Blind Citizens Australia (BCA) would like to respond to the upcoming introduction of independent functional assessments for National Disability Insurance Scheme (NDIS) participants, as per the recommendations of the Tune review, and those of the Productivity Commission. BCA shares the concerns of other peak bodies in the disability sector regarding the lack of consultation around whether independent assessments are indeed a beneficial approach for NDIS participants, and strongly encourages the National Disability Insurance Agency (NDIA) to provide genuine and numerous opportunities for input and consultation into how independent assessments will be implemented prior to roll-out.

The intent of the recommendations is to make functional assessments more holistic, and to result in more consistent outcomes for NDIS participants. However, without genuine consultation with the disability sector, there is a significant risk that this goal will not be realised. There is potentially great benefit for people who are blind or vision impaired in approaching assessment of each person’s needs in a way that reflects their unique strengths, needs and circumstances. However, an assessment conducted by a professional with no knowledge of blindness or vision impairment, or an appreciation of the holistic approach to each individual, will not be able to deliver these important outcomes.

BCA is concerned by the proposal that independent functional assessments will not take into account the specific needs, knowledge and expertise of professionals who routinely work with people who are blind or vision impaired to inform functional assessments. It is likely that assumptions may be made regarding what equipment people who are blind or vision impaired need, what access to specific areas of training they have and how daily tasks are performed, by a generic approach to assessment. As people who are blind and vision impaired have episodic needs such as orientation and mobility training, or the acquisition of assistive technology and related training, it is vital that assessments are informed by specialist knowledge held by professionals who work in the blindness sector. BCA strongly urges the NDIA to be mindful of the need for this specific knowledge when choosing the successful tender applicants.

It is also of great importance that the NDIA understands that assessors with such specific knowledge are often not available to people in regional, rural and remote areas. Hence, it is vital that people who are impacted upon by the lack of availability of appropriately trained assessors be assisted to gain access to assessors with the expertise required to complete a fully informed assessment of their function and capacity.

To find out more information about the qualifications independent assessors will have, you can visit the NDIA’s webpage which explains who will conduct assessments, at

There is an opportunity for you to question Minister Stuart Robert about your concerns regarding the introduction of independent functional assessments. The “Every Australian Counts” website has a proposed list of questions which you can email Minister Robert via their online form. To see the questions and complete your own submission to Minister Robert, go to

BCA is looking forward to the opportunity of working with the NDIA to ensure that the introduction of independent functional assessments will benefit people who are blind or vision impaired. It is understood that the recommendations of the Tune review and the Productivity Commission are well intended. It is now time to make sure that those good intentions are realised.