NDIS Policies and Procedure

POLICIES and PROCEDURES

National Disability Insurance Scheme (NDIS) is a niche and regulated industry that provides individualised, life-long support to Australians who are born with or who acquire a significant and permanent disability.

Clear policies and procedures is the driving force for all providers to ensure exceptional services are provided to the NDIS participants. These policies help the providers to ensure that their services manifest quality. To this end, NDIS Quality and Safeguards Commission established in 2018 to regulate NDIS providers and to ensure provider compliance.

It is mandated that all NDIS providers maintain an exhaustive list of documents that are called ‘Policies’ and ‘Procedures’. These demonstrate that the provider has processes in place that comply with the NDIS Practice Standards.

The distinction between these terms are often blurred in its everyday usage across the industry. However, the primary difference is with regards to how it is enacted

Policy

Policies detail how certain things are expected to be carried out. They draw a basic framework on all specific modules of interest.

Procedure

Procedures define how the Policies will be implemented. The inspiration here is to translate intentions to action.

EXAMPLES

It is important that every provider has a comprehensive set of policies and procedures that ensure they meet the quality standards set by the NDIS. It aids in providing quality and safe service for people with a disability, their families and carers in the provision of all NDIS services.

Some of the examples are (not limited to the following):

Governance and Management

  • Governance Policy and Procedure
  • Succession Policy and Procedure
  • Conflict of Interest Policy and Procedure
  • Strategic and Operational Policy and Procedure
  • Financial Management Policy and Procedure
  • Risk Management Policy and Procedure
  • Emergency Planning Policy and Procedure
  • Safety and Security Policy and Procedure
  • Infection Control Policy and Procedure
  • Medication Management Policy and Procedure
  • Workplace Incident Policy and Procedure
  • Human Resources Policy and Procedure

Participants, Families and Carers

  • Participant Rights and Responsibilities Policy and Procedure
  • Protecting participants from harm Policy and Procedure
  • Decision making and Choice Policy and Procedure
  • Service Access Policy and Procedure
  • Assessment, Planning and Review Policy and Procedure
  • Service Delivery and Participation Policy and Procedure
  • Participant Money and Property Policy and Procedure
  • Positive Behaviour support Policy and Procedure

Early Childhood Supports

  • Client Participation and Social Inclusion Policy and Procedure
  • Parent Carer Engagement Policy and Procedure
  • Best Practice early Intervention Policy and Procedure

NEXT STEPS

NDIS providers are required to create appropriate policies and procedures to reflect the kind of service they intend to provide the participants.

We have an extensive knowledge of the sector and have people who are very experienced and skillful. Our diverse and qualified team can help draft your documentation to match the supports you provide.

For specialized guidance, feel free to reach us: care@hhccndis.com.au

Good luck with your documentation!

NDIS Auditing

AGENDA

1. AUDITING – THE DRIVING FACTORS

a) NDIS Practice Standards – The Basis for Auditing

b) NDIS Quality and Safeguarding Framework – The Intention of Auditing

2. AUDITING – THE BIG 3 FACTORS

a) “Why” of Auditing explained

b) “Who” of Auditing explained

c) “What” of Auditing explained

3. AUDITING – 2 TYPES

a) NDIS Verification Audit

b) NDIS Certification Audit

4. AUDITING – RESULTS

5. AUDITING – PRICING

6. NEXT STEPS

1. AUDITING – THE DRIVING FACTORS

a) NDIS Practice Standards – The Basis for Auditing

The basis for Auditing is NDIS Practice Standards. It is against these standards that all NDIS Providers are audited. This paves way for the Provider self-assessments and audits.

The Standards express an objective set by the NDIS as an ‘Outcome’.

Every provider is responsible to achieve these ‘Outcomes’

Every ‘Outcome’ is associated with achieving ‘Quality Indicators’

Note:

The standards rarely mention specific laws or regulations. They don’t specific methods and techniques for managing compliance either.

For example, the Standards simply state:

“A quality management system is maintained that is relevant and proportionate to the size and scale of the provider and the scope and complexity of the supports delivered. The system defines how to meet the requirements of legislation and these standards. The system is reviewed and updated as required to improve support delivery.”

These standards have different ‘Modules’ to cover all the different types of services that are provided. They consist of a core module and several supplementary modules that apply according to the types of supports and services NDIS providers register and deliver.

The Core module covers:

  • Rights and responsibility for participants
  • Governance and operational management
  • The provision of supports, and
  • The support provision environment

The supplementary modules cover:

  • High intensity daily personal activities
  • Specialist behaviour support, including implementing behaviour support plans
  • Early childhood supports
  • Specialised support coordination
  • Specialist disability accommodation

You can download a copy of the NDIS Practice Standards and Quality Indicators here: https://www.ndiscommission.gov.au/document/986

b) NDIS Quality and Safeguarding Framework – The Intention of Auditing

These standards reflect the NDIS Quality and Safeguarding Framework, and the laws with which providers must comply.

The NDIS Quality and Safeguarding Framework provides a nationally consistent approach to help empower and support NDIS participants to exercise choice and control, while ensuring appropriate safeguards are in place and establishes expectations for providers and their staff to deliver high quality supports.

