Lessons from the pandemic: how Standards have evolved

We’re now two years into the pandemic, and the care and support sector has had to make some major adjustments to their service delivery in response to the COVID-19 crisis.

A number of standards have been amended or updated with significant new changes, to provide guidance on improving and standardising infection control processes, as well as ensuring that there are processes to manage workforce capacity and disaster readiness.

We’ve updated our self-assessments in SPP to reflect these changes, and thought it would be helpful to summarise the core themes that have emerged across the different major standards.  

Core infection control and disaster response themes

The core themes that have appeared consistently in standards updates include:

  • ensuring the workforce has the capacity, skills, training and equipment to implement infection prevention and control systems,
  • planning for and sourcing an alternative workforce in the event of disruptions,
  • developing, testing and reviewing an emergency and disaster management plan,
  • reporting to the governing body on infection control processes and implementation/testing of the emergency and disaster management plan,
  • testing, fitting and training in the use of PPE,
  • training in hand hygiene, respiratory hygiene and cough etiquette,
  • implementing stringent processes for communicating relevant information to family, patients and carers,
  • undertaking routine environmental cleaning,
  • ensuring workplace policies and procedures are in line with the relevant state or territory public health requirements,
  • managing movement of staff between areas and supporting staff required to isolate, and
  • procedures for waste management including safe storage and disposal of clinical waste.

These are some key areas that service providers should be addressing to ensure they are on top of their compliance requirements. Providers should check that they are familiar with any updates to standards that apply to their organisation. SPP can assist you with this, as we always update the modules on our platform in response to changes to standards.

Here are the main standards that have been updated to incorporate infection control requirements so far:

The updated Standards

National Safety and Quality Health Service Standards (NSQHS)

Changes to the NSQHS were introduced in May 2021 and include requirements to:

  • plan for public health and pandemic risks,
  • ensure the workforce has the capacity, skills, training and equipment to implement infection prevention and control systems,
  • test, fit, train workers and use PPE, and
  • ensure policies and procedures are in line with the relevant state or territory public health requirements.

NDIS Practice Standards

In November 2021 the NDIS Commission released a number of changes to these standards, to address:

  • planning for alternative workforce arrangements in the event of disruptions,
  • developing, testing, and reviewing emergency and disaster management plans,
  • implementing infection prevention and control precautions throughout all settings,
  • ongoing training on and supplies of PPE for workers, and
  • waste management including safe disposal of clinical waste.

QIC Health and Community Service Standards

In February this year, an updated version of the QIC Standards was released, with updates addressing infection control requirements including:

  • staff training in hand hygiene,
  • infection prevention management program aligning with state and territory guidelines,
  • regular cleaning of the environment, and
  • waste management.

Australian Community Industry Standard

The Australian Community Industry Standard was also updated towards the end of last year to include the following infection prevention and control requirements:

  • workplace preparation for pandemic,
  • workforce response to pandemic consistent with advice from health authorities, and
  • implementing and documenting an outbreak management plan.

RACGP Standards for General Practitioners

The RACGP Standards have seen a number of updates throughout 2021 and more recently in 2022, with the most recent update being in February 2022. The updated requirements address:

  • increased requirements around telehealth consultations (e.g. ensuring privacy etc.),
  • managing the risk of cross infection during a home visit,
  • updated processes for isolating patients and traceability processes for identifying patients who have used instruments,
  • establishing protocols for managing outbreaks of infectious disease in line with local, state and national guidance, and
  • environmental cleaning.

Aged Care Quality Standards

While the Aged Care Quality Standards haven’t been updated with new infection control requirements, the Aged Care Quality and Safety Commission has released a number of resources to guide providers in their implementation of infection control requirements. 

Resources to help you

We’ve developed and updated a number of resources in our platform to assist providers to manage infection control requirements under the standards that apply to them, as well as implement best practice processes. Here are some examples of how we can help:

  • a module for the “First 24 hours – managing COVID-19 in a residential aged care facility”,
  • a module to guide organisations to implement COVID-safe operations based on recommendations from Safe Work Australia,
  • a module to guide organisations through the components they should address in developing infection control / respiratory outbreak plan based on recommendations from various sources including the Department of Health, the Aged Care Quality and Safety Commission, and the NDIS Quality and Safeguards Commission,
  • resource templates including:
    • an outbreak management plan checklist,
    • an information sheet for employers on staff vaccination against COVID-19,
    • first 24 hours – managing COVID-19 in a Residential Aged Care facility checklist,
    • an emergency and disaster management plan,
    • emergency and disaster management procedures,
    • working from home policy,
    • working from home agreement,
    • client risk assessment.

Want to take a closer look at our Covid-19 resources?

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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2021 – that’s a wrap!

It has certainly been a busy year for service providers and compliance professionals in our sector. Providers have been truly tested by the challenges of the pandemic and a changing regulatory landscape. We invite you to reflect with us on the key developments of this past year.

