DRC: Human Rights

Upholding the human rights of participants is a common theme that underpins the discussion and Recommendations published by the Disability Royal Commission (DRC). Whilst most of the human rights Recommendations are directed at the federal, state and territory governments, several Recommendations are related to human rights requirements for providers.

The United Nations’ Convention on the Rights of People with Disability (CRPD) is the foundation of the DRC’s investigation into the human rights of people with disability. The CRPD lays out Australia’s obligations in relation to the human rights of people with disability. There are eight guiding human rights principles that underlie the CRPD (the Human Rights Principles), as follows:

  1. Respect for inherent dignity, individual autonomy (including the freedom to make one’s own choices), and independence of persons;
  2. Non-discrimination;
  3. Full and effective participation and inclusion in society;
  4. Respect for difference and acceptance of persons with disabilities as part of human diversity and humanity;
  5. Equality of opportunity;
  6. Accessibility;
  7. Equality between men and women; and
  8. Respect for the evolving capacities of children with disabilities and respect for the right of children with disabilities to preserve their identities.

The DRC found that the above Human Rights Principles were not adequately protected and upheld under Australian law or policy and practice.

The DRC's key human rights Recommendations

Recommendation 10.1 of the DRC final report suggests that the NDIS Quality and Safeguards Commission should develop a program to ensure that human rights are embedded in the design and delivery of each NDIS Provider’s services. The specifics of the program are not clear, however the final report suggests that the program will give regulators oversight of providers’ implementation of human rights policies and procedures.

Accompanying Recommendation 10.1 are several recommendations from Volume 4: Realising the human rights of people with disability. These Recommendations endorse the enactment of a disability rights act, which would enshrine the human rights of people with disability in Australian law.

The DRC made a distinction between actual and potential impacts on the human rights of people with disability.

Potential impacts

Potential impacts include identified risks to the legal and human rights of people with disability. Potential impacts should be identified and addressed before they happen. This can be dealt with through an organisation’s risk management system.

Actual Impacts

Actual impacts on human rights include breaches of a person’s human rights which have already happened. Addressing actual impacts may require remediation and should be dealt with as a priority.

Embedding human rights in service provision

Implementing policies and procedures related to human rights is an essential first step that NDIS Providers should take to stay ahead of new requirements stemming from the DRC. Implementation should include:

  • Assigning responsibility
    Ensure that responsibility for the organisation’s human rights impacts is assigned to a senior staff member or a committee.
  • Training
    The workforce should be made aware of their responsibilities in relation to human rights, and understand how they can ensure human rights are being upheld.
  • Assessment
    Assessing the organisation’s services and identifying the potential human rights impacts will help the organisation to prevent potential impacts from becoming actual impacts.
  • Monitoring and review
    The organisation should regularly review its performance in relation to human rights. Any breaches or impacts should be addressed as soon as possible.
  • Complaints and grievances
    Complaints, feedback and grievances in relation to human rights impacts should be taken very seriously and investigated as soon as possible by the organisation.

How BNG can help

We have developed a new Human Rights policy template to help providers stay on the front foot in relation to human rights. The policy template will help you understand the central principles of the CRPD and embed human rights in service delivery.

This blog post is the third in our series of posts on the Disability Royal Commission. You can see the other blog posts in the series here.

Need a human rights policy?

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The 10 most common complaints in residential Aged Care

The Aged Care Quality and Safety Commission recently released their first annual report regarding the common complaints received about aged care services. Complaints and feedback play a central role in the quality improvement process, as they can highlight issues of concern that care recipients may have.  Understanding the problem areas of other providers can help to inform your own quality improvement.

In total there were 9,198 complaints submitted to the Commission from July 2022 to June 2023. The Commission identified 10 main complaint categories in residential aged care. These categories provide some insight into the most common issues faced by service users, and will help providers to identify the processes which they could review as part of their continuous improvement system.

As we go through these main complaint categories, we will note resources that we’ve developed which will help providers ensure that they are working to best practice in these areas. If you already have policies and procedures to address these processes, it might still be helpful to review them and compare them with ours.