You can access the same using the URL below:

https://www.dss.gov.au/disability-and-carers/programs-services/for-people-withdisability/ndis-quality-and-safeguarding-framework-0

2. AUDITING – THE BIG 3 FACTORS

a) “Why” of Auditing explained

Auditing ensures that all services are delivered safely and consistently across all states in Australia. It helps the providers to hone their services and ensure compliance to offer an exceptional experience to all their participants.

Now, one may wonder the purpose of getting audited. A common question lingering in the minds of all those who attempt to embark on this journey is “Why” – Why do I need to get audited? Well, for the starters there is no choice. It is mandatory for all NDIS providers to undergo audit as a part of registration process.

b) “Who” of Auditing explained

Audits are conducted by approved Quality Auditors. The approved list of Auditors can be found in the link below: https://www.ndiscommission.gov.au/resources/ndis-provider-register-and-compliance-andenforcement/auditors

c) “What” of Auditing explained

Now, that we know ‘Why’ we undergo the audit and ‘Who’ conducts the auditing, the most obvious question is ‘What’ type of auditing should one go through? The type of audit required depends on the supports (registration groups) provided.

There are two types of NDIS audit

  1. Certification audits
  2. Verification audits

Verification Audits currently apply to providers delivering low-risk supports (listed below); Certification Audits apply to all other providers.

3. AUDITING – 2 TYPES

The audits are performed every 3 years (excluding an Interim review within 18 months of the Initial audit)

Now that we know there are 2 types of Auditing, let us briefly look at what it entails.

a) NDIS Verification Audit

Verification audits are usually undertaken by small organizations delivering low risk supports to NDIS participants. These low risk supports cover the following:

These low risk supports cover the following:

  • Accommodation/Tenancy Assistance
  • Assistive Products for Personal Care and Safety
  • Personal Mobility Equipment
  • Assistance with Travel/Transport Arrangements
  • Vehicle Modifications
  • Home Modification Design and Construction
  • Assistive Equipment for Recreation
  • Vision Equipment
  • Community Nursing Care
  • Innovative Community Participation
  • Specialised Hearing Services
  • Household Tasks
  • Interpreting and Translation
  • Hearing Equipment
  • Assistive Products in Household Tasks
  • Communication and Information Equipment
  • Management of Funding for Supports — Plan Management
  • Therapeutic Supports
  • Specialised Driver Training
  • Assistance Animals
  • Hearing Services
  • Custom Prostheses and Orthoses
  • Exercise Physiology and Personal Well-being Activities

The auditors review policies and other organisational documentation and provide a report to the NDIS Commission with their recommendations.

These audits are conducted off-site.

b) NDIS Certification Audit

Certification audits are more comprehensive (and more expensive) than Verification audits.

These are undergone by organizations delivering high risk supports to NDIS participants.

  • These high risk supports cover the following:
  • Assistance to Access and Maintain Employment or Higher Education
  • High Intensity Daily Personal Activities
  • Assistance in Coordinating or Managing Life Stages, Transitions and Supports
  • Daily Personal Activities
  • Specialist Positive Behaviour Support
  • Assistance with Daily Life Tasks in a Group or Shared Living Arrangement
  • Development of Daily Living and Life Skills
  • Early Intervention Supports for Early Childhood
  • Participation in Community, Social, and Civil Activities
  • Specialist Disability Accommodation
  • Support Coordination
  • Specialised Supported Employment
  • Group and Centre-Based Activities

They are conducted in 2 stages.

Stage 1: Desktop Review

Auditors review the policies and procedures. Stage 1 Report identifies the Areas of Concern

Stage 2: Onsite Review

Auditors visit onsite

Auditors review the documentation again.

Areas of Concern raised in Stage 1 are reviewed Auditors review Staff and Participant files.

Stage 2 Interview is conducted for staff and participants to ensure policies are understood and implemented.

Stage 2 Report outlines non-conformances. The providers have to create a Corrective Action Plan to outline how they plan to fix the nonconformances that have been identified.

4. AUDITING – RESULTS

As in an exam, anxiety is often a precursor to receiving results. Fortunately, it is not a black and white situation. There are no PASS or FAIL situations. Items are flagged as minor and major non-conformances. The provider is asked to formulate a Corrective Action Plan to rectify non-conformances.

Minor non-conformances come with a grace period of 12 months to be rectified.

Major non-conformances come with a grace period of 3 months to be rectified.

Note: The dates commence from the day of your audit

If one is unable to address the non-conformances, auditor’s recommendation to the NDIS Commission will be not to approve the audit (Verification or Certification).

5. AUDITING – PRICING

We’ve already seen in this blog that the audits will be conducted by an Approved Quality Auditor, whom we can choose from the list we have here

In order to approach the auditors, one will need to have a ‘Scope of Audit’ letter first. This letter is sent by the NDIS Commission in response to the application/renewal application made by the provider.

Prices vary depending on a lot of factors:

  • Registration groups (services and supports) that are intended to be delivered
  • Strength of Staff employed
  • Number of Participants (currently receiving services)
  • Number of Sites (from which services are delivered)

Prices also vary between different auditing bodies. It is recommended to therefore obtain a few quotes before finalizing one.

6. NEXT STEPS

NDIS providers are allowed to take help in preparing for their audits. Our experts can help you reduce stress and minimize non-conformances identified during the audit process.

For specialized guidance, feel free to reach us: care@hhccndis.com.au

Good luck with the process!