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Author: Beatrice Hobson

You have policies and procedures – but are they being implemented?

Posted on by Beatrice Hobson

A common theme across just about all standards that apply to community and health service providers is a requirement to have appropriate policies and procedures in place in order to:

  • ensure the delivery of safe and high-quality services to clients, and
  • meet the governance and quality management requirements of the standards and legislation that applies to them.

But having policies and procedures in place is only the first step.  Even more important is that the policies and procedures are specific to the services and operations of each individual provider, and that they are understood and followed by all workers.

We’ve reviewed a number of recently published audit reports, and we’ve also had some discussions with auditors, and it is clear that some providers fall short along the way to actually implementing their policies and procedures across their organisation.  The consequences of this can be very serious, ranging from unprepared or ill-informed workers, through to the delivery of services that have an increased risk profile, or that are unsafe.

For example, in one recent audit it was found that while the provider had an open disclosure policy and risk framework policy, workers were not consistently following procedures in relation to risk management and incident and feedback identification, and so these were not effective.

In another audit, a provider was found to be non-compliant in their medication management.  Despite the provider having a policy for medication management, workers demonstrated poor practices, including leaving medication out and not keeping them secured. Additionally, despite the service having an incident reporting system, many workers appeared to not use or be aware of the system.

In a number of cases, auditors have reviewed providers’ policies to find that they didn’t even refer to the correct organisation, or the specific services delivered by that provider.  A very early indicator to an auditor of a shortfall between documentation and implementation!

So, how can providers improve the consistent implementation of relevant and appropriate policies and procedures across their organisation?

We’ve set out below some key principles that should be followed.  As well as a couple of key actions.

The policies and procedures must reflect how your particular organisation operates, the services you deliver, and the types of clients to whom you provide services 

  • Auditors report that policies often fail to reflect the practices of the organisation and the skill base of the staff.  Your policies need to be relevant to your organisation and the needs of your consumers.  When tailoring policies to your organisation, consult with consumers, other relevant stakeholders and your workers, to ensure that they reflect the needs and rights of consumers as well as the capabilities and expected practices of workers.


    Policies and procedures also need to address and meet the specific requirements of the legislation and service standards that apply to your organisation, so ensure you refer to and understand the relevant legislation and service standards that apply.  Ensuring that policies and procedures reflect how your organisation operates means that they will underpin consistent practices and service delivery across the whole organisation.

Ensure that staff have read, and understand, your organisation's core policies and procedures 

  • Auditors have provided feedback that organisations often fail to adequately communicate policies and procedures to staff.  You should ensure that each worker reviews, considers and acknowledges their understanding of policies.  To ensure that staff have read and understood them, you can distribute a core pack to each worker containing the relevant policies and procedures, and then structure discussion sessions so that they understand what these mean in practice.  You could maintain a record that each worker has acknowledged receipt of, and read and understood the core pack, for example:

     “I, [insert name here], confirm that I have read and understand the organisation’s policies and procedures relating to (e.g. Client rights, medication management, complaints management, Code of Conduct, incident reporting etc).

    Policies and procedures should be easily available to staff on an ongoing basis, so that they can re-familiarise themselves with them as needed.

Boards play an important role in implementation 

  • Board members play a critical leadership role in setting expectations for behaviour and organisational culture.  They have a responsibility to ensure that policies and procedures are in place, so that all aspects of the business are functioning in line with their purpose and objectives.  Board members should create a culture of review and understanding of policies and procedures.  They need to periodically evaluate the policies that are in place, and be alert to the need for new or updated policies.

Policies and procedures must grow with the organisation 

  • The organisation’s policies and procedures should reflect its sense of identity, its approach to service delivery and the standards it expects of all workers – and these policies and procedures must also be living documents.