Common complaint categories for residential aged care:

  • Medication administration and management
    Medication management accounted for 5.5% of complaints received by the Commission. Concerns included issues such as medications being delivered late, identification of patients and medicines, and medications not being started.
    SPP resources
    • Policy: Medication Management
  • Personal and oral hygiene
    Personal care was identified as a problem area for residential aged care providers, with 5.3% of complaints. Personal care includes things such as showering, bathing, and oral hygiene.
    SPP resources
    • Policy: Showering and Bathing
    • Policy: Oral Health (Aged Care)
  • Personnel number/proficiency
    Accounting for 4.8% of complaints about residential aged care, personnel play an essential role in the delivery of safe and quality services. Providers should focus on human resources issues such as recruitment, training, retention, and conditions.
    SPP resources
    • Policy: Employment Conditions
    • Policy: Staff Recruitment
    • Policy: Key Personnel
    • + many more human resources
  • Consultation and communication with family/representatives
    Lack of communication with family and representatives made up 4.4% of residential aged care complaints in the last year. Engagement with family and representatives is important in ensuring that service users are receiving adequate care and services.
    SPP resources
    • Policy: Partnering with Consumers
    • Template: Consumer Advisory Body Terms of Reference
  • Falls prevention
    While falls prevention and post fall management made up only a small portion of the complaints made to the Commission, these areas present a serious risk for providers.
    SPP resources
    • Policy: Falls Prevention (Aged Care)
    • Policy: Showering and Bathing
  • Food and catering
    Quality and variety of food and catering in residential aged care have received increased focus from the Commission recently. And the new Standard 6 (Food and Nutrition) in the Strengthened Quality Standards, currently being piloted, is dedicated to this area. Providers should implement processes to ensure that meals, drinks and snacks are co-designed, nutritious, and varied.
    SPP resources
    • Policy: Nutrition, Meals and Hydration (Aged Care)
    • Template: Mealtime Management Plan
  • Client assessment and service implementation
    Complaints pointed to service implementation and client assessment as areas which providers should review. Client assessments should not only occur at the beginning of service delivery, but should be a regular and ongoing process.
    SPP resources
    • Policy: Client Assessment and Review
    • Template: Client Risk Assessment
  • Consultation and communication
    Communication was another area identified in the Commission’s report as a problem area. With increased focus now on co-design, supported decision-making and consumer advisory bodies, providers should be implementing best practice communication processes.
    SPP resources
    • Policy: Supported Decision-Making and Dignity of Risk
    • Template: Consumer Advisory Body Terms of Reference
  • Physical environment
    Lack of cleanliness in the physical environment was a common complaint received by the Commission from residential aged care service users. Cleanliness is important in upholding the dignity of service users, and infection prevention and control.
    SPP resources:
    • Policy: Hospitality Services
  • Constipation and continence management
    Constipation and continence management accounted for 2.8% of residential aged care related complaints. Though only a small number of complaints were made about these issues, proper management of these areas is essential in providing quality and safe care to service users.
    SPP resources:
    • Policy: Continence Management (Aged Care)

Take this opportunity to review your policies and procedures

The Commission’s new report is a great prompt for providers to consider the identified areas of common complaint as part of their continuous improvement activities.  Ask yourself the following questions regarding each area, to help you determine whether your current procedures could be improved:

  • What complaints and other feedback have we received in each of these areas?
  • What is working well?
  • Are our procedures consistently followed by all workers?
  • Are there improvements we could make?
  • Do we need to update our policies as a result?
  • If so, have we clearly communicated our revised procedures to all workers?

Interested in our resources?

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DRC: Complaints Management

Now that the Disability Royal Commission (DRC) has released its final report, we will be publishing some blog posts on a number of the report’s key themes.  

Our posts are intended to help providers understand the changes to the disability system that the DRC is recommending, so that they can consider whether they need to adjust or improve how they provide services.  It is also a great time for providers to  review their policies and procedures. Note that the Australian Government has not yet accepted the recommendations of the DRC, so they are subject to change further down the track.

