The 2026 NDIS overhaul introduces significant changes for occupational therapists conducting AT assessments. This guide focuses on what's changing, when it takes effect, and how to adapt your practice.
The New Functional Assessment Tool (January 2028)
What's Changing
The NDIS is introducing a standardised functional assessment tool to determine eligibility and ongoing support needs. This tool focuses on what participants can and cannot do in daily life — not on diagnosis or what's available in the market.
Timeline
January 2028: New functional assessment tool introduced for all eligibility reviews
2026-2027: Transition period — current assessment practices still apply, but documentation should prepare for the change
What the Tool Will Assess
The functional assessment will evaluate:
Daily living activities
- Personal care, mobility, communication
- Ability to manage home environment
- Social and community participation
Support needs
- Type and frequency of human support required
- What technology reduces support needs
- What enables independence
Capacity building
- Ability to learn and use new technology
- Potential for increased independence with appropriate supports
How This Changes OT Assessments
Current approach: Diagnosis-based with functional description
New approach: Function-first with diagnosis as secondary consideration
Practical impact: Your assessments need stronger emphasis on:
- Measurable functional outcomes
- Quantifiable support hour reduction
- Evidence of what technology enables
Provider Registration Changes (July 2026)
What's Changing
The reforms expand mandatory registration requirements for providers working in:
- Personal care
- Daily living supports
- Supports provided in closed settings (including SDA properties)
Impact on OTs
For employed OTs: No direct impact — you're employed by registered providers
For private practice OTs: May need to register if providing:
- Ongoing therapy in participants' homes
- Daily living supports beyond assessment
- Supports in SDA or similar settings
For assessment-only OTs: Generally no impact if conducting assessments only
What This Means for Referrals
When referring clients to smart home providers:
Verify registration status — Ensure providers like Innogreen are registered for services provided
Document coordination — Note if provider will install technology, conduct training, or provide ongoing support
Clarify responsibilities — Specify who provides what in your assessment report
Documentation Changes That Start Now
Even before 2028, strengthen your assessment documentation:
Focus on Function Over Diagnosis
Current emphasis: Diagnosis → limitations → technology
New emphasis: Functional barriers → independence outcomes → cost-benefit
In practice:
Instead of: "Client has cerebral palsy affecting mobility"
Use: "Client cannot physically reach door switches from wheelchair. Cannot manage keys due to reduced grip strength. These barriers prevent independent home access and environmental control."
Quantify Support Reduction
Document current support hours:
- What specifically are support workers doing?
- How many hours per week for each task?
- What is the hourly cost?
Project reduction with technology:
- Which specific tasks will technology address?
- How many support hours will be reduced?
- What is the annual cost saving?
Example:
Current support for home entry and environmental control: 6 hours weekly at $65/hour = $390 weekly or $20,280 annually.
Recommended technology: $4,500 (smart lock, voice control, basic automation)
Expected support reduction: 4 hours weekly = $260 weekly or $13,520 annually
Payback period: Approximately 4 months
Evidence-Based Justification
The new functional assessment will require stronger evidence:
[ ] Trial results where possible
- What was trialed and outcomes
- Client feedback on usability
- What worked and what didn't
[ ] Measurable outcomes
- Specific independence gains documented
- Support hour reductions quantified
- Safety improvements identified
[ ] Long-term value demonstration
- How technology supports ongoing independence
- Maintenance and replacement planning
- Integration with future needs
The "In and Out" List Impact
NDIS is formalising what gets funded and what doesn't. This affects:
What Remains Fundable
Smart home technology addressing:
- Physical access barriers
- Safety risks in the home
- Communication limitations
- Environmental control needs
- Support worker reduction
What Faces Greater Scrutiny
Technology that is:
- Primarily for convenience
- Available without disability-specific adaptation
- More expensive than necessary alternatives
- Not clearly linked to functional barriers
OT Documentation Response
Strengthen the link: Explicitly connect each technology to a specific functional barrier