    They must be reviewed and updated regularly, to take into account changes to or expansion in services provided, experience from incidents and near misses, as well as feedback and complaints.  Auditors often find that as organisations grow, sometimes their policies and procedures do not adapt to reflect these changes and growth.  Organisations can then find themselves providing certain supports that their policies and procedures don’t address.  It is important for senior management and the governing body to review and update policies regularly throughout the year, so that they reflect any changes.  A good way to implement this is to incorporate a review of policies into regularly scheduled meetings.  

Reinforce policies and procedures through training 

  • Auditors have also found that staff are often not provided with regular refreshers of policies and procedures, some of which may have been amended or updated.  In addition to new staff receiving training on policies and procedures, six monthly refreshers could be scheduled (and records of attendance kept), to ensure that all staff remain familiar with current policies and procedures and are trained on any new requirements, for example for any new or specialised service delivery.

The delivery of consistent, safe and high-quality services does not just depend on having policies and procedures in place for your organisation.  You must ensure that they reflect the services that you currently provide, how you provide those services, and that they are understood and followed by all workers.

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Working in partnership with family, friends and carers

Posted on by Beatrice Hobson

Historically, staff training and delivery of care for people with a mental illness have been based around the individual. The emphasis on confidentiality has sometimes acted as a constraint when caring for an individual. Carers often report that they are not recognised and are not given sufficient information to fulfil their role. The failure to engage with carers has excluded the very people who are often responsible for putting care plans into action.

In 2013, the National Report Card on Mental Health and Suicide Prevention recommended that a practical guide be developed and implemented for the inclusion of families and support people in services and that this must include consideration of the services and supports that they need to be sustained in their role. Similarly, in 2014 the National Review of Mental Health Programmes and Services – Contributing lives, Thriving Communities highlighted Australia’s complex mental health care system and the importance of ensuring that “people with lived experience, families and support people encounter a system that involves them in decisions, is easily navigable and provides continuity of care.”

In 2016, the Practical Guide for Working with Carers of People with a Mental Illness (the Guide) was released. A number of mental health care experts worked together to develop the Guide including: Helping Minds, Mind Australia, Private Mental Health Consumer Carer Network (Australia), Mental Health Australia and Mental Health Carers Australia.

In developing the Guide, national consultation with relevant stakeholders found that:

  • Current practices were not meeting national, state and territory policies of carer engagement;
  • Staff did not feel that they were trained to undertake the practice of Family Therapy;
  • Carers often felt that they were not recognised sufficiently or given key information or support in their role;
  • Where carers persist in the quest for information, they are often labelled as ‘angry’, ‘over-involved’ or ‘difficult’; and
  • There is a no consistency in treatment across clinicians and across service sectors.

There was also strong support for adoption of the “Triangle of Care” model that was developed by the UK Carers Trust.  The Triangle of Care recognises that there are three partners in the care relationship, being the consumer who is living the experience of illness, the carers of the consumer, and the service provider.

Family members are in a unique position where they know the person, and in many cases knew them before they became unwell. The Triangle of Care model combines the knowledge and skills of staff with the knowledge and lived experience of the consumer, their family and other carers in a partnership approach to service delivery across all settings.

About the Guide

The Guide seeks to assist providers to better engage, support and work with carers in all areas where mental health is provided.

There are six partnership standards contained in the Guide:

  1. Carers and the essential role they play are identified at first contact, or as soon as possible thereafter.
  2. Staff are carer aware and trained in carer engagement strategies
  3. Policy and practice protocols regarding confidentiality and sharing of information are in place.
  4. Defined staff positions are allocated for carers in all service settings.
  5. A carer introduction to the service and staff is available, with a relevant range of information across the care settings
  6. A range of carer support services is available.

Within each of the six standards there are practical examples of tasks that individuals and organisations may undertake to demonstrate that they are able to work in a partnership manner. These practical examples aim to assist providers to work with carers in a mutually beneficial way.

How can your organisation implement the standards?

