NDIA Accountability Project

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Safeguarding timely access to assistive technology (Provider advocacy)

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Submission 776

Safeguarding timely access to assistive technology

ATSA Submission to the Senate Community Affairs Legislation

Committee Inquiry: National Disability Insurance Scheme

Amendment (Securing the NDIS for Future Generations) Bill 2026

June 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

E:

Approved by:

Serena Ovens

Chief Executive Officer

E:

Submission 776

Contents

About Assistive Technology Suppliers Australia (ATSA) …………………………………….. 3

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

Introduction …………………………………………………………………………………………………. 6

  1. Tighter criteria for plan reassessments ignore the underlying problem of inadequate plans ………………………………………………………………………………………….. 6

  2. 90 days for a decision can undermine timely access to assistive technology …….. 8

  3. Value for money considerations do not consider full benefits of timely access to assistive technology ……………………………………………………………………………………… 9

  4. Plan renewal and non-rollover of funds may disrupt AT supply ………………………. 10 Closing ……………………………………………………………………………………………………… 11

References ………………………………………………………………………………………………… 12

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Submission 776

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 requires 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.

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Submission 776

Summary of Recommendations

Schedule/ provision Recommendations

Schedule 1 – Section 48A Recommendation 1 Conditions for conducting Amend the Bill to specify a streamlined pathway reassessment of participant’s for assessing requests for plan changes that plan on request relate to assistive technology and associated supports (e.g. repairs, maintenance, replacement) Recommendation 2 Reforms to unscheduled reassessments must be accompanied by measures to improve the quality, consistency and transparency of initial planning decisions, including stronger consideration of allied health recommendations and anticipated assistive technology needs across the life of a plan. Schedule 1 - Subsection 48(3) Recommendation 3 90 day decision period for plan Reinstate the 21 day requirement for a decision reassessments on whether to proceed with a plan reassessment. Schedule 1 - Subsections Recommendation 4 34(1A) - (1C) – Value for Amend the value for money provisions to require money considerations decision-makers to consider the broader benefits and avoided downstream costs associated with the provision of assistive technology and home modifications, including:  reduced utilisation of funded supports;  preventative benefits;  whole-of-life costs;  reduced utilisation of health and aged care services;  impacts on informal carers;  participation in education, employment and community life; and  whole-of-government savings arising from improved functional outcomes. Schedule 1 - Section 50A, Recommendation 5 Paragraph 2(b) – Roll over of Ensure that during plan renewal funding is funds in new plans preserved where assistive technology has been:  assessed,  trialled,  quoted,

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 approved,  ordered,  manufactured,  awaiting delivery,  awaiting installation or training. Recommendation 6 Open requests for plan reassessment, plan variation or other inquiries should be retained during the plan renewal process to ensure that requests for essential AT are not lost.

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Submission 776

Introduction

Assistive Technology Suppliers Australia (ATSA) welcomes the opportunity to provide a submission to the Community Affairs Legislation Committee inquiry into the

National Disability Insurance Scheme Amendment (Securing the NDIS for Future

Generations) Bill 2026.

ATSA recognises the importance of ensuring the long-term sustainability and integrity of the National Disability Insurance Scheme (NDIS). However, sustainability need not come at the expense of timely access to essential assistive technology (AT), home modifications and related services. In fact, there is strong evidence that timely access to AT and home modifications improves participant outcomes while reducing long-term expenditure across the NDIS, health and care systems. Appropriate AT and home modifications can prevent avoidable injuries and hospital admissions, reduce reliance on paid and informal supports, support independence and self-management, and increase participation in education, employment and community life1-7.

This submission outlines key concerns and recommendations regarding the practical impact of the Bill on participants who rely on assistive technology and home modifications.

  1. Tighter criteria for plan reassessments ignore the underlying problem of inadequate plans

The Bill proposes tighter criteria for unscheduled plan reassessments (Schedule 1 Section 48A) restricting plan reassessments to participants who can demonstrate significant and ongoing change in functional capacity or personal/ environmental circumstances.

Why is this an issue?

ATSA supports measures to stop unscheduled plan reassessments a) by intermediaries such as support coordinators and plan managers, and b) without a participant’s knowledge. However, further tightening of the criteria risks harm to participants with genuine needs for an unscheduled plan review. It also fails to address one of the key reasons for genuine request for plan reassessment inadequate initial planning decisions.

Feedback from ATSA members and other stakeholders consistently demonstrates that many requests for unscheduled reassessments arise because assistive technology and related supports were either not included or inadequately funded during the original planning process, despite supporting evidence being provided.

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Submission 776

Examples reported by members and other stakeholders include:  recommendations contained in allied health assessments being partially or entirely disregarded during planning, requiring participants to seek further funding through an unscheduled reassessment process;  assistive technology being included in a participant’s plan without adequate funding for maintenance, repairs, consumables or ongoing allied health support required to safely use the equipment;  funding to replace ageing equipment not included in a person’s plan despite formal clinical recommendations being made available to the NDIS planner.

