How to Write an NDIS Functional Capacity Assessment (FCA)
A Functional Capacity Assessment (FCA) is the document an NDIA planner leans on most when deciding what supports a participant can access. Written well, it makes the case for funding almost self-evident. Written poorly, it triggers questions, delays, and plan reviews.
Written for occupational therapists working in the Australian NDIS context. Structure, assessment tools and the reasoning planners look for, in that order. For the section order itself, use the NDIS functional capacity assessment template.
Contents
- What an FCA is actually for
- Use the ICF framework as your spine
- Choose and report standardised assessments
- The NDIA’s own tool is changing
- Structure the report the way planners read it
- Write ADL findings with specifics, not generic statements
- Tie every recommendation to reasonable and necessary
- Avoid the things that trigger queries
What an FCA is actually for
An FCA describes how a person’s disability affects their capacity to complete everyday activities (self-care, mobility, communication, domestic tasks, and community participation) and what support is reasonable and necessary as a result.
The planner is not reading it to learn the diagnosis. They are reading it to understand functional impact and to see that each recommendation is justified. Keep that lens on every paragraph you write: what is the functional limitation, and what does the person require because of it.
Use the ICF framework as your spine
The clearest FCAs follow the World Health Organization’s ICF logic: Health Condition → Impairment → Activity Limitation → Participation Restriction. This chain shows the assessor is reasoning from disability to impact rather than simply listing tasks the person cannot do.
For every limitation you describe, make the disability attribution explicit. "Marcus requires physical assistance to shower" is weaker than "Marcus’s cerebral palsy results in reduced left-sided coordination and standing tolerance, which means he requires physical assistance to shower safely." The second version links impairment to activity to support.
Choose and report standardised assessments
Planners give more weight to findings backed by recognised, standardised tools. Common choices in NDIS FCAs include:
- WHODAS 2.0 in an FCA: whole-of-person disability across six domains
- MoCA: cognitive screening (26 and above normal, 18 to 25 mild, below 10 severe)
- Vineland-3: adaptive behaviour
- IADL / BADL scales: domestic and personal daily living
- Direct observation of activities of daily living in the person’s own environment
The NDIA’s own tool is changing
From April 2027 the NDIA plans to set budgets from its own support needs assessment, built on I-CAN v6, with clinician reports as supporting evidence. The tools above still matter; what changes is the job the report does. See what I-CAN v6 means for FCAs.
Structure the report the way planners read it
A reliable FCA structure moves from identity and goals, to the assessment picture, to specific recommendations. Each section is explained in the FCA template guide. A workable order is:
- Participant details and NDIS goals
- Summary of recommendations (planners often read this first)
- Assessment details: date, tools used, who was present
- Background, medical history and current supports
- Functional findings by domain (cognition, communication, mobility, self-care, domestic, community)
- ADL tables with assistance levels and specific incidents
- Standardised assessment results
- Recommendations table with risk and reasoning
- Clinician sign-off
Write ADL findings with specifics, not generic statements
The difference between a report that gets approved and one that gets queried is specificity. "Requires assistance with meal preparation" tells a planner nothing about how much, how often, or why.
Use a consistent assistance scale (Independent, Prompting, Minimal, Moderate, Maximal, Full Assistance) and pair each rating with a concrete example: "Requires moderate assistance for meal preparation; unable to safely use the stovetop due to impaired grip and reduced standing tolerance, observed to drop utensils on three occasions during assessment."
Tie every recommendation to reasonable and necessary
Section 34 of the NDIS Act is the legal test for funding. Each recommendation should show the support is related to the disability, represents value for money, is likely to be effective, accounts for informal supports, and, since the 2024 changes, is an NDIS support. Include a risk statement: what happens without the support.
A dependable pattern is: "[Participant] requires [support]. This is reasonable and necessary because [disability] results in [impairment]. The support will [link to goal]. Without it, [participant] is at risk of [specific consequence]." The Section 34 justifications guide covers all seven tests in depth.
Avoid the things that trigger queries
Three habits create most avoidable delays: placeholder text left in the report ("TBC", "to be confirmed"), unattributed clinical claims, and estimated figures presented as measured facts. Flag estimates clearly and confirm them before submission.
This is where a drafting tool earns its place. Carearoo generates FCA drafts using this exact structure and highlights anything that needs your clinical sign-off, so the report arrives complete and you review what matters rather than starting from a blank page. The FCA is one of the eight NDIS report types Carearoo drafts.
Frequently asked questions
How long should an NDIS FCA be?
Most FCAs run 1,800 to 2,500 words of narrative (excluding tables). Depth matters more than length: planners want specific, attributed findings, not padding.
Which assessment tools should I use in an FCA?
It depends on the presentation, but WHODAS 2.0, MoCA, Vineland-3, and IADL/BADL scales are common, alongside direct observation of daily activities in the person’s environment.
Can AI write an NDIS FCA?
AI can produce a strong first draft in the correct structure and language, but clinical responsibility and sign-off remain with the treating OT. Tools like Carearoo draft and highlight items for your review; they do not replace clinical judgement. What Ahpra actually requires when you use AI sets out the obligations.
What should an NDIS functional capacity assessment include?
Participant details and NDIS goals, a summary of recommendations, assessment details, background and current supports, functional findings by domain, ADL tables with assistance levels, standardised assessment results, and a recommendations table with a Section 34 justification and risk statement for each support.
Who can write an NDIS FCA?
Usually an occupational therapist, and in some presentations a physiotherapist or psychologist, registered with Ahpra. The clinician who assessed the participant signs the report and carries responsibility for it.
How this guide was written
Carearoo researches and drafts its guides with AI assistance, working from the primary sources linked in the text, and a person checks every fact against those sources before it is published. Last checked 7 September 2026.
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Carearoo drafts the report from your notes on your own Word template. You review and sign off. We'll draft one of your de-identified cases for free so you can judge the output yourself. No cost, no pitch. After that it's $99 a report.