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 decision-makers are not clinicians. They don't read your letter the way another therapist would. They work through a structured decision template with six statutory checkpoints, 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 assessors are actually doing when they review 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 approval sequence: two steps, not one
Before getting into the criteria, it is worth being clear about where a Replacement Support approval sits in the participant's planning cycle, because this is the single most common source of confusion and wasted time.
There is no pathway by which a delegate approves a Replacement Support directly. A tablet and a communication app are not NDIS supports under section 10, which means a delegate cannot fund them at plan stage even where the clinical case is accepted in full. What a delegate can do is allocate funding for an appropriate communication device. Converting that funding into an iPad and app is a separate decision, made through the Replacement Supports process, and evidenced by a formal approval letter.
In practice this means two steps:
Step 1: secure the funding at plan stage. At plan creation, reassessment or variation, present the clinical recommendation and a draft service agreement. The delegate allocates funding for an appropriate communication device in the Capital - Assistive Technology budget, at a value informed by the evidence. If the participant asks the delegate directly for an iPad and communication app, that request will be formally declined, because those items are not section 10 supports.
Step 2: apply to substitute the iPad and app. Once the plan is in place, the participant, their nominee or their plan manager lodges a Replacement Support application to replace the funded communication device with the iPad and app bundle. The application is triaged by the National Contact Centre (NCC), routed to the Technical Advice and Practice Improvement Branch (TAPIB), and assessed by a Technical Advisor against the six criteria below. If approved, a Replacement Support Approval (S10) Letter is issued. That letter is what permits the purchase and the claim.
The one exception. Where the plan document itself specifically names the iPad and the communication app as a stated support, the participant can proceed on the strength of the plan. This is common in plans issued before 3 October 2024. It is rare in plans issued after that date, but it does still occur. If the plan names the specific items, no separate application is required. If it refers only to a "communication device", "Low Cost AT", or an amount of Capital - Assistive Technology funding, a Replacement Support application is required.
A note on the NDIA's published worked example
The NDIA's Would We Fund It guidance on smart tablets includes a worked example in which a delegate appears to approve an iPad and communication app directly at plan stage. That example has been widely read as establishing a delegate-approval route.
In written advice provided to Assistive Tech by the NDIA's Assistive Technology Markets team in May 2026, the Agency confirmed that the Replacement Supports process must be followed in all circumstances, and that a participant can only purchase a tablet or app after a formal approval letter has been issued. The Agency further confirmed that a delegate presented with a direct request for an iPad and app will formally decline it, allocate funding for an appropriate communication device instead, and direct the participant to the Replacement Supports process.
Where the published worked example and that written advice conflict, we apply the written advice, because it is the Agency's stated operational position and it is what determines whether a claim can be paid. If a delegate or Local Area Coordinator tells you a separate application is not needed, ask for that in writing and contact our team before placing an order.
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. Six conditions are assessed. The first two are threshold checks made by the National Contact Centre before the application is referred to TAPIB. The remaining four are assessed substantively by a Technical Advisor.
- The support is on the approved Replacement Supports list (s10(6)(a)) - NCC threshold check
- It replaces an existing NDIS support in the participant's current plan (s10(6)(d)(i)) - NCC threshold check
- It addresses a disability-related functional need (suitability)
- It will provide the same or better outcome for the participant (s10(6)(d)(iii))
- It is safe for the participant to use (assessed as a substantive check in the TAPIB internal workflow and in the NDIA's published consumer guidance)
- The cost is the same or lower than the support it replaces (s10(6)(d)(ii))
If all six are clearly met, the application is approved. If any one of them is not clearly addressed, the assessor will either request more information or decline.
If declined, there is no internal review, no external review, and no Administrative Review Tribunal pathway. The decision is not a reviewable decision under the NDIS Act, and the TAPIB internal guidance explicitly excludes Replacement Support requests from the ART process. The participant must wait 12 months before reapplying for the same Replacement Support. They can apply for a different Replacement Support at any time, and a plan reassessment resets the 12-month bar if circumstances change.
That 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 and no avenue of appeal.
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 six 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 assessor just couldn't find it without reading the entire letter and reconstructing the answers themselves. Assessors working through high application volumes don't have time for that, and the workflow doesn't reward them for trying.
A note on what NDIS actually requires
The NDIA's published position is that there is no requirement for the participant to seek a functional assessment or report from a health professional to support a Replacement Support application. A participant can apply with only their own description of how the support will help them.
This means a Speech Pathologist's recommendation letter is not formally required. The case for the letter is practical: a well-structured letter that maps directly to the six criteria gives the assessor a clear, fast path to approval and reduces the chance the application is returned for more information. Given the 12-month bar on re-applying for the same Replacement Support if declined, the cost of a weak application is high and the value of a strong supporting letter is correspondingly high.
The framing in this article is therefore that the letter is supporting evidence that materially improves the chances of approval, not a regulatory requirement.
What each criterion actually requires
Criterion 1: Is the support on the approved list?
This is the first of two threshold checks the NCC makes before TAPIB ever sees the application. 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 assessor 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.
Dedicated device, not shared. Where the application is for an AAC tablet, the recommendation letter must confirm that the tablet will be the participant's dedicated device and not a shared family device. This is taken directly from the NDIA's published worked example on tablet AAC, which records the delegate's note in that example that "the tablet and communication apps are the only way that [the participant] can communicate but the tablet must not be a shared device." A bundle that includes a tablet without this confirmation invites a request for further information.