A self-assessment for the Practical Guide for Working with Carers of People with a Mental Illness has recently been added into SPP. By self-assessing against these standards, your organisation can highlight priority areas and create action plans to make improvements to the engagement of carers.

Implementation of the standards will demonstrate your organisation’s commitment to working in partnership and to meeting the requirements of the accreditation processes.

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The importance of spiritual health when delivering quality care

Posted on by Beatrice Hobson

Over the past few decades there has been a move towards a more holistic concept of care that includes emotional, physical, social and spiritual aspects.  Consideration of a patient’s spiritual health has been identified as a key component when providing high quality health care.  Research has demonstrated that patients want their spiritual needs considered as part of their overall health care, and that an increase in discussion around spiritual beliefs strengthens the trust between the provider of services and their client or patient.

Everyone has spiritual needs – for some, this is intertwined with their religious beliefs, and for others it may involve a search for a deeper understanding of their purpose and meaning.  Spirituality plays many roles in the lives of patients and of those who are elderly.  For many patients, spirituality can help them cope with health outcomes, and contribute to their having a more positive outlook on life.  Spiritual care often holds greater importance at the end of one’s life, when it can help a person explore what has given meaning to their life, and reduce their stress as they contemplate dying.

Spirituality has also been found to assist with recovery, and spiritual practices such as meditation have been found to improve health outcomes through increasing relaxation.  Spirituality is an important aspect of health, and assists with coping with changes to health and maintaining positive wellbeing throughout the recovery process.

How can your organisation ensure that people's spiritual care needs are met?

Spiritual Health Association’s Guidelines for Quality Spiritual Care in Health, and Meaningful Ageing Australia’s National Guidelines for Spiritual Care in Aged Care were both developed with extensive stakeholder consultation and research, to help providers implement a nationally consistent and best-practice approach to spiritual care.  The two guidelines provide a wealth of information and resources, within their frameworks, to assist providers and practitioners to deliver spiritual care services in a way that ensures high-quality and safe care, and which addresses each person’s individual needs.

Guidelines for Quality Spiritual Care in Health

These Guidelines emphasise the importance of considering the whole person when providing person-centred care.  They provide a standardised and consistent approach to spiritual care, which aligns with the National Safety and Quality Health Service Standards, the National Palliative Care Standards, and evidence-based care.  They focus on responsive and respectful patient-centred care and serving all aspects of patient care.  The Guidelines assist providers with the delivery of quality, evidence-based care through offering a consistent approach to the provision of best practice spiritual care in health services. 

National Guidelines for Spiritual Care in Aged Care

The National Guidelines for Spiritual Care in Aged Care state that “spirituality is integral to quality of life and well-being and it should be accessible to all older people in a way that is meaningful to their beliefs, culture, and circumstances”.  The Guidelines reflect best practice and highlight that the offering of spiritual care is the responsibility of all caregivers.  The guidelines provide resources and suggestions, as well as ideas for implementation.  They are intended to offer spiritual care and support to older people living in residential aged care or receiving care and support through home care packages. 

Assess your organisation's approach to spiritual care

In order to provide more holistic and high-quality care, organisations should work towards embedding spirituality into their key systems and processes.

We’ve developed self-assessments in Standards & Performance Pathways (SPP) for each of the two Guidelines.  Using SPP’s new self-assessments will assist organisations to better understand the best-practice frameworks for delivery of spiritual care, and track their progress over time towards delivery of those best practices.

You can find these self-assessments in SPP under the Standards tab > Australian National Standards.

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High Intensity Daily Activities

Posted on by Beatrice Hobson

The delivery of supports for high intensity daily activities poses some of the greatest risks for NDIS participants and workers. Participants requiring these supports have complex health needs that must be supported by workers with specialised skills and experience, in order to ensure that the supports they receive are safe and of the highest quality.

