The NDIS is Changing: Why Evidence is Becoming So Important in NDIS
Changes to the NDIS are here, and they need to be taken seriously. However, understanding the practical and systemic implications of these changes, how they may influence participants, why evidence is assuming greater significance, and how stakeholders can adequately prepare for an evolving NDIS landscape requires a more considered examination.
Historically, diagnosis has occupied a prominent position in discussions concerning disability, eligibility and support requirements. While diagnostic information remains clinically significant, a diagnosis, in isolation, does not provide a sufficiently comprehensive account of an individual’s functional capacity, lived experience or support needs within the context of everyday life.
This raises an important question: why are functional capacity, functional impact and evidence becoming increasingly prominent within the NDIS?
Consider a relatively straightforward proposition: two individuals may have precisely the same diagnosis while demonstrating substantially different functional profiles and requiring markedly different levels, types and intensities of support.
One individual may independently undertake many activities of daily living, while another may require substantial assistance with personal care, communication, decision-making, emotional regulation, social interaction or community participation.
The diagnosis may be identical. The functional consequences may not be.
This distinction is fundamental to understanding an important shift occurring across the NDIS: increasing attention to functional capacity, functional impairment and evidence capable of demonstrating the nature, extent and practical consequences of a participant’s disability-related support needs.
A diagnosis can identify and clinically characterise the nature of a disability or impairment. It cannot, however, independently establish how that impairment manifests across the multiple contexts in which everyday life occurs.
For example, diagnostic information alone cannot adequately demonstrate whether an individual can independently prepare a meal, manage finances, communicate effectively with unfamiliar people, navigate community environments, regulate emotional responses or adapt to an unexpected disruption to an established routine.
Understanding these dimensions requires consideration of functional evidence: evidence that demonstrates how impairment translates into observable limitations, support requirements and participation outcomes within everyday contexts.
The NDIS conversation is changing
The Independent NDIS Review identified concerns that diagnosis-based access lists had contributed to excessive emphasis being placed on diagnostic classification rather than sufficient consideration of functional impairment and individual support needs.
Professor Bruce Bonyhady AM, one of the original architects of the NDIS and co-chair of the Independent Review, argued that eligibility should be based first and foremost on significant functional impairment and need, rather than primarily on medical diagnosis.
Former NDIS Minister Bill Shorten captured the distinction succinctly:
“No longer ‘what is your label?’. But ‘how does your impairment impact your life?’”
Although expressed simply, the distinction has significant implications.
In practical terms, the relevant question is no longer confined to what condition does this person have? It extends to how does that condition affect the person’s capacity to function, participate and exercise independence within the circumstances of everyday life?
This requires a more nuanced examination of the relationship between impairment, functional limitation, environmental context and support requirement.
What does functional evidence actually tell us?
The NDIA currently considers functional capacity across six domains:
- Communication
- Social interaction
- Learning
- Mobility
- Self care
- Self management
Considered collectively, these domains provide a framework through which the practical impact of disability on an individual’s everyday functioning can be more systematically understood.
Importantly, functional capacity should not be viewed simply as a binary determination of whether an individual can or cannot perform a particular activity.
A more meaningful assessment considers the degree of independence, nature of assistance, frequency of support, consistency of performance and environmental conditions under which an activity can be undertaken.
Accordingly, when examining functional impact, the relevant questions include:
What activities can the participant undertake independently and consistently?
Within which areas of everyday functioning is assistance required?
What form of assistance is necessary, such as verbal prompting, supervision, physical assistance, environmental modification or another form of support?
What is the frequency, duration and intensity of that support requirement?
What are the functional or practical consequences when appropriate support is unavailable?
Does the participant’s functional performance vary according to environment, familiarity, interpersonal context or other circumstances?
Is there evidence of progression towards greater independence, maintenance of existing capacity, or deterioration in particular areas of functioning over time?
These questions move the discussion beyond the identification of disability and towards a more systematic, evidence-informed understanding of functional impact and support need.
They also highlight an important principle: functional capacity is contextual.
This distinction is particularly important when attempting to understand the relationship between disability and actual support requirements.
A diagnosis may establish the nature of a person’s disability or impairment.
Functional evidence can demonstrate the extent to which that impairment affects everyday functioning, independence and participation.
And when evidence is gathered consistently across time and contexts, it can contribute to a more comprehensive understanding of what support is required, why it is required, and whether a participant’s functional capacity or support needs are changing over time.
Evidence does not exist exclusively within the assessment room
Clinical and allied health assessments remain an essential component of a comprehensive evidence base.
Occupational Therapists, Behaviour Support Practitioners, psychologists, speech pathologists, physiotherapists, medical practitioners and other qualified professionals provide specialist assessment, clinical interpretation and discipline-specific expertise that cannot, and should not, be substituted by everyday observation.
