S10 E06 - NDIS Support Determinations: What Are We Actually Dealing With?

Recent NDIS legislative changes are creating new considerations for OTs, particularly around plan reassessments and how participants may be able to use their funding. While some implementation details are still emerging, the potential impact on participants could be significant.

For OTs, the priority is understanding what these changes mean in practice. That includes knowing when a reassessment may be possible, clearly documenting support needs and identifying what could happen if recommended supports aren’t available.

As further guidance is released, practices will also need to review their clinical processes and reporting templates. The aim isn’t to predict every funding decision, but to make sure the participant’s needs and risks are clearly documented.

Changes to plan reassessments

Changes to unscheduled plan reassessments include a longer timeframe for the NDIA to decide whether a reassessment will occur. The timeframe discussed has increased from 21 days to 90 days, which could mean participants wait considerably longer for a decision.

There is also a higher threshold for an unscheduled reassessment. The change generally needs to be significant and ongoing, relating to the participant’s functional capacity, personal circumstances, environment or informal supports.

This distinction matters. A permanent change to a participant’s support network may meet the threshold for reassessment, while a temporary situation may be more appropriately addressed through a plan variation.

What this means for OTs

There is still uncertainty about how some of these changes will work in practice. OTs don’t need to predict every decision the NDIA might make, but we do need to understand how the changes could affect the people we support.

Our role is to clearly document what a participant needs to function safely and participate in everyday life. Recommendations should connect directly to functional evidence, risks and the likely consequences if those supports aren’t available.

That clinical reasoning becomes particularly important when considering support determinations and the possibility that participants may not be able to access all of the funding identified in their plan.

Understanding support determinations

The changes also introduce support determinations that may limit how much of particular NDIS budgets participants can use. The areas discussed include social, economic and community participation and improved daily living.

This could create situations where a participant’s reasonable and necessary supports are identified, but a proportion of the relevant budget is subsequently unavailable to spend. The exact impact will depend on the final support determination and how it is implemented.

OTs should therefore avoid assuming a particular percentage reduction before those details are confirmed. Instead, our reports need to clearly explain what the participant actually requires and why.

Make the impact of reduced support clear

Reduced community participation funding doesn’t necessarily mean a participant can simply spend more time at home independently. Some participants require support regardless of whether they are at home or in the community.

If a participant cannot safely remain home alone, this needs to be explicit in their functional assessment. Reports should explain their supervision requirements, why that support is needed and what happens when it isn’t available.

This may include increased vulnerability, exploitation, safety concerns, behavioural escalation or unsustainable pressure on informal supports. The important point is to connect any potential reduction in support with its real-world functional consequences.

Keep recommendations evidence-based

Knowing that funding may be reduced doesn’t mean OTs should increase recommendations to compensate. If the evidence supports 15 hours of assistance, recommending 30 hours in anticipation of a reduction isn’t clinically defensible.

Instead, document the actual level of support required and clearly explain the evidence behind it. Then describe what is reasonably likely to happen if that support isn’t provided.

Our role is to provide strong clinical evidence, not find ways around funding decisions. Clear, individualised recommendations give decision-makers a much better understanding of what the participant genuinely needs.

Consider the impact on therapy funding

Improved daily living funding may also be affected by support determinations. This could reduce the funding available for OT and other allied health services.

That becomes particularly challenging when a participant has limited funding for specific work, such as a functional capacity assessment. OTs still need enough time to complete assessments and reports to an appropriate professional standard.

Review AT and home modification pathways

Changes to reassessment processes may also affect assistive technology and home modification requests. Participants may become hesitant to request changes if they are concerned about what a reassessment could mean for other areas of their plan.

OTs should understand whether a participant’s circumstances require a reassessment or whether a plan variation may be appropriate. Choosing the correct pathway could become increasingly important as these changes take effect.

Clear communication matters here. Participants need practical information about their options without creating unnecessary fear about requesting essential equipment or supports.

Prepare your OT practice now

OT practices shouldn’t assume every clinician is keeping up with NDIS changes independently. Regular team discussions can help everyone understand what has changed, what remains uncertain and what needs to happen clinically.

Now is also a good time to review FCA templates. Consider whether reports clearly explain supervision requirements, foreseeable risks, informal support capacity and what happens if recommended supports aren’t provided.

At the same time, avoid changing templates based on speculation. Update them as confirmed information becomes available and make sure any new wording remains specific to the individual participant rather than becoming generic boilerplate.

Key takeaways for OTs
• Understand the new reassessment thresholds and longer decision timeframes.
• Keep recommendations grounded in the participant’s actual functional needs.
• Clearly explain what happens if recommended supports aren’t available.
• Identify safety, vulnerability and informal support risks where relevant.
• Don’t increase recommendations simply to compensate for anticipated funding reductions.
• Understand when a plan variation may be appropriate instead of a reassessment.
• Review FCA templates as confirmed NDIS guidance becomes available.
• Keep your clinical team regularly updated as implementation develops.

OT UNPLUGGED COMPETITION ENTRY FORM: https://www.verveotlearning.com.au/ot-unplugged-competition-sit-at-our-table