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The application process
This chapter describes the issues faced by participants and providers as
they navigate through the Assistive Technology (AT) process. It considers the equity
and accessibility of the process, as well as examining the evidence around
delays and inconsistencies in the length of time it takes the NDIA to assess
and deliver AT.
Effective information is the first step to achieving the vision outlined
in the NDIS AT Strategy set out in Chapter 1. Clear information ensures
common understanding, efficiency of resources, and manages participants'
expectations. The committee repeatedly heard of the frustration felt by
individuals, their families, carers, service providers, and suppliers, who are
attempting to navigate the process.
A lack of information about what constitutes a sound application
(including what can and cannot be funded) was a common issue raised. The
committee received numerous reports there are inconsistencies between AT
decisions, even in cases where participants' circumstances, needs, and goals appear
Specifically there is confusion as to:
- the method to submit an AT application;
- who can submit an application;
- what constitutes a sound AT application;
- who considers AT applications;
- how to alter an application; and
- how the results of applications are communicated.
Complaints to the Commonwealth Ombudsman Office indicate that
participants find the AT process confusing. Participants are uncertain as to
what information is required with applications and what form this information
The NDIA refused to consider a quote submitted by the
participant's occupational therapist as the therapist had not completed the
required NDIA training. After submitting another two quotes from NDIA-trained
therapists, NDIA staff told the participant they could not accept either quote
as they were not itemised.
Limbs 4 Life argued that the lack of information has a flow-on effect to
organisations, whose resources become absorbed developing material to assist
participants to navigate the Scheme.
The Benevolent Society argued that transparency in each stage of the
application process is vital to managing participants' expectations.
Inequity between application
Submitters raised concerns about how the method by which applications
are submitted can affect the speed with which they are resolved.
There are three ways individuals can apply for AT under the Scheme:
- Prior to a planning meeting:
- the individual pays for an AT assessment, and trials of equipment, and
takes the assessment report, and quotes, to their planning meeting. The planner
allocates a monetary value for AT on the participant's plan and the item can be
ordered once the plan is approved;
- During a planning meeting:
the participant identifies a need for AT and the planner records AT on
the plan but does not allocate a monetary value while the participant undergoes
assessments and trials. When the participant has obtained an assessment report
and quotes, they request a partial plan review for the AT component of their
plan. When the partial plan review for AT is approved, the item can be ordered;
- During an active plan that does not contain an AT component:
the individual completes an AT assessment and equipment trials and
obtains an assessment report and quotes. The participant submits a request for
a full plan review, and can order the AT item once the full review has been
completed and the AT component approved.
Therapy for Kids et al raised concerns that the speed of decisions on equipment
requests were to some degree dependent on how and when they were raised:
If justification report and quotes are all presented at a
face-to-face planning meeting, they are generally actioned within one month and
if they are approved then the funds are in a participant's plan between one and
3 months after the planning meeting. If they are presented at any time around
this meeting or required within the time period of the plan, there are great
delays being experienced.
In addition to concerns around varying processing speeds, the
probability that applications are less likely to be rejected when considered
in-person rather than online was also raised:
If assistive technology requests are lodged during a planning
meeting there is the opportunity for a verbal discussion to be had. This is
clearly a better form of communication then email, and is a way for planners
and participants to ask questions and ensure there is an understanding of the
request. When an assistive technology application is made outside of the
planning meeting, it can only be lodged via email to the NDIA or through the
relevant state based AT program. There is no opportunity for further discussion
or questions with the NDIA employee who is actioning the request.
Administrative requirements for
The committee received numerous submissions that there are onerous
administrative requirements being placed on prescribing therapists as a result
of inefficiencies in the application process.
For example, several submitters were critical of the need to complete a
full AT application for direct replacement AT, arguing that the process is inefficient,
time consuming, and unnecessary. The committee also heard that items outgrown by participants and require one
size up require a full AT application form to be submitted.
