The Aged Care Quality Standards and the NDIS Practice Standards: common themes – and gaps

Residential aged care providers who support NDIS participants will be aware that as of December 1st 2020, they will become registered providers under the NDIS.  Importantly, providers do not need to do anything to facilitate this – registration will happen automatically.

Residential aged care providers have played an important role in supporting younger people with disabilities, and will continue to do so.  Becoming an NDIS provider brings new obligations, and providers should be aware of the specific goals and responsibilities outlined in the NDIS Quality and Safeguarding Framework, which comprises the NDIS Code of Conduct and NDIS Practice Standards. 

The NDIS Practice Standards compared with the Aged Care Quality Standards

Our SPP Platform cross-maps different sets of standards to each other.  This means that users of SPP can quickly identify thematic gaps between different standards.  And there is some good news – if a user satisfies 100% of SPP’s self-assessment for the Aged Care Quality Standards, they will automatically have completed just over 70% of our self-assessment for the NDIS Practice Standards (Core Module).  For the NDIS Code of Conduct, the crossover is even higher, with 90% completed!

So the reassuring news for RAC providers is that there is a high degree of commonality between the two sets of standards.  It is likely that if your quality management and compliance systems are keeping up with the obligations of ACQS, then you are already well on your way to accreditation against the NDIS Practice Standards.

Similarities between the standards

In our view, the main areas of similarity are in the themes of:

  • Individual Values and Beliefs
  • Privacy and Dignity
  • Violence, Abuse, Neglect, Exploitation and Discrimination
  • Information Management
  • Continuity of Supports
  • Access to Supports
  • Support Planning

For these key areas, pertaining to client rights and service access, it is likely that your organisation already has many policies and procedures in place that will align, in full or at least in part, with the requirements of the NDIS Practice Standards.

Gaps between the standards

However, there are also some clear gaps between the ACQS and NDIS Practice Standards, and these are areas that your organisation may need to focus on when preparing yourself for transition into the NDIS.  In SPP, users who satisfy all of our self-assessment for ACQS will still need to do further work regarding the following NDIS outcomes:

  • Transitions to or from the Provider
  • Safe Environment
  • Participant Money and Property
  • Management of Medication
  • Management of Waste

This is not to say that these themes do not feature in the ACQS, indeed many of you will already have policies on those matters in place within your residential aged care facilities.  However, the requirements in the NDIS Practice Standards are of sufficient specificity or detail as to delineate them from the requirements of the ACQS, and for this reason, RAC providers should pay particular attention to these areas of the NDIS Practice Standards, and the requirements outlined.

Gaps: complaints management and incident management

Another two areas which are distinct within the NDIS are complaints management and incident management.  This is because specific legislative instruments have been drafted to articulate the exact processes that must be followed for the management of both complaints and incidents by registered NDIS providers.

For incidents, the rules include the conditions under which an incident must be reported, and they also set out a comprehensive list of all of the elements that must be addressed in a provider’s incident management system procedures.  For complaints, the rules include requirements for an accessible complaints management system, and a similarly rigorous set of mandatory elements.

RAC providers should familiarise themselves with the rules.  Our SPP platform helps organisations in this, as we take users through each element of the NDIS complaints and incidents requirements, in our specific NDIS modules. 

Worker Orientation Module

Alongside compliance with the NDIS Practice Standards, there are some additional conditions of registration.  All members of your workforce who have more than incidental contact with NDIS participants are required to complete the Worker Orientation Module, ‘Quality Safety and You’.  This is a straightforward online module that can be completed in approximately 90 minutes, and is available on the NDIS Quality and Safeguards Commission website.

Worker screening

In February 2021, the NDIS Commission will launch a National Worker Screening check that will replace existing arrangements which differ across each state and territory.  It will set a single national standard for all workers supporting NDIS participants. Registered NDIS providers will need to make sure that workers have a valid and current clearance.

Until that time, workers who have more than incidental contact with NDIS participants will need to be screened according to State based legislation.  RAC providers should ensure they are familiar with State based requirements.

More information on worker screening is available here

Behaviour support/restrictive practices

Under the NDIS, behaviour support focuses on person-centred interventions to address the underlying causes of challenging behaviours, while safeguarding the dignity and rights of people with disability who require specialist behaviour support.  This is not dissimilar to the aim of minimising the use of restraint under the Aged Care Quality Standards.

Any behaviour support plan which contains a restrictive practice must be developed by an NDIS registered specialist behaviour support provider.  Specialist behaviour support providers must lodge behaviour support plans with the NDIS Commission and notify the Commission of the use of regulated restrictive practices.

Providers using restrictive practices as part of a behaviour support plan must report monthly.

The RAC is responsible for ensuring workers receive appropriate training and understand the risks associated with using a restrictive practice.

RAC providers should familiarise themselves with the National Disability Insurance Scheme (Restrictive Practices and Behaviour Support) Rules 2018, with which they will need to ensure they are compliant. 

Wrapping up

Ultimately, RAC providers supporting NDIS participants should not be too overwhelmed about these new compliance requirements.  The proposed regulatory approach will be proportionate, recognising the co-existing regulation that RAC providers will continue to be subject to under the Aged Care Act 1997, and as highlighted, much of your organisation’s quality and safeguarding work will carry across to the NDIS framework.  However, the NDIS Practice Standards are a distinct set of standards, and organisations should familiarise themselves with some of the new obligations imposed by the NDIS Quality & Safeguarding Framework.  Please access any of the resources listed below to help you in this process.

Additional resources

Need help understanding your obligations?

For assistance with compliance with the NDIS Practice Standards, contact our team.

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SPP has been a great resource for understanding and mapping Standards, preparing for Audits and also sourcing resources for policy development. I would recommend it to other organisations to complement their quality and compliance work. Information can be easily shared, and evidence gathered to support all work done.
Community mental health service provider, Victoria
I like the speed and ease of SPP, I love how it maps multiple standards. It’s so convenient, I couldn’t imagine the nightmare to do the work manually. The templates are great for gap analysis. SPP resource templates are great for implementing new policies in the office and for what we do day to day.
Large provider of settlement services to immigrants, New South Wales
I have found the SPP system amazing. It provides a structured way to work through the standards and then provide a succinct report on the evidence being provided for a surveyor to view how we meet the standard. I used this in our recent accreditation survey, the auditor was very impressed, AND we are now accredited for ISO 9001. Thanks again. A great system.
Provider of diverse range of health programs, Queensland
We really like SPP. We use the resources in the Reading Room and couldn't have passed our accreditation with flying colours without SPP.
Advocacy, support and education provider, Australian Capital Territory
Everything is going well with SPP. It’s helped us through three lots of accreditation over the past nine months plus some internal auditing, so I’m very glad to have had it to assist us through the processes.
Large regional multi-service provider, Victoria