Do you know what the process is for renewing your NDIS registration?
As a registered NDIS Provider, you are required to renew your registration every 3 years. When your NDIS registration is due to expire, the NDIS Commission will send you a reminder email roughly 6 months before expiry with instructions on how to complete your renewal application in the portal.
To ensure that you remain a registered NDIS Provider you must apply to renew your registration and undertake another audit before the expiry date.
You will be required to complete a renewal application in the NDIS portal which is very similar to your initial registration application and includes providing organisation and registration group information. You will also need to provide a self-assessment against the NDIS Practice Standards relevant to the supports and services your organisation delivers and upload any documents required as evidence.
You can find further information on the renewal steps and preparing for your audit with great tips in our blog here.
Dual NDIS and Aged Care Registration Requirements for Residential Aged Care (RAC) Providers
NDIS participants living in Residential Aged Care are dual participants of the NDIS and aged care systems.
On 1 December 2020, Residential Aged Care providers delivering services to NDIS participants in their facilities automatically became registered NDIS providers. This ensured that all RAC providers were required to meet the requirements under the NDIS Code of Conduct and the NDIS Practice Standards.
As such, RAC providers have dual compliance requirements with the Aged Care Quality Commission and NDIS Commission. You can find further information about dual compliance requirements in our blog here.
What is in the 2023-24 Budget for the NDIS?
The Federal Budget for 2023-24 was handed down on 9 May 2023 with funding focused on getting the NDIS back on track to ensure it is sustainable in the future.
The measures outlined in the budget are targeted at improving the effectiveness and sustainability of the NDIS by improving the capability, capacity and systems to better support participants.
Key announcements include:
Capability: $429.5 million investment in the NDIA’s workforce capability and systems to ensure improved consistency and equity in decision-making for NDIS participants
Better planning: $73.4 million to better support participants to manage their plan within budget and holding plan managers, support coordinators and providers to account
Flexibility: $63.8 million to take a lifetime approach to ensure plans are more transparent and flexible
Supported independent living: $56.4 million to strengthen supported independent living decisions, by introducing a home and living panel to improve consistency across decisions and updating guidelines for planners to improve participants’ ability to live independently
Evidence-based supports: $29.3 million to improve oversight of services and increase take up of evidence-based supports
Blended payment trial: $24.6 million to trial blended payment models, to increase incentives for providers to innovate service delivery and improve outcomes
First Nations and remote communities: $7.6 million to pilot approaches to partner with communities to improve access to supports in remote and First Nations communities
Fraud: $48.3 million to crack down on fraud and non-compliant payments in the Scheme and to develop a business case for new IT platforms and systems to detect and prevent fraud and non-compliant payments.
Additional budget information can be found in The Hon Bill Shorten MP budget media release and the budget website here.
One of the key messages from the government is that there will be an increasing focus on ensuring providers are doing the right thing in regard to providing quality supports to their NDIS participants. Measures around: improving outcomes for supported independent living, eliminating unethical practices and introducing system reform to ensure the viability of the scheme will have a huge impact on the NDIS sector in the near future.
We would urge all providers to look at their quality management systems to ensure they are effective in supporting and safeguarding your participants.
If you require any assistance understanding your NDIS obligations or require documentation please contact us on 0478 616 207 or info@engelsfloyd.com for a complimentary consultation.
NDIS Provider Spotlight
The NDIS Commission is promoting on their website NDIS providers who exhibit good and innovative practices in their operations when delivering quality and safe supports and services to their participants. The initiative is called the Provider Spotlight.
The Provider Spotlight is not intended to be an endorsement of a provider’s overall activities, but instead focuses on a particular incident or activity which the Commission believes may be beneficial to share with other providers.
All NDIS providers are encouraged to share their approaches and innovations to support delivery and participant engagement by emailing communications@ndiscommission.gov.au.
In the spirit of continuous improvement, we encourage NDIS providers to have a look at what other providers are doing and reach out to the Commission if you feel like you are doing something well that other providers may benefit from.
NDIS Quality and Safeguards Commission letter to Specialist Disability Accommodation Providers
Inclusion Australia ‘Your service, Your rights’ Workshops
Upcoming Training
We are very excited to announce that we are running some brand new short course online training sessions via Zoom. Take a look below to see what we have on offer!
1. NDIS Plan Review 27 April 2023 – 10am – 12pm AEST Register here
2. Emergency and Disaster Management (Business Continuity) 28 April 2023 – 10am – 12pm AEST Register here
3. Introduction to NDIS Registration Requirements 11 May 2023 – 9:30am – 11:30am AEST Register here
4. Risk Management for NDIS Providers 11 May 2023 – 1:30pm – 4:30pm AEST Register here
5. Introduction to Psychosocial coaching in the NDIS 25 May 2023 – 10am – 1pm AEST Register here
NDIS Quarterly Report
The NDIS Quality and Safeguards Commission has published its Quarterly Activity Report, covering the period 1 October 2022 to 31 December 2022 for all states and territories in Australia. The report provides an overview of NDIS Commission activities, including complaints, registrations, reportable incidents, behaviour support and compliance. The NDIS Commission uses this information along with complaints and incident reports to target areas for compliance and education activities.