This first post is about complaints management, and how providers can get on the front foot to ensure complaints processes are what they should be.

Complaints management principles

Recommendation 11.5 suggests that states and territories develop specific guidelines to help organisations implement complaint handling systems which are accessible and responsive to people with disability.

The DRC outlined ten core principles which the guidelines should reflect, which are:

  • creating a rights-focused complaints culture;
  • encouraging people with disability and others to speak up;
  • making adjustments to enable participation;
  • supporting the person with disability, their family and others in complaint processes;
  • respecting complexity, diversity and cultural difference;
  • providing clear information about how to complain, and multiple pathways to complain;
  • working respectfully and effectively alongside police;
  • conducting safe and inclusive investigations, that are trauma-informed;
  • providing tailored outcomes and redress; and
  • using complaints data to drive continuous improvement in service provision and complaint handling.

Barriers and accessibility in complaints and feedback

One of the key concerns outlined by the DRC was the lack of accessibility in complaints systems. They raised a series of concerns related to things such as:

  • inaccessible policies and processes,
  • a lack of options for raising concerns,
  • potential victimisation, and
  • fear of not being believed or treated or taken seriously, among other things.

To ensure that your organisation’s complaints management does not create barriers, regularly review your policies and procedures and check that they are in line with (and promote) the principles of natural justice.

It is also important to ensure that policies are well communicated and can be easily understood.  For example, adopting an Easy English complaints policies which addresses the communication needs of participants can assist in making your complaint handling processes easier to understand. 

Strengthening complaints systems

The Executive Summary of the DRC report contains recommendations for measures which NDIS Providers can implement to strengthen their existing complaints management systems, including the following:

  • Creating a dedicated complaints management team or individual
    This team or individual should be separate from those delivering services. Their primary role is to increase the engagement with participants and their support networks to ensure that complaints are addressed appropriately.
  • Prioritising complaints based on risk
    This involves assessing each complaint separately to determine its severity, and using a triage system to address complaints which have the most potential risk to participants.
  • Establishing lines of communication
    A common theme from the DRC’s investigation of complaints systems is confusion arising from lack of communication. This includes participants not knowing whom to contact, as well as not feeling comfortable to speak up.
  • Record keeping
    Strong record keeping practices, including documenting the conclusion and resolution of complaints, are central to good complaints management.
  • Organisational culture
    Developing a culture that encourages and welcomes feedback is essential to complaints management, and will help inform continuous improvement activities.

Responding to complaints

The DRC stressed the importance of adequately responding to complaints and concerns. Providers should acknowledge the complaint when it is made, and actively involve participants and their families in the investigation and resolution of a complaint.

Poor communication between service providers and participants can result in feelings of distrust and anxiety.

To address this, providers should communicate regularly with participants about the progress of their complaint and ensure that participants are aware of their rights in relation to complaints.

How we can help

We have a number of resources to help providers with complaints management:

  • Policy: Complaints Management
  • Info: Complaints Management
  • Policy: Complaints (Easy English)
  • Policy: Child Safe Complaints Management
  • Template: Complaints Register
  • Template: Complaints Information for Clients
  • Template: Complaint Process Tracking Form
  • Template: Complaint Submission Form
  • Template: Complaint Response Letter

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Latest from the Disability Royal Commission

The Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability (the DRC) is set to deliver its final report by 29 September 2023. Ahead of the final report, we’ve been tracking some of the common themes that have emerged from the latest Public Hearings, to identify likely recommendations that we might see in the final report.

Public Hearing 32 examined violence, abuse, neglect and exploitation of people with disability, and the role that provider policies and procedures play in safeguarding participants. Public Hearing 32 was the final time in the DRC’s process that service providers were examined, so it is a useful insight into the recommendations for providers that we might see in the final report.

There are some common themes throughout the Counsel Assisting submissions to Public Hearing 32 for which we have developed resources. Our resources will help providers to get on the front foot in terms of best practice service delivery.

