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 manage 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.

Royal Commission Series: eliminating restraints

Welcome to the latest update in our series on the Final Report of the Royal Commission into Aged Care Quality and Safety.

Today’s focus is on the use of restraints, which the Royal Commission highlighted as an area of substandard care. The Royal Commission’s view is that providers should continually work towards the elimination of the use of restraints, and that compliance requirements should reinforce that view. The findings of the Royal Commission were clear:

 “The inappropriate use of unsafe and inhumane restrictive practices in residential aged care has continued, despite multiple reviews and reports highlighting the problem. It must stop now.”

The overuse of restrictive practices in aged care was found to be a major quality and safety issue. “Restrictive practices impact the liberty and dignity of people receiving aged care. Urgent reforms are necessary to protect older people from unnecessary, and potentially harmful, physical and chemical restraints.”

Restrictive practices can also fall under the category of abuse, when used improperly: “where [restrictive practices] occur without clear justification and clinical indication, we consider this to be abuse.”

Ultimately the misuse of restrictive practices is a human rights issue.

“Deficiencies in regulation of restrictive practices have been identified as a significant human rights issue in Australia. A strong and effective regulatory framework to control the use of restrictive practices should be implemented as a matter of priority. The Australian Law Reform Commission has recommended that there should be a nationally consistent approach to the regulation of restrictive practices.”

The Commission's recommendations

To address the above concerns, the Royal Commission made Recommendation 17: Regulation of restraints, which has now been accepted by the Australian Government in its response to the Final Report, which was published on 11 May 2021.

Recommendation 17 calls for the Quality of Care Principles 2014 (Cth) to be amended to ensure that restraints are prohibited unless:

  • the restraint has been approved by an independent expert assessment, or
  • the restraint is necessary in the case of an emergency to avert the risk of immediate physical harm.

If one of those conditions is met, the restraint should only be used:

  • as a last resort to prevent serious harm, after the provider has exhausted all other risk management alternatives;
  • to the extent necessary and in proportion to the risk of harm;
  • for the shortest time possible;
  • subject to monitoring and regular review (as stipulated in the behaviour support plan) by an approved health practitioner;
  • in accordance with relevant State and Territory laws;
  • with informed consent from the person receiving care or someone authorised by law to give consent on their behalf; and
  • in the case of chemical restraint, if prescribed by a doctor who has documented the purpose of the prescription.

Recommendation 17 also suggests that any use of restraints which is not prescribed by an assessment from an independent expert, should constitute a reportable incident under the updated Serious Incident Response Scheme.

Additionally, Recommendation 65: Restricted prescription of antipsychotics in residential aged care recommends that antipsychotic medication be prescribed only by a psychiatrist or a geriatrician, and that each prescription is reviewed at least annually.  The Government has accepted this recommendation in principle, and will refer the recommendation to the Pharmaceutical Benefits Advisory Committee, on whom it relies for advice in this area.

The above recommendations will make the compliance requirements of the use of restraints similar to those of the NDIS.

What should providers do now?

Providers should read Recommendations 17 and 65 in detail and review their current policies and procedures regarding their use of restraints with the recommendations in mind. Providers should ensure that each time restraint is considered, it is first:

  • Determined to be necessary to prevent immediate serious harm; or
  • Approved by an independent expert assessment.

If use of restraint is permitted due to one of the above circumstances, it must be:

  • Proportionate to the risk of harm;
  • Used after obtaining consent from the consumer and their representatives; and
  • Accurately documented.

Most importantly, providers should ensure that their processes continually aim to eliminate the need for the use of restraints.

Our resources

We have several resources to help providers stay ahead of the curve, including:

  • Policy: Eliminating Use of Restraints (Aged Care)
  • Template: Restraints Register (Aged Care)
  • Policy: Incident Management Procedures (Aged Care SIRS)

Our policy template for eliminating the use of restraints in aged care will help providers ensure that their assessment, worker training, and review processes are in line with best practice, and that they are working towards the elimination of all forms of restraint.