We encourage NDIS providers to read the report as it provides them with information about the NDIS market place plus, areas where the Commission will be focusing on in the future in terms of compliance actions. Key issues of note are in the areas of complaints, reportable incidents, unauthorised restrictive practices and compliance actions.
There were 2001 complaints in this period with the highest percentage of complaints in provider practice (43%), followed by alleged abuse and neglect (25%) and worker conduct (23%). This highlights that there is a need for providers to better understand the requirements and responsibilities under the NDIS practice standards by having NDIS policies and procedures in place that are being properly implemented and communicated to their staff through quality training.
There was an overall increase of 7% (5296) in the number of reportable incidents with the highest category in abuse or neglect followed by serious injury. Of those reported 908 were reported to the police. There was also a 12% increase in the use of unauthorised restrictive practices which remains a concern and highlights the need for greater training of staff in this area and the promotion of positive behaviour support strategies to reduce the use of restrictive practices.
The Commission has taken over 7587 compliance actions against providers in the last 6 months including education initiatives (4865), registration refusals (269) and banning orders (42).
The NDIS Commission has been clear that it will continue to focus on ensuring NDIS providers understand their responsibilities and implement the NDIS Practice Standards, NDIS Code of Conduct and other quality and safeguards requirements to ensure the safety and wellbeing of people with disability. They will also take action in cases where there has been a risk to the safety of NDIS participants.
If you are unsure if your documentation or training adequately cover offs on these requirements, we are here to help, contact us on 0478 616 207 or info@engelsfloyd.com for a complimentary consultation to chat about your compliance obligations.
NDIS Quality and Safeguards Commission letter to Specialist Disability Accommodation Provider
On 10 February 2023, Tracey Mackey the NDIS Commissioner wrote to all registered Specialist Disability Accommodation (SDA) providers reminding them of their obligations under NDIS legislation including the NDIS Code of Conduct and NDIS practice standards specific to the provision of SDA.
SDA is a range of housing designed for people with very high support needs with accessible features to help residents live more independently and allow other supports to be delivered in a safe way.
The Commissioner emphasised that the nature of the delivery of SDA supports raises the risks associated with the independence and control of NDIS participants choice of NDIS supports. They have received reports of concerning practices in the sector that is limiting the choice and control of NDIS participants including:
conflict of interest concerns where SDA providers are entering into commercial arrangements to provide other NDIS supports exclusively in their dwellings or specifying who may provide other NDIS supports and services within an SDA dwelling
charging fees to NDIS participants and/or other NDIS providers to deliver supports and services within an SDA dwelling in the absence of transparent service agreements.
The NDIS Commissioner stressed that these practices are inconsistent with NDIS provider obligations that require ‘each participant’s right to exercise choice and control over other NDIS support provision is not limited by the participant’s choice of specialist disability accommodation dwelling’.
It is critical to the rights and interests of participants residing in SDA that:
service agreements transparently outline all terms and conditions that apply to their SDA dwelling and any associated service or tenancy agreements
the provision of accommodation and other NDIS supports is not impacted by the NDIS participants choice of who provides their other NDIS supports.
The NDIS Commission is of the view that SDA providers have had sufficient time to understand their obligations as SDA providers and will initiate compliance activities by issuing requests for information to SDA providers, using the NDIS Commissioner’s powers under section 73F(2)(i) of the NDIS Act to obtain information.
This information will be used to ascertain the compliance of SDA providers and help the NDIS Commission develop and target further education and compliance actions where obligations are not being met.
We urge SDA providers to review their documentation and systems to ensure you are meeting your obligations under the NDIS legislation and practice standards to promote your NDIS participants’ independence, choice and control about the supports they engage under their NDIS plan.
If you require any assistance understanding your NDIS obligations or require documentation please contact us on 0478 616 207 or info@engelsfloyd.com for a complimentary consultation.
Inclusion Australia ‘Your service, Your rights’ Workshops
Inclusion Australia are working with the NDIS Quality and Safeguards Commission to deliver new Your Service, Your Rights workshops for people with an intellectual disability and their supporters to understand their rights when they receive services through the NDIS. The workshops will cover the following topics:
Rights and Services
NDIS Commission – Code of Conduct and complaints process
Importance of speaking up and supports to do so
How to be involved in making supports safe
Workshops will be running across Australia until June 2023 both in person and online.
We recommend all NDIS providers promote this workshop to your NDIS participants. You can find out when they are running in your state and territory by contacting Inclusion Australia.
New NDIS Practice Alert on High Risk Restrictive Practices
NDIS Consumer Rights
NDIS Participant Fact Sheets about behaviour support
Own Motion Inquiry into Platform Providers Operating in the NDIS Market
Upcoming Training
We are very excited to announce that we are running some brand new short course online training sessions via Zoom. Take a look below to see what we have on offer!
1. Introduction Internal Audit Training 24 March 2023 – 10:30am – 1:30pm AEST Register here
2. NDIS Plan Review 27 April 2023 – 10am – 12pm AEST Register here
3. Emergency and Disaster Management (Business Continuity) 28 April 2023 – 10am – 12pm AEST Register here
New NDIS Practice Alert on High Risk Restrictive Practices
Did you know the NDIS Commission released a new Practice Alert on High Risk Restrictive Practices?
