The EFA Enquirer: 19 January 2024

 

In this edition

  • Upcoming Training in 2024
  • NDIS Commission Emergency and Disaster Practice Alert
  • New Disability Services and Inclusion Act
  • Benefits of outsourcing internal audits
  • Benefits of undertaking compliance health check and/or preparatory audit

 


Upcoming Training in 2024

We have a range of training offerings for the new year that will provide NDIS providers with essential information to meet your NDIS requirements and assist you to provide quality supports to your NDIS participants.

Risk Management for NDIS Providers

This workshop will provide you with a working knowledge of Risk Assessment that allows you to develop and apply risk tools in your role as an NDIS provider.  As part of the workshop, you will be provided with a learner’s workbook and workshop scenarios to provide practical experience in implementing risk management strategies.

Workshop Details
Date: February 2nd, 2024
Time: 9:30am – 12:30pm AEDT

Register Here

Abuse and Violence: ‘It Starts With You’ Workshop

We are very excited to be offering our newest workshop Abuse and Violence: ‘It Starts With You’, an empowering session that will provide you with the essential information about violence, abuse, neglect, exploitation and discrimination of people with disability, and importantly how to prevent these from happening, a key priority of the NDIS Commission.

The workshop will cover:

  • The key recommendations of the recent Disability Royal Commission and the NDIS Review.
  • Relevant legislation at the Commonwealth and State levels, including NDIS requirements.
  • What is violence, abuse, neglect, exploitation and discrimination?
  • Best practice processes to have in place.

Workshop Details

Date: February 2nd, 2024
Time: 1:30pm – 4:30pm AEDT

Register Here

Introduction to Internal Audits

 This interactive 2 hour training will provide learners with the essential information about planning and conducting internal audits delivered by our Technical Manager, Patty Wassenaar who has decades of auditing experience. Remember – internal audits are mandatory for NDIS providers!

Workshop Details
Date: February 23rd, 2024
Time: 9:30am – 11:30am AEDT

Register Here

NDIS Business and Strategic Planning

 Delivered by our NDIS Business Planning expert Brendon Grail, this course will provide you with the practical and essential information and tools you need to develop and review NDIS business and strategic plans that work well for your business.

Workshop Details
Date: February 23rd, 2024
Time: 1:00pm– 4:00pm AEDT

Register Here

You have your NDIS policies and procedures, now what?

 This workshop will help new providers understand how to set up the correct systems and processes to implement their NDIS policies and procedures effectively.

Workshop Details
Date: Thursday 7th March 2024
Time: 10:00am– 12:00pm AEDT

Register Here

NDIS Restrictive practices – what should implementing providers know?

 This workshop will provide guidance on your obligations when you support NDIS participants subject to a Restrictive Practice.

Workshop Details
Date: Friday 15th March 2024
Time: 9:30am – 12:30pm AEDT

Register Here

Getting Ready for your NDIS Audit

 Our upcoming workshop “Getting ready for your NDIS audit?” is specially crafted to provide NDIS providers with the fundamental insights to confidently prepare for your next NDIS audit.

The workshop will be presented by Patty Wassenaar, our Technical Manager, who is one of Australia’s leading NDIS auditors.

Workshop Details
Date: Friday 22nd March 2024
Time: 9:30am – 11:30am AEDT

Register Here

Incident Response and Investigation for NDIS Providers

 This workshop will guide you through the requirements for NDIS Providers relevant to reportable incident response and management, and best practice in  incident investigations, including defensible documentation.

Workshop Details
Date: Friday 5th April 2024
Time: 10:00am – 12:00pm AEDT

Register Here


NDIS Commission Emergency and Disaster Practice Alert

All NDIS providers (registered or unregistered) must comply with the NDIS Code of Conduct, which includes putting plans in place for emergency and disaster situations to ensure continuity of supports to NDIS participants.

Registered providers also have additional obligations when meeting the NDIS practice standards in this area.  To assist all providers the NDIS Commission in November 2023 released an Emergency Management Provider Alert. This Alert provides information on how providers can properly prepare for emergencies and disasters and meet their compliance obligations.  The Alert covers:

  • Emergency preparedness information and resources for participants and providers including emergency management plans
  • Provider obligations related to emergency management
  • Links to state and territory government alerts and assistance.

If you require assistance ensuring you are meeting your emergency and disaster compliance requirements please call us on 1300 790 194 or email info@engelsfloyd.com for a complimentary consultation.


New Disability and Services Inclusion Act

The Disability Services and Inclusion Act 2023 (the DSI Act) commenced on 1 January 2024 and replaced the Disability Services Act 1986.

The new DSI Act allows the Commonwealth to fund disability supports and strengthens quality and safeguard arrangements for people with disability outside the National Disability Insurance Scheme. This Act does not apply to NDIS providers, but does apply to disability services such as advocacy and disability employment services.

There are significant changes in the new DSI Act that all disability services covered by the Act need to be aware of including:

  • expansion of eligible disability supports and services
  • a mandatory new code of conduct (based on the NDIS Code of Conduct)
  • reference to international obligations towards people with disability
  • the new requirement to have an appropriate complaints and incident management system. These requirements mirror those for NDIS providers.