It is essential that providers source workers with the relevant skills and knowledge to deliver supports for high intensity daily activities. Support workers need to have additional qualifications and previous experience relevant to the participant’s complex needs. With recent research demonstrating that people with a disability are more likely to suffer preventable deaths, it is increasingly important that extra care is taken to ensure sufficient communication, early detection  and timely medical assistance is provided.

Providers that assist with high intensity daily activities must meet all of the requirements of Module 1: High Intensity Daily Personal Activities, of the NDIS Practice Standards.  The NDIS High Intensity Skills Descriptors set out the skills and knowledge descriptors for Module 1 . Providers need to demonstrate that their workers have the relevant skills and training to provide each form of support. Providers may demonstrate that they meet the requirements of the skills descriptors through records of worker training and qualifications as well as relevant experience in the area.

We have recently developed some new resources to help providers meet and monitor their obligations in relation to the delivery of these complex supports.

Our new NDIS High Intensity Daily Activities Policy template outlines the training and skills required for staff when delivering each high intensity support. The policy template will ensure a consistent and reliable approach is taken to the delivery of complex supports. The policy document can be found in the Reading Room by searching for “high intensity”.

We’ve also recently created a new self-assessment for this area, to help providers track their obligations and compliance status. The self-assessment includes:

High intensity support:

  • Complex bowel care
  • Enteral feeding and management
  • Tracheostomy care
  • Urinary catheters
  • Ventilation
  • Subcutaneous injection

Additional support activities:

  • High risk of seizure
  • Pressure care and wound management
  • Mealtime preparation and delivery
  • Stoma care

You can find the self-assessment for the NDIS high intensity support skills descriptors in SPP under the Standards tab > NDIS Quality and Safeguarding Framework.

The self-assessment will assist providers to ensure that the skills and capabilities used in the delivery of their supports provide a safe environment for NDIS participants.

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Working from home during COVID-19

Posted on by Beatrice Hobson

Working from home can present many challenges. Spending long hours on a laptop at the kitchen table can be both physically and mentally stressful. Employees must take reasonable care for their own health and safety, and must co-operate with employers to ensure the workplace is safe by following any guidelines and carrying out necessary checks. For many organisations the pandemic presents new challenges, however there is an abundance of resources that organisations can use to assist them to maintain a productive workplace, and to assist employees struggling with their mental health.

A few tips to help you work from home safely and effectively:

  • Have a comfortable workstation;
  • Take regular breaks: for some people this may mean putting triggers in place to remind us to have a break- including setting an alarm;
  • Set boundaries between work and home. Setting up a designated space can be a good way to signal when you aren’t working. Moving the workstation to the end of the table, putting it away or covering it can be a good way to establish work hours;
  • Stay connected with your workmates, whether through regular meetings or more casual virtual chats; and
  • Schedule physical or creative activities into each day- get outside if the weather allows, or do indoor activities such as Yoga or Pilates.

Comcare has developed a useful working from home checklist which can assist organisations to ensure that short-term working from home arrangements fulfil the minimum requirements to keep them safe and healthy.  

Mental Health and Working from Home

Comcare has also developed some practical resources to assist you and your workplace to maintain good mental health throughout this time. They are updating their website as the situation evolves, with newly developed fact sheets. Some of their current fact sheets include:

Employers have an important role to play in ensuring their employees maintain their mental health. Employers should:

  • Check in regularly;
  • Create team chats that allow for continued communication;
  • Provide employees with appropriate flexibility when they work;
  • Encourage employees to stay physically active as well as regularly go outside;
  • Ensure employees are effectively disengaging from their work at the end of the day; and
  • Be available, accessible and ready to listen.

Dr Jill Newby, Associate Professor of Psychology at UNSW, who is based at the Black Dog Institute, has noted some common feelings that people may be experiencing during this time when working from home, including:

  • struggling to ‘switch off’ after work hours;
  • feeling isolated or disconnected both socially and professionally;
  • feeling a lack of motivation; or
  • feeling uncertain about their progress.

