How to Write an NDIS AT Justification for a Safety and Communication Device

What a justification is - and why it matters

When an NDIS participant wants to use their funding to buy a piece of assistive technology, they need to show that the item meets the NDIS criteria. That showing - the written evidence and explanation that connects the device to the participant's disability and plan goals - is the AT justification.

The justification is not a separate application or a form the NDIS sends you. It is the documentation you prepare to support the funding decision. For most purchases, it sits behind the scenes: a support coordinator's written rationale, a quote with accompanying explanation, or a formal AT assessment report from an occupational therapist, depending on the cost of the item.

A strong justification makes the funding process faster and reduces the chance of a query or refusal. A weak one - or one that is missing entirely - can stall a plan review or result in the NDIS declining to fund the item. Understanding what the justification needs to cover, and how to write it clearly, removes one of the main friction points in the AT funding process.

This guide covers what the justification must include, how the requirements differ based on the cost of the item, and what language makes the case clearly - specifically for safety and communication devices like the KISA Companion.

Low-cost and mid-cost AT: different requirements

The NDIS divides assistive technology into cost tiers, and the documentation requirements are different for each tier.

Low-cost AT is any item priced below $1,500. For low-cost items, the NDIS does not require a formal AT assessment from an occupational therapist or other specialist. The funding case still needs to exist - the item must be connected to the participant's disability and plan goals - but it does not need to be documented in a formal report. A brief written rationale from a support coordinator, or clear documentation in the service agreement, is typically sufficient.

Mid-cost AT covers items priced between $1,500 and $15,000. For mid-cost items, the NDIS requires a formal AT assessment prepared by a qualified AT advisor - typically an occupational therapist, rehabilitation engineer, or other suitably qualified practitioner. The assessment must address a specific set of criteria, and the NDIA provides a general assistive technology assessment template to guide what must be included.

High-cost AT, above $15,000, requires a full assessment and a formal quote as part of the application.

For the KISA Companion, which is priced at $1,387, the low-cost threshold applies. No formal AT assessment report is required. The justification is simpler - but it still needs to show that the item is reasonable and necessary for this participant. What that looks like in practice is covered in the sections below.

The NDIS assistive technology explained guide covers how the full AT tier system works, including who is eligible and which support categories apply to each type of device.

What "reasonable and necessary" means

The phrase "reasonable and necessary" is the central test the NDIS applies to any support it considers funding. Understanding what it means - and how to address each part of it in writing - is the foundation of a strong justification.

A support is reasonable and necessary when it meets all of the following criteria:

• It is directly related to the participant's disability - the need for it arises from the disability, not from general living requirements that apply to everyone.
• It helps the participant work toward the goals in their NDIS plan.
• It represents value for money - it is not overpriced for what it does, and the benefit to the participant justifies the cost.
• The participant would not need it regardless of their disability - it addresses a need that exists specifically because of the disability.
• It is not more appropriately funded through another system, such as Medicare, private health insurance, or a state government program.
• It is safe and appropriate for the participant's needs and living situation.

A justification that addresses each of these points directly is far stronger than one that simply describes the device and states that the participant has a disability. The NDIS is not assessing whether the device is useful in general - it is assessing whether it is reasonable and necessary for this specific participant, given their disability, their goals, and their circumstances.

Establishing the disability link

The most important element of any AT justification is the disability link: a clear, specific explanation of how the participant's disability prevents them from doing something that the device would enable them to do.

A diagnosis alone is not sufficient. "The participant has autism spectrum disorder" does not explain why they need a specific device. What the justification needs to show is the functional consequence of the disability - what the participant cannot do, or cannot do safely, as a result of their disability.

For a safety and communication device, the disability link typically falls into one or more of these categories:

• The participant cannot reliably sequence the steps required to make a phone call on a standard device - navigating to the phone app, selecting a contact, and initiating the call.
• The participant cannot use a touchscreen reliably due to motor impairment, tremor, or dexterity limitation.
• The participant cannot process the visual complexity of a standard phone interface due to cognitive impairment or vision impairment.
• The participant cannot communicate verbally in an emergency due to a speech or language impairment, and requires a device that can alert contacts automatically.
• The participant lives or moves through the community with a fall risk and cannot reliably summon help after a fall using a standard phone.

The justification should describe the specific functional limitation using the participant's actual situation, not a generic description of the diagnosis. The more specific the description, the more directly it answers the NDIS's question: why does this participant, with this disability, need this device?

Why standard technology does not address the need

The NDIS considers whether a lower-cost or standard option would meet the participant's needs. For safety and communication devices, this means the justification should explain why a standard smartphone or tablet is not a workable solution for this participant.

This is not about the device being inconvenient or unfamiliar. It is about the device being genuinely unsuitable - creating a functional barrier that the disability makes it impossible to overcome with reasonable effort or support.

For participants who cannot use a standard phone, the typical reasons include:

• The number of steps required to make a call - unlock, navigate, select, confirm - exceeds the participant's reliable sequencing ability.
• The touchscreen cannot be reliably operated by the participant due to their motor impairment.
• The abstract, menu-based interface is not navigable without significant support, which defeats the purpose of independent communication.
• In an emergency, the participant cannot be expected to perform the actions required to make a call, even if they can sometimes manage them in calm, supported conditions.