Further information on the DSI Act can be found here.

We anticipate that some disability services may need support to meet these new requirements, and we are happy to provide guidance if required.


 Benefits of outsourcing internal audits

Internal audits are a mandatory requirement of the NDIS Practice Standards (and most other standards too). 

As well as being ‘mandatory’ Internal audits are an important part of managing risks for your organisation, identifying whether you are meeting requirements, following your own policies/procedures, meeting participant/client requirements appropriately and highlighting areas of risk and opportunities for improvement.

Managing your own internal audits can be challenging including:

  • Having the time to do internal audits
  • Having appropriately skilled and trained auditors
  • Internal auditors keeping up to date with changing legislation and requirements
  • Potential conflicts of interest
  • Internal auditing staff do not want to raise ‘issues’, particularly where audits cover areas of governance and management.

A number of organisations outsource their internal audits which enables them to be focused on provision of services and supports.  The benefits of outsourcing include:

  • Enabling trained and experienced auditors to review your systems (so you don’t have the cost of training internal personnel in auditing, standards and keeping up to date with requirements)
  • Engaging auditors who have an in-depth knowledge of Standards and requirements. They can review compliance as well as share best practices and can advise staff whilst auditing.
  • Completely independent of your organisation so can be objective in their role
  • When auditors audit ‘most of time as their profession’ they keep up to date with changes to Standards, legislation and are aware of the ‘gaps’ that often occur in systems.
  • Can help manage risks by identifying gaps, potential gaps, causes and areas for improvement – it is much better for internal audits to find gaps rather than during your formal audits, customer complaints or Commission enquiries.
  • Ultimately, there is a cost saving – from a time and staff training perspective.

Engels Floyd Quality Consultants have experienced and qualified auditors who can assist with managing and conducting your internal audits to assist in meeting your compliance obligations as well as manage organisational risks.   

We can conduct your audits in a way that is easy, efficient, cost effective and customised to meet your business needs.


 Benefits of undertaking compliance health check and/or preparatory audits

 As part of organisational Governance responsibilities, it is important that you’re aware of your current compliance status.

The NDIS Practice Standards include a range of Governance and Compliance responsibilities, and it is important that you have systems to keep up to date with changes, as well as ensuring you are meeting these requirements, not just for external audits but at an organisational level.

Key requirements include:

  • The NDIS Code of Conduct, which has recently been updated
  • NDIS Rules such as Worker Screening, Complaints, Incidents and Behaviour supports
  • Input from people with disability at a Governance Level
  • Ensuring a structure to meet financial, legislative, regulatory and contractual obligations
  • Ensuring skills and knowledge of the Governing body are identified, with training to address gaps
  • Governance responsibilities relating to areas such as risk management and emergency and disaster management.

A preparatory audit or training session with Executive Management and/or Board personnel can help to review your awareness of these obligations and identify potential gaps and organisational risks.

Preparatory audits can also help you meet your ‘internal audit’ requirements which also form part of the Standards.

Engels Floyd have experienced personnel with NDIS audit experience, who can assist you with assessing your compliance obligations as well as manage organisational risks.

Let us provide you with Governance Training or a Preparatory Audit to review your compliance requirements. We can do this at a fraction of the cost of an in-house resource. We will help you to embed and systematise quality and compliance, help manage risk, plus help you meet compliance requirements.

A testimonial from a valued client

“We engaged F & E for a preparatory audit, as it was felt based on previous engagements that their expertise and knowledge was exactly what we needed to prepare for our external recertification audit. The experience was in line with expectations and the reports were professional and insightful. Thank you again for your assistance”. Sue Horsnell HCO CEO

 


Passionate experts in quality improvement for disability & human services. Supporting all States and Territories.

The EFA Enquirer: 20 December 2023

 

In this edition

  • Christmas Greeting
  • NDIS Review
  • NDIS Code of Conduct Change
  • Key Points Arising from the Commission’s Latest NDIS Quarterly Report

Christmas Greeting

As the year draws to an end, we want to take a moment to express our deepest gratitude to all our clients. We extend our heartfelt thanks for your unwavering trust and support throughout the year.  We value the ongoing partnerships we have with our clients and your continued confidence in our services has been the cornerstone of our success.

We wish you and your families a very Merry Christmas and we look forward to continuing our journey together in the upcoming year.


NDIS Review

 The NDIS review much anticipated final report is now released.

The report makes 26 recommendations with 139 actions to improve the system that supports people with disability.

A key theme of the review is to ensure the NDIS is seen as one part of the whole system of foundational and mainstream supports for people with disability and not the major source of support.

A key recommendation that NDIS providers should be aware of is the changes to the NDIS registration and regulation process.  A graduated and risk proportionate based approach will take place where all providers including currently unregistered providers will be subject to some type of registration or enrolment.  This will range from:

  • advanced registration for high risk supports
  • general registration for medium risk supports
  • basic registration for low risk supports
  • enrolment for the lowest risk supports.

All NDIS providers will be subject to the Code of Conduct, Worker Screening and complaints process, with compliance obligations increasing with each level of registration.

