Reform explainer
Functional capacity assessment
From 2028, this replaces diagnosis-led eligibility as the primary NDIS gateway. Here's what the assessment covers, who conducts it, and how to build your evidence base now — before the tool even exists.
The key shift
- From: diagnosis → functional impact → "reasonable and necessary" test
- To: standardised assessment of what you cannot do across 8 domains
- Two people with the same diagnosis can have completely different outcomes
- The tool doesn't exist yet — expected operational from 2028
- Your next review (2026 or 2027) uses current rules
The 8 functional domains
The expected domains are drawn from WHO international frameworks and comparable disability schemes overseas. Your overall pattern across all domains — not any single score — determines eligibility.
Communication
Expressing yourself, understanding others, reading and writing. This covers verbal and non-verbal communication, use of assistive communication devices, and comprehension in everyday settings.
Mobility
Moving within your home, your community, and your workplace. Includes walking, transferring, using mobility aids, and accessing public transport and buildings.
Self-care
Bathing, dressing, eating, managing personal hygiene, and managing your own health. Includes frequency and type of assistance needed and ability to self-manage medications.
Self-management
Making decisions, managing finances, organising daily tasks, and planning ahead. Covers cognitive and executive function as they affect independence in everyday life.
Learning
Applying new skills, solving problems, and retaining information. Includes functional learning across home, work, and community settings — not academic learning in isolation.
Social participation
Maintaining relationships, participating in community activities, and engaging in employment or study. Covers frequency, quality, and any barriers to meaningful participation.
Domestic life
Household tasks, preparing meals, shopping, and maintaining a home. Includes level of support needed and any safety considerations related to unsupported domestic activity.
Community involvement
Using transport, accessing services, participating in civic and cultural life. Covers ability to navigate the community independently and use mainstream services.
How the current process works vs the new one
Current process (2026–2027)
- Diagnosis of a permanent disability
- Evidence that disability substantially reduces functional capacity in at least one of five areas
- Planner determines supports are "reasonable and necessary"
New process (from 2028)
- Accredited assessor administers standardised FCA tool
- Assessment covers all 8 domains on a severity scale
- Overall functional profile across domains determines eligibility threshold
- Diagnosis still relevant — but not the primary gateway
The detailed eligibility threshold under the new framework has not yet been published.
What assessors will look at
The assessment is not a self-report — it involves a structured interview with an accredited assessor and may include observation of tasks. Assessors are expected to evaluate:
- — How you perform tasks in each domain, with and without your usual supports
- — The frequency and intensity of support required
- — What happens when support is unavailable
- — Variability — how your functioning changes across the day, week, or under stress
- — Safety risks when operating without support
- — Carer burden and informal support dependency
How to prepare your evidence — now
The tool doesn't exist yet, but the evidence base takes months to build. Start now and you'll be ready regardless of when your review falls.
Start a functional diary
Daily notes on what you can and cannot do — not your diagnosis, but specific tasks. Include both good and bad days. Note what supports you used and what you couldn't do without them.
Get an up-to-date OT assessment
Occupational therapy assessments already use functional outcome frameworks and will translate directly to the new tool. An OT report from the last 12 months is one of your most valuable assets.
Ask treating professionals for functional statements
Rather than a letter saying "X has [diagnosis]," ask for: "X cannot [specific task] without [specific support] because [functional reason]." This is exactly the language the new system will use.
Document support dependency
What happens when your support isn't available? What specific tasks fail? What are the consequences? This "no support" evidence will be critical — and hard to reconstruct after the fact.
Document variability if your condition fluctuates
For MS, psychosocial disability, ABI, and similar conditions, capture both your best and worst functioning. Note the triggers, frequency, and duration of episodes. Snapshots on good days will underrepresent your support needs.
Connect with a free disability advocate
Advocates through DANA and state services can help you frame your evidence in functional-outcome language, before the stakes are higher. Free and available now.
Implications by condition type
Physical disability / mobility impairment
Strong alignment with FCA domains — mobility, self-care, and domestic life capture physical support needs well. Risk is lower for established physical presentations.
Psychosocial disability
High-risk under the new framework. Fluctuating presentation, episodic impairment, and variable functional capacity are difficult to capture in a snapshot assessment. Evidence of variability is essential.