During planning, clinical recommendations are often ignored or only partially implemented, resulting in the need for plan review. Restricting access to unscheduled reassessments without addressing poor initial planning risks the safety and wellbeing of NDIS participants who have a genuine need for essential assistive technology and home modifications.

Case example: Poor planning leads to request for plan review

An occupational therapist (OT) from Victoria supporting a participant with high support needs reported significant issues following the approval of a 5-year NDIS plan. As part of the planning process, the OT submitted a Functional Capacity Assessment outlining the participant’s assistive technology replacement needs, including replacement of a 20-year-old ceiling hoist and a 10-year-old pressure care mattress. The report included estimated replacement costs and identified the risks associated with ageing equipment. Despite this, the approved plan did not include sufficient funding to replace this ageing equipment which was expected to fail within the 5 year period of the plan. The participant was allocated approximately $500 per year for repairs and maintenance, which was largely exhausted within the first six months of the plan.

Shortly after plan approval, the participant’s ceiling hoist failed. The participant and providers are now faced with deciding whether to spend approximately $1,500 on urgent, but short-term repairs or embark on a lengthy process of having the plan changed.

This case demonstrates that tightening access to unscheduled plan reassessments does not address the underlying issue of poor planning decisions and failure to adequately consider existing evidence. Inadequate initial plans can create avoidable reassessment requests, additional administrative burden, increased costs and heightened risk for participants.

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Submission 776

Recommendation 1 Amend the Bill to specify a streamlined pathway for assessing requests for plan changes that relate to assistive technology and associated supports (e.g. repairs, maintenance, replacement)

Recommendation 2 Reforms to unscheduled reassessments must be accompanied by measures to improve the quality, consistency and transparency of initial planning decisions, including stronger consideration of allied health recommendations and anticipated assistive technology needs across the life of a plan.

  1. 90 days for a decision can undermine timely access to assistive technology

The Bill proposes that the NDIA will have up to 90 days to decide whether to reassess a plan (Schedule 1 - Subsection 48(3)).

Why is this an issue?

Without amendment, the proposed 90 day timeframe for deciding whether to proceed with a plan reassessment risks increasing already excessive wait times for essential AT, home modifications and associated supports.

Currently the NDIA has guaranteed participants that they will make a decision on whether to include AT in their current plan:  within 28 days (low or mid cost AT) or  within 50 days (high cost AT).8

The NDIA has consistently failed to measure, report or honour these commitments to timely AT access. Despite the lack of AT specific measures, the most recent quarterly report to the disability ministers indicates that the NDIA is failing to process requests in a reasonable timeframe. It shows that the NDIA has:

 failed to make a decision on whether to proceed with a plan reassessment within the required 21 day timeframe in 71% of cases9.

 failed to amend a plan, after the receipt of information that triggers the plan amendment process within the required 28 days in 61% of cases9.

ATSA members and other stakeholders consistently report wait times of 6 months or more for low/mid cost AT and 12 months or more for high cost AT, well in excess of the guaranteed time frames.

Alarmingly, our members report that delays in AT provision are already resulting in:  increased risk of injury or deterioration in function;  avoidable hospitalisation;  delayed independence, social and workforce participation;

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Submission 776

 increased costs to the NDIS due to extra allied health time chasing AT applications; and  increased costs to the NDIS due to reliance on other more expensive forms of care and rentals.

Importantly, delaying access to appropriate AT undermines scheme sustainability. The NDIS achieves long-term savings when participants receive the right equipment at the point of need, preventing escalation of support needs and reducing reliance on more intensive interventions.

Recommendation 3 Reinstate the 21 day requirement for a decision on whether to proceed with a plan reassessment.

  1. Value for money considerations do not consider full benefits of timely access to assistive technology

The Bill changes how reasonable and necessary supports are assessed and specifies some value for money considerations (Schedule 1 - Subsections 34(1A) (1C))

Why is this an issue?

ATSA supports considerations relating to value for money but cautions against approaches that focus solely on lowest upfront cost.

Appropriate assistive technology and home modifications can:  reduce paid support hours1  reduce carer strain2,3,4  prevent injury5  reduce hospital admissions6; and  support education and employment7.

It is critical that these broader benefits and savings are considered within decision-making frameworks, as the cumulative cost associated with denying access to a support can be far greater than the cost of the support itself.

Case Example: Vehicle modifications deliver strong social and economic returns

Research published in the Australian Occupational Therapy Journal examined the social return on investment associated with vehicle modifications for people with disability. The study found that vehicle modifications generated positive returns across all investment scenarios, ranging from $2.78 to $17.32 in social value for every $1 invested, depending on the complexity and cost of the modification.

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Submission 776

The research identified a broad range of benefits associated with access to modified vehicles, including increased independence, improved participation in employment and education, reduced reliance on paid supports, reduced carer burden and improved community participation. Importantly, the study found relatively short payback periods for both consumers and funders, demonstrating that vehicle modifications can deliver cost savings within months or a small number of years.