Safeguarding

Preventing and responding to violence, abuse, neglect and exploitation of people with disability is not a new concept for NDIS providers, however Counsel Assisting submissions to the DRC identified a number of processes which should be implemented by providers to ensure that the rights of participants are upheld, including:

  • implementing proper recruitment, training and oversight processes to ensure that all workers understand and uphold the core rights of participants. This includes exercises such as conducting reference checks and querying gaps in employment history; and
  • implementing appropriate redress processes, including the important step of making apologies when redress is required.

Trauma–Informed Care

Public Hearing 32 introduced the concept of trauma-informed care to the disability sector, particularly in the context of cultural safety for Aboriginal and Torres Strait Islander participants. Providers should incorporate principles of trauma-informed care into all aspects of the organisation, recognising that everyone may have a history of trauma, and that everyone’s responses to trauma and needs arising from trauma will be different.

Establishing effective trauma-informed care procedures contributes both to a safer care environment for participants, and to care that is person-centred and tailored to the unique needs of each participant.

Supported Decision-Making

Supported decision-making is another area that has been closely examined by the DRC. Understanding each participant’s will and preferences was highlighted as central to supporting the decision-making process. Organisations should presume that every adult participant has the ability to make decisions that are directed by their will and preferences, unless there is evidence otherwise.  Organisations should implement processes to seek to understand and document each participant’s will and preferences, and then ensure that they and their families are actively involved in all decisions.

While it was not explicitly called for in the Counsel Assisting submissions, a clear emerging principle in this area is that substitute decision-making should be a last resort only.  An organisation’s supported decision-making processes should prioritise supported decision-making in partnership with the participant, and only utilise substitute decision-makers as a last resort, when someone is unable to assist in making a decision, or does not want to make a decision.

Human Rights & Dignity

Clearly understanding and protecting all participants’ human rights is an issue which has been consistently raised by Counsel Assisting submissions, and the DRC more broadly. Enshrining each participant’s human rights in policies and procedures is a core governance concept for NDIS Providers. The DRC has pointed out that, whilst providers should have a human rights policy, it is essential to ensure that the processes outlined in the policy are clearly communicated to, and understood by, all workers so that they are consistently implemented and followed in practice, throughout the organisation.

Co-design

Co-design was also a common theme throughout Public Hearing 32. There are some guiding principles of co-design which providers should follow, including:

  • Representation in the design process, particularly including people with lived experience and diverse cultural representation;
  • Effective leadership and acceptance of change;
  • Education and training for staff;
  • Empowering staff to make change;
  • Communication and information sharing to draw on the experiences and expertise of other providers; and
  • Monitoring, evaluation and continuous improvement.

For more information about co-design, see our blog post on the topic.

How we can help

We have developed and updated several resources to help you implement processes to address the above common themes. These resources include:

  • Policy: Safeguarding (Responding to Abuse);
  • Info: Safeguarding (Responding to Abuse);
  • Policy: Supported Decision-Making and Dignity of Risk (NDIS);
  • Policy: Supported Decision-Making and Dignity of Risk;
  • Policy: Trauma-Informed Care;
  • Policy: Trauma-Informed Care (Disability); and
  • Policy: Trauma-Informed Care (Child Safe).

We are also in the process of developing resources for:

  • Human rights and dignity of risk; and
  • Inclusive co-design.

Towards better practice!

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The new high intensity support skills descriptors

High Intensity Daily Personal Activities are the highest risk, and most personal in nature, of all supports delivered under the NDIS. To uphold the wellbeing of participants, providers who support participants with high intensity daily personal activities must ensure that workers who are not qualified health professionals have the necessary skills and knowledge to safely provide these supports.

In December 2022, the NDIS Quality and Safeguards Commission (the Commission) released revised skills descriptors for High Intensity Daily Personal Activities, outlining the skills and knowledge workers must have to deliver High Intensity Daily Personal Activities supports.