Royal Commission Series: Aboriginal and Torres Strait Islander aged care

Welcome to our third update on some of the recommendations contained in the Final Report of the Royal Commission into Aged Care Quality and Safety. Today’s update will highlight the Royal Commission’s specific concerns related to culturally safe aged care for Aboriginal and Torres Strait Islander people.

The Final Report’s Executive Summary states that Aboriginal and Torres Strait Islander people do not currently consistently receive culturally safe services, and this is an area that requires focus:

Aboriginal and Torres Strait Islander people who require aged care should be embraced by an aged care system that shows respect for their cultures and heritage.

The current aged care system does not ensure culturally safe care for Aboriginal and Torres Strait Islander people. Unless things change, it will be unable to meet the growth in demand that will accompany the increase in the eligible population.

Recommendations 47, 48, 49, 50 and 51 all focus on prioritising the delivery of culturally safe care to Aboriginal and Torres Strait Islander people who require aged care. Key themes include:

  • Maximising their ongoing connection to community and country, through the delivery of services at the regional and local level wherever possible, and by workers who are trained in culturally respectful, safe and trauma-informed care;
  • Seeking closer engagement and levels of trust between care providers and local Aboriginal and Torres Straits Islander communities;
  • Ensuring accessibility to needs-based, tailored and flexible aged care for Aboriginal and Torres Strait Islander people
  • Prioritising Aboriginal and Torres Strait Islander organisations as aged care providers; and
  • Increasing the training and employment of Aboriginal and Torres Strait Islander people in aged care services roles.

Maintaining connection with community and country was highlighted as an area of importance for Aboriginal and Torres Strait Islander aged care consumers. The final report recommended that consumers be supported to maintain their connections through travel, engagement with community and, where possible, receiving services on country.

Trauma-Informed Care for Aboriginal and Torres Strait Islander People

In addition to the MHCC’s Trauma-informed Care and Practice Organisational Toolkit (TICPOT) that we mentioned in our last post, they also offer a course developed and delivered by Aboriginal people for workers who support Aboriginal people impacted by trauma.

The Healing Foundation

Providers may also wish to consider some of the specialised resources on the Healing Foundation’s website. The Healing Foundation “is a national Aboriginal and Torres Strait Islander organisation that partners with communities to address the ongoing trauma caused by actions like the forced removal of children from their families.”

In particular, take a look at their fact sheet on providing effective aged care services to Stolen Generations survivors. It is an excellent resource to help providers and their staff understand the trauma and challenges lived by Aboriginal and Torres Strait Islander people, and how to provide them with care which is sensitive to their needs.

Along with the fact sheet, the Healing Foundation has also published a helpful two-page summary action plan to help providers ensure their services meet the needs of Aboriginal and Torres Strait Islander people.

Diversity Action Plan

To help you consider the issues raised in the Royal Commission’s recommendations, a great place to start is the Diversity Action Plan: Older Aboriginal and Torres Strait Islander People self-assessment in SPP. The self-assessment will help you to ensure your processes are aligned with best practice, and give you a means by which to benchmark your progress against three levels of actions: Foundational, Next Steps and Leading the Way.

For more background on the Department of Health’s Diversity Action Plans, take a look at our earlier post.

Inclusive Service Standards

As we noted in our last post, another helpful SPP self-assessment for aged care providers is for the Inclusive Service Standards. Developed by the Centre for Cultural Diversity in Ageing, the Inclusive Service Standards are a helpful resource for ensuring that your services are individualised, and that culturally safe service delivery is embedded in the governance of your organisation.

Royal Commission Series: culturally safe service delivery

Welcome to our second update on some of the recommendations contained in the Final Report  of the Royal Commission into Aged Care Quality and Safety.