In January 2023, the NDIS Commission released a new Practice Alert on high risk restrictive practices.
High-risk restrictive practices place participants at high risk of harm and are associated with adverse and catastrophic outcomes for participants such as long-term psychological or physical injury and death.
The NDIS Commissioner remains concerned about the use of high risk restrictive practices in the sector.
We recommend NDIS providers read the Practice Alert and review their current practices to ensure that no high risk restrictive practices are in use. You can read more about this new practice alert in our blog here.
NDIS Consumer Rights
As an NDIS provider do your know your clients have consumer rights for the supports they purchase under Australian Consumer Law?
Just like regular businesses providing goods and services to consumers, businesses who provide goods and services to consumers with a disability have obligations under the Competition and Consumer Act 2010 (CCA), referred to as Australian Consumer Law and the NDIS Code of Conduct.
The consumer law provides a set of protections and obligations for any consumer transaction within Australia, including those through the NDIS. Breaches of NDIS participants consumer rights are a key concern of relevant government agencies.
The ACCC have released resources to assist NDIS participants and providers understand consumer rights when selling and buying goods and services. You can read more about these consumer rights at our blog here.
NDIS Participant Fact Sheets about behaviour support
The NDIS Commission have released five Fact Sheets about behaviour support targeted at NDIS Participants. The fact sheets were created out of consultations with NDIS participants, peak and practitioner bodies to ensure they and their families have the right information about behaviour support delivered in an accessible manner.
We encourage NDIS providers to share these resources with their clients.
If you have any questions regarding your obligations in relation to behaviour support and restrictive practices please contact us on 0478 616 207 or info@engelsfloyd.com for a complimentary consultation.
Own Motion Inquiry into Platform Providers Operating in the NDIS Market
NDIS Platform providers are online platforms and online subscription services that connect workers with NDIS participants. There are registered and unregistered Platforms Providers with variations in how quality and safeguards and uncertainty about who is responsible for ensuring services are delivered safely and of a high quality.
The number of Platform Providers now represent a significant and growing proportion of the NDIS market.
The Inquiry will hear from people with disability accessing NDIS services and supports through Platform Providers, and Platform Providers themselves.
The issues that will be looked at in the Inquiry include:
Participants access, experience and engagement
Supports and services accessed and delivered
Quality and safeguarding arrangements aligned with the NDIS Code of Conduct spanning quality improvement and assurance
Trends, patterns and insights from data and feedback
Relationship between Platform Providers, workers and participants
Differing business models, assurance and governance structures
The Commissioner intends to share key learnings and helpful resources with the goal to promote participant rights to safe and quality NDIS supports.
Consultations are open until 28 April 2023 and NDIS providers and participants can make a submission by:
NDIS Workforce Capability Position Description Tool
The Importance of Emergency and Disaster Planning
How well are you prepared for your mid-term audit?
Upcoming Training
NDIS Business and Strategic Planning
This is a brand new training session on offer!
This workshop is delivered by a NDIS Business Planning expert. This course will provide you with the practical and essential information and tools you need to develop or review your NDIS business and strategic plans. Business and Strategic planning are mandatory NDIS requirements, but moreover essential for successful, sustainable and viable businesses.
Date and time: Friday, 24 February 2023, 10:30 am – 1:30 pm AEDT
Original price: $330 Now $297 Simply enter promo code ‘SAVE10’ upon checkout to receive a 10% discount
Welcome Patty to the EFA team
We would like to warmly welcome Patty Wassenaar to the EFA team. Although Patty has worked as an associate for EFA she has now joined our EFA team on a permanent basis two days a week.
Patty has an extensive background in Quality Management Systems that are coupled with over 20 years lead auditor experience in the Disability and Human Services Sector as well as training and mentoring staff. She has an encyclopedic knowledge of Certification Accreditation Requirements for both JAS-ANZ and related Government Department schemes.
We are privileged and excited to have someone of Patty’s caliber working for us.
NDIS Workforce Capability Position Description Tool
Having the right position descriptions are vital to attracting the right people to your organisation with the skills and knowledge that are suited to the role and your NDIS business.
The NDIS Commission have developed a NDIS Workforce Capability Framework that describes core worker capabilities that can give your workers and potential workers a clearer understanding about both the type of work they will be doing and how it should be done. You can read more about the Framework here Guidance document for providers about impact of Workforce Capability Framework – Engels Floyd.
These core capabilities can be used as the foundation for building and reviewing current position descriptions for different participant needs and delivery environments.
To assist you in this, the NDIS Commission have released a Position Description Tool to support NDIS providers to develop position descriptions based on the capabilities in the Framework. You can read more about this tool in our blog here.
The Importance of Emergency and Disaster Planning
How well is your business prepared for handling emergencies and disasters that may impact how you provide ongoing services to your NDIS participants?
The last few years have taught us how important it is for NDIS providers to have robust emergency and disaster management plans in place to ensure the continuity of supports critical to the safety, health and wellbeing of participants.