Cerebral Palsy Alliance argued that the requirement can cause delays for
AT for participants, waste funding and therapists' time, and affect the
development of children in particular. One submitter provided an example of this process in action:
A 15-year-old girl with a chromosomal syndrome, severe
intellectual disability and very low muscle tone requires specialist orthotics
in her shoes. These need to be assessed and replaced every 12 to 18 months. The
girl required an intensive early intervention program to get her walking and
many people with the same condition us a wheelchair.[...] Every year the planner
agrees the orthotics are reasonable and necessary, however, the family is still
required to submit an assistive technology request, costing $500 in paper work
for orthotics that cost between $800 to $1200 and can take 3 to 6 months for an
The Agency said it is working to address this issue in Q2 2018–19 by allowing
replacement items to be sourced quickly without needing reassessment. It has developed a form for participants, providers and planners to outline
what criteria must be met for replacement items to be added to plans without
further assessment. The approach has recently commenced testing in several
sites in NSW.
Duplication of paperwork to meet
state and federal requirements
Submitters argued there is duplication of paperwork when AT items are
requested through NDIS plans but are obtained through state based equipment
programs, and that this is is further delaying participants' access to AT.
OTA questioned why applications are required to pass through two
approval systems for the same equipment:
Occupational therapists are faced with a system where each
agency blames the other for blockages...It is not clear why there is this
requirement in Victoria for AT requests to pass through two systems of
checking, with all of the expensive delay this entails....The system is
challenging at best, and broken at worst. The involvement of two agencies, and
the unnecessary duplication of bureaucratic requirements, is adding further
delays to an already protracted process. This is frustrating for our members
and tragic for their clients.
Therapy for Kids et al argued that the SWEP process comprehensively
considers AT applications and that participants should not be subjected to an
additional NDIS process:
SWEP receives applications for assistive technology for
people in Victoria [and] approves the items based on their thorough
prescription forms providers are required to provide. However, the NDIS
participants' applications now go through an additional approval process direct
with the NDIA...
OTA argued that the interaction of systems is placing excessive
administrative burden on therapists:
One occupational therapy practice reports that its clinicians
are each having to devote at least one hour a week to following up SWEP
applications. The practice does not bill participants for this time, as its
clinicians do not believe this is fair. Across this organisation, with more
than 50 therapists, it is estimated that AT-related problems amount to 100
hours per week of non-billable time. This is 100 hours that would otherwise be
spent helping NDIS participants achieve outcomes. It also, of course,
undermines the financial viability of the practice.
The NDIA advised that it is continuing to streamline its arrangements,
and highlighted that, in the case of SWEP in Victoria, the state equipment
program altered its online submission tool to receive NDIS related assessments
as part of their assistance in providing quality assurance before passing to
the NDIA for decision.
AT assessment and trials
Before funding for AT can be included in a participant's plan, an
assessment must be conducted by an AT assessor. Depending on the type and
complexity of the AT and the needs of the individual, an assessor may be an AT
Mentor, allied health practitioner, continence nurse, registered dietician,
psychologist, or rehabilitation engineer.
Not all AT requires an assessment to be conducted. The NDIA uses four
complexity levels to identify participants' needs. Complexity Levels 2, 3 and 4
typically require an appropriate assessment form to be completed by, or with
the oversight of, an AT assessor with suitable experience in that AT. No
assessment is required for Level 1 as these items are easy to purchase, low
risk, and require little or no assistance to set up.
Where assessment is compulsory, assessors are required to:
- trial AT with the participant to ensure it is best fit for their
needs and used correctly and safely;
- recommend appropriate AT for the individual's needs;
- provide a recommendation report (including quotes) to the NDIA;
- assist the participant to select and purchase AT once funding has
been approved; and
- set up and provide training on how to use the equipment.
The assessment forms attracted substantial criticism from submitters. AT
assessors are required to complete assessment templates provided by the Agency.
The forms provide information on the participant's goals, needs, equipment
options trialled, and recommended AT. However the templates were criticised for duplicating sections, and being
time-consuming to write, counter-intuitive, and unfit-for-purpose.
Permobil argued there is inadequate scope on the forms to convey how
essential the AT is for the participant:
...therapists are reporting frustration with the report
templates they are required to fill out and submit. The format does not allow
adequate scope for providing information resulting in therapists feeling they
can answer all the questions but still feel like they have not been given
adequate opportunity to highlight how essential the Assistive Technology is.
The report needs to be redesigned with consultation from therapists.