Today we focus on the Royal Commission’s concern that there needs to be better cultural safety for every older person within the aged care system.  We’ve highlighted a couple of important themes in the following extracts from the Executive Summary of the Final Report:

“Across the aged care system, staff are often poorly trained in culturally safe practices, with little understanding of the additional needs of people from diverse backgrounds.

“To deliver high quality and safe care, those providing services must respect the diverse backgrounds and life experiences of every older person, and tailor the delivery of care to meet their needs. Diversity should be core business in aged care

“Cultural safety must be embedded throughout aged care—from initial contact with the system, during assessment, and when an older person receives aged care services at home, in their community or in a residential setting. The pressing need for trauma-informed care is also relevant to cultural safety.”

Diversity and Cultural Safety

To address the above concern, the Royal Commission made Recommendation 30: Designing for diversity, difference, complexity, individuality.  This recommendation includes a requirement that “as a condition of approval or continued approval of providers, training on cultural safety and trauma-informed service delivery be provided for all workers engaged by providers who are involved in direct contact with people seeking or receiving services in the aged care system.”

See also Recommendation 21: Priority issues for periodic review of the Aged Care Quality Standards, which includes a recommendation to consider, by 1 July 2022, making mandatory the Aged Care Diversity Framework and underlying Diversity Action Plans – as well as having them better reflected in a revision of the Standards.

Aged Care Diversity Framework

Launched in 2017, the Aged Care Diversity Framework and Diversity Action Plans are designed to guide providers through the challenges of providing aged care services to people of all backgrounds and life experiences. There are four Action Plans in total:

  • Diversity Action Plan: All Diverse Older People;
  • Diversity Action Plan: LGBTI Elders;
  • Diversity Action Plan: Older Aboriginal and Torres Strait Islander People; and
  • Diversity Action Plan: Older CALD people.

The Action Plans are based on a progression scoring model, requiring providers to reflect on the level of quality at which they deliver services to diverse older people.

To date, the Diversity Action Plans have not been broadly publicised or implemented in detail by providers.  However, about a year ago we added self-assessments in SPP for each of the four Diversity Action Plans, to help providers understand, implement and monitor the actions they can take to tailor a more inclusive service for all older persons.  These self-assessments can be found on the Standards tab in SPP, under Aged Care Diversity Framework.

Inclusive Service Standards

In addition to the Aged Care Diversity Framework, we added the Inclusive Service Standards to the platform in 2019.  Developed by the Centre for Cultural Diversity in Ageing, the Inclusive Service Standards were designed to “assist aged care providers in the development and delivery of inclusive services to all consumers”. The standards will help providers ensure that the services they deliver are culturally safe, and reflect the cultural needs of the target group. Click here to read more about the Inclusive Service Standards in SPP.

Trauma-Informed Care

The Final Report has emphasised the importance of trauma-informed service delivery across the aged care system.  The Mental Health Coordinating Council (MHCC) defines Trauma-informed Care and Practice (TICP) as “a strengths-based framework that emphasises physical and psychological safety, creating opportunities for people with lived experience to rebuild a sense of control and empowerment.

We plan to develop some additional resources to help providers align their processes with the recommendations of the Royal Commission. However in the meantime, you may wish to consider some of the excellent resources available on MHCC’s Online Learning hub, including several courses related to trauma-informed service delivery.

In addition, take a look at MHCC’s Trauma-informed Care and Practice Organisational Toolkit (TICPOT), which is a comprehensive roadmap, with resources and tools, to build and strengthen trauma-informed service delivery.

Culturally Safe Aged Care for Aboriginal and Torres Strait Islander people

The Royal Commission has also made a number of recommendations to address its particular concern that Aboriginal and Torres Strait Islander people do not currently receive services that are consistently culturally safe.

Our next post will consider these recommendations in detail, and highlight a number of resources and tools available to providers.

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You can access these resources and many more in the SPP platform. 

