If you're a Speech Pathologist who has had a Replacement Support application returned for more information, or worse, declined outright, the reason is rarely that the clinical case was weak. The reason is almost always that the recommendation letter was written for the wrong reader.
NDIS delegates are not clinicians. They don't read your letter the way another therapist would. They work through a structured decision template with four statutory checkboxes, in order, and they need to find a specific answer to a specific question at each step. If they can't find that answer quickly, the application is returned or declined.
This article sets out what delegates are actually doing when they assess your application, what each criterion requires, and the most common reasons applications get returned. Our full Replacement Support Decision Guide with a worked example recommendation letter is available to download at the end of this article.
The legal basis - section 10(6) of the NDIS Act
Replacement Supports are governed by section 10(6) of the National Disability Insurance Scheme Act 2013. The Act sets out the conditions for approval. Four of these are assessed substantively by the delegate, in this order:
- The support is on the approved Replacement Supports list (s10(6)(a))
- It replaces an existing NDIS support in the participant's current plan (s10(6)(d)(i))
- The cost is the same or lower than the support it replaces (s10(6)(d)(ii))
- It will provide the same or better outcome for the participant (s10(6)(d)(iii))
If all four are clearly met, the application is approved. If any one of them is not clearly addressed, the delegate will either request more information or decline. If declined, options for review are limited. In practice, the participant must wait 12 months before reapplying for the same support.
That 12-month consequence is why the rest of this article matters. A returned application is an inconvenience. A declined application means a year without the funded equipment.
The mindset gap that breaks most applications
The single biggest predictor of a returned application is whether the recommendation letter is written as a clinical document or a decision document.
A clinical document tells the story of the participant: their diagnosis, their history, their goals, their trial, their progress. The clinical reasoning is woven through the narrative. This is how Speech Pathologists are trained to write, and for almost every other purpose it is the correct approach.
A decision document is structured around the assessor's questions. Each section maps directly to one of the four statutory criteria. The answer to each criterion is stated explicitly, in the language the legislation uses, and supported by evidence in that order. The clinical narrative is still there, but it sits underneath the structural scaffolding rather than above it.
Most returned applications contain all the necessary clinical evidence. The delegate just couldn't find it without reading the entire letter and reconstructing the answers themselves. Delegates working through high application volumes don't have time for that, and the workflow doesn't reward them for trying.
What each criterion actually requires
Criterion 1: Is the support on the approved list?
The approved Replacement Supports list contains: standard commercially available household items, smartwatches, tablet devices, smartphones, and apps for accessibility or communication.
For an AAC application, a tablet device and a communication app each qualify as separate items on the list. A bundle containing both (an iPad and Proloquo, for example) is requesting two replacement support items, both of which are on the list.
What the delegate is looking for: explicit confirmation that each item being requested is on the approved list. Naming the bundle without naming its components is a common cause of return.
Criterion 2: Does it replace an existing NDIS support?
The replacement support must replace an existing funded support in the participant's current plan. This is not additional funding. The total budget does not increase.
What the delegate is looking for: the specific budget line, named, with the dollar amount stated. In most AAC cases this will be Capital - Assistive Technology, although Replacement Supports can be drawn from other budget categories where relevant. "The participant has NDIS funding for this" is not enough. "The participant's current plan includes $5,000 under Capital - Assistive Technology, allocated for the purchase of an appropriate communication device" is what the delegate needs to read.
Criterion 3: Is the cost the same or lower?
The cost of the replacement support must not exceed the cost of the support it replaces in the plan.
What the delegate is looking for: a direct comparison between bundle cost and the plan allocation. The cost must include all costs (including shipping) and must match exactly the supporting quote or service agreement included with the application. Mismatches between letter and quote are one of the most common triggers for an application being returned. Where an app requires a specific device platform (most do), an explicit statement that the device included is the lowest-cost model on which that app operates.
The most common error at this criterion is comparing the bundle cost to open-market dedicated communication device prices, for example: "this bundle costs $1,500 compared to dedicated AAC devices which cost $7,000 to $8,000." That is not the comparison the delegate is making. The delegate is comparing bundle cost against the plan allocation. The market price of a dedicated alternative is not relevant to the legal test.
Criterion 4: Will it provide the same or better outcome?
This is the clinical criterion. The delegate must be satisfied that the replacement support will produce an equivalent or better outcome than the funded NDIS support it replaces.