However, formal assessment represents only one component of the broader evidentiary picture.
The NDIA also recognises information from carers and support workers, as well as case notes from service providers, as potential evidence of how disability impacts everyday life.
This presents an important opportunity for disability providers.
A participant may engage with an OT, BSP or other allied health professional for defined periods at particular intervals throughout their plan.
Support workers, by comparison, may spend hundreds of hours supporting that same participant across a diverse range of everyday situations and environments.
Those hours represent repeated opportunities to observe functional capacity as it manifests in real-world contexts.
They provide opportunities to understand not merely whether an activity was completed, but how it was completed, what level of assistance was required, which barriers emerged, what strategies were effective, and whether functional performance changed over time.
The distinction between recording an activity and capturing evidence
Consider a typical community access note:
“Participant went shopping and had lunch. Participant had a good day.”
It tells us where somebody went.
But it tells us very little about their functional capacity.
Compare that with:
“Participant selected items independently but required three verbal prompts to remain within budget. They approached the checkout independently but required assistance completing payment. When an expected item was unavailable, they required reassurance and redirection before continuing.”
The activity hasn’t changed.
The quality of the information has.
We can now see independence, prompting, decision making, money management, response to unexpected change, emotional regulation and where direct assistance was required.
Most importantly, we now have something that can be compared over time.
One observation is useful. A pattern is powerful.
Imagine collecting meaningful observations consistently over six months.
A participant who initially required five prompts may now require three.
A participant who previously needed assistance completing a purchase may now need only verbal prompting.
A strategy recommended by their BSP may be reducing barriers to community participation.
A skill developed with their OT may begin transferring from a controlled environment into the supermarket, café, workplace or public transport.
Alternatively, evidence may demonstrate that support needs have remained consistent or increased.
All of this matters.
Good evidence isn’t about proving incapacity.
It should accurately capture capacity, barriers, support requirements and progress.
That means documenting improvement just as carefully as we document difficulty.
The 2026 reforms make this conversation even more important
The direction towards functional evidence has continued through the current NDIS reforms.
In 2026, Minister for Health, Disability and Ageing Mark Butler announced reforms involving standardised, evidence based assessments of functional capacity for future NDIS access arrangements.
This reinforces a broader direction that has been developing across the Scheme:
Diagnosis matters, but understanding functional impact is critical.
For Support Coordinators, OTs, BSPs and disability providers, this means the quality and consistency of evidence collected throughout a participant’s plan deserves serious attention.
We need to reconsider progress notes as more than an administrative requirement
Across the duration of an NDIS plan, there may be hundreds, and potentially thousands, of hours of direct support during which meaningful observations of functional capacity occur.
Yet much of this information risks being lost when documentation is limited to recording where a participant went, what activity was undertaken or whether the participant appeared to enjoy the experience.
This is not an argument for increasing administrative burden.
It’s an argument for better evidence.
The support is already occurring.
The observations are already occurring.
The opportunity is to document those observations in a way that contributes to a meaningful longitudinal account of functional capacity and support need, including:
Capacity.
Support requirements.
Prompting and assistance.
Environmental and functional barriers.
Strategy implementation.
Skill acquisition and generalisation.
Progression or change over time.
Connecting the evidence
The strongest evidence picture doesn’t come from asking one professional or provider to do everything.
It comes from collaboration.
An OT may identify a functional goal or strategy.
A BSP may establish strategies to reduce barriers or improve participation.
A Support Coordinator may help connect the participant’s broader supports.
Support workers can then observe what happens when those strategies are implemented repeatedly in real world environments.
Those observations can help inform the wider team.
Nobody replaces anybody else’s expertise.
Instead, the evidence becomes more connected.
Where we believe community access can do more
At Therapeutic Support, this perspective has prompted us to reconsider the conventional parameters of community access.
Community participation should remain meaningful, enjoyable, purposeful and participant-led.
However, these objectives are not incompatible with capacity building, strategy implementation and meaningful functional observation.
Community access occurs within dynamic, real-world environments in which participants encounter decisions, social interactions, unfamiliar circumstances, financial transactions, transportation, changes to routine and varying levels of environmental demand.
These contexts can provide valuable opportunities to understand how functional capacity translates beyond controlled or familiar settings.
Over the coming weeks, we’ll be sharing more about Evidence Based Community Access, what meaningful functional documentation can look like, and how stronger collaboration between Support Coordinators, OTs, BSPs and frontline support teams can help create a clearer picture of participant progress.
Because community access shouldn’t simply record:
“Where did we go today?”
We should also be asking:
“What was the participant able to do, what support did they require, what did we learn, and is that changing over time?”
Further reading
Independent Review of the NDIS, commentary from Review co-chair Professor Bruce Bonyhady AM,
Former NDIS Minister Bill Shorten Speech,
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