SIRS, the new aged care incident scheme

The Aged Care Quality and Safety Commission’s (the Commission) Serious Incident Response Scheme (SIRS) for government-funded Residential Aged Care Providers is set to commence in April 2021.  The new SIRS aims to further safeguard aged care consumers from abuse and neglect by empowering consumers, and by ensuring that providers follow the incident response procedures specified in the scheme.

The SIRS brings the requirements of incident reporting in aged care into alignment with those of the NDIS. For providers of both aged care and NDIS services, and providers familiar with the NDIS requirements, the new scheme will not present new compliance concepts.

The SIRS will fit in alongside several other residential aged care compliance requirements. Under the Charter of Aged Care Rights, consumers have a right to live without abuse and neglect. Likewise, under the Aged Care Quality Standards, providers are required to uphold this consumer right by identifying and responding to abuse and neglect. Additionally, the scheme will uphold the principles and requirements of open disclosure.

The SIRS is made up of two key components, being incident management obligations and compulsory reporting obligations.

The incident management component consists of identifying, responding to, managing, and recording incidents, as well as improving to prevent similar future occurrences.

The compulsory reporting obligations require providers to submit reports to the Commission within specific timeframes, depending on the severity of the incident.

Defining incidents under the SIRS

It will be essential for workers to understand which occurrences constitute an incident, as well as the category of the incident (ie “Priority 1” or “Priority 2”) and the appropriate procedures that must be followed when an incident occurs.

The Commission’s documentation includes detailed explanations of the various categories of incidents, which are certain “alleged, suspected or actual occurrences … where the person affected by the incident is a consumer in residential aged care”.

The types of incidents as defined by the SIRS are:

  • unreasonable use of force;
  • unlawful or inappropriate sexual contact;
  • psychological or emotional abuse;
  • unexpected death;
  • stealing or financial coercion by a staff member;
  • neglect;
  • inappropriate physical or chemical restraint; and
  • unexplained absence from care.

It is important to note that providers must assess the degree of impact on, or harm to, the consumer for each incident.  If there is a higher level of impact on or harm to the consumer, then the incident must be categorised as a Priority 1 incident.

Unexpected deaths and unexplained absences will always be categorised as Priority 1 incidents.

Supporting affected individuals

One of the requirements under the new scheme will be to support aged care consumers affected by an incident. The central component of this requirement is clear, ongoing communication between the provider and affected consumers, in line with the principles of open disclosure. Affected consumers may also require trauma or counselling services, and the provider is expected to help consumers access these services.

Incident reporting to the Commission

The SIRS outlines timeframes within which providers must report alleged, suspected or actual Priority 1 and Priority 2 incidents to the Commission.

Timeframe for reporting Priority 1 incidents

Priority 1 incidents have the highest priority, with the Commission requiring an initial report within 24 hours. Additionally, a follow-up incident status report is required within 5 business days of a Priority incident occurring.

Timeframe for reporting Priority 2 incidents

On the other hand, Priority 2 incidents must be reported to the Commission within 30 days.

In some cases, the Commission will require providers to submit a final report detailing the findings from incident investigations and, where relevant, how an incident was resolved. If required by the Commission, the final report will be due within 60 days of the incident occurring.

SIRS record keeping requirements

The SIRS will bring only minor changes to the current record-keeping requirements related to incidents. Providers will need to continue recording the details of each incident which occurs, regardless of whether the incident was determined to be trivial or have negligible impact. The SIRS adds another record keeping requirement: the category of incident will need to be recorded and, in the case of Priority 1 or 2 incidents, whether the incident has been reported to the Commission.

Quality and Safety

One of the central goals of the scheme is to “drive learning and improvement at a system and service level to reduce the number of preventable serious incidents in the future”.  The SIRS will encourage organisations to use the quantitative and qualitative data collected from their incident management recording processes to refine their procedures, minimise the likelihood of incidents re-occurring, and to improve the overall quality and safety of the care they deliver.