Do you also have a good understanding of how emergency and disaster processes should be reflected in each participant’s service agreement and support plan?
Have your clients been consulted and included in plans to manage disaster risk to ensure their critical supports are person centred and tailored to their situation?
Have your considered how you will monitor the safety and wellbeing of your clients if they could not receive services temporarily?
It is a requirement of NDIS registration that NDIS providers demonstrate that they meet the requirements of the new NDIS practice standard ‘Emergency and Disaster Management’. This will be assessed at every audit.
If you are unsure if your policies and procedures cover off on these requirements, we are here to help, contact us on 0478 616 207 or info@engelsfloyd.com for a complimentary consultation.
How well are you prepared for your mid-term audit?
Under the NDIS Quality and Safeguarding Framework, all registered NDIS providers whose last audit was a certification or recertification are required to complete a mid-term audit as a condition of maintaining your registration as an NDIS provider.
The mid-term audit is an onsite assessment of how well you are continuing to meet the requirements of the NDIS Practice Standards. This usually includes a documentation review and interviews with participants and staff.
You can read more about how to prepare for your mid-term audit and what might happen if you fail to undertake a mid-term audit by the due date here.
Important Information for Supported Independent Living Providers – NDIS Commission’s First ‘Own Motion’ Inquiry into Supported Accommodation
Upcoming Training
Happy New Year!
Welcome to 2023! All of us at EFA wish you, your families, your colleagues, and all NDIS participants a Happy and Safe New Year. We look forward to supporting you in the new year to provide safe and quality supports for NDIS participants. If you require any assistance, please contact us on 0478 616 207 or info@engelsfloyd.com for a complimentary consultation.
Important Information for Supported Independent Living Providers NDIS Commission’s First ‘Own Motion’ Inquiry into Supported Accommodation
The NDIS Quality and Safeguards Commission has recently released the findings of its first ‘own motion’ Inquiry looking at the experiences of NDIS participants living in supported accommodation.
For supported independent living (SIL) NDIS providers, it is important to consider these findings, and the actions that will now be taking place to improve long term outcomes. Read here for more information.
There will be an increased and strengthened focus on compliance, particularly around new SIL specific regulatory requirements, tenancy management, feedback and complaints, incident management, reportable incidents, training and restrictive practices.
A robust quality framework will be essential to fulfil these new requirements.
If you would like to discuss how you are meeting your requirements under the NDIS Practice Standards, and how you can prepare for these new compliance requirements please contact us on 0478 616 207 or info@engelsfloyd.com for a complimentary consultation.
Upcoming Training
We are excited about our suite of training for 2023. Some ‘old favourites’ plus some new training – all designed to set you and your business well for the next year.
1. NEW! Business and Strategic Planning – Introductory discounted rate.This workshop is delivered by a NDIS Business Planning expert, 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. Business and Strategic planning are mandatory NDIS requirements, but moreover essential for successful, sustainable and viable businesses.Date and time: Friday 24 February 2023, 10:30 am – 1:30 pm AEDT
2. NDIS Restrictive Practices & Behaviour Support for Implementing Providers – Discounted rate available!This workshop focuses on compliance requirements and obligations of providers implementing behaviour support plans associated with the NDIS Practice Standards and associated NDIS (Behaviour Support and Restrictive Practice) Rules. Date and time: Thursday, 16 February 2023, 10:30 am – 1:30 pm AEDT
Key Points Arising from the Commission’s Latest Quarterly Activity Report
NSW Disability Inclusion Consultations
Free Online Resources: Mealtime Management
Find a Translation
A Principled Approach to Working with First Nations Peoples
EFA at The Geelong Business Excellence Awards
The entire EFA team (unfortunately minus our beautiful Rachael) met up together recently for the first time in years at the Geelong Business Excellence Awards. As you may be aware the EFA team are spread across several interstate locations so this is a rare treat.
Engels Floyd and Associates were finalists in The Geelong Business Excellence Awards 2022. This year was the first event held face-to-face in three years and the biggest with over 800 people in attendance. The program celebrated the clever, creative and connected local business community across twenty award categories. EFA is proud to have been runner up in three categories.
EFA would like to congratulate the winners and other finalists of the 2022 Geelong Business Excellence Awards.
NDIS Residential Aged Care Toolkit
EFA together with our partner organisation ARTD Consulting have recently been working on an important project for the NDIS Commission, developing easy tofollow resourcesfor Residential Aged Care providers (RAC) who are undergoing NDIS registration.
With pleasure, we advise that you can now access a number of fact sheets, tools, resources and webinars to not only support RAC providers but also NDIS participants, during the audit and registration activities.
You might recognise our EFA Directors, Jen Engels and Sharon Floyd in the webinars! Here’s the link formore info.
Key Points Arising from the Commission's Latest Quarterly Activity Report
The total number of registered providers plateaued to 19,536 in this quarter. The Commission advises that ‘the stabilisation of this figure is largely driven by targeted compliance activity leading to refusal of applications of transitional providers’.
There was a 9% increase in complaints, notably in NSW.
Also a 9% increase in reportable incidents (excluding unauthorised restrictive practices).