Cerebral Palsy Alliance argued that some sections are poorly formatted
and not clear on what information is being sought. Noah's Ark argued that the application phase is taking 'at least twice as long
as previously' in order to provide sufficient evidence that demonstrates need
for AT. Spinal Life Australia argued that AT report writing under the NDIS is arduous,
not user friendly, and places clinicians under unnecessary stress.
The NDIA acknowledged that further improvements to its templates are
required and advised that it is working to improve its templates to make them
simpler and easier to use.
Assessment for complex cases
For participants who require more complex AT, assessments and equipment
trials are required. Following purchase, assessors assist by setting up
equipment and training the participant in how to use the AT. Each stage of the process is critical to ensuring participants have appropriate
AT and are using it correctly.
AT assessments often require a considerable amount of time for the
assessor to travel to the individual's home, develop an understanding of the
participant's and family's needs, order and assess pieces of trial equipment,
obtain quotes from suppliers, and write a recommendation report for the on
Agency's template. In some cases this can take up to 20–30 hours required for liaison, trial,
reporting, delivery, and set up.
Families who cannot afford to source assessments and reports for AT are
reliant on the funding allocated in their plans to understand what AT solutions
are most appropriate. Without an effective assessment, participants are at risk
of missing out on key AT items. The committee heard that most of the steps in
AT provision are not product-related, and that 90 per cent of work is done prior to providing a quote.
Submitters also reported that not all elements of the assessment and
trial process were funded, particularly around the travel time required to conduct trials, and to set up
equipment and devices. For example, Therapy for Kids et al pointed out that therapists are often not
within close range of participants and that multiple trips to the participant's
home are usually needed. The committee heard that one participant was unable to undertake any training
with his AT because the funding allocated for his AT trial had been drained by
traffic delays in Sydney.
Submitters drew attention to the lack of additional loading for
therapists to travel to participants in regional and remote areas, and for
associated trial and fitting costs. Evidence from the family of Tim Rubenach identified that significant
underfunding of the remote travel cost component of his plan contributed to
unnecessary, stressful, and extensive delays for AT.
Funding for AT, and repairs and maintenance
Several submitters argued that funding for AT equipment or devices is
also frequently insufficient. Therapy
for Kids et al argued that some plans underestimate the cost of AT items even
despite provision of a quote or estimate.
The committee also heard that some plans include insufficient funding
for repairs and maintenance, causing unnecessary delays while an unscheduled plan review process is
With regard to the repairs and maintenance issues, the NDIA has been
attempting to address the funding, and access, for participants. According to
their response to questions on notice, they are calculating an appropriate
budget for repair and maintenance coverage, as well engaging with AT repairs
and maintenance services nationally to explore market-based arrangements to
meet demand. Changes to the process following this work are expected from Q2 2018–19.
Multiple trials and quotes
Submitters expressed frustration that some participants were asked to
undertake several trials and provide multiple quotes in order to demonstrate
cost effectiveness of the selected AT. The Australian Rehabilitation and Assistive Technology Association (ARATA)
argued it is unreasonable to require assessors, participants, and suppliers to
undertake numerous trials simply to obtain cost comparisons, as each trial
takes up considerable time, resources, and NDIS funding. Spinal Life Australia argued that comparative quotes cannot be guaranteed to be
like-for-like due to differences in trial equipment and changes to
prescriptions following second assessments.
The committee heard that some practitioners were asked to trial lower
cost equipment even in complex cases where low cost equipment was not
ILC Tasmania pointed out that that the multiple trial and quote
requirement results in increased report writing time, creating a convoluted and
NDIS requires multiple trials of AT and the therapist to
demonstrate transparency in their clinical justification. This may then result
in additional time/inefficiencies sourcing AT from interstate and increased
report writing time to provide evidence about AT trialled and reasons for
discounting various options.[...] OTs undertake the same trial process which can
take several hours using NDIS plan funds. At the basic AT (Level 2) we still
need to provide 2 quotes which takes time.
Likewise, Noah's Ark was concerned that a significant amount of
providers' time is spent contacting suppliers which can reduce the participant's
funding for other supports. The
inefficiency of the system was underscored by evidence from this NDIS
As a wheelchair user for more than 38 years, with some
experience of scripting wheelchairs, I filled out the wheelchair script and
used the therapists as a check to ensure I had measured correctly. Then we
spend 4-5 hours wasting the time of suppliers and the therapist's time so that
we could say we had tried different brands of chairs and had quotes. The
therapist cost of the equipment trials and quotes was around $900, and of
course had to happen over several days due to coordination of dealers and the
therapist and my time.