Further reading

We have several resources to help providers identify, assess, investigate, manage, record and resolve incidents in line with the new scheme. Our resources are intended to complement one another, and have been updated to take into account the requirements of the SIRS.

Our aged care incident management resource templates include:

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

To access these resources, and hundreds more, log in to SPP.

Help with aged care incidents

Need help with the new SIRS? Sign up for SPP!

The new NDIS worker screening check

With the new worker screening arrangements commencing next week, we thought it was an appropriate time to revisit a blog we posted in February 2020.

On February 1, 2021 the nationally consistent NDIS worker screening requirements will come into effect in all states and territories except the Northern Territory, ending the interim arrangements which have been in place since 2018.

The NDIS Worker Screening Check and the worker screening database

The rollout of the new worker screening approach follows the establishment of the NDIS Commission’s new worker screening database. The database allows workers to work in multiple states without obtaining separate clearances in each state, ultimately decreasing the red tape and compliance requirements for workers.

To support the roll out of the nationally consistent approach, the NDIS Commission has established a worker screening unit for each state. The worker screening units will be responsible for conducting NDIS Worker Screening Checks, and ensuring that the database is maintained.

What workers and providers will need to include in their applications

Under the new approach, to start the screening process each worker must apply to the relevant worker screening unit to be cleared.  Workers with existing clearances will have to do this when their current clearances need to be renewed, and of course any new workers will have to do so from next week.  After verifying the identity of the worker, the worker screening unit will conduct a risk assessment to determine whether the worker should receive clearance.

In applying for an NDIS Worker Screening Check, the worker will need to nominate an NDIS provider or self-managed participant with whom they are engaged, or are intending to be engaged. The provider or self-managed participant will then need to verify that the worker is engaged by them, or is intended to be engaged by them.

Rules which have not changed

Moving forward to the full rollout of the NDIS Worker Screening requirements, some requirements will remain the same as they were under the interim arrangements, including:

  • Risk assessed roles remain roles which include more than incidental contact with people with disability, and include key personnel such as CEOs and Board Members;
  • Record keeping requirements remain unchanged, with NDIS providers required maintain a list of the risk assessed roles in their organisation, along with the details of workers engaged in those roles; and
  • Rules for engaging workers before they have a check remain the same as they were under the transitional arrangements, and differ from state to state.

Self-managed participants or unregistered providers

If supports are being provided to a self-managed participant, or the provider is unregistered, worker screening checks are not mandatory. However self-managed participants and unregistered providers may request a worker obtain a clearance by undergoing an NDIS Worker Screening Check.

Residential Aged Care NDIS providers

The same worker screening rules will apply to aged care providers who provide NDIS supports. However the Commission has made it clear that aged care provider checks obtained before February 2021 will be viewed as valid for the full 3 year period of the check.

Queensland-specific worker screening rules

In Queensland, it is an offence for a registered NDIS provider to engage a person to work if they do not have clearance, or are subject to suspension interim bar or exclusion.

BNG Resources

To help your organisation ensure that its worker screening processes are aligned to the incoming requirements of the NDIS Commission, we have a number of resources including:

  • Policy template: Worker Screening (Disability);
  • Template: Risk Assessed Roles List;
  • Template: Risk Management Plan for Unscreened Workers;
  • Template: Worker Screening Register.

Want to know more?

For more information about worker screening and the NDIS generally, sign up for SPP!

Implementing the 5 principles of co-design

There is increasing focus on the important role that co-design and consumer engagement play in community service delivery.  All health and human services quality and safeguarding frameworks seek to ensure that every consumer receives person-centred care that is safe, effective, and individualised.  Co-design and consumer engagement incorporate the consumer’s lived experience and perspective, which should be central to the design, delivery and review of services.

However, co-design and consumer engagement can be hard concepts to nail down. They can sometimes be used a little too broadly, for example to describe situations where consumers have simply been asked for feedback, or to provide their opinions.  But there is more to co-design and consumer engagement than that.