A massive 29% increase in the number of NDIS behaviour support practitioners considered suitable to deliver behaviour support services.
These and some other key mentions in the report highlight the need for a focus on effective quality management, training and compliance and ongoing reviews through internal auditing. EFA is here to support you and your service in navigating that terrain.
One of our partners, ARTD is currently holding community consultations on behalf of Transport for NSW to inform their Disability Inclusion Action Plan.
Your feedback matters and will help Transport for NSW (TfNSW) identify priority actions that they will take over the next five years towards its vision for a transport system that provides equal access for everyone regardless of their age, where they live, ability, socio-economic or personal circumstances.
ARTD is an independent research company. With the results of this research TfNSW will hear the valuable input of more people with disability, families and carers, service providers, representative disability organisations and other community members.
Attend a forumduring November 2022. (Both online and face-to-face. The face-to-face consultations will take place in Grafton, Parramatta, Sydney CBD and Wagga Wagga.)
Free Online Resources: Mealtime Management
Food and meals are such a pleasure for most people. Having access to delicious meals that are also safe and enjoyable is something that every person chooses. When assisting someone with a swallowing difficulty this can be much more complicated.
Supporting Safe and Enjoyable Meals is a new NDIS Practice Standard. The associated free resources are of benefit to all providers involved in mealtime management.
There are several resources that you may find beneficial including an e-learning module, various practice alerts, and a suite of resources and training modules developed by the Disability Research Network at the University of Technology in Sydney.
Find a Translation is a free multilingual search engine website for various translation resources. The purpose of this initiative is to ensure it is easy to find free trusted content in many different languages. Find a Translation does not create the information you find on the website, but rather it enables you to search and find links for information in your preferred language.
Find a Translation can also be used to locate translated information from Government Departments such as VicRoads and the Department of Social Services.
A Principled Approach to Working with First Nations Peoples
In collaboration with Aboriginal and Torres Strait Islander Australians, Social Ventures Australia have developed a set of ‘First Nations Practice Principles’.
This framework is designed to be a guide for non-Indigenous organisations to build effective partnerships and working relationships with Aboriginal and Torres Strait Island Australian organisations.
The five Principles for inspiring better practice are:
Self-determination: recognising and supporting First Nations peoples right to exercise control over their own lives.
Recognising diversity: acknowledging unique cultures and histories and the need for First Nations people to be involved.
Respectful relationships: meaningfully engaging with First Nations peoples to ensure their priorities, values, perspectives and voices inform the work.
Real partnership: seeking reciprocal benefit, value and learning for First Nations peoples and being accountable for the impact that our work has on First Nations peoples.
Trauma aware: embedding cultural safety by providing positive and emotionally safe experiences, and implementing culturally-specific practices.
We encourage you to consider these principles in your service provision as part of your commitment to diversity and inclusion.
Internal Audits are a mandatory requirement for NDIS providers under the NDIS Practice Standards.
This internal audit training on 11 November 2022 will give you a sound basis and the tools to move forward with your own audits. EFA are auditing and quality specialists. Tickets are $495 each. Book here!
NEW NDIS Practice Alerts
The NDIS Commission has released new Practice Alerts in a range of areas some of which are vitally important such as preventing respiratory infections, polypharmacy, respiratory depression, cardiovascular disease, and epilepsy. Other alerts including transitions of care between disability services and hospital, medicines associated with swallowing problems, and lifestyle risk factors help providers offer best practice support for people with disability.
The new Practice Alerts were developed in response to the Scoping review of causes and contributors to deaths of people with disability in Australia.
These engaging resources include short animations, quick reference guides and easy read versions which provide important information on safe and quality service delivery to people with disability.
Why become Registered Provider
Although it takes a bit of organisation and effort, the benefits of becoming a Registered Provider are many. Here’s a few of the reasons why it’s worthwhile considering registration:
You can work directly with NDIA-managed participants as they are required to only use registered providers.
There is a publicly available list that participants can access, which only includes registered providers.
Certain supports can only delivered by registered providers.
Payments can be sped up as they are handled directly through the NDIS portal.
Research indicates participants are more trusting of registered NDIS providers rather than unregistered providers.
Potential participants know that the provider has been assessed as meeting particular quality and compliance requirements.
Marketing and promotion as a registered provider in your local area/s allowing for greater exposure and a higher uptake of your business.
You can work side by side with an experienced, approachable, and personable team of partners here at EFA who can assist you in the registration process and to raise the potential of your business significantly.
EFA can help you grow your business by becoming a registered provider which offers your business the greatest potential. Contact us today!
NDIS Participants in Hospital, Discharge to Home, Not Housing Webinar
If you are interested in finding out more about this topic there is an online webinar on the subject of ‘NDIS participants in hospital – discharge to home not housing’ which will be held at 1 pm (EST) on Monday 24th October by one of our partners, Brendon Grail. And it’sfree!
Whilst the session is particularly targeted at Government decision makers (people such as discharge coordinators, hospital/health/housing executives, NDIS planners, LACs and complex needs specialists), it is also relevant for NDIS Support Coordinators, allied health practitioners, NDIS providers and families. If you are interested in how to use Supported Independent Living (SIL) and/or Independent Living Options (ILO) funding in less restrictive ways it could be worthwhile joining.
