S7E01 - It’s Not the Tool, It’s the Process: The ICAN Conversation
The recent announcement confirming the ICAN tool as the foundation for future NDIS support needs
assessments has sparked serious discussion across the Occupational Therapy community. While many clinicians recognise the need for a more consistent national approach, the way ICAN is being positioned raises major questions about process, workforce capability and the independence of assessments. Used as part of a broader OT evaluation, ICAN can be useful. Used alone to determine funding it risks misrepresenting function and undermining the professional reasoning OTs bring to complex cases.
Beyond the tool itself: why process matters more than the platform
ICAN is currently used with participants under the Disability Support for Older Australians (DSOA) program. It provides a framework across domains such as mobility, self-care, cognition and communication. The concern lies not in the tool’s existence but in its unstructured nature. Assessors decide which domains to explore, what questions to ask and how deeply to probe. There are no standardised questions, norms or benchmarks meaning two assessors could reach entirely different conclusions about the same person.
This flexibility demands significant clinical experience and interviewing skill – qualities that develop over years of OT practice. Without that depth, important details can be missed especially when assessments rely heavily on self-report rather than observation. The training for ICAN focuses mainly on how to complete the form, not how to interpret or validate the information gathered. When used by non-clinical assessors the potential for bias and inaccuracy increases sharply.
Reliability, bias and the independence problem
The NDIS has indicated that the agency itself will employ assessors to complete support needs assessments. When the same organisation controls both assessment and budget setting questions of neutrality are unavoidable. Current legislative wording requires assessors to consider NDIA-requested assessments but only may consider other professional reports. That single word – “may” – creates uncertainty about whether participant-provided clinical evidence will be given proper weight.
This approach mirrors earlier concerns raised during the independent assessment debate of 2021. If an NDIA-employed assessor’s findings can override treating clinicians’ data without opportunity for clarification, participants risk losing access to necessary supports and OTs risk having their evidence dismissed without review. The process must allow for right of reply, transparent reasoning and consistent standards across assessors.
What makes ICAN different from functional assessments
Unlike structured tools such as the Vineland or other standardised measures, ICAN lacks normative data and published inter-rater reliability. It generates narrative statements rather than comparable scores. While it may complement a clinical assessment it should never replace comprehensive observation, task analysis and validated functional measures. The risk is that a conversational checklist could be treated as a definitive reflection of capacity when it captures only part of the picture.
For now, ICAN is intended for participants aged 16 and over but paediatric therapists should still pay attention. The broader reform agenda signals a long-term move away from current functional capacity assessments (FCAs) so understanding the principles and limitations of ICAN will help clinicians prepare for future expectations.
How OTs can safeguard quality, ethics and business continuity
In the meantime OTs can take practical steps to strengthen practice and protect service viability.
First, continue writing clear and defensible reports that link observed function, assessment data and participation outcomes. Be explicit about what was trialled, what worked, what didn’t and why.
Second, corroborate self-report with direct observation, caregiver input and measurable results wherever possible. Simple additions like annotated photos or short video clips (with consent) can help bridge gaps if decisions rely on third-party review.
If you encounter an NDIA decision based solely on ICAN findings, reference the tool’s lack of standardisation and reliability in your response then present the alternative evidence your assessment provides. The key is to keep reasoning transparent and grounded in observable function.
Business-wise, services that rely heavily on FCAs should diversify now. Build capacity in home modifications, assistive technology, participation-focused therapy and supervision. These areas remain in demand regardless of how assessment frameworks evolve. Supporting participants through reviews and appeals will also remain critical. Educate clients about documenting outcomes, collecting incident notes and keeping evidence ready for future reviews or tribunal processes.'
Transitional rules and funding decisions
The 12-month leniency period for incorrect purchases under $1,500 has ended. From now on, errors may trigger recovery or compliance action. With final guidance still pending, OTs should document the functional rationale, cost-effectiveness and risk mitigation for every recommendation.
Across the country, decision-making on low- cost AT and community access supports remains inconsistent and appeals continue to overturn a large proportion of NDIA determinations – proof that sound, evidence-based documentation still carries weight.
Compliance and business obligations for 2025
The changing funding environment isn’t the only issue to watch. In New South Wales, a portable long service leave scheme has been introduced for the community services sector. While it includes disability supports, allied health professionals may fall outside scope because they provide clinical not ongoing support services. Nevertheless, all employers must complete the self-assessment to confirm their position and keep records in case of future audits.
Meanwhile, providers delivering paediatric services in Queensland must now comply with the Child Safe
Standards. Align policies with national frameworks, ensure all staff complete safeguarding training and embed clear procedures for recruitment, incident reporting and complaints.
Key takeaways for OTs
Support needs assessments are changing and ICAN will soon form part of that picture. The tool itself isn’t the danger – it’s how it’s applied, who applies it and whether independent clinical reasoning remains central.
Continue documenting comprehensively, question decisions that don’t align with observed evidence and adapt your business model so your expertise stays indispensable regardless of future funding structures.
In summary:
• ICAN is planned for participants aged 16+ but its rollout will take time
• The process and workforce matter far more than the tool itself
• Lack of norms means outcomes can vary assessor-to-assessor
• Maintain defensible, evidence-based reporting and advocate for right of reply
• Diversify beyond FCAs and monitor compliance changes in NSW and QLD
• Change is inevitable – but with strong reasoning, clear evidence and ethical practice OTs can continue to anchor the system in quality, fairness and function-first care.