Submitters argued that, in some circumstances, it may also be
inappropriate to require participants to undertake trials of equipment before
AT can be included in their plans for logistical reasons. For example, some AT equipment is manufactured and supplied from overseas and
may not be available for participants to trial before purchasing. In one case,
the requirement resulted in perverse outcome for the participant and the
We had an example of a participant who required titanium
heavy duty crutches for mobility which could only be supplied from the US.
Trial was not possible, however trials were completed of other products which were
not suitable. The NDIA planner did not approve this equipment as we couldn't
trial it, and chose to fund less suitable crutches despite the high likelihood
that they would require much more frequent replacement and greater long term
For participants in regional, rural, and remote areas, accessing trial
equipment presents additional difficulties. The Benevolent Society explained that some suppliers may only visit remote
areas every few months:
It is particularly difficult for practitioners in regional
and remote areas to comply with the trialling requirement and ensure that
equipment is provided to clients in a timely manner. In some regional areas,
equipment suppliers may only visit the area every four months so opportunities
to trial equipment is limited. When the practitioners and the family have done
their research and are certain that the equipment they are requesting is what
is needed to support the participant to function, being asked to trial other
equipment which the practitioner and participant know is unsuitable is time
consuming, costly and appears unnecessary.
Assessors' ability to conduct trials may also be impacted by a limited
number of suppliers in some regions. Northcott argued that therapists in regional NSW have limited access to
equipment and it is often impossible for them to organise more than one trial. In Tasmania, the ILC pointed out that often only one supplier may stock the
Even in cases where suppliers stock the required equipment, the ability
to trial can be impacted by the limited number of items available. In Melbourne, Therapy for Kids et al reported that items are often not
available for trial at the time they are needed which can prolong delays for
Other submitters highlighted that some suppliers are reluctant to cover
freight costs, which can further limit access to trial equipment.
WA OTA argued that coordinating availability of equipment with the
required health professional can also complicate and delay the process. Noah's Ark reported that typical wait times in Victoria were 3–4 weeks for an
appointment and 3–4 weeks to receive a quote.
Impact of quote shopping
Submitters raised concerns that AT suppliers who have taken the time to
provide trials and quotes to participants are being penalised for doing so.
Mr David Sinclair, Executive Officer, Assistive Technology Suppliers
Australia, explained that suppliers expend considerable resources to provide a
quote, which is provided to the NDIA, however, some planners will then carry
out a 'desktop shop' for a competing price and another company will benefit for
undercutting the original price.
Special Needs Solutions drew attention to suppliers' inability to claim
for trial services under the NDIS:
We, as a highly specialised service provider, cannot charge
for our services at the moment. We predominantly cover Queensland and northern
New South Wales. I currently have two of our team on a trip from Brisbane and
Hervey Bay to Bundaberg, Gladstone, Rockhampton and return. We are not paid any
fees for actually going out and doing those trials and those assessments with
the occupational therapists and the physiotherapists. For our business to
remain sustainable, we need to be able to charge a fee for our service. Under
the NDIA there is a rental line which the NDIA have advised us that we can draw
a fee for our service from. However, this is very rarely allowed in a plan, so
it's simply not working...The general cost of a week-long road trip is about
$15,000...under the state-based scheme, when we had a tender system, that cost
was built into that. But we were fairly much guaranteed that we were the
preferred supplier under that tender system, so that cost would be
recuperated...At the moment we cannot recuperate those costs at all.
Assistive Technology Suppliers Australia argued that the quote shopping
process has potential to affect market sustainability, and that some businesses
were beginning to protect themselves by charging participants for quotes:
The current approach by the NDIA insisting on multiple
quotations has created an unsustainable market for quote shopping and
under-cutting. Decisions to work with an AT supplier are being based on price,
rather than who has invested time and expertise working with a participant...In
the quoting process, the supply of trial equipment is common, and historically
this has been provided by the supplier at no charge. However due to the quote
shopping that is current with the NDIA, these costs will need to be charged as
businesses cannot sustain hours of work with a risk of missing out on the
The Agency has submitted that it is working to introduce a new funding
tool to calculate appropriate funding for AT supports to replace the current
reliance on quotes. The new tool is expected to be introduced progressively
starting with the most common AT items from Q2 2018-19.
