Compliance

NDIS "Reasonable and Necessary": Writing Section 34 Justifications

6 min readUpdated 7 September 2026

Section 34 of the National Disability Insurance Scheme Act 2013 is the legal test that decides whether a support is funded. If your report does not show a support is "reasonable and necessary", a planner cannot approve it, no matter how clinically sensible it is. Since the 2024 amendments a support must also be an NDIS support, or an agreed replacement support, before the other tests are reached.

The seven tests a planner applies

Under Section 34, a support must satisfy all of the following. Your justification should touch each where relevant:

  • Related to the participant’s disability
  • Not a day-to-day living cost unrelated to disability support needs
  • Represents value for money
  • Likely to be effective and beneficial, based on good practice
  • Takes into account informal supports (family, carers, community)
  • Most appropriately funded by the NDIS rather than another system
  • Is an NDIS support, or an agreed replacement support, for that participant

The seventh test: is it an NDIS support?

The 2024 amendments to the Act added a gate that sits in front of the other six. A support has to be an NDIS support, as defined in the rules, or a replacement support the NDIA has agreed to for that participant. The NDIS page on reasonable and necessary, updated 1 September 2026, now lists seven requirements, and the seventh is that the support must "be an NDIS support or agreed replacement support for you".

For a report writer the practical effect is simple. Name the support in the terms the NDIS uses for it, and if you are recommending something that is on the excluded list or in a grey area, say why it is a replacement and what it replaces. A justification that clears the other six tests but names a support the scheme does not fund goes nowhere.

The single most common reason supports are questioned is a weak link to disability. Do not assume it is obvious. Spell it out: name the impairment, then the activity limitation it causes, then the support that addresses it.

Always include a risk statement

A justification without consequence is incomplete. Planners need to understand what is at stake if the support is not funded. State the specific risk: safety, deterioration, isolation, carer breakdown, hospital admission, or loss of an existing capacity.

A repeatable justification pattern

Use a consistent sentence frame and you will never miss a criterion: "[Participant] requires [support]. This is reasonable and necessary because [participant’s disability] results in [impairment and activity limitation]. The support will [link to goal and expected benefit]. Informal supports [are/are not able to meet this need because…]. Without this support, [participant] is at risk of [specific consequence]."

This is the pattern behind the recommendations table in the FCA template guide, and it is the same frame the assistive technology report guide uses for equipment, where value for money against the options considered carries most of the weight. The full report structure is in how to write an NDIS functional capacity assessment.

Carearoo builds this Section 34 reasoning into every report it drafts, so each recommendation arrives with its disability link, benefit, and risk already framed for your review.

Frequently asked questions

What does "reasonable and necessary" mean in the NDIS?

It is the Section 34 test the NDIA applies to every support: it must be disability-related, value for money, effective, mindful of informal supports, appropriately funded by the NDIS, and, since the 2024 changes, an NDIS support or an agreed replacement support.

What are the reasonable and necessary criteria?

Seven tests: the support relates to the disability, helps the participant pursue their goals, helps them take part in work, study and social life, is value for money, is likely to be effective and beneficial, takes account of what family, carers and the community reasonably provide, and is an NDIS support or an agreed replacement support.

What is an NDIS support?

A support that the NDIS rules list as one the scheme funds. Since the 2024 amendments a support has to be an NDIS support, or a replacement support the NDIA has agreed to for that participant, before a planner applies the other tests. Name the support in the scheme’s own terms in your report.

Can a planner reject a support that meets all seven tests?

A planner decides on the evidence in front of them, so a support that meets the tests can still be refused if the report does not show it. Make the disability link explicit, state the risk without the support, and give the hours or cost, so the decision rests on your evidence rather than on assumptions.

Do I need to address all seven tests for every support?

Address every test that is relevant. At minimum, always make the disability link explicit, name the support in NDIS terms, and include a risk statement. Those are where most justifications fall short.

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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