There are currently eight high intensity supports:

  • Complex Bowel Care;
  • Enteral Feeding Support;
  • Dysphagia Support;
  • Ventilator Support;
  • Tracheostomy Support;
  • Urinary Catheter Support;
  • Subcutaneous Injections; and
  • Complex Wound Care Support.

The revised skills descriptors

Each of the High Intensity Daily Personal Activities is supported by its own unique set of skills descriptors. The Commission’s document also lays out the context, scope and necessary training for each of the above supports.

Following the contextual information, the updated skills descriptors outline the behaviours which demonstrate the skills and knowledge each worker should possess. The skills and knowledge are divided into three segments representing a participant’s care journey: preparing to deliver supports, implementing the support plan, and reviewing the support.

Regulatory context

The revised skills descriptors provide more detailed guidance about the expectations of workers, and align with the requirements in Module 1 of the Practice Standards.

If your organisation provides High Intensity Daily Personal Activities supports, auditors may use the skills descriptors as guidance when performing a quality audit.

Who are the skills descriptors for?

The Commission has developed the skills descriptors for use by participants, auditors, providers, workers and trainers. For participants, they are useful for understanding the standard of care expected by the Commission, and using this information to assess their provider’s performance. For providers, workers and trainers the skills descriptors provide a standard by which skills and knowledge can be benchmarked.

How we can help

Following the release of the revised skills descriptors, we have developed a new self-assessment which providers can use to evaluate whether their workers have the adequate skills and knowledge to deliver High Intensity Daily Personal Activities supports. We’ve also updated our policy template to help providers ensure that their processes are aligned with the expectations of the skills descriptors.

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The new Digital Mental Health Standards

Accreditation to the National Safety and Quality Digital Mental Health Standards (NSQDMHS) became available for all organisations on November 1 2022. Digital mental health services provide valuable support to clients, as they can be easier to access for most clients, and they can also offer clients the opportunity to discuss issues anonymously.

Launched in November of 2020, the Standards are not mandatory, however they do provide an opportunity for providers to give greater confidence to users of their services.

Who are the NSQDMHS for?

The Digital Mental Health Standards are available to a variety of mental health support providers. These include providers of:

  • Peer to peer support;
  • Services that provide information about accessing mental health services;
  • Digital counselling; and
  • Treatment services (assessment, triage and referral).

Digital mental health services may be provided via telephone, video conference, online (including web chat), SMS, and mobile applications.

What is in the standards?

There are three standards, and a total of 59 actions within the Digital Mental Health Standards. The three standards are:

  • Clinical and Technical Governance Standard;
  • Partnering with Consumers Standard; and
  • Model of Care Standard.

The standards map directly to the National Safety and Quality Healthcare Standards (NSQHS), however they contain fewer requirements than the NSQHS.

For more information about the content within the National Safety and Quality Digital Mental Health Standards, see our previous blog post on the topic.

Should we consider accreditation to the NSQDMHS?

Accreditation to the Digital Mental Health Standards provides clients with the assurance that their service provider is meeting the expected standards for safety and quality. The standards will also help to refine a provider’s processes, and provide better outcomes for users.

Feedback from organisations who participated in the pilot program for the Digital Mental Health Standards was that the standards helped them to document the processes they already had in place, and helped them to identify if they had any issues or areas for improvement in their processes. Organisations highlighted the data collection and management requirements within the Standards, saying that these assisted in mapping patient care journeys and change management processes.

What is the accreditation process?

Accreditation is provided by independent accrediting agencies who have been approved by the AHSSQA Scheme. The Australian Commission on Safety and Quality in Health Care (the Commission) has a list of accreditors on their website.