She offers some practical tips for individuals to stay motivated and productive when working from home.

It is vital that workers are supported to reach out and seek professional help if they are struggling during this time. Beyond Blue has many useful resources to help individuals stay positive and stay connected. It also provides support services which allow people to talk with a counsellor or to connect with others through online forums.

BNG has also developed some resources which may be useful when working from home. Our working from home policy outlines the responsibilities of both employees and employers when working from home, and outlines the confidentiality requirements when taking home or accessing client files from home. Our working from home agreement ensures that employers are aware of their obligations when working from home, and that the employee has undertaken the appropriate health and safety checks on their workspace.  

These resources are now available in SPP:

  • Policy: Working from home
  • Template: Working from home agreement

You can access these resources by searching for “working” in the Reading Room. 

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Aged Care Diversity Action Plans

Posted on by Beatrice Hobson

The ageing population in Australia is increasingly diverse, with one in three older Australians born overseas. Aged care facilities have not always responded well to these diverse needs and often do not reflect the diversity of the wider population. Without taking specific actions to address the diversity of consumers in care, there is a risk that older people can be left feeling neglected and isolated.

A recent hearing on diversity in aged care in the Royal Commission into Aged Care Quality and Safety heard of instances where providers have failed to accommodate diverse older people. Malloy, a lesbian woman in her 80s, spoke of the discrimination that she has felt in aged care facilities, and highlighted the lack of awareness and the discrimination that she had experienced from staff.

Providing residents with choice and control is central to Standard 1 of the Aged Care Quality Standards: Consumer Dignity and Choice. To exercise this choice and control, residents need to have their diverse needs catered for.

In 2019, as part of the Aged Care Diversity Framework initiative, the government released four Diversity Framework Action Plans. These action plans outline procedures that can be taken to support all diverse groups of older people. These plans are not mandatory compliance requirements, however they guide organisations in delivering more inclusive and culturally appropriate services to all older people.

BNG has developed self-assessments in Standards & Performance Pathways (SPP) based on the action plans, to help guide your organisation in delivering a safe and inclusive service environment for individuals. There are three levels of each action plan to work through: foundational actions, next steps and leading the way. The action plans acknowledge that each provider is starting from a different place and therefore allow providers to work through three different levels according to what is most relevant to their services and client base.

The four diversity action plan self-assessments are:

This self-assessment assists providers in creating a more safe and inclusive service for all diverse older people. The action plan recognises that there is no ‘one size fits all’ approach to diversity. Taking steps to make the services more inclusive for diverse older people means better engagement with existing and potentially new consumers, improved wellbeing for consumers and new partnerships built within the community.

While the national Aboriginal and Torres Strait Islander population is projected to grow by 59% between 2011 and 2031, the Aboriginal and Torres Strait Islander population aged 65 and over is projected to grow by 200%[1]. This means that aged care facilities need to respond to the growing demand from older Aboriginal and Torres Strait Islander people. Aged care providers need to ensure that they are working to address the current barriers to service access that many older Aboriginal and Torres Strait Islander people face, and ensure they receive culturally appropriate services.

Many older CALD Australians face additional barriers to access and awareness of aged care services. In June 2015, only 18% of people in permanent residential aged care were from non-English-speaking countries, which is not reflective of the fact that around 33% of people in the wider community were born in a non-English-speaking country[2]. As a bilingual person ages, they can lose the English skills that they have acquired over their lifetime and revert back to their original language. This means that additional support needs to be provided to allow older CALD people to access aged care services, and ensure they receive culturally appropriate care.

BNG has an interpreter services policy that can be a useful resource for organisations when providing care to older CALD people.

The action plan acknowledges that many older LGBTI people have faced significant discrimination and neglect throughout their lives. This means that many older LGBTI people may be ashamed or may face significant anxiety in expressing themselves. Organisations should be considerate of this experience and build confidence among older LGBTI people by providing the support and care that they need.

