Assistive

Technology Suppliers Australasia Inc 2015

www.atsa.org.au

ATSA Briefing Note January 2015
NDIAs Towards Solutions for Assistive Technology Discussion Paper
published 24th December 2015

The NDIAs Discussion Paper contains many worthwhile points, however ATSA does not endorse its overall
direction and has some significant concerns with the proposed new AT scheme. This brief overview is
intended to stimulate debate and discussion by identifying some of these concerns and questions. ATSA
encourages all stakeholders to carefully read and analyse the Paper and make their own submission.
The Paper is complex and open to interpretation, and this briefing note is based on ATSAs understanding
of the likely impacts of the Papers proposals. There is a need for a clear statement from the NDIA that
explains in straightforward language how their proposals will work in practical terms in the real world and
what this will mean to Participants who rely on AT and related services.
According to the Queensland Competition Authoritys 2014 report into AT pricing, the Australian AT market
is highly evolved and very competitive with prices on average 24% lower than those in other countries.
Australians with disability have access to most of the worlds leading brands of AT through a network of
some 350-400 specialist AT suppliers. This is remarkable in a market of just 22 million people.
The Paper proposes a complete re-engineering of the AT marketplace with the primary goal of driving
down AT hardware prices. Throughout the Paper it is argued that the model to be adopted should be one
of panel supply based on contracts with preferred suppliers (see pages 4, 6, 11. 12. 15-17, 19 and 36).
On pages 16 and 21, the Paper highlights that the NDIA has not yet determined how to provide the
continuum of specialist AT services (many of which are already provided by suppliers, but will disappear
under the proposed model) essential to ensuring quality AT solutions that deliver optimal outcomes for
Participants. Proposing a new hardware acquisition model without a clear understanding of how essential
associated services will be provided and who will pay for them, is a high risk proposal with significant
potential to lead to major failures in services, quality and outcomes. It is also likely to also cause cost
blowouts for the NDIA, and significant delays while it is being developed and implemented.
As detailed in the Paper, Participants AT needs will largely be met by a panel of suppliers that successfully
tender to the NDIA or a third party provider and achieve preferred provider status. There are exceptions
to this including some low cost/low risk AT items purchased through mainstream retailers. Participants
will also be able to procure AT elsewhere when they can demonstrate that their needs cannot be met
through proposed contracted supply arrangements.
ATSA is concerned about the potential ramifications of a panel supply arrangement
a)

Participants choice of what AT they can access will be limited to the brands and models preferred
by the NDIA or another third party.

b)

Participants will not be able to choose their preferred supplier unless their supplier is successful in
being awarded a contract and becomes a preferred supplier.

c)

It seems unlikely that NDIS Participants will own their AT under this purchasing model and the
proposed reissuing/recycling model. This will mean that NDIS Participants are unlikely to have
protections under the Competition and Consumer Act 2010 if they do not own their AT.

d)

Large scale contracted supply arrangements typically advantage large suppliers over smaller, often
niche suppliers, and over time will reduce competition, product variety, innovation, services and
quality and, will eventually lead to higher prices.
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 Assistive Technology Suppliers Australasia Inc 2015

www.atsa.org.au

The evidence used in the Paper for alleged savings on prices is unpublished and unverifiable. Given that
Australia already has the lowest average prices for AT in comparison to other countries, the only way
significant price savings can be made is by reducing choice, quality, services and shifting costs to other
stakeholders. A key aspect of AT prices not directly discussed in the Paper is the extensive range of services
that AT suppliers provide which are included in the retail price.
With regard to the panel supply approach, Participants and allied health professional may want to
consider
a)

How important do you believe it is for Participants to be able access the widest possible range of AT
to meet their needs?

b)

How important do you believe it is for Participants to be able to select their own specialist AT
supplier, and what difference will this make?

c)

Will limiting access to AT products and suppliers in this way be problematic?

d)

Should AT be owned by NDIS participants or loaned to them by the NDIA or another third party?

e)

Will requiring Participants who want non-contracted AT to prove their need for a different product
pose any problems?

f)

Will this have any impact on maximising outcomes for Participants, or their choice and control in
relation to AT?

As well as the above, AT suppliers should consider

a)

What would be the impact on outcomes for your existing customers?

b)

Will you able to participate in large-scale contract negotiations and arrangements with the NDIA or
other third party?

c)

What will be the impact on your viability if your turnover is reduced due to being unsuccessful in
tendering to the NDIA (and possibly other agencies if the model is widely adopted)?

The NDIS and other jurisdictional agencies are investing substantially to reform disability supports from the
traditional, failed, block-funded model, into one where people with disability have choice and control over
what supports they require and where they obtain them. ATSA fully endorses this move, which is
significantly at odds with the approach proposed in the Paper, where choice of AT and suppliers will largely
be vested in the NDIA or other third party.
A much less complex and lower risk approach could be achieved very quickly and simply through utilising
the existing competitive AT market-place and a retail model for AT delivery, as outlined in ATSAs 2014
briefing paper Supporting Choice and Control: Assistive Technology Funding Reforms. Additional safeguards
in the form of price surveillance and intervention when problems arise should be implemented, along with
the existing safeguards of having an independent allied health professional sign-off on expensive and/or
high risk AT, the Therapeutic Goods Act 1989, Competition and Consumer Act 2010, ATSA Code of Practice,
and relevant Australian and international product standards.
ATSA will be developing a detailed response to the Paper and we welcome feedback from people with
disability, their families and caregivers, as well as allied health professionals and AT suppliers. Please send
us your comments via info@atsa.org.au.
To download a copy of the NDIAs Paper -

http://www.ndis.gov.au/document/1286
To respond directly to the NDIA -

http://www.ndis.gov.au/form/assistive-technology-discussion-paper-feedback-form
Note that the closing date for feedback is 28th February 2015, and we strongly encourage all potential NDIA
Participants, their families, allied health professionals and AT suppliers to carefully read the Paper and
make your own submissions.

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