Recently, the Aged Care Quality and Safety Commission released a very helpful literature review, which points providers to a number of resources to help them streamline their co-design processes.  Included in that review is a concise summary of what is involved in co-design and consumer engagement:

  • Co-design is involving consumers, their families, carers and staff in the design of care and services to ensure they achieve desired outcomes, and consumer experience is used to inform quality improvement.
  • Consumer engagement is about engaging consumers in discussions and decisions about day-to-day care, service planning and delivery, setting priorities, identifying improvements, and evaluating health care services.

There is considerable overlap between the two concepts, however there are also some subtle differences.  Organisations who already have effective consumer engagement processes are likely to have implemented many key aspects of co-design.

Another valuable resource for community service providers is the Client voice framework for community services, published late last year by the Victorian Department of Health and Human Services.  It is a great resource to assist services to consider how they “seek, listen and act on the client voice”.

Benefits and outcomes of implementing a co-design approach

Evidence from the health sector suggests that co-design improves the quality of services and the consumer’s experience of care.  Consumers receiving services which have been co-designed have seen improvements to their self-esteem, identity, and dignity. It also empowers consumers’ decision-making ability and increases the transparency between the provider and the consumer.

Staff also benefit from a co-design approach, with evidence suggesting an increase in staff satisfaction. Trust and confidence in staff increase when there is transparency and cooperation, leading to better outcomes for consumers and service providers.

Co-design principles

There are five principles which service providers should practice in the implementation of co-design processes.

  • Effective leadership and acceptance of change
    It is important for leaders and senior management to embrace consumer-centred care, and ensure that consumers are engaged from governance to service delivery.
  • Education and training for staff
    Staff must receive training to understand their role in partnering with consumers and positioning consumers as experts in their own care to improve consumer engagement.
  • Empowering staff to make change
    Staff at all levels should be involved in identifying actions and driving improvement.
  • Communication and information sharing
    Ongoing communication between all people involved in a consumer’s care will help to build rapport and trust, to encourage participation.
  • Monitoring and continuous improvement
    Performance measures should be established with outcomes measured and improvements identified and implemented.

Implementing co-design

Implementing co-design and consumer engagement comes with a unique set of challenges. Along with adherence to the above principles, there are some other techniques which may prove useful.

Formalise the process

To ensure effective co-design processes are in place, it is important to formalise the process. 

Begin at the top

Properly implemented co-design begins at the top. Involving consumers at a board level gives those who have received services the opportunity to have input into the policies and procedures which affect them. Co-designing board processes may mean inviting consumers to be board members or having them act as consultants to the management team.

Co-production working group

Providers may want to form a co-production working group. This working group, made up of consumers and stakeholders, can provide valuable review of programs which can improve service outcomes. They are also able to provide suggestions for new programs. Council on the Ageing (COTA), has a practical guide with more information on how to form a working group with consumers.

Positioning consumers as training advisors

Positioning consumers as training advisors is another strategy which has been used to great effect in implementing co-design. Consumers are a great source to help identify the gaps in staff training and knowledge, and should be consulted in the development of training programs. In the same vein, consumers should be consulted when the organisation is reviewing its service delivery processes, as they are able to identify gaps that may not be obvious to the service provider.

How BNG can help

We have a number of resources that service providers may find useful in implementing co-design. SPP has assessments on service design, individual service planning and responsive service delivery, amongst others.  We also have several templates that will help with implementation, including the following:

  • Client Decision Making and Choice
  • Client Involvement checklist
  • Supported Decision Making
  • Providing Client Advocacy and Support
  • Client Rights
  • Client Participation and Social Inclusion
  • Partnering with Consumers

Further Reading

Need help with co-design?

For everything your organisation needs to implement co-design, contact our team

NDIS Code of Conduct guidance for providers

The NDIS Code of Conduct, which has been in place since 2018, ensures that workers understand how they must act, and their responsibilities to provide high quality, safe services and supports to people with disability.