A further development is that the threshold for when quotes are required
was raised from $1000 to $1500 in the last quarter of 2017–18, which will
apparently impact 50 per cent of AT applications.
Tracking application status
As discussed at the start of this chapter, effective communication is
essential to empowering participants, and their families, providers, and
suppliers, throughout the AT process. The committee heard that a lack of
communication throughout the AT process is a cause of considerable stress for
individuals who are waiting for essential equipment. Applicants are continually calling and emailing the Agency to seek updates on
the status of their applications in the absence of any communication.
Evidence indicates that the Agency frequently fails to provide verbal or
written advice to applicants on:
- receipt of applications;
- progress of applications;
- when applications are likely to be considered; and
- the outcome of applications.
The Commonwealth Ombudsman received similar complaints from participants
encountered by participants in finding out about the progress of their AT
request, despite having contacted the NDIA multiple times. In one case cited by the Ombudsman, a participant was never notified of the
outcome of their application:
[T]he complainant had made an assistive technology request
for a prosthetic arm in mid-2017. In March 2018, the NDIA accepted quotes for
the prosthetic arm and added funding to the participant's plan at the time of
conducting a scheduled plan review. However, the NDIA did not notify the
participant of the outcome. In June 2018, the participant complained to our
Office about the apparent delay in his assistive technology request being
decided. Our investigation revealed a decision had been made, but that it had
not been clearly communicated to the participant.
Other submitters reported similar situations.
Lifestart pointed out that Enable NSW would provide written confirmation
of the outcomes of applications to both prescriber and participant, and contact
both of them again when funding became available.
Ms Melissa Noonan, CEO, Limbs 4 Life, argued that replicating the
practice in use at the Transport Accident Commission (TAC) in Victoria might be
beneficial for the NDIS:
I am actually a TAC client...When I meet with my clinician and
discuss my needs and what I need to achieve an independent life, I have
timelines of when that is submitted and when it's accepted. I'm also corresponded
with quite frequently during the review process, and there are timelines in
place. It might be a 28-day process. When the quote is approved, I receive a
copy of that quote. It outlines all of the pricing and everything else related
to the assistive technology I'm going to receive. That could be similar if I
require—if I'm changing devices or upgrading a device and I request a number of
days of training sessions from a physiotherapist, I get exactly the same
Submitters argued that participants should be able to track the progress
of their AT requests through the myplace portal. For example, the portal
could indicate: receipt of application, with delegate, referred to technical
advisory team, awaiting further information, rejected/approved.
According to responses to questions on notice the Agency has designed a
method to track participant and provider AT requests in its business systems,
and that, when implemented, participants and providers will be able to view the
status of individual applications in the myplace portal. It is expected
to be incorporated into the system in the first half 2019.
The committee heard that a lack of clear consistent information on the
AT application process is contributing to confusion for participants and their
prescribing therapists. Whilst the information on the website outlines the
process generally, that process does not appear to be delivered once
participants actually enter the system and go through the application and
Further clear information is required on assessment, trial, and quote
phases, as well as on the methods by which applications can be submitted, what
constitutes a sound application, and who can submit them. The Agency should
also clarify when trials of equipment and quotes will be required and what
format quotes and other information should take.
The committee recommends that the Agency revise the AT information on
its website to improve clarity around all aspects of the AT process, and ensure
training and guidance is provided to NDIA staff to improve consistency in the
information provided to participants, providers and AT assessors.
All submitters, including the Agency itself, agree that the ability to
track the progress of an AT request would assist everyone. It is a basic
requirement, and the committee welcomes steps taken by the Agency to
incorporate it into the myplace portal. It will also provide valuable
data which will assist the Agency in providing further improvement to the AT
process at a systemic level, while alleviating some stress on participants that
a lack, or inconsistency of, information brings. The committee will monitor the
introduction of the capability with interest.
The committee also heard from AT providers on the prohibitive costs of
providing trial items to participants, especially in an outreach context in
regional and rural areas. This service is crucial to participants, and despite
the NDIA advising that there is a 'rental line' item available to pay for such
costs, the committee is of the view that a specific line item for trial costs
should be available for participants in receipt of AT.