The action plans have been developed to assist aged care providers to ensure continuous improvement in providing care that meets the diverse characteristics and life experiences of all clients. Completing the new self-assessments in SPP is a simple way for providers to incorporate the Aged Care Diversity Framework into their service delivery, and work towards best practice in tailoring their care to assist individuals.

[1] https://www.health.gov.au/sites/default/files/documents/2019/12/actions-to-support-older-aboriginal-and-torres-strait-islander-people-a-guide-for-aged-care-providers.pdf
[2] https://www.health.gov.au/sites/default/files/documents/2019/12/actions-to-support-older-cald-people-a-guide-for-aged-care-providers.pdf

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Contingency planning: the importance of a “Plan B”

Posted on by Beatrice Hobson

It is important that organisations have risk management plans in place to ensure that they are prepared for changes that may affect the operation of their business. Changes could involve internal factors or issues, or there could be external factors that are outside the control of the organisation. Contingency planning is essential for risk management and business continuity. Lack of contingency planning can mean that your organisation is exposed to unnecessary risks, or that it cannot quickly take steps to mitigate or respond to the impacts of certain risks, if indeed they do eventuate.  

With the spread of COVID-19 (novel coronavirus) currently being monitored around the world, it is a good reminder to businesses to have a risk management plan in place. While Australia is currently at low risk from the coronavirus, it is possible that the number of cases will steadily increase. Organisations should consider and plan for changes to the way they do business, that may come about due to the spread of the virus. For aged care facilities, this is particularly important as the virus appears to have more serious consequences for older people. A contingency plan is important for both aged care organisations, as well as other workplaces who may have to accommodate changes to the operation of their business. The spread of the virus may have impacts such as a rise in absenteeism, or requirements for businesses to arrange for some or all staff to work from home.

It is not possible to anticipate all risks that a business faces, however a risk management plan is essential to identify and prepare for potential risks. Anticipating potential risks, and formulating a plan to respond to and mitigate those risks, can help prevent significant loss to productivity. It is important that businesses regularly evaluate, review and update their business continuity plans.

BNG has a number of resources that can assist organisations to identify risks and impacts to their business, and develop recovery or alternative plans that can be implemented.

Risk register and management plan template:

  • This resource guides organisations in identifying risks, prioritising them according to likelihood that they will happen as well as impact if they do occur, and finally creating a recovery plan or a strategy for continuing operations in alternative ways;
  • It guides the organisation through potential risks to do with:
    • Governance and management
    • Legal/ compliance
    • Financial/ funding
    • Human resources
    • Work health and safety
    • Reputation and relationships
    • Operations and service delivery; and
    • Administration and information technology

Business impact analysis template:

  • This template assists organisations to identify which activities are critical to the operation and continuation of the organisation; and
  • it allows them to identify and assess the potential impact that failure of certain operations will have on the organisation.

Business continuity policy:

  • This policy assists businesses in the process for preparing for potential risks and recovering and returning to their pre-incident condition as quickly and effectively as possible.

These documents are all available in SPP:

  • Policy: Business continuity
  • Template: Business Impact Analysis
  • Template: Risk register and management plan

You can access these resources by searching for “business” or “risk” in the Reading Room. 

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Intimacy and sexuality in aged care

Posted on by Beatrice Hobson

When we talk about the elderly, the topics of sex and intimacy are often taboo. There is a common misconception that older people lack sexual drive, however intimacy, sexuality and sexual expression continue to be important throughout our lives.

Understanding and supporting the sexual and intimacy needs of older individuals can be challenging for staff who have limited training in the area. The area of sexuality and intimacy remains largely misunderstood and often ideas about sexuality and intimacy are informed by cultural and social constructions. Understanding the needs of older individuals is an ongoing responsibility that requires special skills and knowledge. Having a policy is essential for addressing embarrassment, confusion and helplessness around the area and for training staff to provide this level of care. Neglecting these needs can cause mental health issues and can affect self-esteem for elderly residents.