These findings highlight the importance of assessing value for money over the longer term rather than focusing solely on upfront purchase costs. Restrictive or narrow interpretations of “reasonable and necessary” supports risk overlooking the broader economic and social benefits that assistive technology can provide.

Source: Hutchinson, C., Berndt, A., Cleland, J., Gilbert-Hunt, S., George, S., & Ratcliffe, J. (2020). Using social return on investment analysis to calculate the social impact of modified vehicles for people with disability. Australian occupational therapy journal, 67(3), 250–259. https://doi.org/10.1111/1440-1630.12648

Recommendation 4 Amend the value for money provisions to require decision-makers to consider the broader benefits and avoided downstream costs associated with the provision of assistive technology and home modifications, including:  reduced utilisation of funded supports;  preventative benefits;  whole-of-life costs;  reduced utilisation of health and aged care services;  impacts on informal carers;  participation in education, employment and community life; and  whole-of-government savings arising from improved functional outcomes.

  1. Plan renewal and non-rollover of funds may disrupt AT supply

The Bill proposes that unspent funds for time limited supports will not roll over into renewed plans (Schedule - Section 50A, 2(b))

Why is this an issue?

This creates significant risks for assistive technology provision because AT supply processes often extend beyond a single plan cycle.

AT pathways may involve:  assessments,  trials,  quotes,

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Submission 776

 prescriptions,  funding approval,  custom manufacture,  freight,  installation,  training,  repairs, maintenance and follow-up.

Delays are frequently caused by NDIA processes or supply chain factors beyond the participant’s control.

Also, ATSA members and other stakeholders have reported many instances where plans have been renewed without consideration of open requests for AT and related services (e.g. repair, ongoing maintenance), resulting in the request being lost. Allied health professionals are required to resubmit these requests at a cost to both the participant and the scheme.

Recommendation 5 Ensure that during plan renewal, one off funding is preserved where assistive technology has been:  assessed,  trialled,  quoted,  approved,  ordered,  manufactured,  awaiting delivery,  awaiting installation or training.

Recommendation 6 Open requests for plan reassessment, plan variation or other inquiries should be retained during the plan renewal process to ensure that requests for essential AT are not lost.

Closing

Timely access to appropriate assistive technology is both a safeguard for participants and a mechanism for achieving a sustainable NDIS. We wish to highlight that this Bill and associated operational reforms must ensure that participants can continue to access safe, timely and appropriate assistive technology without unnecessary administrative barriers or delays.

ATSA thanks the Committee for the opportunity to provide comment on the Bill and welcomes the opportunity to continue engaging with government and the Committee as reforms progress.

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Submission 776

References

  1. Hutchinson, C., Berndt, A., Cleland, J., Gilbert-Hunt, S., George, S., & Ratcliffe, J. (2020). Using social return on investment analysis to calculate the social impact of modified vehicles for people with disability. Australian occupational therapy journal, 67(3), 250–259. https://doi.org/10.1111/1440 1630.12648

  2. Chinho, N., Choi, Y., & Patterson, P. (2024). Reducing the Burdens of Paid

Caregivers of Older Adults by Using Assistive Technology: A Scoping

Review. Western Journal of Nursing Research, 46, 315

  1. https://doi.org/10.1177/01939459241234233.

  2. Kim, H., & Shin, Y. (2026). Effect of assistive technology on the burden of caregivers to older adults: A systematic review.. Assistive technology : the official journal of RESNA, 1-12. https://doi.org/10.1080/10400435.2026.2634725.

  3. Marasinghe, K. (2016). Assistive technologies in reducing caregiver burden among informal caregivers of older adults: a systematic review. Disability and Rehabilitation: Assistive Technology, 11, 353 - 360. https://doi.org/10.3109/17483107.2015.1087061.

  4. Clemson, L., Stark, S., Pighills, A., Torgerson, D., Sherrington, C., & Lamb, S. (2019). Environmental interventions for preventing falls in older people living in the community. Cochrane Database of Systematic Reviews. https://doi.org/10.1002/14651858.cd013258.

  5. Australian Healthcare Associates, (2020). Review of Assistive Technology

Programs in Australia: Final Report for the Australian Government

Department of Health. Commonwealth of Australia. Available at: https://www.health.gov.au/resources/publications/review-of-assistive technology-programs-in-australia-final-report?language=en

  1. ATscale, (2020) The Case for Investing in Assistive Technology. Technical Report 2020/11, ATscale. Available at: https://atscalepartnership.org/atscale publications/case-investing-assistive-technology

  2. NDIS, (2023). How can you get assistive technology in your plan? Available at: https://ndis.gov.au/our-guidelines

  3. NDIS, (2026). Quarterly Report Q3 2025-26. Available at: https://www.ndis.gov.au/publications/quarterly-reports

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