Comments on NDIA solutions for assistive technology
NDS appreciates the opportunity to comment on the National Disability Insurance
Agency (NDIA) discussion paper ‘Towards Solutions for Assistive Technology’.
NDS strongly supports the objectives of the discussion paper to maximise participant
choice and control, expand innovation and ensure sustainability around the use of
technology. We also endorse the capacity building framework. However, we are
disappointed that the discussion paper narrowly focuses on misguided strategies to
reduce cost through wholesale prices. The paper proposes a managed approach (either
by the NDIA or external organisation) to the sourcing and procurement of bulk assistive
technology products, with an expert panel overseeing decisions about what products to
buy. This option would not be appropriate for a great majority of assistive technology; it
is at odds with the broader NDIS market design principles and inconsistent with ‘best
practice’ research. Wholesale provision, through a managed tender process, has a
place but should not be the main strategy for delivering sustainability.
NDS would like to see the NDIA explore and test a broader market-based approach to
assistive technology provision. Once properly tested in trial sites we will know what
problems need fixing, whereas the current procurement proposals seem to be leaping to
solutions for historic problems in non-NDIA funding regimes. The problem with current
processes for accessing assistive technology, including in the NDIA trial sites where
they use state equipment schemes, is that funding criteria and constraints prevent
efficient markets from developing –reducing choice and timeliness of supply.
The NDIA should, instead, make strategic investments that enhance existing technology
markets so they become more inclusive, responsive and efficient. This can be achieved
by making sure reliable advice and support for helping consumers make informed
choices are available, collecting information about market activity and prices to inform
package sizes; and enabling specialist and volunteer networks that provide adaptation,
refurbishment and loan schemes.
This submission builds a case for, and proposes steps towards, a more market-oriented
approach to assistive technology consistent with the NDIS objectives.
Tap into the ordinary yet constantly evolving technology markets
The dynamic role technology plays in enhancing the lives of people with disability and in
reducing long-term support costs is indisputable. We should also recognise that this
happens in ordinary life too. Technology companies play a major role in constantly
adapting and modifying offerings to better meet all of our needs and desires. By
recognising the impact of technology in our lives, and the way markets and choice drive
this for most people, we can look at better ways to include people with disability in this
much wider market.
Unfortunately governments have mostly failed to use ordinary markets or create
disability funding regimes that allow a sufficiently personalised or innovative response to
technological disability support options. As a result, people with disability’s life plans are
National Disability Services: Submission on NDIA Solutions for Assistive Technology
frustrated by administrative hurdles, waiting lists, nonsensical delays in authorising
procurement, inadequate adjustments and many missed market opportunities1.
These well-documented barriers preventing good use of general and disability-specific
technology are imposed by overly bureaucratic and underfunded regimes. The NDIS
provides the perfect opportunity to turn this around with its individualised funding
completely changing market demand. It gives us an opportunity to explore the potential
of the wider market that has proven to effectively offer innovation, choice and efficiency
in technology to all people.
We are very disappointed that the main proposals in the paper set up supply constraints
rather than allowing the market to develop.
Build from the evidence to test the market
The NDIA must use a more evidence-based and evaluative approach. Good research is
available on the practical challenges and opportunities with assistive technology and
related markets,2 which emphasise the importance of consumer choice and considering
what’s involved in every step of the pathway to accessible technology, such as
adequate advice and support to inform good choices.
We also urge the NDIA to take advantage of the ‘learn and build’ approach to the
scheme implementation by carrying out market trials of the technology funding
approaches. This should be done as soon as possible as part of an evaluative process.
Make use of the value-add that comes from competing retailers
Some of the costing assumptions in the paper have not considered the value of human
services provided by assistive technology retailers. Assistive technology is not simply a
product market, it involves significant human services as acknowledged in the proposed
capacity building framework. Retailers provide a number of services, including
information, advice, personalisation, trialing and fitting services.
However, these services would be absent in a predominantly wholesale environment.
Therefore some purported financial gains from a wholesale approach to purchasing will
be lost through additional, less efficient, expenditure on information and advice
provision through individual plans. This loss would add to efficiency losses in a market
that is driven by government tender processes rather than consumer demand and need.
Invest in increasing choice and control
We commend the choice and flexibility in the proposed capacity building framework
which recognises that individual interests, circumstances and capacity can all vary, in
addition to the complexity of technological support options. However, we are concerned
that there is no clarity in the paper about how essential and independent information
1
Layton, N. Wilson, E. Colgan, S. Moodie, M, Carter, R. 2010. The Equipping Inclusion
Studies: Assistive Technology Use and Outcomes in Victoria. Burwood: School of
Health and Social Development and Deakin Health Economics, Deakin University.
