
Well, many of us thought Functional Capacity Assessments (FCAs) would be on the way out by now, replaced by the proposed Support Needs Assessments. However, those plans have been pushed back and FCAs are still in hot demand.
FCAs are a topic that always brings out plenty of opinions. We talk about cost, quality, the training required, and whether it’s a good or bad thing that this has become such a massive part of the OT role within the NDIS. In this article, I’m going to share my thoughts on these topics, and I’d love to hear your thoughts, too.
Hot tip: There are some TLDR take-home messages at the end if you don’t have time for the full read!
Being able to deliver a quality FCA requires real training. And I’m not talking about just a one-hour webinar. That only scratches the surface of what "good" looks like, but it doesn't show you how to get there.
Sometimes you have to go back to basics and ensure you are competent in the core information-gathering skills needed to collect the evidence for the FCA. Do you know how to assess functional mobility? Can you do a functional cognitive assessment? Do you know how to choose a standardised assessment with purpose, rather than just blindly following what everyone else does?
These concepts are taught at uni, but they must be refined in practice. This means more self-directed learning, shadowing, and direct teaching. It requires supervision and report reviews to ensure that learning translates into clinical outcomes. Don’t just find a template and fill it in. In the many, many report reviews I’ve done, this is the biggest gap I see. It’s rarely the report writing itself; it’s the ability to gather the right information efficiently and effectively.
This is why I’ve got so many options when it comes to FCA training. There’s the obvious step-by-step FCA course, and also a template, but I call it a teaching tool rather than a template because it is annotated with how to collect the evidence (not just a script for what to write). If you’re still developing information gathering skills, I’ve also got a whole library of on-demand tutorials that cover those core OT skills like home assessments, functional assessments, cognitive assessments and more. And if you’re already past the basic skills but want someone to critique your work in a way that will give clear ideas for how and why it could be improved, then that’s where my report review and supervision services can help.
Business owners control quality, and they can ensure pricing reflects that quality. We’ve all seen or heard about an OT FCA that was billed out at 15–20 hours where the quality was terrible. Often, this is the result of an early-career clinician not being supported to develop their skills, combined with a business owner focused on quantity over quality.
The business owner may think they are winning; the clinician appears productive and invoices are going out, but long-term, nobody wins. The participant doesn’t get funding for the supports they actually require. The clinician eventually realises they’re not doing a great job, doesn’t know how to improve, and burns out or leaves. The business won’t get repeat referrals and will build a reputation for delivering sub-par work.
Your initial "win" isn’t sustained long-term. If you’re a business owner who wants to do this better, ensure your staff receive training and report reviews until competency is reflected in consistent quality. While they are developing their skills and things take longer, some of this time needs to be accounted for as the cost of training staff and removed from the final price of the FCA. If an experienced clinician could deliver the same quality in 10 hours, that’s what the participant should be billed for, not the additional 10 hours it took the clinician who was still learning. With this in mind, the smart move may not be to train everyone in the team to do every type of referral, but to build niche skills in individuals where quality can be guaranteed.
Yep, the recommendations need to be based on YOUR reasoning. Not what was listed in the referral, not what a support coordinator or carer asks for, and not what the client has previously been receiving in their plans. Those are your starting points, not your definitive finish line.
To do this, you’ll need to value the OT process, and help others to value it too. Make sure you explain why you can’t just "write a letter," and emphasise that the most important part of the FCA process is the information gathering. Remember, you’re an OT. Follow an OT process that starts with identifying the functional goal and the impairments impacting it. You don’t start with the solution and try to work backwards to make it fit. This is the exact reason why so many clinicians struggle with justifying their recommendations; the starting point was wrong.
For more info on returning to the core OT process in a "just write me a letter" scenario, check out this blog or this video on my YouTube channel.
FCAs aren’t dead yet, but they won’t exist in their current form forever. However assessing function and identifying support needs is OT101, so we need to be proactive in continuing to have a voice in shaping whatever replaces them. Luckily, there are many great organisations leading the way with consultancy and submissions grounded in research evidence and alternative models, rather than just criticisms of what the government has presented. OTSI is one of these organisations.
If you have made a submission in the recent NDIA consultations, thank you. This takes a lot of spoons that many providers and participants just don’t have. But if you want to make sure your submissions have the best impact possible for that effort, follow OTSI’s work and focus your feedback on:
Tangible outcomes: Focus on what your service provision has achieved, rather than only how much it costs.
Research evidence: Illustrate what good service provision looks like and the outcomes it can achieve, rather than relying only on passionate statements that what we do matters (it does matter, 1000%, but the government cares about numbers, not feelings).
If you actually love the assessment and report-writing aspect of FCAs rather than ongoing therapy, that doesn’t make you a bad clinician. First, I’ll preface this by saying that I still firmly believe there is immense value in delivering traditional therapy or capacity building at some stage in your career. It allows you to make better recommendations because you’ll know what can realistically be achieved in a block of therapy sessions, or how complex an AT prescription is likely to be.
But if you’ve tried both ongoing therapy and one-off assessment services and you prefer the latter, that is 100% OK. I feel the same way! Your skills might lie in gathering information efficiently, seeing the big picture holistically, and prioritising recommendations. Other OTs might struggle with that part, but they have the patience, creativity, and love of long-term connection to excel at delivering ongoing therapy that achieves those outcomes you hoped were possible. You can also be a clinician who loves a mix of both. It’s okay to have a preference, and you're not a 'bad' OT if you strongly favour one over the other.
If you are one of these OTs who loves doing FCAs and you're worried about what your future holds, you’ll be OK. You’ll just need to adapt. There are plenty of ways to pivot your skills to other OT services focused on assessment, recommendations, and report writing. I know because I’ve done it myself.
I’ve worked in acute hospitals, outpatient consultancy clinics, and medicolegal roles where these skills are essential:
Acute Hospital Wards: You have to gather information efficiently, prioritise immediate actions, and refer onward for lower-priority needs.
State-Based Consultancy: You may only have an hour to identify key functional difficulties, provide education, and arrange local referrals.
Medicolegal Work: If you are able to complete a complex FCA well, you’re probably readier than you think for the next step of exploring medicolegal work.
FCAs aren’t dead yet, but if they one day disappear, you’ve got options. Think about why it is that you love doing FCAs, and you’ll find the right fit.
If you follow my posts, you know I try to focus on more than just raising awareness or finding issues; it’s important to have solutions too. Here are the key things you can do better right now when it comes to FCAs:
Train the skills, not the template: Good FCA training goes beyond handing over a template. Teach core information-gathering skills, use a structured OT process, and review reports until competency is consistent.
Price reflects quality: The price of an FCA should reflect the quality of the product, not a clinician’s lack of training or efficiency.
Own your clinical reasoning: Go through the OT process with your client from the start so you can be entirely confident in what you’re asking for and why, and your client will see you as more than someone who ‘writes letters to get stuff’.
Advocate with data: If you’re advocating for OT to stay central to whatever replaces FCAs, ground your submissions in outcome data and research. Following OTSI's work will help.
Value therapy experience, but follow your passion: Take the time to build skills in ongoing therapy, but it’s ok if your true love is assessment and report writing.
Prepare to pivot: If FCAs disappear tomorrow, identify the core reasons you enjoy them and pivot to acute, consultancy, or medicolegal roles where those exact skills shine.
If you need help with any of these things, send me a DM and we can work out where to start!
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