Woodard and National Disability Insurance Agency

This matter concerned an application by an individual with a hearing impairment seeking funding from the National Disability Insurance Agency (NDIA) for various assistive technologies and home modifications. The applicant sought funding for a Visualert Custom Made Visual and Vibrating Alert System, CCTV cameras with motion sensor lighting, floodlights, and later, a "Tiny Red Box." The NDIA had previously made a decision regarding the applicant's supports, which was subsequently varied. The Administrative Appeals Tribunal (AAT) was tasked with determining whether the requested items constituted reasonable and necessary supports under the National Disability Insurance Scheme.

The core legal issues before the Tribunal were whether the Visualert system, the Tiny Red Box, CCTV cameras with motion sensor lighting, and floodlights were reasonable and necessary supports. Specifically, the Tribunal had to consider if the Visualert system represented value for money, if it duplicated existing supports such as the applicant's Brooks Visual Notification System, and whether the Tiny Red Box met any of the applicant's disability-related needs based on the evidence. Furthermore, the Tribunal needed to assess whether the CCTV cameras and floodlights were day-to-day living costs or directly related to the applicant's disability needs.

In its reasoning, the Tribunal considered extensive evidence, including occupational therapy reports, clinical audiology reports, and user guides for various devices. It noted a previous AAT decision, *Buckley*, which had found the Visualert system to be reasonable and necessary, but distinguished the present case due to significant differences in the quoted cost of the Visualert system (almost double that in *Buckley*) and the fact that the applicant in *Buckley* had not sought alternative visual alarm systems. The Tribunal also considered evidence regarding a potential conflict of interest involving the occupational therapist who recommended the Visualert system, as her husband was the director and sole shareholder of the company supplying the product. Despite these considerations, the Tribunal ultimately found that the existing supports in the applicant's plan, as approved and varied, were reasonable and necessary.

Consequently, the Tribunal affirmed the NDIA's decision under review, as varied on 20 December 2022, pursuant to paragraph 43(1)(a) of the *Administrative Appeals Tribunal Act 1975* (Cth).