A comprehensive European position paper on the delivery of effective assistive
technology published in 2013 comprises more than a decade of research and policy
review (http://www.atis4all.eu). This was 'translated' for Australia by Australian
Rehabilitation & Assistive Technology Association (http://www.arata.org.au)
2
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National Disability Services: Submission on NDIA Solutions for Assistive Technology
and advice will be provided and funded, or how related expertise should be developed
and sustained. It is also important to acknowledge that some technology will always
require expert assistance regardless how expert the consumer.
The evidence is clear that to ensure enough information, advice and decision support is
available to ‘novice’ or ‘developing’ participants using assistive technology, we need to
invest in specialist advisors and allied health professionals. Otherwise, these services
will not be available where and when required. The NDIA funding and pricing approach
must look to ensure sufficient clinical governance and supervision to prevent
undersupply and loss of expertise.
The NDS would like to see direct bulk purchasing explored for technological expert
advice hubs that are widely accessible, consistent with the ‘Information, Linkages and
Capacity Building’ (ILC) proposals recently released by the Government. This should
enhance existing ‘independent living centres’ and other not-for profit and independent
advice providers. This approach could proceed in the trial sites and be evaluated.
Another avenue that should be explored is investment in remote communication
technology and infrastructure to help improve staff supervision and direct service
provision. Telecommunications, video conferencing, internet, video games or virtual
worlds3 could all play a role in developing participant capacity and assisting with the
ongoing use of technology. Communication technology is particularly useful for remote
and rural regions but it could also be beneficial for using allied health professional staff
in urban environments. The investment required for this infrastructure can be significant
and the public benefits are widespread. This means it is best achieved through
collaborative government initiatives between the NDIA, aged care, health and education
which all have some similar needs.
Ensure sustainability with clearer guidance for determining individual
funding - not by constraining the market
The paper recognises the diversity of assistive technology; from mass-produced
products to complex and custom-made solutions. For much of this technology (though
not all) a normal competitive consumer market should work well at producing the
innovation required, including a diverse range of products, timely supply and
competitive prices, such as wholesaling simple products to attract customers to their
retail outlet. This is assuming the demand side issues have been addressed with
capacity support and advice for decisions and individualised funding.
However, we recognise that there must be a limit to funding. Similar to other support
types, the amount of funding the NDIA makes available for technology must have
defined boundaries informed by evidence about reasonable costs, investment outcomes
and the market.
NDS is surprised that options for determining the size of funding for technology, within
individual packages, have not been explored in the paper. There are complex questions
that need to be answered about pricing and provision in plans, including:

What is reasonable and necessary?

What up-front costs will pay off over the longer term?
3
Enaksa Garde, E and Bruce, W. 2013. Literature Review: Specialist Support at A
distance, Scope, Practical Design Fund Project (NDIA)
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National Disability Services: Submission on NDIA Solutions for Assistive Technology

How much depreciation and maintenance should be built in?

Can participants invest their own money to customise products, such as
choosing a preferred colour?
Developing guidelines to address these questions is a significant part of the task of
ensuring sustainability for the NDIA using a market model as adopted for other
supports. These matters should be addressed urgently.
The existing market is already regulated by legislation covering consumer protection,
therapeutic goods and imports and state-based funding rules. With the implementation
of the NDIA, the market could benefit from additional surveillance of price and
independent sign off processes for some more expensive prescribed technology (similar
to the pharmaceutical market) in addition to NDIA registration requirements.
Facilitate the growth of hire and refurbishment service options
Some assistive technology needs can be effectively met using hire and refurbishment
options. This is particularly useful for people whose function and requirements change
rapidly. This may be due to the development of capacity over time (such as children), or
the progression of a particular condition. The market can, and does deliver these
options where possible, as many suppliers routinely recycle and reissue assistive
technology through rental programs. There are also volunteer-based networks in place
that facilitate reuse. However, the proposed tender, panel and wholesale approach may
reduce the viability of some of these smaller services. This is a major concern as a
vibrant and diverse market should include many niche providers and networks of
equipment.
Value and enhance existing networks and services
NDS is disappointed by the lack of consideration of how to retain or grow very effective
initiatives with strong infrastructures and networks in place. This includes, but is not
limited to the volunteer-based ‘Technical Aid’ organisations4, the Victorian
Communication Network and several specialised technology equipment libraries or loan
scheme networks, such as those run by organisations which support people with MND
and with blindness or low vison.
These services have evolved over time in response to specific needs and have built
significant social capital. The NDIA needs to make sure they remain viable or the sector
will lose infrastructure and expertise around some assistive technology needs. This
could create under-supply and drive up prices as well as reducing positive outcomes for
people with disability. NDS would like to see bulk purchasing of information and advice
from these services consistent with the ILC proposals, as well as a funding model that
maintains the ability of these services to operate in the market place. This means not
narrowing the scope for choice to a managed wholesale procurement approach.