The committee recommends that a line item for trial costs of AT
equipment be created and included in the plans of all relevant participants.
Delays in AT decisions
Nearly every submitter to the inquiry raised concerns about the length
of time it takes the Agency to process AT applications. The committee
repeatedly heard that it can take several months, and in some cases over a
year, for the NDIA to process applications.
The most common issue raised in complaints about AT to the Commonwealth
Ombudsman in 2017–18 related to the time taken by the NDIA to decide an AT
request. Some participants who had approached the Office had waited 12 months with no
decision having been made by the NDIA on their request for particular
equipment, such as power wheelchairs, while other participants who requested AT
in the form of home modifications or prosthetics, waited 24 months for an
Impact of delays to participants
AT items typically restore function, prevent deterioration, and improve
quality of life. As such, delays for approvals can significantly impact
participants and their families. The committee heard some participants cannot
be discharged from hospital, others cannot access their own bathroom, and some
have no means of communicating without the requested AT or modifications.
The committee heard there is widespread frustration amongst individuals,
families, carers, service providers, and suppliers, who do not know when
funding will become available.
Amputees awaiting prosthetic limbs are at increased risk of pressure
areas and resulting wounds, infections, and risk of falls which could result in
preventable hospital admissions, and the potential for carer injuries was also
raised. The committee heard that damage can be caused to the remaining limb when
sockets do not confirm perfectly to the individual's body. ECIA drew attention to the impact that these delays are having on children who
miss developmental milestones for lack of essential equipment.
Some families purchased equipment with their own funds in order to avoid
the Scheme' delays for approvals:
If we had to delay surgery whilst waiting for the NDIS to
approve orthotics, our daughter's mobility would have continued to decline, she
would quite likely have gone "off her feet", her muscles would have
lost more strength, she would have done more damage to her joints and it would
have been more difficult for her to regain her mobility post-surgery...
In NSW, the state government intervened to mitigate the impact of AT
approval delays on participants:
As at 7 September 2018 at least 990 participant requests
reviewed by EnableNSW at the request of the NDIA are yet to be finalised by the
NDIA and have been in the system for longer than three months awaiting a 'reasonable
and necessary' decision for plan finalisation...Consequently, EnableNSW has
provided equipment for 567 NDIS participants who are waiting on approval of AT
in their plans. While AT is now the responsibility of the NDIS, NSW Health is
aware that delays in the provision of aids and equipment are adversely
impacting participant's health and has intervened to minimise the impact from
A side-effect of delays for approvals was highlighted by The Benevolent
Society, in that the person who requested the equipment may no longer be
involved with the client or that funding in the plan may be exhausted by that
time. In these cases, there may no longer be a practitioner or funding
available to set up the equipment.
Lengthy plan reviews
Inadequate plans not only have potential to compromise participants'
outcomes, but they can result in the need for participants and their families
to undergo an unscheduled plan review or appeal process which can further delay
access to AT.
MS Australia reported that over 80 per cent of participants the
organisation is providing support to have required a plan review due to errors
in plans, underfunding of supports, or unmet needs not addressed during plan
Submitters were critical of the need for participants to undergo
unscheduled plan reviews in order to correct insufficient funding or errors in
plans. Submitters argued that the process is inefficient and there are often
significant delays before a resolution is reached. Attention was drawn to the additional stress the appeal process takes on
participants and their families.
MS Australia pointed out that undergoing an appeal process does not
guarantee that a satisfactory result will be achieved:
The process for submitting and waiting for a response from
the NDIA is just another cause of stress for those people that are most
vulnerable. The fact that a total plan reset is required to change a single
item in a plan or to amend an error by the Agency is causing a strain on the
resources within the Agency which is then transferring to participants and the
MS support staff involved. Once reviewed, changes to those support areas which
were not included in the plan review leads to reductions in funding for core
supports. These reductions then lead to yet another review and the cycle begins
The Benevolent Society argued that appeals drain funding from
participant's plans and there may be insufficient funding for therapists to
assist with the process.