If you would like to speak to us about how you can prepare for these changes,  please contact us on 1300 790 194 or info@engelsfloyd.com for a complimentary consultation.


NDIS Code of Conduct Change

 On 18 December 2023, the National Disability Insurance Scheme (Code of Conduct) Rules 2018 were amended to specify that NDIS providers, their workers and members of their key personnel must not charge a price for the supply of the same or substantially the same goods for NDIS participants which is higher than the price for those who are not NDIS participants without genuine, reasonable and objectively sufficient justification.

The changes also specify that members of the key personnel of NDIS providers must comply with the NDIS Code of Conduct and held to the same standard as NDIS providers and workers.

The NDIS Commission has provided some resources for NDIS Providers and participants to guide you in the area of price differentiation and the recent updates to the Code of Conduct here.


Key Points Arising from the Commission’s Latest NDIS Quarterly Report

The NDIS Commission has released its latest quarterly performance report for July to September 2023.

Key points of interest include:

  • A 25% increase in complaints over the previous quarter, with the highest category of complaints (33%) on provider practice.
  • 6% of complaints centered on alleged abuse and neglect.
  • A 27% increase in complaints closed by the NDIS Commission within 90 business days of receipt.
  • More than 71% of complaints were reported by a person with disability or their support person.
  • A 27% increase in individuals excluded from working with people with disability in a risk assessed role.
  • 1% of the total NDIS participant population were associated with regulated restrictive practice notifications, equating to 13,494 NDIS participants.

We are running an Abuse and Violence: ‘It Starts with You’ workshop that will provide you with the essential information about violence, abuse, neglect, exploitation and discrimination of people with disability, and importantly how to prevent these from happening, a key priority of the NDIS Commission.  Registration details are here.

If you are in need of support in the areas of complaints and incident management or compliance please contact us on 1300 790 194 or info@engelsfloyd.com for a complimentary consultation.


Passionate experts in quality improvement for disability & human services. Supporting all States and Territories.

The EFA Enquirer: 21 November 2023

 

In this edition

  • City of Charles Sturt NDIS Networking Event
  • NDIS Commission action to revoke NDIS registrations

City of Charles Sturt NDIS Networking Event

The EFA Enquirer: 21 November 2023 1 The EFA Enquirer: 21 November 2023 3 The EFA Enquirer: 21 November 2023 5 The EFA Enquirer: 21 November 2023 7 The EFA Enquirer: 21 November 2023 9  The EFA Enquirer: 21 November 2023 11 The EFA Enquirer: 21 November 2023 13

We were excited to be asked by the City of Charles Sturt to co-present at their recent NDIS Networking Event on the 16th November 2023 and talk about the upcoming NDIS reforms.  Our Director, Sharon Floyd spoke about the recommendations from the Disability Royal Commission which are likely to impact on provider compliance obligations. We were honoured to be presenting alongside some amazing NDIS experts – Dr Guy Turnbull (Managing Director, VIVA Mutual Foundation) and Brendon Grail (Director Grail Group Consulting and Engels Floyd Quality Consulting Associate) who brought a wealth of knowledge and experience to the discussion. 

The proactive engagement of enthusiastic NDIS providers reflects a collective readiness to navigate the potential changes arising from the NDIS reforms. Anticipating and preparing for these changes is crucial for organisations to stay ahead and ensure they can effectively adapt to any new regulations or standards that may emerge.

If you have not already, we urge all NDIS providers to start thinking and planning for the recommendations from the Disability Royal Commission and NDIS Review may impact your organisation.  

It is expected that that findings of the NDIS review will be released in December 2023. We will keep you posted on the key outcomes of the NDIS Review and how they will impact NDIS providers.


NDIS Commission action to revoke NDIS registrations

We understand the NDIS Commission is being proactive in chasing up NDIS providers who are not meeting their registration requirements, including those providers who are overdue in their NDIS audits. These providers have been sent letters revoking their NDIS registration status. Remember that you as a provider are responsible for monitoring your audit and registration dates – it isn’t the responsibility of your audit body, so please stay on top of this!

The NDIS Commission have the power to revoke the registration of a person as a registered NDIS provider under Section 73P of the NDIS Act 2013. 

Factors that the NDIS Commission will consider under section 73P(2) include:

  • the nature, significance and persistence of any contravention, or proposed contravention, of the NDIS Act
  • action that can be taken to address any contravention, or proposed contravention, of the NDIS Act
  • the extent (if any) to which the person is conducting its affairs as a registered NDIS provider in a way that may cause harm to, or jeopardise, public trust in the NDIS;
  • the health, safety or wellbeing of people with disability receiving supports or services from the person
  • any other matter the Commissioner considers relevant.

On receipt of the letter the NDIS Commission allows providers 28 days to make a submission on the matter before final revocation of your registration.

If you have any NDIS registration queries or you have received a letter like this and would like some advice, please let us know and we will arrange a complimentary consultation.  We can be contacted on 1300 790 194 or info@engelsfloyd.com.  We look forward to hearing from you.

 


Passionate experts in quality improvement for disability & human services. Supporting all States and Territories.

Request a free, no obligation 20 min consultation with one of our experts!