The process for accreditation to the National Safety and Quality Digital Mental Health Standards is as follows:

Application and engagement

  • Application – apply to an approved accrediting agency
  • Preparation – implement the NSQDMH Standards and clarify arrangements for an assessment
  • Application for not applicable actions – not all of the actions within the NSQDMH Standards are applicable to all providers, here you will specify which actions are irrelevant

Assessment and remediation

  • Interim assessment – the approved accreditor conducts an interim assessment which includes:
    • Desktop review – a review of evidence submitted by the provider to demonstrate compliance with the NSQDMH Standards
    • Verification – an assessment to verify the safety and quality systems described by the provider
  • Remediation period – a period of 60 business days is allowed in order to address any areas where the service provider does not comply with the requirements of the Standards
  • Final assessment – this assessment is for the actions that were either ‘not met’ or ‘met with recommendations’ during the interim assessment

Outcome, reporting and monitoring

  • Outcome – the provider receives an outcome based on the final assessment
  • Final report – the accrediting agency delivers a final assessment report
  • Submission of data – the Commission is notified of assessment outcomes by the accrediting agency
  • Registration the Commission adds the provider to their register of accredited digital mental health service providers
  • Ongoing monitoring – the service provider continues their monitoring and continuous improvement responsibilities

Further reading and how we can help

Since April 2021 we have had a module available to help providers self-assess against the NSQDMH Standards and ensure that their documented processes are in line with the requirements of the Standards. The module is intended to help to conduct a gap analysis before beginning accreditation, and with ongoing monitoring.

The Commission has developed a resource pack for the Digital Mental Health Standards, which can be found on their website.   

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ISO self-assessments for community organisations

Over the last ten years or so, we’ve seen the emergence and continuing refinement of many comprehensive community and health services standards, at both the state/territory level as well as the national level.

These standards share common aims, the core of which are to:

  • educate and assist NFPs to implement more robust and consistent approaches to corporate governance and quality improvement processes; and, as a result,
  • improve the consistency, safety and quality of the services for their clients.

There are too many standards to name here, but they apply to a broad range of services such as:

  • aged care;
  • disability and mental health services;
  • primary, community and other healthcare;
  • homelessness services;
  • alcohol and other drug services;
  • domestic violence services; and
  • a wide range of services that are funded by state government departments.

While there are numerous areas of commonality across these standards, each has also been tailored to address the specific needs and requirements of the clients served in their particular sector.

Aside from these Australian service-specific quality standards which have developed and evolved over time, the International Organisation for Standardisation (ISO) has a suite of standards which are recognised globally as a benchmark of best practice across core thematic areas.

ISO’s standards are some of the most well-known and widely used standards in the world. While a large number of service streams in Australia are now mandated to follow the particular standards that apply to their service (or their funding agreement), many organisations continue to follow ISO standards, and in certain cases (for example disability employment services) they may be required to do so.

For this reason, we continue to support and add to our self-assessment modules for ISO standards, alongside the more than 100 other standards and best practice modules we now carry in our SPP platform. Here is a snapshot of what we have currently:

ISO 9001:2015 Quality Management Systems

These very well-established standards address continuous improvement, and are used across a range sectors. Since their release, many standards that are specific to the community and health services sector have incorporated the themes and requirements of ISO 9001. ISO’s Quality Management Systems standards are the backbone of ISO’s approach to their standards, as quality management is a central theme throughout their other sets of standards. ISO 9001 itself heavily prioritises the ‘Plan, Do, Check, Act’ cycle of continuous quality improvement, and requires organisations to implement continuous improvement processes throughout their operations.

ISO 45001:2018 Occupational Health and Safety (OH&S) Management Systems

This set of standards is about the documentation, implementation, operation and review of an organisation’s OH&S management system. It ensures that documented processes are in place to improve the health and wellbeing of the workforce, as well as addressing and eliminating hazards, risks and non-conformities. As ISO 9001 does, these standards also place an emphasis on review and continuous improvement.

ISO 27001:2013 Information Security Management Systems (ISMS)

In recent years, information security has become a more pressing issue for organisations, particularly those who are involved in the delivery of community services and, by extension, the management of client records. These standards are a good measure of best practice for organisations who are concerned about their information security systems. They help organisations to understand the primary risks to information security, and how to protect against those risks. Additionally, the Australian Federal Government requires ISO 27001 certification for all providers of employment skills training and disability employment services.