The committee heard that some families are choosing to avoid the process
altogether by paying for AT themselves, and those who cannot afford to do so
are simply going without:
...in many cases, clients or parents/carers of clients are
taking it upon themselves to fund repairs to equipment because they cannot wait
for the NDIS approval or review process for essential equipment. But in cases
where clients are not able to cover the cost of the equipment or repairs
themselves they are simply going without necessary equipment, which impacts on
the quality of their life.
The lack of communication from the Agency on the progress of reviews was
A major concern is the lack of communication from the NDIA to
participants regarding the progress of a review. This is especially frustrating
for participants waiting for aids and equipment or home modifications.
The Benevolent Society highlighted that a flow-on impact of unscheduled
plan reviews is that service providers are unable to continue to deliver services
to the client while the plan is placed on hold:
Given that NDIS plans do not include flexible or contingency
funding, whenever funding in a plan is insufficient and additional funding is
needed for new equipment, equipment upgrades or repairs a plan review is
required. Whenever a plan is being reviewed, the plan is placed on hold and
service providers are unable to continue to deliver services to the client, or
to bill for services already delivered. Anytime an adjustment is required to
the AT line item in a plan- the plan is placed on hold, and clients and
providers are often not advised that the plan review is underway.
The Commonwealth Ombudsman's May 2018 report into the NDIA's handling of
reviews identified that the Agency had around 8100 reviews on hand, was
receiving around 620 new review requests each week (at February 2018), and some
reviews are taking up to nine months to be completed.
Causes of delays
Evidence indicates there could be a number of reasons why participants
are experiencing delays for an AT application outcome.
- NDIA staffing pressures; 
- Minor changes require a full plan review. 
Specific language required
The committee received feedback that some therapists are uncertain how
to write AT reports in a way that meets the requirements of the Scheme. Permobil argued that therapists are used to writing from a clinical perspective
rather than in a way that links requested equipment to goals:
We have found that often the reports therapists put together
do not link the Assistive Technology to the goals of the participant. Many
therapists are still writing the reports with a focus on "clinical
requirements" without linking the equipment to goals, which results in the
applications being rejected by the NDIA. When the reports are rewritten linking
the equipment to the participants goals the review approves the equipment.
However, this process can take months.
Mrs Julienne, Physiotherapist, Australian Physiotherapy Association,
told the committee that prescribing therapists are learning to write their
reports and recommendations in a way the NDIS requires:
They're non-clinical; they don't understand jargon. Gone are
the days when we could talk to people who understood the disability and what we
were saying. As physios, we dumb it down. We're taking out anything of clinical
significance and putting really basic words in it in the hope that the person
understands it...That's what we're all trying to work towards: what is the
language we need to use; and how do we use NDIS language in our communications
to the agency?
Lack of assessors
Several submitters reported that participants are experiencing
considerable delays accessing AT assessors and that many professionals are heavily booked and managing lengthy waiting
lists. Moreover, the committee heard that some therapists automatically decline NDIS assessment
work due to the delays involved.
PDCN reported that participants who require therapists to prescribe
complex AT are experiencing additional delays that can add weeks or months to
the process. Similar feedback was provided by this NDIS participant:
This was the big hold up for me. The shortage of prescribing
therapists with the skills to deal with a customised wheelchair script meant
that it took about a month to be able to have an appointment with a therapist I
trusted. Her feedback was that she is inundated due to the lack of
therapists...It then took approximately 6 weeks for the therapist to do the
report. Followed up several times but again she said she was flat out and was working
through the assessments systematically.
Able Australia drew attention to the difficulties faced by certain
cohorts, for example, those with combined vision and hearing loss, who face
additional complexity finding an appropriately experienced and qualified allied
health professional who can recommend suitable specialised AT.
There are additional concerns for participants living in regional, rural
and remote areas. Independent Living Centre WA reported that participants in
rural and regional WA are having AT assessments completed by the Health
Department's therapy services as there are no private providers in the region.
Lack of priority system for urgent
A common concern in submissions was the lack of a priority system to
escalate urgent AT requests. According to feedback from stakeholders, there is no way for applicants to
distinguish urgent or dangerous situations for the Agency.
APA drew attention to the lack of a public risk management system in use
by the team processing AT applications:
Decisions and wait times appear to be inconsistent and do not
follow any clear pattern (or documented process) around cost of equipment,
needs, outcomes or risks to the participant. There appears to be no business
rules for when applications will be responded to (approved / declined). There
appears to be no published risk matrix or clear information available around
how to request an urgent application where health or safety risks are imminent'.
