Women with Disabilities Australia (WWDA) is seeking clarity from government and the National Disability Insurance Agency (NDIA) about concerns from the community regarding impairment mapping and the introduction of impairment notices under the NDIS. This work is important, as it shapes how people with disability are understood within the Scheme.
Understanding Impairment Mapping and Notices
Impairment mapping is where the NDIA links a person’s diagnosis or condition to one or more of the six impairment categories set out in the laws about the NDIS (the NDIS Act): intellectual, cognitive, neurological, sensory, physical, and psychosocial. For children, developmental delay is considered separately. Notice of Impairments, which are now given to all new participants, record the impairment categories that have been used to confirm someone’s eligibility for the NDIS.
These categories are listed in the NDIS Act, but they are not clearly defined. This can cause confusion and inconsistency for participants and for NDIA staff making access decisions, because there is room for different interpretations. The NDIA is talking to Disability Representative and Carer Organisations like WWDA and we want to share the questions we have been asking.
Required vs Optional Categories: Hierarchies and Language
WWDA has raised issues with the language used in impairment mapping, including words like “required” and “optional” when talking about impairment categories for certain diagnoses. For example, a person with Multiple Sclerosis (MS) may have a “required” neurological category, and “optional” cognitive or sensory categories. Feedback from our community suggests these terms imply that there is a hierarchy of impairments – like some are more important than other. This does not reflect a person-centred approach. We understand that this is not the intention and that other options like “highly likely” and “often associated” may be considered, to better reflect the diverse ways people experience disability.
There are also concerns that interactions between the different diagnoses, conditions and experiences a person has might not be understood when using this kind of categorisation. This is particularly important for our community, because women and girls are more likely to have multiple, co-occurring conditions and diagnoses, that impact their whole disability experience.
Autism, Sensory Impairment, and Category Definitions
WWDA has heard feedback from our community about the way Autism is currently categorised. Autism is grouped under the neurological category, with possible associations with intellectual, cognitive, physical, and psychosocial ‘impairments’- but not sensory. The NDIA has said that the sensory category relates only to auditory and visual impairment, but the NDIS guide suggests it could be broader. It says: “Sensory impairments usually relate to hearing or vision loss but may include all senses”. Sensory processing differences related to autism are considered part of the neurological category which is defined as “how your body’s nervous system functions”.
WWDA has asked questions about this separation. Many Autistic people identify sensory processing as a core part of their experience and want to have this recognised. We have asked for clarification to understand why neurodevelopmental experiences (like Autism, ADHD, dyslexia) and neurological conditions (like Parkinson’s, MS, Motor Neurone Disease) can be grouped together – even though they are different, but the category of sensory disability only relates to auditory and visual disability experiences. We understand that people in our community might have a range of views on this.
Neurodevelopmental vs Neurological: Are they the same?
Autism is neurodevelopmental, which means that while it is ‘neurological’- there is a difference that is often connected to how people with disability understand their identities. Neurological conditions are typically acquired or degenerative health conditions that affect the nervous system. Neurodevelopmental experiences refer to variations in brain development, often present from early childhood.
WWDA and many people in the neurodivergent community reject the framing of these experiences as “health conditions” or as deficits to be treated.
Currently, these different disability experiences are together under the “neurological” impairment category. This is different from the decision to apply narrow definitions for other categories. We have shared with the NDIA that this may cause confusion and concern for some of our members. We have asked for clear, consistent reasons for these decisions.
Moving the NDIS into the Health Portfolio
We know that concerns are heightened by the recent shift of the NDIS into the Government’s health portfolio. WWDA is hopeful this is an opportunity to address the current gaps in the disability and health systems and ensure the needs of women and gender diverse people with disabilities are met. Currently women and gender diverse people with disability (particularly those with chronic health conditions) are underserved due to the gaps between the NDIS and health system. Equally, WWDA understands there are concerns that this move signals a step backward toward the medical model of disability. In the context of this, it is important that there is clarity about impairment categories and mapping.
WWDA understands that the categories are not designed to limit the sort of supports people can access or determine plan budgets. Supports will still be available to an Autistic person for needs related to sensory processing under the neurological category. However, WWDA wants to understand more about what the categories are used for and why strict categories are needed, if it is not for determining the type of supports available or plan budgets. WWDA has asked whether these distinctions support the strengths-based, rights-focused intentions of the NDIS. If the neurological category is interpreted broadly to include both disability related to neurological health conditions and neurodivergent experiences, we wonder if other categories should also be broad.
To avoid medicalised, deficit focused categorisations, WWDA has advocated for decisions related to impairment mapping to be co-designed with people with disability and our representative organisations.
Next Steps
WWDA will continue to seek clear, accessible information from the NDIA about any changes to impairment mapping and will advocate for a transparent process that centres the lived experiences of women, girls, and gender-diverse people with disabilities. We ask the NDIA to make sure that reforms are genuinely co-designed and uphold the rights and dignity of all people with disability.
We encourage our members to share their experiences and concerns with us, as your voices are vital in shaping our advocacy.
