This submission raises concerns about the planned rollout and implementation of the NDIA’s independent assessments process, noting that the chosen assessment tools and workforce may not be able to consistently capture the true functional capacity of people living with vision loss. It makes a number of suggestions as to how the NDIA could introduce a functional assessments process which resolves some of the problems it intended to address, but does not disadvantage or disempower people with low prevalence disabilities like blindness and low vision.