Accessibility features built into standard smartphones - larger text, simplified mode, voice control - are worth addressing if they have been tried and found insufficient. "Accessibility settings were explored and were not sufficient for this participant because [specific reason]" is a useful addition to the justification. If they have not been tried, it is better not to mention them than to leave an obvious gap that the NDIS may query.

Writing the plan goal connection

Every NDIS plan is built around the participant's goals. A well-written justification identifies the specific goals in the participant's current plan that the device supports, and explains the direct connection between the goal and what the device does.

For a safety and communication device, the relevant goals are usually in one or both of these areas.

Communication and social connection. Goals such as maintaining regular contact with family members, being able to initiate communication independently, or participating in community life without constant support align directly with a purpose-built communication device. The justification should state the goal - using the language from the plan, where possible - and explain how the device supports it. If the plan goal says "maintain regular contact with my support network", and the device provides one-button calling to pre-set trusted contacts, the connection is clear and direct.

Safety and independent living. Goals around living independently, managing daily risks associated with the disability, accessing the community safely, or reducing reliance on constant carer presence support the case for a device with SOS, fall detection, and GPS functions. The specific functions of the device should be mapped to the goal clearly: "The KISA Companion's fall detection function supports this goal by alerting nominated contacts automatically in the event of a fall, without requiring any action from the participant."

Where a device supports multiple goals, both connections should be documented. Support coordinators often find this useful when a participant's plan includes goals across both communication and safety - it may be documented under more than one AT category in the participant's plan.

If the relevant goals are not yet in the participant's plan, they cannot be used as justification for the current plan period. The appropriate step is to raise the goals at the next plan review, or discuss a plan variation with the support coordinator or local area coordinator (LAC) before the purchase is pursued.

Writing the justification: what to include

For low-cost AT like the KISA Companion, the written justification does not need to be a long document. A clear, factual one-to-two-page summary that covers the key points is sufficient. The following elements should be included.

Participant details. Name, NDIS number, and plan management type - agency-managed, plan-managed, or self-managed. This confirms who the item is for and how the purchase will be processed.

The specific item and its cost. The exact product name, price, and the NDIS support category under which it will be claimed. For the KISA Companion, this is the Core Supports - Consumables budget, low-cost AT below $1,500. KISA can provide a formal quote that includes this information, along with documentation identifying which support categories the device qualifies under.

The disability-related reason. A clear description of the functional limitation that creates the need for the device - not just the diagnosis. This is the most important section of the justification, and it should be specific to this participant's actual situation.

The plan goal it supports. The specific goal or goals from the participant's current NDIS plan that the device will help achieve. Quote or closely paraphrase the goal as it appears in the plan wherever possible.

Why this specific item. A brief explanation of why this device - rather than a lower-cost or standard alternative - is appropriate for this participant. For a participant who cannot use a standard smartphone, this section addresses that question directly and pre-empts the most common query.

Who is writing it. The name, role, and contact details of the person preparing the justification. For low-cost AT, this can be the support coordinator, LAC, or a family member who is the participant's plan nominee. For mid-cost AT, it must be a qualified AT advisor.

For mid-cost AT: what the formal assessment must cover

If the item falls in the mid-cost range ($1,500 to $15,000), a formal AT assessment from a qualified advisor is required before the NDIS will fund it. The full requirements are detailed on the NDIS assistive technology assessments page, which also provides a downloadable template.

The assessment must include:

• An explanation of how the assistive technology will help the participant work toward their plan goals.
• Information about any previous assistive technology the participant has used and why it was insufficient.
• An explanation of how the item fits with the participant's other NDIS supports.
• An approximate cost for mid-cost items, or a formal quote for high-cost items.
• Where a trial has been completed, details about how the participant can safely use the item and the long-term benefits observed.

The qualified advisor - typically an occupational therapist - does not have to use the NDIS template, but the evidence they provide must cover all the information the template asks for. Gaps in any of these areas are the most common reason an assessment is returned or queried.

For safety and communication devices at the mid-cost level, the occupational therapist's assessment will usually include an observation of the participant attempting to use a standard phone, a functional description of where that process breaks down, and a recommendation of the specific device with a direct connection to the participant's identified goals.

Language that strengthens a justification

The language used in a justification shapes how clearly it answers the NDIS's criteria. A few specific choices make a significant difference.

Describe function, not diagnosis. "The participant cannot reliably initiate a phone call without step-by-step verbal prompting from a carer" is more useful than "the participant has an intellectual disability." The NDIS already knows the participant's diagnosis from the eligibility process. What it needs to see in the justification is the specific functional consequence that creates the need for this device.

Use goal language from the plan. Where a plan goal is directly relevant, reference it by name or with the exact phrasing used in the plan. "This device directly supports the participant's plan goal to maintain regular contact with family members independently" is stronger than a general statement about communication needs.