Coming soon: ISO 31000:2018 - Risk Management - Guidelines

We will shortly be adding a self-assessment module for ISO 31000. This set of standards helps organisations to understand and implement a best practice approach to risk management.

Want to access our ISO self-assessments?

Conducting NDIS Practice Reviews

The NDIS Quality and Safeguards Commission recommends that all providers undertake Practice Reviews as part of the continuous improvement processes, to ensure that their governance and service delivery processes are aligned with the expectations of participants.

A Practice Review is a reflective process which generally involves simple discussions with participants and support workers, with the aim of understanding the experience of participants, and improving service quality. Practice Reviews generally focus on a specific area of a provider’s services and help providers to actively learn from incidents or near misses to reduce the risk of reoccurrence in the future.

Regulatory context

Practice Reviews are not a regulatory obligation under the NDIS Practice Standards. They should, however, form a part of a provider’s incident management and quality improvement systems.

Practice Reviews will help to establish the contributing causes to an incident or near miss. Understanding the ‘how and why’ behind each incident will help you to make the best decisions in improving your processes following an incident.

Co-design

In recent years there has been increasing focus in the community sector on co-design and consumer engagement from regulators and industry groups alike. Put simply, co-design is the involvement of participants, their families, support workers and other staff in the design and implementation of care and services. Co-design is a central concept of NDIS Practice Reviews and will give participants the power and freedom to shape the way they receive services.

For more information about implementing co-design, see our blog post on the topic.

When to conduct a Practice Review

Practice Reviews can be conducted whenever a provider considers it to be an appropriate time. However, there are certain triggers which may help to determine when a Practice Review should be undertaken. These triggers include things like changes in health or behavioural needs, increased number of incidents or injuries, WHS breaches or changes in workplace atmosphere. In response to patterns identified during regular review of incident records, providers should consider undertaking a Practice Review.

How to conduct a Practice Review

Practice Reviews may involve support workers and other relevant people; however, they must involve participants. The Commission has outlined four principles which should be observed when conducting a Practice Review:

  • People with disability have a right to safe, innovative, high-quality support.
  • People with disability are experts in their own lives.
  • Continuous improvement is fundamental to high quality support.
  • Best practice is the goal that all providers strive to achieve.

Central to the NDIS Commission’s messaging regarding Practice Reviews is the imperative that people involved in Practice Reviews should be made to feel comfortable voicing their concerns, and should be free from facing consequences for doing so. It is also crucial to understand and respect each participant’s communication needs before a Practice Review is undertaken, and ensure that everyone involved understands the purpose of a Practice Review and what it involves.

How BNG can help

To help you conduct Practice Reviews we have developed a template to guide your organisation through the steps before, during and after a Practice Review.  

As a Practice Review is essentially a short discussion, our template includes questions and prompts to help you understand how your services are being received by participants.

You can find the new template under Disability Resources in the Reading Room, or search for “Practice Review”. If you don’t have an SPP account, click here to visit our sign-up page.

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Incident Management – the key elements for best practice

Incident management in Aged Care now aligned with NDIS

With the recent updates to the aged care Serious Incident Response Scheme (SIRS), including a new indicator being added to the Aged Care Quality Standards, the requirements for incident management in aged care have become more closely aligned with those under the NDIS Practice Standards.   

Given these developments, we thought it would be timely to take a look at what a best practice incident management system looks like.  

So, what does “incident management” involve?

The overall goal of an incident management system is to reduce the risk of harm to clients, workers and the community. Incident management is an ongoing process that needs to be integrated into your quality improvement processes.  It begins with documenting and communicating your approach; requires that all workers follow a consistent process to respond to and resolve the incident; and concludes with a review, learning and improvement process, to minimise the likelihood of the incident re-occurring.   

A best practice incident management cycle

Documenting the process

To ensure that all workers know what to do when it comes to incidents, your incident management system should be clearly documented, with policies and procedures that are easily accessible to the workforce. 

Communication and training

It is important that workers receive training related to incidents, so that they understand the organisation’s incident management procedures, and how to respond if they witness or hear about an incident.  