Autism spectrum disorder
Significant risk if masking or late-diagnosed. High-functioning presentations may score better on domain scales than they actually perform in real-world settings. Reports framing real-world functional impact are critical.
Acquired brain injury
Fatigue, cognitive load, and executive function deficits may not be visible in a structured interview setting. Assessments should include conditions that reflect everyday complexity, not optimal performance.
Intellectual disability
Well-documented functional impact across most domains. Lower risk of under-representation compared to fluctuating or hidden disability — but ensure reports describe real-world independence, not just test performance.
ADHD
Significant risk of under-representation. Adults with ADHD may perform well in short structured assessments while facing major functional impairment in unstructured daily life. Functional diary evidence is particularly important.
The fluctuating conditions problem
This is the most contested issue in the reform design. Conditions like multiple sclerosis, psychosocial disability, and acquired brain injury involve significant day-to-day variation. A single assessment on a good day will not capture the full picture — and a one-time snapshot could unfairly disadvantage participants whose needs are real but variable.
Advocacy organisations including Every Australian Counts and PWDA are pushing for the tool to account for variability. The NDIA has acknowledged this as a design challenge. Watch for consultation on this point as the design is finalised — and in the meantime, document your variability in detail.
Get a personalised read in 5 minutes.
The check tool asks 8 questions about your specific plan, support types, and situation — not just your diagnosis. You'll get a clear risk assessment plus a printable preparation roadmap.
Start the check →Frequently asked
What is a functional capacity assessment?
A standardised evaluation of what you can and cannot do in everyday life — independent of your specific diagnosis. It looks across 8 functional domains: communication, mobility, self-care, self-management, learning, social participation, domestic life, and community involvement. Under the April 2026 reforms, this replaces the diagnosis-first model as the primary NDIS eligibility gateway from 2028.
How is it different from how NDIS eligibility works now?
Currently, NDIS eligibility requires a permanent disability diagnosis plus evidence that it substantially reduces functional capacity in at least one of five areas. The new framework removes the diagnosis as the primary gateway. The same standardised tool is used for everyone, regardless of diagnosis — what matters is your functional presentation across the 8 domains, not which condition caused it.
Who will conduct functional capacity assessments?
Accredited allied health professionals — occupational therapists, psychologists, physiotherapists, and similar — who have completed specific FCA training. The assessment will not be self-reported. It involves a structured interview and may involve observing you carry out tasks. The accreditation requirements for assessors are still being designed.
When does my assessment happen?
The new FCA tool is not expected to be operational until 2028. If your plan is due for review in 2026 or 2027, it will be assessed under current rules. From 2028, the new tool phases in as participants reach their natural plan review cycle. You will not be fast-tracked to early reassessment.
What if my condition fluctuates?
Fluctuating conditions — MS, psychosocial disability, acquired brain injury — are the most significant design challenge in the new framework. A snapshot assessment on a good day will not capture the full picture. Disability advocacy organisations are actively pushing for the tool to account for variability. Until the design is finalised, document both your best and worst functioning, and build evidence of variability over time.
Will I lose my plan if my condition is well-managed?
Not automatically. The assessment evaluates functional capacity with supports in place, not just raw capacity. But there is a legitimate concern that well-managed conditions may present as higher functioning than they actually are when support is withdrawn. This is why evidence of what happens when supports are unavailable is critical to build now.
How can I prepare before the tool exists?
Start a functional diary now — daily notes on what you can and cannot do, not just your diagnosis. Ask treating professionals for functional outcome statements rather than diagnostic letters. Get an up-to-date OT assessment. Document what happens when supports are not available. This evidence base takes months to build and will be critical when assessments begin.
What are my rights if I disagree with the assessment result?
The existing NDIS review rights apply. You can request an internal review within 3 months, then appeal to the Administrative Review Tribunal within 28 days of the internal review outcome. Free legal aid and disability advocacy are available throughout. The detailed review process under the new framework has not yet been finalised.
Information current as of 7 May 2026. The FCA tool and full eligibility criteria are still in development. This page will be updated as the NDIA publishes further guidance. For advice on your specific situation, speak to your plan manager, support coordinator, or a free disability advocate. Full disclaimer