If you’d like to find out more and book you only need complete a registration form.
What does good support look like
Have you heard of Dr George Taleporos yet?
The NDIS Commission has partnered with disability advocate Dr George Taleporos to deliver new episodes of his ‘Reasonable and Necessary’ podcast on You Tube. A recent episode, ‘What does good support look like?’ has many meaningful messages for service providers.
In this episode Dr George and his two guests discuss how being an NDIS participant as well as being a service provider enables a deeper insight into what good service is and how to keep in individualised. Did you know that EFA has several NDIS participants amongst its team including one of the Directors? That additional perspective really does impact on the uniqueness and quality of the service ultimately.
With an updated vision, focuses, and measures of success it aims to be more responsive to the needs of NDIS participants.
Building trust with participants is a big focus of this strategic plan.
If you are seeking help in becoming more aligned with the NDIS strategic plan in your business and in ensuring there is a high degree of trust in your service EFA can assist you.
The NDIS Commission has just uploaded its Activity Report for the January to March 2022 quarter.
EFA has some insights which we would like to share with you.
Complaints (page 9)
A total of 1,897 complaints were received by the Commission during the reporting period. The majority of complaints received were from people with disability themselves, most of which related to provider practice and worker conduct or capability.
EFA insights:
An effective complaints management system that can be easily followed is imperative. Such a system needs a process to systematically and continually seek participant feedback. Although optimally we would desire to have no complaints, in a dynamic, ever evolving human services organisation the lack of complaints is not necessarily a good thing. In fact, it could mean there is something wrong with the process and there’s a lack of trust and open communication.
If you feel it would be beneficial for yourself or some of your staff to explore the effectiveness of your complaints management system further, EFA is holding a workshop on August 19th on NDIS Feedback and Complaints Management Essentials.
Registered Providers (page 12)
There are now a whopping 19,015 registered providers nationally in Australia. This is almost a 4% increase from the previous quarter. The majority of which are classified as organisations (11,727) i.e. companies, Trusts, etc. The remaining 7,288 are individuals.
EFA insights:
This is an interesting side step as data in the NDIS quarterly reports has indicated previously there was more of a 50:50 split between organisations and individuals. What is encouraging is the overall growth in the number of registered providers since the previous quarter. The significant number of providers who did not seek to maintain their registration in that quarter (totalling 242) may highlight the importance and benefit of providers having effective strategic, business and marketing plans to promote sustainability and viability. Partnering with good reputable NDIS mentors can make a big difference to staying afloat and thriving.
Audit Activity (page 13)
Unsurprisingly, of certification audit activities the ‘Core Module’ is the highest percentage of modules completed. Of the supplementary ‘high risk’ modules, Module 2a; Implementing Behaviour Support Plans has the highest rate of completion.
Unauthorised Restrictive Practices (page 15)
There was a slight downward trend in the number of unauthorised uses of restrictive practices. (In the last quarter 329,328.) Of those, the majority of regulated restrictive practices used were chemical restraints.
EFA insights:
Providers implementing behaviour support plans must meet not only Module 2a requirements, as well as associated NDIS (Restrictive Practice and Behaviour Support) Rules 2018. These are complex requirements and providers must ensure their workers are appropriately supported and trained to support implementation of behaviour support plans, and to understand what are appropriate uses of regulated restrictive practices.
The Positive Behaviour Support (PBS) Capability Framework, which is used to consider the suitability of behaviour support practitioners to deliver behaviour support services is now being implemented at a more rapid pace. The last quarter there were over four times the number of practitioners that are considered provisionally suitable than there were the previous quarter. Behaviour Support Practitioners firstly self-assess against this framework to determine their appropriateness. Thereafter, they are considered provisionally suitable until their applications are reviewed by the NDIS Commission.
The report also discusses a new Restrictive Practice Guide to Safe Transportation. Whilst promoting the rights and inherent dignity of people with disability, the guide assists in identifying the safe use of regulated restrictive practice during transportation.
EFA insights:
The Restrictive Practice Guide to Safe Transportation is a great tool for providers to self educate on how regulated restrictive practices can be used during transportation to ensure safety for the person, the driver, and any other persons travelling in a vehicle.
In the last quarter there were 4,188 reportable incidents. What is especially frightening you may agree, is that basically 50% of those incidents relate to alleged abuse and neglect (2,058 incidents actually).
EFA insights:
The development and ongoing review of the effectiveness of a providers’ policies and procedures to prevent abuse and neglect, as well as policies and procedures to deal with allegations thereof is a matter that all providers need to take seriously. These processes need to cover off on the requirements of the NDIS (Incident management and reportable incident) Rules 2018.
Are you wondering what types of steps the NDIS Commission undertakes as part of its own compliance activities? This can happen at any time and checks may be random. The report explains through a useful case study how improvements were made after compliance measures were undertaken with a particular provider.
EFA insights:
Compliance is not just around audit activities. The NDIS Commission can instigate compliance activities to assess a range of provider obligations impacting on quality and safeguarding of NDIS participants. The case study in the report illustrates the need for effective incident management. Internal auditscan be a great way of keeping abreast of the effectiveness of systems and any potential systemic issues that may arise before they become too ingrained.
