Earlier this year, the NDIA announced that they would commence sending Impairment Notices to all Participants. After we get past the gag reflex upon reading the term ‘Impairment Notice’, we need to understand how they fit into the day to day of the NDIS – because they stand to be a very important document indeed.
What does the legislation say?
Essentially the legislation that amended the NDIS Act in 2024, states the following:
Section 34(1) aa:
the support is necessary to address needs of the participant arising from an impairment in relation to which the participant meets the disability requirements (see section 24) or the early intervention requirements (see section 25)
This means that supports will only be approved to be funded by the NDIS if it is demonstrated that they will directly address the impairment that the Participant has been deemed to be NDIS eligible for.
Impairments are categorised into 6 categories; Intellectual, Cognitive, Neurological, Sensory, Physical and Psychosocial.
What does an Impairment Notice look like?
Last week, we had no idea as to whether Participants would receive a dedicated document or whether the approved Impairments would be listed within their Plan. This week, it seems that the template was inadvertently sent to a Participant – who promptly shared it to a large community on social media. We are most grateful for that generosity.
The template gave us some insight into what Participants are going to be provided with. They will be told what the NDIA has on record as to their listed, eligible Impairments. There is an option to make corrections or add impairments categories with the requisite evidence.
How do they decide on which Impairment categories are approved?
This is where it gets interesting.
The NDIA have been busy mapping Impairment categories to diagnosis.
The Operational Guideline for Applying to the NDIS lists the Diagnosis / Conditions that are recognised under each Impairment Category. You can find this here.
More recently, an FOI request revealed mapping with several discrepancies when compared against the Operational Guidelines. You can request a copy of this document via the Freedom of Information page on the NDIS website. Document FOI 24/25-0883. I will also upload this document within our Nacre Consulting Facebook Group, Allied Health Business Brilliance.
Either way, the Impairment Categories appear to be quite blunt and I anticipate some ‘to and fro’ while cases are made as to whether the NDIA are accurately representing the impact of a particular diagnosis or condition.
The Impact for our Reporting
We know that when supporting a Participant to access the supports that they need, our reports need to very carefully address that support request in terms of how it is going to address the approved impairment.
Asking a Participant for a copy of, or at least to read their Impairment notice might feel like overreach – but if requested supports are going to be approved they are going to have to be framed against the eligible Impairment Category with information relating to how the intervention will support that impairment.
Where to From Here
Like all NDIS changes, we will only really understand the full implications for this implementation through trial and error. Staying connected will be essential so that we can all share and learn from each other as reports are submitted and Plans are built. You can stay connected with us and our 2000+ strong Allied Health community via our Facebook page Allied Health Business Brilliance. https://www.facebook.com/groups/alliedhealthbusinessbrilliance
If you would like a more intensive NDIS focused discussion, you can book in with me for an NDIS focused 2-hour online call. Find out more here.
Until then, keep in touch with us on our website and socials. We love connecting.
