants or prospective participants that includes the person.…
Note 1: For subparagraphs (a)(i) to (vii), see the Convention on the Rights of Persons with Disabilities done at New York on 13 December 2006.
Note 2: The Convention is in Australian Treaty Series 2008 No. 12 ([2008] ATS 12) and could in 2024 be viewed in the Australian Treaties Library on the AustLII website (http://www.austlii.edu.au).
Note 3: For subparagraph (a)(viii), see paragraph 51(xxiiiA) of the Constitution. \
Living independently and being included in the community
a) Persons with disabilities have the opportunity to choose their place of residence and where and with whom they live on an equal basis with others and are not obliged to live in a particular living arrangement;
b) Persons with disabilities have access to a range of in-home, residential and other community support services, including personal assistance necessary to support living and inclusion in the community, and to prevent isolation or segregation from the community;
c) Community services and facilities for the general population are available on an equal basis to persons with disabilities and are responsive to their needs.
The ICF sets out areas of life in its Activities and Participation dimension (listed previously) i.e. for the identification of areas where the person may experience difficulty or need assistance
Thus, Section 10(a)(i) – Living independently and being included in the community – embraces important needs and services and the NDIS must deliver on the promise of Article 19 of the CRPD.
We are concerned that the list in (a) may exclude important supports which are included in the CRPD. The Explanatory Memorandum gives no information on how the list in proposed Section 10(a) was compiled.
Mobility, health and habilitation/rehabilitation are drawn directly from Articles 20, 25 and 26 of the CRPD. But other similar Articles, including Access to justice (Article 13) and Education (Article 24) are not included in proposed Section 10(a). Proposed clauses 10(b) and 10(c) provide a mechanism to specify those elements of each support class which are available through the NDIS and those which are not possibly because they are to be provided by States and Territories.
The Rules referred to in Section 10(b) and (c) should be consistent with CRPD. A rule can specify an NDIS or foundational support, but the result for the person should be consistent with the CRPD.
Assessment and Rules
According to the Human Rights Overview (appended to the Explanatory memorandum), the Bill amends the Act to do a range of things, including (point 3):
Provide for the needs assessment process and the method for calculating the total amount of the participant’s flexible funding and funding for stated supports for new framework plans to be specified
ICF Australia Interest Group submission to the Community Affairs Legislation Committee 10
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in legislative instruments and NDIS rules. These will be developed in consultation with people with disability, the disability community, health and allied health technical professionals, and with all States and Territories
Generally, we support the NDS Review’s proposals to develop more consistent, robust and transparent approaches for determining eligibility and setting plan budgets, involving functional capacity and support needs assessment tools that map to the ICF and are designed with and acceptable to the people and groups for whom they will be used. Assessing environment must be an important aspect of support needs assessment.
The Explanatory Memorandum (pages 22-23) sets out:
‘What an assessment covers
Subsections 32L(2) to (4) deal with how an assessment must be undertaken.
The assessment must be undertaken using the assessment tool and in accordance with any other requirements determined under subsection 32L(8). It must assess the participant’s need for supports only in respect of impairments that meet the disability or early intervention requirements.
The needs assessment must have regard to any information or reports requested by the CEO for the purposes of the assessment and may have regard to any information held by the Agency in relation to the participant…’
‘Ministerial determinations relating to assessments and reports
Subsection 32L(8) allows the Minister, by legislative instrument, to determine the following:
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assessment tools to be used in undertaking needs assessments
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requirements for undertaking assessments (such as a requirement for a person undertaking the needs assessment to have certain skills or qualifications)
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information that must be included in a needs assessment report
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requirements that the needs assessment report must satisfy (including matters that must be set out in the report). ‘
The needs assessment tool (or tools) will be highly technical and developed in consultation with the disability sector and medical and professional experts, as well as relying on international learning and best practice. These instruments will be evidence based and it is expected the instruments will need to be changed and updated in
ICF Australia Interest Group submission to the Community Affairs Legislation Committee 11
Assessment Tools
Section 32L(8)
The Minister may, by legislative instrument, determine assessment tools to be used in undertaking assessments of a participant’s need for supports.
Considerations For Needs Assessment Design
Considerations for needs assessment design were set out in Box 18 (page 275-76, Review Report, Supporting Analysis) and provide a good summation of criteria to be met, including that the needs-based assessment must:
- Be able to consistently measure support needs and intensity. It should be mapped to the International Classification of Functioning, Disability and Health
- Be valid across different groups of participants, including the full range of age groups and disability types (including multiple disabilities).
It is important that these principles be specified in the Act. The use of the ICF is essential to ensure common approaches across all participants in the NDIS, across all community groups and across all classes of impairments. Assessment should be based on the ICF to promote the quality, consistency and meaning of data captured by the operation of the NDIS.