Address alternatives: Document why simpler or cheaper options are inadequate
Show adaptation: Describe disability-specific configurations or customisation
For more on what gets funded, see: NDIS Supports — The In and Out List Explained
Changes to Plan Reassessments
What's Different
Frequency: Some participants will face more frequent reviews under the new system
Focus: Functional assessment will determine ongoing eligibility, not diagnosis
Evidence: Stronger documentation required for continued AT funding
How to Prepare Clients
Document everything:
- Keep records of all technology installed
- Track support hour reductions achieved
- Note safety improvements and incidents prevented
- Collect client feedback on independence gains
Plan ahead:
- Don't wait until review is scheduled
- Build evidence over the entire plan period
- Prepare for potential increased review frequency
Communicate early:
- Discuss potential review changes with clients
- Plan assessment timing strategically
- Coordinate with support coordinators
Strategic Assessment Planning
Before 2028 Changes
Focus on building evidence:
- Conduct thorough functional assessments now
- Document outcomes meticulously
- Quantify all benefits and savings
- Create strong foundation for future reviews
Use the current framework:
- While current rules still apply, document with future requirements in mind
- Reference functional barriers in all justifications
- Emphasise measurable outcomes
Preparing for 2028
Align documentation with functional assessment focus:
- Centre all assessments on what client can and cannot do
- Quantify functional limitations
- Demonstrate how technology enables specific activities
Build longitudinal evidence:
- Track how technology use changes over time
- Document evolving needs and solutions
- Show adaptive capacity of technology
Common Assessment Mistakes to Avoid
Diagnosis-First Approach
Avoid: Leading with diagnosis and inferring functional needs
Use instead: Start with functional barriers, reference diagnosis as context
Vague Functional Descriptions
Avoid: "Client has mobility difficulties"
Use instead: "Client uses power wheelchair and cannot reach switches or door handles. Cannot manage keys due to reduced grip strength."
Missing Cost-Benefit Analysis
Avoid: Requesting technology without showing value
Use instead: "Technology cost $4,500. Reduces support by 6 hours weekly ($312/week value). Pays for itself in 4 months."
Not Considering Future Needs
Avoid: Solutions that don't adapt to changing needs
Use instead: "System allows for expansion and adaptation as client needs evolve"
What Stays the Same
Despite reforms, core principles remain:
Functional Justification Remains Central
NDIS still funds technology based on functional need. The reforms strengthen this focus, not weaken it.
OT Role Remains Essential
OTs are still the primary professionals assessing and documenting AT needs. Your role isn't diminished — but documentation standards are rising.
Smart Home Technology Remains Fundable
When properly justified, smart home technology addressing functional barriers remains fundable. The key is stronger documentation.
Timeline Summary
Now (2026):
- Conduct assessments with future standards in mind
- Strengthen functional documentation
- Build evidence for potential earlier reviews
July 2026:
- Some reform provisions begin taking effect
- Provider registration changes for some categories
2027:
- Continue evidence-based documentation
- Prepare for functional assessment tool introduction
January 2028:
- Functional assessment tool introduced
- All assessments use new framework
Practical Next Steps for OTs
[ ] Review current assessment templates
- Align with functional-first approach
- Add cost-benefit calculation fields
- Include evidence-gathering sections
[ ] Update documentation practices
- Centre on functional barriers
- Quantify support hour reductions
- Strengthen alternative analysis
[ ] Prepare clients
- Discuss potential review changes
- Plan assessment timing strategically
- Build evidence over plan period
[ ] Coordinate with providers
- Work with registered providers like Innogreen
- Ensure quotes align with new documentation requirements
- Clarify provider responsibilities in assessments
Working with Innogreen Through Changes
Innogreen is already registered under current NDIS requirements. We can:
- Provide NDIS-compliant quotes and documentation
- Collaborate on functional justification
- Support evidence gathering for assessments
- Help prepare for reassessment under new standards
Contact our team to discuss how we can support your assessments through the reform transition.
This article reflects announced policy as of June 2026. For official information on the NDIS reforms, visit the NDIS Reform page.
For assessment guidance, see: OT Assessment Checklist for Smart Home AT