Child safety

In the child safety space, progress has been underway over the last couple of years to implement the recommendations of the Royal Commission into Institutional Responses to Child Sexual Abuse. We published a blog post on this topic in March of this year.

On 1 July 2021, the new Victorian Child Safe Standards were released, bringing these standards into alignment with the National Principles for Child Safe Organisations. Our mapped self-assessment for the Victorian Child Safe Standards is available on SPP.

NSW followed in a similar vein and in November 2021, legislation passed in NSW Parliament mandating compliance with the NSW Child Safe Standards by certain ‘child safe organisations’. The NSW Child Safe Standards, which also map to the National Principles, can be accessed in SPP.

At present, Australian Catholic Safeguarding Ltd is finalising the Second Edition of the National Catholic Safeguarding Standards, and we expect to be providing assessment modules of these standards early in the New Year.

Aged care

The Royal Commission into Aged Care Quality and Safety was the focal point for aged care this year, with some regulatory changes already implemented and others underway.

The Serious Incident Response Scheme (SIRS) brought in new compliance requirements for residential aged care providers in April. Our Incident Management Procedures (Aged Care SIRS) Policy can help get you up to speed on this. In correlation with SIRS, the Aged Care Quality Standards were updated to include a requirement on incident management, and our ACQS self-assessments have been updated accordingly.

Rules around use of restrictive practices changed, with shift in terminology from ‘restraints’ to ‘restrictive practices’, bringing aged care into alignment with disability regulation. Our updated Use of Restrictive Practices (Aged Care) Policy reflects this.

This year we released an educative version of the Aged Care Quality Standards on SPP, based on the Commission’s Guidance and Resources for Providers document, and which walks providers through their requirements in greater depth. We have also released the Board Governance Toolkit, a comprehensive suite of resources designed specifically to support board members to fulfil their responsibilities under the Aged Care Quality Standards.

Disability

In late 2021, the NDIS Practice Standards saw their biggest overhaul since their inception. The NDIS Quality and Safeguards Commission identified emergency and disaster management and mealtime management/swallowing problems as key focal areas for additional guidance and regulation, and brought in three new Practice Standards to reflect this. In addition, a number of Quality Indicators were added and amended, reflecting a focus on infection control, staff training, individualised risk assessments and insurance requirements. Our blog post will flesh this out for you.

All changes to the NDIS Practice Standards are available for completion in SPP, and you can choose from mapped or stand-alone modules, depending on your organisation’s needs.

Health care

The National Safety and Quality Healthcare Service Standards (Second edition) were updated in 2021, to include new requirements around infection control. We added two new modules to our NSQHS self-assessment on SPP to address the new Standard 3 – Preventing and Controlling Infections.

The Australian Commission on Safety and Quality in Health Care has also begun releasing a number of new standards, aiming to ensure a consistent approach to safe and high-quality health care across different service environments. In 2021, we added self-assessment modules for the National Safety and Quality Digital Mental Health Standards and the National Safety and Quality Primary and Community Healthcare Standards to SPP, and we will be closely tracking the development of the National Safety and Quality Mental Health Standards for Community Managed Organisations.

During 2021 we also released three new modules for the RACGP Standards for general practices (5th edition). We worked closely together with the RACGP to ensure that all of the standards, criteria and indicators in each module are reflected in detail in SPP’s self-assessments.

ISO

ISO standards are popular accreditations amongst our users, and this year we were pleased to add ISO 27001 Information Security Management Systems to SPP. ISO 27001 is an internationally recognised standard that requires organisations to implement an Information Security Management System (ISMS). The Australian federal government requires ISO 27001 certification for all providers of employment skills training and disability employment services, and a number of health and community service providers also choose to follow this standard.

All the best for the holiday period!

The past 12 months have definitely been jam-packed, and we expect 2022 will be just as busy.

We thank you all for your continued collaboration, and from everyone in the BNG team, we wish you a safe and happy holiday season.

See you next year!

Need to get on top of your compliance work?

Access a broad selection of Standards in SPP.

The new NDIS Practice Standards are here! What now?

We have been waiting on the release of an update to the NDIS Practice Standards for a little while now, and as of November 2021 the NDIS Commission has provided details of key amendments. Read on to get our rundown on all the changes.

What are the key changes?

The most significant change brought in by these amendments is the introduction of the following three new NDIS Practice Standards:

In Core Module Standard 2 (Governance and Operational Management):

  • Emergency and disaster management – This standard addresses the planning required by providers to prepare, prevent, manage and respond to emergency and disaster situations whilst mitigating risks to, and ensuring continuity of, supports that are critical to the health, safety and wellbeing of participants. Note that this practice standard specifically highlights the responsibilities of a provider’s governing body in this area.

In Core Module Standard 4 (Support Provision Environment):

  • Mealtime management – This practice standard applies to providers of supports to participants who require assistance to manage their mealtimes, including those with mild dysphagia. The standard deals with the nutritional value and texture of meals, and concerns the planning, preparation and delivery of meals. The standard aims to ensure quality and safety of mealtime management. 