The design and testing of assessment tools require ‘highly transparent, rigorous and inclusive design and testing prior to implementation’ (NSID Review Supporting Analysis p.247). There should be ‘significant engagement and collaboration with people with disability, families, representative organisations, functional measurement experts and researchers and health professionals.’ (Supporting Analysis pp.230, 244, 247)
Evident in this submission and the Bill is the importance of Rules in extending the reach of the legislation. The matters to be subject to Rules have been greatly expanded by the Bill (Section 209).
Open and transparent processes for setting and amending the increased number of Rules and other instruments will be vital to the success of the reformed NDIS, including the quality of the assessment tools and the consistent use of the ICF as explained here.
Data for monitoring the NDI$, people’s experience and outcomes
Improved and standard definitions open the way to having relatable data flowing from each of the steps and components in NDIS process (see Fig. 1 in Attachment 2 – our submission to the Review). What is required is an underpinning of common language in definitions and classification – and this is what the ICF can provide. Coherence of data across different stages is needed – they are all about individual people going through the system.
Data on outcomes – changes experienced as a result of supports accessed – can inform knowledge about the efficacy of various supports (what works), changes to their NDIS budget decisions, or about whether the person remains in the NDIS. Currently outcome data are captured only through satisfaction surveys and cannot support these decisions.
Confusion in definitions will result not only in administrative confusion but also in inconsistent, confused and possibly unusable data about the NDIS and its participants. Data based on the ICF concepts underlying the Act will be capable of building coherent and connected data to monitor the NDIS and people’s experiences and outcomes.
Further information about use of the ICF to support the NDIS
The ICF Australia Interest Group (ICF-AIG) is a collaborative, multidisciplinary group of people who have diverse expertise in the ICF and its uses, including for data development and the development of assessment instruments. The ICF-AIG paper titled The ICF and its potential uses in the National Disability Insurance Scheme (NDIS) (see Attachment 1) was provided to the NDIA in April 2022. It sets out the role and value of the ICF to develop new and valid approaches for assessment and outcomes measurement for NDIS participants, and for developing a comprehensive NDIS data structure. It contains links to other key ICF-related resources. Attachment 2: The benefits of an ICF-aligned NDIS data structure was submitted to the Review in 2023.
The ICF-AIG can provide further advice and detail to the Committee on the matters raised by us in the present submission or the attached papers.
This submission has been written by the following authors, on behalf of the ICF Australia Interest Group:
ICF Australia Interest Group submission to the Community Affairs Legislation Committee 13
Ros Madden AM, PhD, Honorary Research Fellow Centre for Disability Research and Policy, WHO CC for Strengthening Rehabilitation Capacity in Health Systems, The University of Sydney
Richard Madden AM, PSC, BSc, PhD, FIAA. Honorary Professor, University of Sydney
Dr David Kellett B.Med, FAFRM (RACP), PhD Senior Staff Specialist, Hunter New England Area Health Service
Muriel Cummins BSc OT (Hons), MPH, Co-convenor, Occupational therapy Community of Practice
Sources
This is an informal list, which includes abbreviated names used in the text (rather than numbered references); intended for the convenience of the reader
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Bickenbach, J.E. (2011). Monitoring the United Nation’s Convention on the Rights of Persons with Disabilities: data and the International Classification of Functioning, Disability and Health. BMC Public Health, 11(Suppl 4), S8.
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Commonwealth of Australia 2023. Working together to deliver the NDIS. Independent Review into the National Disability Insurance Scheme. Final Report October 2023 Referred to as the ‘NDIS Review’, or ‘the Review’
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Commonwealth of Australia 2023. Working together to deliver the NDIS Independent Review into the National Disability Insurance Scheme Final Report Supporting analysis. Referred to as: NDIS Review, Supporting Analysis
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National Disability Insurance Agency. Assessment of Functional Capacity for NDIS – Development and Framework. August 2020.
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The Parliament of the Commonwealth of Australia, House of Representatives. National Disability Insurance Scheme Amendment (getting the NDIS back on track no. 1) Bill 2024 Explanatory Memorandum Referred to as: the ‘Explanatory Memorandum’
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United Nations [UN]. Convention on the rights of persons with disabilities. New York: United Nations; 2006. Referred to as the CRPD
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World Health Organization. International Classification of Functioning, Disability and Health. WHO: Geneva, Switzerland, 2001. Referred to as ‘the ICF’
Appendices: Previous ICF AIG submissions
Attachment 1: The ICF and its potential uses in the National Disability Insurance Scheme (NDIS)
Attachment 2: The benefits of an ICF-aligned NDIS data structure
ICF Australia Interest Group submission to the Community Affairs Legislation Committee 14