An Open Letter to the Broader Allied Health Community, Supporters, Families:
It’s time to broadcast this more publicly - We ALL need to fight NDIS on the upcoming changes it appears are coming regarding Support Needs Assessment.
For more details on that, please see Nacre’s wonderful summary of the 3 documents put out to Tender last week here:
From an occupational therapy perspective, there are several critical issues with the ideas contained in this NDIS Request for Information (RFI). The proposed assessment tool and associated processes present significant concerns related to the complexity of disability support needs, the nature of functional assessments, and the qualifications of those administering the tool. So many red flags, and inherent misunderstandings of the processes, the interpretation and the wholistic viewpoint that is ESSENTIAL in understanding support needs.
1. NDIS Workers Are Not Trained Allied Health Professionals
One of the most problematic aspects of this proposal is the expectation that an NDIS workforce—comprising individuals with varying levels of professional qualification (that is, from none, to some) and disability experience (again, from none, to some) —will be responsible for assessing support needs.
This isn’t good enough! The vast majority of these staff have not done extensive education, training and then worked with the disabled population for many years to hone their skills in using standardised tools to glean accurate information. We’ve already seen these issues when the LACS misunderstand diagnoses, and then misrepresent information under the current structure. Occupational therapists, along with other allied health professionals, undergo extensive training in understanding the interaction between disability, function, and environmental factors. Assessing support needs requires not just knowledge of a tool but clinical reasoning skills that come from professional training.
Without appropriate clinical qualifications, NDIS assessors risk misinterpreting information, oversimplifying complex needs, and failing to capture the full picture of an individual’s requirements. The use of an assessment tool does not replace professional expertise, nor does training in administration equate to the ability to apply clinical judgment to complex cases.
2. The idea presented seems to be that NDIS staff will look at separating ‘Support needs', from the person-factors including disability, functional capacity, informal supports and the environmental context, as well as those needs that should be serviced by ‘other departments’’ – This truly isn’t possible.
The fundamental assumption that ‘support needs’ can be assessed in isolation from function, severity of impairment, quality of life, and broader contextual factors is deeply flawed. Support needs arise from the interaction of an individual's disability with their personal goals, daily routines, environmental factors (such as home and community accessibility), and social determinants of health.
For example, two individuals with the same disability/diagnosis may have vastly different support needs due to differences in their home environments, family support, mental health, or co-occurring conditions. A standardised tool that only considers ‘support needs’ without integrating these broader elements risks reducing complex, individualised requirements into rigid categories that may not accurately reflect reality.
3. Reductionistic Approach to Disability and Functioning
The proposal’s emphasis on a highly structured, standardised tool to determine budgetary allocations suggests a reductionistic approach that prioritises bureaucratic efficiency over person-centred, evidence-based practice. While standardisation can be useful for consistency, it is inappropriate if it fails to capture the nuanced, evolving nature of disability and support needs.
Disability and functional capacity are dynamic and influenced by physical, cognitive, psychosocial, and environmental factors. The suggestion that an assessment tool can ‘accurately predict support needs’ based on research or application in another context assumes a level of objectivity and stability that does not exist in real-world disability support. People’s needs change over time, and their supports should be responsive to these changes rather than determined solely by an assessment at a single point in time.
4. Risk of Inadequate and Inaccurate Support Planning
A tool designed to generate ‘scores’ that directly inform budgetary requirements risks reducing people’s lived experiences to numerical values, leading to inappropriate funding decisions. Occupational therapists are trained to conduct holistic assessments, considering not just what a person ‘can’ or ‘cannot’ do, but also how they engage in meaningful activities, their personal goals, and the unique barriers they face.
By placing heavy reliance on a structured tool/s, there is a significant risk of:
Overlooking individualised needs: A participant’s unique strengths, coping strategies, and informal supports may not fit neatly into pre-defined categories.
Creating funding inequities: People with the same ‘score’ will still generally have vastly different real-world support requirements.
Failing to capture fluctuating conditions: Many disabilities (such as autism, chronic illness, and mental health conditions) involve variability in function, which may not be reflected in a static assessment.
Have I mentioned yet that Support Needs Assessments are NOT A REVIEWABLE DECISION?
Can we please think about why this is an issue?
a) This means that whatever the untrained NDIS staff writes down, and however that scores, you cannot argue the outcome of it… Whoever thought that was a sound decision has some explaining to do – the Agency, who determines the funding, is doing the assessment, as an untrainined non-allied-health staff member… and you can’t argue it.
b) This means also that when NDIS Staff speak directly to a participant with severe intellectual impairment, or psychosocial disability who answer (somewhat optimistically, but categorically incorrectly) that they can manage their money and cook themselves meals, rather than their carers or support staff who could more accurately respond that in fact that individual requires significant support to do these and other self-care tasks…. Where are we left? With no recourse for review.
5. Trauma-Informed and Culturally Appropriate Practice Cannot Be Achieved Solely Through a Tool
While the RFI acknowledges the need for trauma-informed and culturally appropriate assessments, these approaches require more than just a well-designed tool. They require skilled, experienced professionals who can build rapport, recognise the impact of trauma on engagement, and adapt assessments accordingly. Without a workforce of trained allied health professionals, there is a risk that assessments will be procedural rather than genuinely responsive to participants’ lived experiences.
In summary, the proposed approach in the NDIS RFI presents serious ethical and practical concerns. It assumes that disability support needs can be assessed in isolation from broader functional and contextual factors, disregards the necessity of clinical expertise, and risks reducing individuals to rigid numerical scores. This reductionistic model is not only inappropriate for the complexity of disability but could lead to funding decisions that fail to meet the actual needs of participants.
A robust, person-centred approach would instead require trained allied health professionals conducting comprehensive, individualised assessments that consider the full scope of a participant’s life circumstances.
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