There has been some amendments to the NDIS Act concerning the variation of participant plans and timing. Now in certain circumstances, when participants and/or their authorised representatives ask for a change to their NDIS plan, the Agency will be able to do this without having to replace the current plan with a new one. Accordingly, this will be called a plan variation.
Effectively, these variations will help participants access new supports quickly without having to go through a full plan reassessment.
Other changes to the NDIS Act that started on 1st July include:
Recognising the importance of carers and family in the principles of the NDIS Act.
Adding lived experience of disability as a consideration for membership of the NDIS Board.
Clarifying that episodic and fluctuating impairments can be considered permanent when determining eligibility to the Scheme, including for people with psychosocial disability.
Putting risk assessments in place for participants who want to use a plan manager to purchase supports from unregistered providers.
19 August 2022 – NDIS Feedback and Complaints Management Essentials
Our three (3) hour workshop via Zoom is presented by an experienced NDIS auditor, is interactive, and will provide you with some practical tips and strategies you can use immediately. Remember Complaints management training for workers is also mandatory! Book a spot here!
14 October 2022 – NDIS Incident Management Essentials
Managing incidents effectively is an essential part of providing quality and safe supports for NDIS participants. This interactive workshop will include: benefits of effective incident management and managing incidents to comply with the relevant NDIS Practice Standards and NDIS Incident Management Rules and reporting. Book your spot!
11 November 2022 – Internal Audit Training (One Day)
Internal Audits are a mandatory requirement for NDIS providers under the NDIS Practice Standards.
This internal audit training will give you a sound basis and the tools to move forward with your own audits. EFA are auditing and quality specialists. Book here!
17 November 2022 – NDIS Restrictive Practices & Behaviour Support for Implementing Providers
Seeking guidance about obligations of NDIS providers that support participants subject to a Restrictive Practice? We can demystify behaviour support and restrictive practices and share that information with you in a way that makes sense for you and your NDIS service. Book a spot!
While all care has been taken in the preparation of this material, no responsibility is accepted by Engels Floyd & Associates for any errors, omissions or inaccuracies. The material provided in this resource has been prepared to provide general information only. It is not intended to be relied upon or be a substitute for legal or other appropriate professional advice. Engels Floyd & Associates accept no responsibility for any known or unknown consequences that may result from reliance on any information provided in this newsletter, or any external websites referred to.
A relative new team member to Engels Floyd & Associates is Kathy Gronthos. Kathy has taken on Rachael’s role as Client Engagement Administration Manager so she may be the one who responds to your inquiry or answers your phone call.
Kathy has had extensive experience working as a senior administrator in the health, disability and carer space in the Commonwealth and State Government. She has worked on national disability policy and carer agreements, government funding initiatives and policy strategies.
Speaking with Kathy this week she is obviously thrilled at her move to EFA and, with Kathy’s skills and wide ranging experiences, we are equally thrilled to have her join our team.
So who is Kathy?
What do you love about your work?
Kathy: I love the variety. No day is the same. The work is varied, interesting and fast paced. It is quality work where I feel like I am making a difference for people with disability. The day flies and you don’t even notice the time.
My team at EFA are lovely, very supportive and every day I am learning new things. The team are all so knowledgeable and very wise. There is a lot of wisdom and years of experience at EFA and it really shows.
The more I spoke with Kathy the more this quote I had heard rang true: “We are not a team because we work together. We are a team because we respect, trust, and care for each other.” Kathy appears to be the actualisation of that phrase.
What are the highlights of your life to date?
Kathy: My three children. They are really good kids, with good hearts and amazing personalities. They make my life very interesting and there is never a dull day in our house. You could say they keep me young and on my toes.
(Kids can be great role models for helping our own inner child and imaginations to flourish.)
What three words would you use to describe yourself?
Kathy: Family orientated – I come from a large extended Greek family with a lot of cousins. Everyone is very supportive and we are all there for each other through good and bad times. It’s true!
Down to earth – I am a very grounded and practical person. I respect truthfulness and being treated respectfully. What you see is what you get.
Honest – I do my best to live my life honestly and ethically. It is those principles which I was taught growing up in my family and try to teach my children.
(This is the sort of person you want on your team isn’t it! We certainly do. Honesty and grounded, practicality are ideal. Although it wasn’t raised, I did get the feeling that Kathy holds a high standard of integrity as a key attribute also.)
What is the best piece of advice you have received?
Kathy: I was brought up around the principle of the Golden Rule. To treat others in the same way you would like to be treated in terms of respect, kindness, generosity, and love. A great foundation and my parents were good role models in the Golden Rule. I do not think you can go wrong in life if you try to base your life on that rule.
(The Golden Rule was new to me although many of us probably know it by another term or by the act itself. The most familiar version of the Golden Rule says, “Do unto others as you would have them do unto you.” Also known as the Ethic of Reciprocity. Something all of us could benefit from practicing.)
What is the most courageous thing you have done?
