Writing NDIS Reports for Providers and Allied health professionals matter. We all want to do what is best for the people we support. In this article I will explain the case that brought the recommendations of how to write a better report, and what you can do to write a better report.
Buttler Vs. The NDIS
On the 28th of August 2025, Administrative Review Tribunal (ART) member, Senior Member B De Villiers handed down their decision in the case ‘Butler and the National Disability Insurance Agency (NDIS) [2025] ARTA 1579 (28 August 2025)’. This decision offers clear guidance for allied health professionals and support teams on how to write effective reports. This is because while Butler had a lot of evidence, the member found a lot of it wasn’t helpful.
For years as a support coordinator I would annoy anyone who would listen about these issues and now you can see it in black and white. I even discussed it on the first live episode of “What in the NDIS Now?” when we were asked about the point of writing carefully written reports when no one reads them. The point is that someone will, eventually. If the planner or the delegate doesn’t, the ART will pick apart your report, so get it right. You owe it to your participants, the industry, and your profession to get your report in order.
Without further fluff here is what you need to ensure that you do.
Criticisms of the Reports Provided
The Tribunal was highly critical of many of the expert reports submitted. Key concerns included:
Lack of Independent Assessment
- Several practitioners were found to have copied or repeated supports proposed by the Applicant without critically evaluating whether they were reasonable and necessary.
- The Tribunal described this as a “cut-and-paste exercise”, lacking independent professional judgment.
Failure to Distinguish Between Clinical and Therapeutic Supports
- Some reports failed to clearly distinguish whether the support was clinical (excluded) or therapeutic (potentially included) under the NDIS.
- For example, use of Acceptance and Commitment Therapy (ACT) was questioned for being framed as therapeutic when it appeared to be clinical.
Overreliance on Applicant’s Self-Report
- Reports often relied heavily on the Applicant’s own descriptions and preferences, without objective verification or critical analysis.
- For example, one allied health professional admitted they repeated a list of supports provided by the Applicant without independent assessment of the list.
Use of AI in Report Writing
- Reports were generated with the help of AI, but the authors could not explain or verify key content.
- The Tribunal emphasized that practitioners must take responsibility for the content of their reports, even if AI is used to assist.
Lack of Specificity and Justification
Reports often lacked clear
reasoning as to why a support was:- Necessary under S34(1)(aa)
- Value for money under S34(1)(c)
- Effective and beneficial under S34(1)(d)
What Future Reports Should Include
To be persuasive and useful to the Tribunal, future reports should:
Demonstrate Independent Clinical Judgment
- Clearly explain how the practitioner formed their opinion.
- Avoid simply repeating the participant’s requests.
Critically Assess Each Support
- Evaluate whether the support is:
- Necessary for the participant’s S24 disability
- Value for money
- Effective and beneficial based on current good practice
- Evaluate whether the support is:
Avoid Advocacy Tone
- Reports should be objective, not written as advocacy documents.
Clarify the Nature of the Support
- Clearly state whether the support is therapeutic (NDIS-eligible) or clinical (excluded).
- Justify the classification with reference to the NDIS Act, Rules, or Schedule 1/2.
Be Transparent About Methodology
- If AI or templates are used, the practitioner must:
- Review all content
- Be able to explain and justify every statement
- Take full responsibility for the report
- If AI or templates are used, the practitioner must:
Provide Evidence-Based Justifications
- Reference relevant guidelines (e.g. NICE, peer-reviewed literature)
- Explain how the support addresses the participant’s functional impairments
Report Checklist for Practitioners
Independence & Professional Judgment
- Have I independently assessed the participant’s needs?
- Have I avoided copying or repeating the participant’s own list of supports without critical analysis?
- Have I clearly stated how I formed my opinion, based on my expertise?
“The Tribunal was critical of reports that merely repeated supports proposed by the participant without critical assessment.”
Clear Link to S24 Disabilities
- Have I clearly linked each recommended support to the participant’s S24 disabilities (not just general health conditions)?
- Have I avoided conflating impairments from non- S24 conditions?
“Supports must be necessary to address needs arising from impairments in relation to which the participant meets the disability requirements.”
Support Classification
- Have I clearly stated whether the support is therapeutic (NDIS-eligible) or clinical (excluded)?
- Have I justified this classification with reference to NDIS legislation or rules?
“Supports that are clinical in nature are excluded under Schedule 2. Reports must distinguish this clearly.”
Evidence-Based Justification
- Have I explained why the support is:
- Necessary under S34(1)(aa)?
- Value for money under S34(1)(c)?
- Effective and beneficial under S34(1)(d)?
- Have I cited relevant guidelines, research, or professional standards?
“The Tribunal expects evidence of necessity, value for money, and current good practice.”
Avoiding Advocacy Tone
- Is my report objective and impartial, not written as advocacy?
- Have I avoided emotionally charged or adversarial language?
“The Tribunal criticised reports that appeared to advocate for the participant rather than provide independent expert opinion.”
Use of AI or Templates
- If I used AI or templates, have I:
- Reviewed all content personally?
- Verified all citations and conclusions?
- Taken full responsibility for the final report?
“Practitioners must be accountable for the content of reports, even if AI is used to assist.”
Specificity & Clarity
- Have I clearly described:
- The type and amount of support recommended?
- The functional outcome it is intended to achieve?
- Why existing supports are insufficient?
“Reports must explain why additional supports are needed beyond what is already funded.”
Final Bit of Wisdom
One of the most common mistakes is listing medical diagnoses instead of focusing on disabilities. If the NDIS deems something medical, it cannot fund it. So stay focused on the functional impairments related to the participant’s S24 disabilities.