Restrictive practice flag for tracking. Where the application is for a smartwatch (or a tablet) with tracking or location-monitoring features, the application must address the restrictive practice question explicitly. The NDIA's published Replacement Supports list document states that any smart device used for tracking purposes could be considered a restrictive practice and needs to be considered in this context. If tracking is part of the proposed use, address it in the letter rather than leaving it implied.
Criterion 2: Does it replace an existing NDIS support?
The second NCC threshold check. 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 assessor 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 assessor needs to read.
Common error: writing the request as though it were new money. If the application reads as a request for additional funding rather than a substitution, it fails at triage.
Criterion 3: Does it address a disability-related need?
This is the suitability criterion, and it is the first one assessed substantively by TAPIB. It asks whether the requested support actually addresses the participant's disability. For tablets, smartwatches, smartphones and apps, the need must relate to communication and accessibility.
What the assessor is looking for: a documented functional need, and a clear link from that need to the requested item. For AAC, is there evidence the participant has a communication impairment that the tablet and app will address?
Lived experience is acceptable evidence here. The NDIA does not require a clinical report. A Speech Pathologist's letter is not mandatory but materially strengthens this criterion, because it establishes the impairment on professional authority rather than self-report.
Common error: describing what the device does without first establishing what the impairment is. The assessor needs to see the disability-related need stated first, then the link from that need to the proposed support. A letter that opens with the product rather than the person inverts the logic the assessor is following.
Criterion 4: Will it provide the same or better outcome?
This is the clinical criterion. The assessor must be satisfied that the replacement support will produce an equivalent or better outcome than the funded NDIS support it replaces.
What the assessor is looking for: the phrase "same or better outcome" stated explicitly as a clinical opinion, supported by trial evidence.
The statutory language matters. An assessor 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 assessor anything about outcome. The letter should also identify alternatives that were trialled or considered, and explain why they were ruled out.
Common error: comparing the technical specifications of two devices rather than the outcomes for the participant. The assessor is not assessing hardware. They are assessing the consequence for the participant's life.
Criterion 5: Is the support safe to use?
This criterion is straightforward but easy to miss in applications that focus on clinical justification. The assessor is asking whether there are safety concerns above an acceptable level. The TAPIB internal assessment template phrases it as: safety concerns are either not identified, or any safety concerns are below an acceptable level.
What the assessor is looking for: a brief, explicit statement that safety has been considered and that no concerns are identified, or that any concerns are below an acceptable level and have been addressed.
For a tablet-and-AAC-app bundle, this typically reads as a single sentence or two. Mention the protective case (a rugged case appropriate to the participant's age and use pattern) and the screen protector. If the device will be used by a young child, note that supervision arrangements are in place. If the application involves any tracking or location feature, address the restrictive practice question here as well.
The common error at this criterion is silence. The criterion still has to be assessed even where no concerns exist, so the assessor needs to read a statement confirming this. A single sentence is sufficient. Leaving the question unanswered creates a gap the assessor either fills with assumptions or returns to the applicant to clarify.
Criterion 6: 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. This is a strict numerical test.
What the assessor 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 assessor is making. The assessor is comparing bundle cost against the plan allocation. The market price of a dedicated alternative is not relevant to the legal test.
The reason the plan allocation is the right comparator is that the allocation already represents the dedicated communication device the NDIS agreed to fund. The delegate has priced that device and written the amount into the plan. Your job is to show the bundle lands at or under that number, not to re-argue what a dedicated device is worth on the open market.
A second common error: quoting an app subscription that runs longer than the plan. A Replacement Support approval lasts for the current plan only. App subscriptions should be sized to the plan duration unless the participant has confirmed they will reapply at next plan stage.
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
Assessors check whether the replacement support creates additional ongoing NDIS-funded costs. If your letter is silent on this, it raises a question the assessor 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 (where one has been prepared), 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 8 to 12 weeks once submitted. This is not a fast process. Where a participant has just received a plan with appropriate funding allocated, the time to start the application is immediately, not when the equipment is needed.
Before the decision is finalised
Before finalising, the Technical Advisor calls the participant or their authorised representative to inform them of the proposed outcome and the reasons. This applies to both approvals and declines.
If the application is heading for a decline, that call is the participant's only practical opportunity to address gaps before the decision is locked in. Given there is no review pathway afterwards, it is worth being available and prepared for it.
What good looks like
A recommendation letter that gets approved on first read tends to share the same shape:
- It confirms each component of the bundle is on the approved list.
- It names the budget line and the allocated dollar amount, and states explicitly that the bundle replaces that funded support rather than adding to it.
- It establishes the disability-related communication need first, then links the proposed support to it.
- It states the clinical opinion on outcome using statutory language, supported by specific trial evidence and a record of alternatives considered.
- It addresses safety in a brief, explicit statement, including the dedicated-device confirmation where applicable.
- It compares bundle cost against the plan allocation, addresses platform exclusivity if relevant, and confirms the lowest-cost model.
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 (v2.4, July 2026) 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 structured against the six criteria. It is mapped against the NDIA staff guidance released under FOI 25/26-1041 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 an iPad bundle requires a Replacement Support application even when the funding is already sitting 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, including the framework set out in FOI 25/26-1041, released by the NDIA on 28 November 2025. For the most up-to-date information on Replacement Supports, refer to ndis.gov.au. This article does not constitute legal advice.