State cause and effect directly. "Because the participant cannot navigate a touchscreen reliably, they are unable to make an emergency call without carer assistance. The KISA Companion removes this barrier by replacing the touchscreen interface with large mechanical buttons, each pre-programmed for a specific trusted contact." This structure - because of X, the participant cannot do Y; the device addresses this by doing Z - answers the reasonable and necessary test in one step.

Address value for money specifically. State the cost of the item and explain what the package includes at that price - the KISA Companion NDIS package at $1,387 (GST free) covers the device, 12 months of GPS tracking, unlimited emergency calls, 24/7 Australian-based monitoring, and call screening, plus accessories and delivery. Compare that to the alternative: for a participant who cannot communicate in an emergency without carer assistance, a purpose-built package that removes that dependency is straightforward to justify on value-for-money grounds.

Common mistakes that weaken a justification

A few patterns consistently produce weak or unsuccessful AT justifications. These are worth checking before submitting.

Relying on diagnosis alone. The participant's diagnosis establishes eligibility for the NDIS. It does not establish the need for a specific device. The justification must go beyond the diagnosis to explain the functional impact that makes this device necessary for this particular participant.

Describing the device instead of its effect. A justification that spends most of its words explaining what the device is and what features it has is answering the wrong question. The NDIS is asking what the device will enable the participant to do that they cannot currently do without it.

Not linking to plan goals. An AT purchase that cannot be connected to a goal in the participant's current plan is unlikely to be funded in the current plan period. The goals need to be in the plan before the purchase can be justified against them. If the right goals are not yet there, a plan review is the first step.

Missing the value-for-money argument. For items at the higher end of the low-cost range, or any mid-cost item, the justification should address why the cost is reasonable relative to the benefit. A brief explanation that connects the device cost to the functional outcome it delivers - and notes what the alternative would cost in ongoing support or risk - is sufficient.

Leaving obvious gaps unaddressed. If a standard smartphone has accessibility features that might appear to address the participant's needs, acknowledge them and explain why they are insufficient for this participant. If this is not addressed, the NDIS may query it, and the process will slow down while you respond to the follow-up.

How KISA supports the process

For support coordinators and families working through the justification for a KISA Companion purchase, KISA can provide a formal quote with full product specifications, documentation identifying which NDIS assistive technology support categories the Companion qualifies under, and guidance for plan managers on the correct claiming process.

KISA has been a registered NDIS assistive technology provider since 2014 (Registration No. 96153614). The NDIS Companion package is priced at $1,387 (GST free), placing it within the low-cost AT tier. It can be funded from the Core Supports - Consumables budget in an approved NDIS plan and qualifies under three NDIS support categories: Communication and Information Equipment, Assistive Products for Personal Care and Safety, and Vision Equipment.

The KISA Companion has no screen, no keypad, and no internet access. It has up to ten large mechanical buttons, each pre-programmed for a trusted contact. The contact buttons can be labelled with text, photographs, or braille to help the participant identify each one.

It includes GPS tracking, automatic fall detection (built in at no cost and activated after delivery via the client portal or by contacting KISA), a dedicated SOS button connected to emergency services, medication and task reminders, and 12 months of 24/7 monitoring by an Australian-based team. Each device is configured before delivery and arrives ready to use.

More detail on the full funding process - which budget category applies, how the purchase works across the three plan management types, and why the Companion does not require a Replacement Support application - is in the guide to how to use your NDIS plan to fund a safety and communication device.

Quotes can be requested at any time at order.kisa.com.au.

Frequently Asked Questions

Does the KISA Companion require a formal AT assessment or justification report?

No. The KISA Companion is priced at $1,387, below the NDIS low-cost AT threshold of $1,500, so no formal AT assessment from an occupational therapist or specialist is required. A brief written justification connecting the device to the participant's disability and plan goals is sufficient for most plan managers and support coordinators. KISA can provide a quote and supporting documentation to help with this.

Who can write the justification for low-cost AT?

For low-cost AT, the justification can be written by a support coordinator, a local area coordinator, or a family member who is the participant's plan nominee. It does not need to come from an occupational therapist or other health professional - though an OT's written opinion can strengthen the case if one is already involved with the participant. For mid-cost AT ($1,500 to $15,000), the formal assessment must be prepared by a qualified AT advisor.

What happens if the NDIS queries the justification?

If the NDIS queries a justification, it will typically ask for more specific information about the disability-related need or the connection to plan goals. The best response is to address each query point directly and specifically - using functional language rather than diagnostic labels. Having a support coordinator or OT assist with the response often speeds the process. For low-cost AT, queries are uncommon when the justification clearly addresses the disability link, the plan goal connection, and why standard technology is insufficient.

Can the same device be justified under both communication and safety goals?

Yes. A device that addresses both communication independence and personal safety can be connected to goals in both areas within the same justification. The KISA Companion functions as both a communication device - pre-set buttons for trusted contacts, two-way calls - and a safety device - SOS button, fall detection, GPS tracking. Where a participant's plan includes goals in both communication and safety, the justification can reference both, and the device may be documented under more than one AT category - a support coordinator can help identify the strongest goal connections in the participant's specific plan.