Indeed, the committee received feedback that some applications were not
appropriately escalated. In the case of Timothy Rubenach, the urgency of his
situation was communicated at several points; however, the requests failed to
trigger an urgent response:
Urgency was identified in many emails...regarding Tim's health and
wellbeing and this was repeatedly ignored/not acted upon/not even acknowledged
by return email from NDIS, and our 8th March letter, sent the NDIS and to the
Disability Minister was ignored as well...Out of desperation, media (Fairfax and
ABC) was contacted in early May...A final plea was made to politicians the day
before Tim passed away...
Similarly, the AT request for this participant was not escalated:
In one case, our team member watched powerlessly as
recommended equipment requests bounced around between NDIA staff and suppliers,
as the man's condition deteriorated. He eventually passed away, 12 months after
the date of the initial assessment, and the emotional strain caused our team
member to resign.
The committee understands that the Agency has guidance to prioritise
certain requests, including for: children with a rate of developmental changes
that affects need; people with broken equipment in urgent need of replacement
due to risk; and people with progressive neurological conditions where support
needs change rapidly.
The Agency has also advised that it has placed guidance on its website
on how applicants can indicate urgency of requests. It also advised that a
central team of planners is trying to respond to escalations within two
Impact of delays to providers and
Evidence indicates that approval delays can have considerable
consequences on AT suppliers and providers. Most quotes are only valid for
three months and expire by the time the NDIA approves them, meaning suppliers
have to continually requote AT for participants which requires considerable
resources on behalf of the supplier, participant, and assessor. The committee heard that delays can sometimes be so extensive that a new
assessment of the participant is required.
Submitters argued that delays in approval have potential to impact
sustainability of suppliers. PDCN argued that repeat consultations and quotes is inefficient and
uneconomical, especially for smaller businesses:
Suppliers frequently find they are required to re-do
consultations, for example in situations where the initial assessment and quote
was provided up to 12 months prior. This impacts on the viability of businesses
and may edge smaller suppliers out of the market, reducing the level of choice
Likewise, ILC Tasmania argued that it is unreasonable to expect
suppliers to place items on hold for prolonged periods of time:
This is placing pressure on businesses as they run a trial
for the AT, hold the items for the participant for approval, and due to delays,
cash flow suffers. When this is the case for multiple orders, it can create
major problems for a small specialised business.
A common issue raised in submissions was the erosion of the
client-provider relationship as a result of delays for AT. Indeed, OTA argued that reputational risk has become a genuine concern for many
prescribing therapists despite their innocuous role in the AT process:
A related and very serious issue for OTA members is
reputational. Participants frequently develop a negative view of our members
because of delays in the delivery of AT; delays which are attributable to
existing arrangements for AT provision, and over which our members have no
control. This has also impacted adversely on longstanding business
relationships and given rise to a situation where the prescription of AT and
home modifications, an integral part of the occupational therapist's role, has
now become a business risk.
The Agency does not currently have specific KPIs in place across the
Scheme for the consideration, and delivery, of Assistive Technology. The
committee is strongly of the view that what you can measure, you can improve.
The length of time that some people have had to wait for decisions around AT is
unacceptable, especially in light of the length of time people had to wait
under previous state and territory schemes.
The committee heard that it can take months, even years in some cases,
to receive requested equipment or devices. Delays for AT place can have
profound effects on the development of young children, those who require
prosthetics or orthotics, and those with degenerative conditions. The committee
welcomes steps taken by the Agency to address delays, however, it is of the
view that the Agency should set KPIs for the length of time in which staff must
consider and process applications. This will improve inconsistencies in the
Scheme and help to manage the expectation of participants and their providers.
The committee recommends that the NDIA prescribe KPIs for the length of
time in which staff must consider and process AT applications.
The committee also heard that therapists are having to amend their
language in order to meet the requirements of planners, and the administration
of the Scheme. The Committee is concerned that if planners do not have the
knowledge or training to understand clinical language, how can they be in a
position to make decisions about the clinical needs of participants.
The committee urges the Agency to ensure that all delegates responsible
for deciding which AT equipment a recipient may receive, have all the necessary
skills and training to make those decisions.
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