NDIS reasonable and necessary: what it means for your reports

Under Section 34 of the NDIS Act 2013, a support is reasonable and necessary if it: (1) will assist the participant to pursue their goals and aspirations, (2) will assist the participant to undertake activities that facilitate their social and economic participation, (3) represents value for money, considering comparable and cost-effective alternatives, (4) is, or is likely to be, effective and beneficial for the participant, having regard to current good practice, (5) takes into account the reasonable expectation of support from families, carers, informal networks, and the community, and (6) is most appropriately funded through the NDIS and not through another service system. From October 2024, the additional criterion applies: the support must be necessary to address needs arising from the participant's disability-related impairments.

The NDIS Amendment Act (Getting the NDIS Back on Track No. 1) that took effect on 3 October 2024 replaced criterion (f) of the old Section 34 test. The previous criterion required that the support 'is most appropriately funded or provided through the NDIS, and not through another service system.' The new criterion is more specific: the support must be necessary to address needs arising from impairments that meet the disability or early intervention requirements. This is not a dramatic change for most allied health reports. It is a tightening. Reports that already linked recommendations to disability-related functional limitations will meet the new standard. Reports that recommended supports without clearly connecting them to the participant's disability will not.

Every recommended support must be directly related to the participant's disability-related functional limitation. This seems obvious, but it is the criterion most often addressed poorly in reports. Medical treatments, general health services, and supports unrelated to disability are not NDIS-funded. Your report must explicitly link each recommendation to a specific functional limitation caused by the participant's disability. 'Participant requires support with meal preparation' describes a need. 'Participant requires support with meal preparation due to impaired executive function and bilateral upper limb weakness secondary to cerebral palsy, which prevents safe use of kitchen appliances and sequencing of multi-step cooking tasks' links the need to the disability.

The NDIA considers whether the recommended support is the most cost-effective option that meets the participant's needs. This does not mean the cheapest option. It means the most effective option at a reasonable cost. If there is a lower-cost alternative that would achieve the same outcome, your report should explain why it is not appropriate for this participant. This is especially important for high-cost items: assistive technology over $1,500, home modifications, and high-frequency individual therapy. 'Individual therapy is recommended because group sessions do not meet this participant's communication needs due to severe social anxiety that prevents participation in group settings' addresses value for money by explaining why the more expensive option is necessary.

Recommendations should be supported by clinical evidence or established professional standards. You do not need to cite peer-reviewed research for every recommendation. But if you are recommending an approach, the planner needs to see that it is an accepted clinical practice, not an experimental or unproven method. Reference clinical guidelines, professional standards, or established evidence where relevant. For common interventions (individual OT, speech pathology, physiotherapy), the evidence base is well established and a brief reference is sufficient. For less common or higher-cost interventions, provide more detail.

The NDIS is the funder of last resort. Before funding a support, the NDIA considers what the participant can reasonably access through family, carers, informal networks, community services, and mainstream service systems (health, education, employment). Your report should acknowledge what informal and mainstream supports are already in place and explain why they are insufficient. If a participant has a carer who provides daily support, note what the carer does and why your recommended support is in addition to, not a replacement for, that informal care. If the participant could access a mainstream service but cannot due to their disability, explain why.

You do not need to write 'this support is reasonable and necessary' in your report. That reads as performative rather than substantive. Instead, address each criterion through your clinical reasoning. For each recommendation: state the specific functional limitation it addresses (criterion 1 and the disability link). Explain how the support will help the participant participate in daily life and community (criterion 2). If the support is higher-cost, explain why lower-cost alternatives are not suitable (criterion 3). Reference the evidence base briefly (criterion 4). Acknowledge informal supports already in place (criterion 5). If the support could be confused with a mainstream service, explain why it is an NDIS responsibility (criterion 6). Done well, this adds two or three sentences to each recommendation. Done poorly, it adds nothing and the planner guesses.