When a participant needs more support than their NDIS plan recognises

I've recently had an experience with the NDIA that has made me think more carefully about how we're identifying and evidencing higher intensity support needs in our Functional Capacity Assessments.

With the NDIS funding reset now underway, this is something I think we all need to have on our radar.

Under the new Support Determination, funding for social, economic and community participation is being reduced by 50%, while Improved Daily Living Skills funding is being reduced by 10%. However, certain supports are excluded from these reductions, including High Intensity Supports and Intensive and Complex Behaviour Supports.

This made me think about something we might not always pay close attention to when reviewing a participant's NDIS plan. It's not just how much support is funded, but how that support is classified, and whether that classification accurately reflects the participant's needs.

So as OTs, what do we need to do?

Start by checking what's actually funded

I recently reviewed the NDIS plan of a participant with significant support needs and an existing Positive Behaviour Support Plan. She attends a day program five days per week and has experienced approximately 70 documented behavioural incidents since January 2026. Despite these support needs, her community participation assistance was funded at the standard support worker rate.

We submitted a plan variation request asking whether her support classification could be changed to Intensive and Complex Behaviour Supports, supported by her Behaviour Support Plan and incident reports. Unfortunately, the NDIA didn't agree. We were advised that changing the classification would require a plan reassessment rather than a variation. The NDIA also considered the behavioural evidence insufficient and raised concerns about outdated documentation and unused behaviour support funding.

It's one experience, and I wouldn't assume every request will receive the same response. But it reinforced something important for me. We need to be checking how supports are classified in existing plans, not just how many hours of support a participant receives. Particularly when we're completing Functional Capacity Assessments for upcoming reassessments.

What do we mean by intensive and complex?

I think this is where our clinical reasoning becomes particularly important. When we consider Intensive and Complex Behaviour Supports, we need to look beyond whether a participant has behaviours of concern or an existing Behaviour Support Plan. What is the nature of those behaviours? How frequently do they occur? What risks do they present, and what strategies are required to support the person safely?

We also need to recognise that behaviours exist across a spectrum. Not every behaviour of concern will warrant an intensive and complex classification, but we need to consider the frequency, severity, impact and complexity of the support required. In my recent experience, the NDIA didn't consider the documented behaviours sufficiently significant, despite the number of incidents reported. It left me questioning where that threshold sits and how we're expected to demonstrate when it has been met.

The same applies to High Intensity Supports. It's not simply about the amount of assistance someone needs, but the nature of the tasks being performed and the additional skills or competencies support workers require. Our recommendations need to explain why a particular level of support is necessary, rather than simply stating that the participant has high support needs.

What evidence do we actually have?

The other important lesson from this experience is to look closely at the evidence available before making a recommendation. In this participant's case, we had substantial incident reporting, but the NDIA also considered whether her Behaviour Support Plan was current and whether existing behaviour support funding had been utilised. These were factors that ultimately worked against our request.

When completing Functional Capacity Assessments, we need to consider what evidence demonstrates the nature, frequency, risks and complexity of the assistance required. For participants with behavioural support needs, this may include current Behaviour Support Plans, incident reports and evidence of the strategies support workers are implementing. For High Intensity Supports, we need to clearly document the tasks involved and the additional competencies required to provide that assistance safely.

I think it's also worth asking whether the evidence we have actually supports the classification we're recommending. Having significant support needs doesn't automatically mean someone meets the criteria for a higher intensity classification. We need to be able to demonstrate why their particular circumstances warrant that level of support and ensure our clinical reasoning is clearly reflected in our reports.

The consequences of getting this wrong

For the participant I've described, the consequences are significant. She requires 24-hour assistance, but her family provides her overnight support. Because she doesn't receive funded 24/7 disability supports, she doesn't qualify for the High Support Needs safeguard pathway. With the reduction to her community participation funding, she's facing the loss of approximately two and a half days of day program support each week.

Her support needs haven't changed. The funding available to meet them has. I had hoped that having her support classification reconsidered might help protect some of that funding, but unfortunately that hasn't been the outcome. And when she's no longer attending her day program, there isn't additional funding available to ensure she can be safely supported at home.

For me, the biggest takeaway is that we need to identify and evidence higher intensity support needs as early as possible, particularly when completing assessments for upcoming plan reassessments. That doesn't mean every participant with significant support needs will meet the criteria, but where the evidence supports it, we need to make sure we're considering it and clearly explaining our clinical reasoning.

Because as these funding changes take effect, I keep coming back to the same question.

When funding arrangements change, but a participant's actual support needs remain the same, who is expected to fill the gap?