What the delegate is looking for: the phrase "same or better outcome" stated explicitly as a clinical opinion, supported by trial evidence.
The statutory language matters. A delegate scanning for this criterion is looking for the phrase that sits in the legislation. Burying an equivalent statement in clinical narrative makes it findable only by careful reading, which is the opposite of what you want.
The supporting evidence should be specific and observable: how many trial sessions, over what period, with what observed behaviours. "The participant formed multi-word sentences including questions and comments" is useful evidence. "The participant demonstrated willingness to engage with the device" is not, because it doesn't tell the delegate anything about outcome. The letter should also identify alternatives that were trialled or considered, and explain why they were ruled out.
What falls outside NDIS scope
The NDIS is clear that supports used in the education system are the responsibility of the education system. This applies to AAC and other communication supports the same way it applies to any other assistive technology.
If the device will be used only at school or in an education setting, it should be provided and funded by the education system. Participants and families should speak to their school about supports for the classroom environment, not the NDIS.
A Replacement Support application is appropriate where the device addresses disability-related needs in:
- Home and family life
- Community participation and social connection
- Independence in daily tasks
- Emotional wellbeing and communication safety
If your letter justifies the device on the basis of school participation, classroom learning, or risk to mainstream school placement, the application will be flagged as out of scope and may be declined. Frame the rationale around the participant's life outside the education system. Where school is referenced at all, it should be as part of the participant's broader social environment, not as the reason the support is needed.
Ongoing costs
Delegates check whether the replacement support creates additional ongoing NDIS-funded costs. If your letter is silent on this, it raises a question the delegate has to resolve before they can approve.
State the answer explicitly, even when the answer is none:
"This bundle carries no additional ongoing NDIS-funded costs. Ongoing wifi and network costs are the responsibility of the participant's family."
Two sentences. Removes a potential blocker entirely.
How applications are submitted
Speech Pathologists do not submit Replacement Support applications. The application is lodged by the participant, their nominee, or their plan manager via one of three pathways:
- By email to enquiries@ndis.gov.au
- Through their Local Area Coordinator
- Via the myNDIS portal
The application package includes the recommendation letter, a quote or service agreement showing the total bundle cost (including shipping), and any other documentation the applicant wishes to provide. The bundle cost in the recommendation letter and the supporting quote must match exactly.
For families and plan managers handling the cost side of the application, our self-service tool at easyas.assistivetech.com.au generates a draft service agreement that can be submitted directly with the application, with all costs (including shipping) already included.
Assessment typically takes 6 to 8 weeks once submitted.
What good looks like
A recommendation letter that gets approved on first read tends to share the same shape:
- It opens by naming what is being requested, what it replaces, the bundle cost, the budget line and dollar amount, and confirms list eligibility for each component.
- It states explicitly that the bundle replaces the funded support.
- It compares bundle cost against plan allocation, addresses platform exclusivity if relevant, and confirms the lowest-cost model.
- It states the clinical opinion using statutory language, supported by specific trial evidence and a record of alternatives considered.
- It closes with a functional narrative tied to NDIS goals, framed around home, community, independence, and wellbeing.
This is not a longer letter than the clinical-style version. It is often shorter. The work is in the structure, not the volume.
Download the full Decision Guide
Our free Replacement Support Decision Guide sets out the full assessment framework, with worked examples of language that meets each criterion, a pre-submission checklist, and a fully worked sample recommendation letter. It is intended as a working reference for clinical practice and is updated as NDIS guidance evolves.
For families and plan managers
If you've been approved for a "Communication Device" in your plan and you're trying to work out whether your funding covers an iPad-based AAC bundle, our companion article NDIS Communication Device Funding: What It Actually Covers explains the difference between dedicated communication devices and iPad bundles, and why the second pathway requires a Replacement Support application even when funding is already in your plan.
Need to discuss a specific application?
Assistive Tech supplies AAC bundles to NDIS participants under the Replacement Supports framework. We do not write recommendation letters, that is the clinician's professional responsibility. We can discuss bundle composition, current pricing, and how the cost comparison should be framed in your recommendation letter.
- Phone: 1300 088 222
- Email: support@assistivetech.com.au
- Browse: iPad AAC bundles | AAC apps
This article reflects NDIS guidance current at time of publication. For the most up-to-date information on Replacement Supports, refer to ndis.gov.au. This article does not constitute legal advice.