The training should be included in your induction processes, as well as on an ongoing basis.  Workers need to know how to identify incidents, even low-risk incidents, so that they are able to respond to the incident accordingly. And they should understand the procedures to follow, and which staff members to inform, immediately after an incident occurs.  

You should have a clear definition of which occurrences (including acts and omissions) constitute an incident. This will help to streamline your response to incidents, ensuring that all incidents that occur in connection with service delivery are quickly identified and resolved.  

You should also have a priority rating system for incidents. This will help to categorise the severity of each incident and respond accordingly. The Aged Care Serious Incident Response Scheme (SIRS), for example, has an in-built priority system where incidents are given a rating of Priority 1 or Priority 2 depending on their severity. 

Managing an incident

Identification and response

Immediately following an incident, the primary goal is to ensure the safety of the client and the community. For serious incidents it may be necessary to contact emergency services.  

Even minor incidents must still be treated seriously, and be responded to in accordance with the organisation’s incident management processes. Minor incidents can have serious implications for clients and the organisation’s processes. 

Notification procedures

After an incident occurs, workers should notify senior management of its occurrence, so that senior management can determine what the next steps should be. This may include notifying families/guardians/advocates of the incident as a first step.  

Aged care, disability and/or child services providers are required to notify the relevant government entity of serious incidents which have occurred in connection with service delivery.  

For both aged care and disability providers, it is a requirement that a staff member within the organisation has the designated responsibility of notifying the relevant Commission within a particular timeframe, in an approved format. 

Assessment and investigation

Following an incident, the organisation should ensure that the incident is assessed to understand its severity and determine whether a formal internal investigation is required. 

If the incident is serious, the organisation should conduct a formal investigation to determine: 

  • The cause of the incident, 
  • The effect of the incident, 
  • Any organisational processes that contributed to or did not function in preventing the incident, 
  • Changes the organisation can make to prevent further incidents from occurring, 
  • What, if any, remedial action must be undertaken to prevent or minimise future incidents, and 
  • The effectiveness of the organisation’s incident management system in relation to the incident. 

Supporting those affected

The organisation must support the people involved in the incident, whether they are a client, a worker or a community member. This may include reassuring clients, providing access to professional counselling or trauma services, or changes to services. 

Keeping people affected by an incident informed of the response and resolution progress is central to the incident management process. Incidents should be managed in accordance with the principles of open disclosure 

Resolution

In some cases it may be necessary to take remedial action following an incident. Remedial action can range from providing a formal apology to providing financial compensation. You should involve those affected in the resolution of an incident, to ensure that all parties are satisfied with the outcome of the incident management process.  

Record-keeping and improvement

Recording

Record-keeping is central to the process of incident management and resolution. Record-keeping is a requirement for aged care, disability and child service providers. Accurate and detailed records are an important part of the continuous improvement aspect of managing incidents. 

Continuous Improvement

Each incident is a learning opportunity, and should be viewed as such. During the assessment and investigation stage of each incident, you should examine your processes to determine if any organisational processes failed and are in need of review. You should regularly review your incident register to identify trends, and address processes which may need revision. 

The goal: incident prevention

Overall, it is important that workers and organisations understand that the ultimate goal of an incident management system isn’t just to reduce the risk associated with incidents, but to prevent them altogether.  

BNG resources

We have quite a number of resources which will help you to develop your incident management processes in line with best practice: 

  • Policy: Incident Management and Procedures 
  • Policy: Incident Management Procedures (Aged Care SIRS) 
  • Policy: Open Disclosure
  • Template: Incident Register 
  • Template: Incident Register (Aged Care SIRS) 
  • Template: Incident Report Template 
  • Template: Incident Report Template (Aged Care SIRS) 
  • Template: Incident Investigation Template 
  • Template: Incident Investigation Template (Aged Care SIRS) 

Additionally, organisations should follow the incident management guidelines of the relevant Commission. For aged care or disability providers, click the links below: 

Help with incident management

Looking to refine your incident management system? Log in to SPP to see pur resources in the Reading Room.