In late 2018, a research report by the Australian Centre for Evidence Based Aged Care found that less than a quarter of Australian residential aged care facilities surveyed had a policy on sexuality or sexual health, and less than one-tenth reported having a written policy. This means that the sexuality and intimacy needs of residents are at risk of being mishandled or ignored.

Policies regarding sexuality and intimacy are important to guide staff through this sensitive topic. Helping residents to connect with others and maintain relationships, including intimate relationships, is an important component of Standard 1 of the Aged Care Quality Standards: Consumer Dignity and Choice.

To help you support clients with their needs surrounding intimacy and sexuality, BNG has developed a policy and an information sheet. These outline:

  • how to maintain an inclusive environment within the organisation;
  • the importance of recognising the diversity of residents and that they all have different needs and preferences;
  • how to start a conversation around the sexual and intimacy needs of the individual;
  • how to handle unwanted or inappropriate sexual behaviours;
  • the importance of respecting the privacy of individuals; and
  • the importance of recognising the diversity of residents and treating things on a case by case basis.

The new resource will help you to develop answers for questions such as what to do if:

  • A couple moves into a residential facility, but there are no shared rooms?
  • A resident asks to pay for the weekly visits of a sex worker?
  • A resident wishes to continue to express themselves the way they did in their own home?
  • A resident is showing inappropriate behaviour towards another resident?

These are now available in SPP:

  • Policy: Intimacy and Sexuality in Aged Care
  • Info sheet: Intimacy and Sexuality in Aged Care

You can access these resources by searching for “Intimacy” in the Reading Room. 

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Conflict of interest and the NDIS

Posted on by Beatrice Hobson

A conflict of interest arises when a person or organisation takes advantage of their position for personal or corporate benefit. The conflict may be actual (because it occurs), potential (because it may or is likely to occur), or perceived (because people could or would think it is a conflict, even if it is not).

Within the NDIS, the issue can arise when a provider offers multiple supports. A support coordinator, for example, is required to provide advice that is unbiased and fair, in helping to connect participants with the supports they need. However, if the support coordinator’s organisation also delivers other supports, they may unintentionally influence a potentially vulnerable participant’s decision-making process in the selection of the providers of their supports.

In his recent review of the NDIS Act, David Tune AO PSM discussed the potential conflict of interest that arises when support coordinators are also the providers of other funded supports within the individual’s plan. He recommended that:

“The NDIS rules [be] amended to outline circumstances in which it is not appropriate for the providers of Support Coordination to be the provider of any other funded supports in a participant’s plan, to protect participants from providers’ conflicts of interest.”

The Tune Review found that in some cases, where the participant was receiving funded supports as well as support coordination, the coordinators only directed participants towards supports provided by their own organisation. This limits the individual’s freedom of choice and control over their funded supports.

It is important that participants receive transparent advice about support options available, and providers respect the participant’s rights to freedom of expression, self-determination and decision-making. The Review recommended that where possible, a person’s support coordination should be independent from other service provisions.

Support providers have an obligation to put processes in place to limit conflicts of interest where possible. We have developed several resources that organisations can use to assist with this. Our support coordination and plan management policy outlines how providers can reduce the risk of conflicts of interest by:

  • Maintaining a separation between the service delivery team and the support coordination team where possible;
  • Ensuring that information and records of supports participants have received remain confidential;
  • Ensuring that participants receive all the information regarding support options under the NDIS;
  • Ensuring that the individual is aware of their rights to choose support from a provider that is different to where their support coordinator or plan manager works.

You can access these policies in SPP’s Reading Room:

  • Policy: Support coordination and plan management
  • Policy: Conflict of interest NDIS

Our Policy: Specialist Disability Accommodation (SDA) also addresses conflict of interest in the SDA context.

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