There are certain requirements placed on providers regarding worker compliance with the Code of Conduct.  Providers must implement systems to ensure that their staff are conducting themselves in line with the expectations of the NDIS Rules.

This blog post looks at the worker’s responsibilities from the provider’s perspective and examines how the provider can ensure that the conduct of their workers conforms with the values outlined by the NDIS Quality and Safeguards Commission. This is not intended to be an exhaustive resource; for further reading see the NDIS Commission’s Code of Conduct guidance for providers and workers.

Service delivery

Under the NDIS Code of Conduct, it is the responsibility of providers to ensure that workers delivering supports have the appropriate training, qualifications and competence to deliver supports.

In practice, these requirements mean:

  • Supporting workers to understand and implement the core values of the NDIS, including person centred support delivery;
  • Refining recruitment and selection processes to ensure that workers with appropriate skills and values are selected by the organisation to deliver services;
  • Providing workers with relevant training;
  • Providing workers with supervision to ensure that services are being delivered safely, with care and skill; and
  • Discussing with workers to ensure that they are competent and feel comfortable delivering the required supports and services.

In addition, as part of the recruitment and induction process, providers must ensure that:

Incidents & complaints

Registered NDIS Providers must have incident and complaints management systems in place.  It is the responsibility of the provider to ensure that staff are familiar with these systems.  This includes training to ensure that workers are able to identify, respond to, and report incidents and complaints to their supervisor and/or authorities where relevant.

Workers must understand that, in relation to incidents, their first priority is always the safety of people with disability.  Immediately following an incident, workers must ensure, to the best of their ability, that the person with disability is safe, following which they should then follow the provider’s processes for responding to and reporting incidents.

Workers should be familiar with the organisation’s complaints management systems, as well as how to make complaints directly to the NDIS Commission.  Workers are expected to support people to make complaints to the provider or the Commission, and so should be familiar with the appropriate processes for doing so.  Workers must not, under any circumstances, threaten or take adverse action against someone who proposes to make a complaint.

Staff responsibilities

Under the NDIS Code of Conduct, workers are expected to speak up to authority and call out any conduct that is not compliant with the Commission’s rules.  Staff are expected to inform senior staff if they are unable, or do not feel comfortable, to carry out particular tasks in connection with service provision (see p14, NDIS Code of Conduct – Guidance for Workers).

Staff should be aware that they are required under the Code of Conduct to declare any conflicts of interest related to their beliefs and values that may impact on the delivery of services or supports provision (see p19, NDIS Code of Conduct – Guidance for Workers).

All workers should understand that they are able to contact the Commission if they have any concerns regarding the conduct of their employer or others.  In some circumstances, which include the reporting of serious incidents, the Commission has legislative powers to protect those who raise concerns with the Commission.

Fostering a culture that encourages feedback and complaints

It is the responsibility of providers to ensure that they welcome and encourage feedback, and that their staff feel comfortable reporting any misconduct that they witness.  From the provider’s perspective, this involves encouraging and welcoming feedback and complaints.

The organisation should ensure that staff, as well as clients and advocates, will not face any adverse action for raising concerns regarding the conduct of the provider or its staff.  The workforce should be made aware that the provider will not undertake any action in retaliation for a worker raising, in good faith, their concerns about conduct.

How BNG can help

We have a number of resources and self-assessments to help providers ensure that they, and their workers, comply with the Code of Conduct.

  • SPP’s NDIS Code of Conduct self-assessment will walk providers through their obligations, as well as provide resources, policy templates and guidance
  • Worker recruitment, screening and training policy templates and guidance
  • Incident and complaints management system policies and guidance
  • Conflict of interest policy templates and guidance

NDIS Code of Conduct

Want to know more about how BNG can help with the NDIS Code of Conduct? Sign up today!