4
Not-for-profit Technology Assisting Disability (TAD) organisations operate across
Australia drawing on the qualified volunteers (e.g. professional engineers, architects,
technicians, tradespeople, skilled handymen, etc.) in concert with occupational
therapists, physiotherapists, and rehabilitation specialists. These remarkable services
meet specific life-style equipment needs for people with disability through advice,
design, construction and adaption of equipment otherwise commercially unavailable.
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National Disability Services: Submission on NDIA Solutions for Assistive Technology
Limit ‘panel’-informed and managed procurement
The proposed approach to manage bulk purchasing of wholesale products informed by
an expert panel can only efficiently apply to commonly used and generic products that
do not benefit from human assistance or tailoring. As noted earlier there is a value-add
in retail services for many assistive technologies that is not available in a wholesale
environment, and which must be paid for in individuals’ plans if a wholesale approach is
adopted too broadly.
A panel-informed approach to procurement decisions will limit choice, personalisation
and innovation which are essential for a vibrant market and especially the fast-evolving
possibilities of technology. Some reports from the trial sites show that a lack of regard
for the need to closely tailor some technology, with an over-emphasis on using generic
products, has led to wasted efforts, costing more in the long run and delaying provision.
The proposed tender process to determine suppliers coupled with the panel approach to
determine products, with relatively tight prescription, can seriously impede innovation as
evident in the tendering and prescriptive approach to purchasing and contracting
Disability Employment Services.
There is also a risk that by favoring big supply tenderers, some of the smaller local
technology providers will find it hard to stay in business. This is a particular risk in rural
regions where participants are likely to lose access to local technology providers.
For these reasons NDS urges caution with adopting this procurement model and
suggests that firstly a market approach should be tested and if problems are evident
trials should be established comparing managed and market approaches. Evaluation of
costs and outcomes would help clarify the best way to proceed.
NDS suspects the efficiency and cost savings predicted in the discussion paper would
not eventuate. We note that recent work comparing recommended retail prices across
six OECD countries and Australia found that on average Australian assistive technology
prices were 14% lower.5
Promote innovation to improve total system efficiency
Achieving improved efficiency through innovation and investment in technology is not
just about reducing the cost of technology: it must be seen in the context of overall
support services. Often technology innovations can dramatically reduce the need for
other support options over the shorter and longer term as well as improve outcomes.
However, the ‘panel’ proposal may inadvertently restrict innovation, as a panel decision
on what choices will be available for participants is at high risk of missing the full
possibilities of technology.
There is yet-to-be-invented technology which will dramatically improve support options
and efficiency. It is inherently hard to illustrate this but an example on the horizon is
software for instant Auslan interpreting (translation on a hand held device in both
directions). A communication support of this nature would profoundly improve
community access for Deaf participants, as well as significantly reducing demand for
interpreters. Another example currently under development is the use of robotic
technologies to undertake some personal care tasks.
5
Assistive Technology Suppliers Australasia (ATSA). 2014. Assistive Technology
Pricing: Is it fair and reasonable? briefing and background: http://www.atsa.org.au
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National Disability Services: Submission on NDIA Solutions for Assistive Technology
The scope for innovation is very wide indeed. To fully embrace the opportunities we
need a true market approach - one which can broaden not just the disability sector’s
ideas of how to meet support needs, but also the wider community’s. Innovation may
come from technology sectors or elsewhere and for that to happen these other sectors
need to know about opportunities in the disability sector. The NDIA should play a role in
facilitating this market by distributing information, rather than constraining it by
preventing retail and other business responses. In addition, some targeted seed
investment and partnerships could help create connections between developers and
suppliers and which have regard for existing expertise.
Cooperate across sectors on investment and innovation
NDS has long called for improved consistency in the approaches to funding and
accessing technology and equipment across allied sectors. Particularly, across the aged
care and disability sectors where there is significant scope for improving equity of
access to assistive technologies as well as reducing costs. However, the opportunity for
better cooperation is not only about joint bulk procurement of some simple items. It is
about joint investment, expertise and supply, and is particularly relevant for major
infrastructural developments such as the National Broadband Network. Across Europe
there are a range of telecare and telehealth services being explored in aged-care,
health care, and to a lesser extent the disability sector. The NDIA could play an
important role in promoting and evaluating this kind of innovation through cross-sector
initiatives.
February 2015
Contact:
Dr Ken Baker
Chief Executive
National Disability Services
Ph: 02 6283 3200
Mob: 0409 606 240
[email protected]
National Disability Services is the peak industry body for non-government disability
services. Its purpose is to promote and advance services for people with disability. Its
Australia-wide membership includes more than 1000 non-government organisations,
which support people with all forms of disability. Its members collectively provide the full
range of disability services—from accommodation support, respite and therapy to
community access and employment. NDS provides information and networking
opportunities to its members and policy advice to State, Territory and Federal
governments.
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