In Module 1: High Intensity Daily Personal Activities

  • Severe dysphagia management – This practice standard applies to providers registered to provide high intensity daily personal activities and who have severe dysphagia management set out in their certificate of registration. Providers will be required to ensure that participants with severe dysphagia receive support that is relevant and appropriate to their specific needs and circumstances.

Quite a number of other new and amended Quality Indicators

There are also a number of new and amended Quality Indicators throughout the Practice Standards. Providers should familiarise themselves with all of these changes as soon as possible.

Many of the new or amended indicators relate to emergency and disaster management, including infection outbreaks, and the associated necessary worker training and capabilities.  However, there are also other amendments in areas such as:

  • the consideration of preventative health measures in planning supports, where relevant; and
  • more prescriptive requirements in relation to participant risk assessments, and their regular review.

The new and amended Quality Indicators appear in the following Practice Standards:

Core Module

Standard 2: 
  • Risk Management
  • Human Resource Management
  • Continuity of Supports
Standard 3: 
  • Support Planning
  • Service Agreements with Participants
  • Responsive Support Provision
  • Transitions to or from a provider (Previously Transitions to or from the provider)
Standard 4:
  • Safe Environment
  • Management of Waste

Module 3: Early Childhood Supports

  • The Child

Verification Module

  • Human Resource Management
  • Risk Management

When do the changes come into effect?

  • 15 November 2021: for registered NDIS providers, the new severe dysphagia management practice standard, together with all of the new and amended quality indicators we’ve mentioned above, are applicable from this date.
  • 13 December 2021: the mealtime management practice standard is subject to a transition period and comes into effect from this date. 
  • 24 January 2022: the emergency and disaster management practice standard is subject to a transition period and comes into effect from this date. 

Updated and new SPP self-assessments will be available shortly!

We’ve been working hard to update our SPP self-assessments for the NDIS Practice Standards as soon as possible, to help you get on top of the new requirements and streamline your compliance work.

We expect to be releasing updated self-assessments within the next couple of weeks.

We will also be making available a new “educative” self-assessment for the NDIS Practice Standards, as well as a new module to help board and governing body members better understand their responsibilities under the Practice Standards, and hopefully enhance their engagement with management.

So watch this space!

Further information

An updated version of the NDIS Practice Standards has been published here.

If you would also like to read the legislative amendments in full, you can access those here and here.

Want to manage NDIS compliance simply?

Access self-assessments for the NDIS Practice Standards on the NDS Quality Portal.

High Intensity Daily Activities

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

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

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

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

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

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

High intensity support:

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

Additional support activities:

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

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

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

Contact us

Want to know more? Talk to our team.

Conflict of interest and the NDIS

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

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

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

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

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

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

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

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

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

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

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

Want to find out more?

To access these resources and hundreds of others in SPP, click the button to the right!

Conducting client risk assessments

Taking a person-centred approach is a key theme of the NDIS Practice Standards, and undertaking an individual risk assessment for each participant is part of this process.

Under Division 3 of the NDIS Practice Standards, Provision of Supports,  providers are required to demonstrate the following:

“In collaboration with each participant, a risk assessment is completed and documented for each participant’s support plan, then appropriate strategies to treat known risks are planned and implemented.”

This assessment should take place at the Support Planning stage, where a client’s individual circumstances and needs are being considered.

We have developed two risk assessment templates to help you undertake this assessment. These templates are designed to be easily filled out, and consider risks to both clients and staff. The templates cover common risk areas including client history and circumstances, physical risks associated with assisting a client in their home and WHS concerns.

You can easily add additional rows and content to adapt the templates to the specific risks and service environments that are relevant to your organisation.

Find our templates in the Reading Room:

  • Template: Client risk assessment 
  • Template: Client risk assessment (home visits)

Restrictive practices

Restrictive practices are practices which involve the use of actions, methods and interventions that restrict the rights or freedom of a person with a disability. The main categories of restrictive practices are restraint (chemical, mechanical, physical or social) and seclusion.

There is a concern that restrictive practices are used as a ‘means of coercion, discipline, convenience, or retaliation by staff, family members or others providing support.’ If used in this manner, restrictive practices constitute a breach of a person’s human rights. Consequently, the use of restrictive practices in Australia has become a topic of concern, and recent focus among government bodies and policy makers has been on reforming policy and legislation in this area. The Australian Law Reform Commission has stated that the overall aim of reform is to reduce, and ultimately, eliminate the use of restrictive practices.

Each state and territory have their own rules regarding what restrictive practices can be used as part of a client’s treatment plan, however only five types of restrictive practices are permissible in Australia. To make it easier for NDIS providers to navigate these regulatory requirements, BNG have developed a suite of resources which are available in the SPP Reading Room:

  • Info Sheet: Eliminating Restrictive Practices
  • Policy: Eliminating Restrictive Practices (Disability)
  • Template: Restrictive practices reporting form
  • Template: Restrictive practices register