Kathy: Recently, becoming an amateur beekeeper. I always had an interest and then out of the blue the opportunity to have some hives in my backyard presented itself. So I said, “Why not!” An 80 year old Greek beekeeper brought the hives over and taught me how to take care of them. He taught me in Greek which was a challenge at times because my Greek is not the best but we got by. It was pretty daunting and scary at the beginning and sometimes still is, but I am learning every day the beauty of bees and how important they are to the environment. All that yummy raw honey I get to enjoy and gift to others is a fantastic bonus.
Leaving the security of the Commonwealth Public Services for family reasons was a big decision at the time. However, it led me to spend more time with my kids when they were young by allowing me to be a full time Mum for a few years and opened up new opportunities for me. After which I moved into working for private organisations which was an eye opener and eventually this led me to work here with EFA.
(Now that was unexpected! Beekeeping. Did you know there are 20,000 different species of bees on our planet? And of those only eleven can make honey. Beekeeping definitely takes a bit of courage and tenacity too I bet.)
What accomplishment are you most proud of?
Kathy: Being successful at not being eaten alive by the bees although I have had quite a few stings, which isn’t nice. Showing my kids that you can learn something new and totally left field and take yourself out of your comfort zone. I still haven’t convinced them to help me yet. I think the bites on my face when I swelled up like a balloon have scared them off.
Also successfully turning a hobby, making concrete and eco resin homewares, into an online small business and having to set up the whole infrastructure myself. I learned so much about social marketing, taking photos for artwork, social media, setting up a new website, and all the associated stuff that is part and parcel with setting up a new small business.
(I’m sure seeing your mother’s face swollen into welts from bee stings would scare off most kids. LOL)
What could you not live without?
Kathy: My children, my big Greek family, my dog, five cats, and six chickens. Yes, I am one of those cat ladies, it’s the running joke in my family.
Coffee as well but I am sure I could live without it. Not so sure if I would be a very nice person though.
(LOL – I reckon most of us would not have our nice guy faces on everyday without coffee either Kathy. I’m sure your large human & fur family would always keep you smiling though.)
If you could sit over dinner with anyone who would it be and why?
Kathy: My mum, I lost her suddenly 13 years ago and would love to have the opportunity to say to her all the things I didn’t say while she was alive and to talk with her about my children.
My mum taught me so much about family, faith, values, love, and hospitality. Our house was always open and she loved helping people. She had a soft and giving heart for others and there were always new people we hadn’t met yet who visited our home. No-one left our house hungry. There was always an endless saucepan of beautiful, yummy Greek food cooking that never seemed to run out.
(Kathy told me how her Dad comes from the Greek island of Ikaria which has been identified as a Blue Zone. In case you don’t know what that is, blue zones are regions of the world thought to have a higher than usual number of people who live much longer than average. They eat mainly vegetarian diets and their healthy cuisine is now represented in many published cook books.)
What song do you HAVE to sing along with when you hear it?
Kathy: “Total Eclipse of the Heart” by Bonnie Tyler because who doesn’t like an 80s classic. I can’t sing to save my life but I give it a good go especially in the car, despite my kids protests.”
(I must agree – the 80s had some brilliant classics. Songs like “Jump” by Van Halen or “Express Yourself” by Madonna. Personally I think “S..S..Single Bed” has to be up there. Just kidding!)
Kathy certainly came across as a genuine, compassionate, and friendly person on our first conversation. If you contact EFA and Kathy responds I’m sure you will find her very welcoming and eager to support you in the best way possible.
EFA Supporting Residential Aged Care NDIS Providers
Upcoming EFA Training
July 15 Internal Audit Training (One Day)
Internal Audits are a mandatory requirement for NDIS providers under the NDIS Practice Standards.
This internal audit training will give you a sound basis and the tools to move forward with your own audits. EFA are auditing and quality specialists. Book your spot now!
July 27 NDIS Restrictive Practices & Behaviour Support for Implementing Providers
Seeking guidance about obligations of NDIS providers that support participants subject to a Restrictive Practice? We can demystify behaviour support and restrictive practices and share that information with you in a way that makes sense for you and your NDIS service. Book in here!
August 19 NDIS Feedback and Complaints Management Essentials
Our three (3) hour workshop via Zoom is presented by an experienced NDIS auditor, is interactive, and will provide you with some practical tips and strategies you can use immediately. Remember Complaints management training for workers is also mandatory! Book a spot here!
Oct 14 NDIS Incident Management Essentials
Managing incidents effectively is an essential part of providing quality and safe supports for NDIS participants. This interactive workshop will include: benefits of effective incident management and managing incidents to comply with the relevant NDIS Practice Standards and NDIS Incident Management Rules and reporting. Book your spot here!
EFA, Awarded NDIS Auditor Training For 5th Year
We are so thrilled to announce that EFA, and our partner ARTD have, for the 5th consecutive year been contracted by the NDIS Commission to undertake NDIS auditor training. To date we have trained 869 auditors through forty five sessions. A huge feat since 2018.
What this means for you is that you can be reassured that when you engage Engels Floyd & Associates you are dealing with the best in the business when it comes to NDIS compliance and registration. We understand NDIS requirements like the back of our hand. We train the auditors. If you need help from the experts in NDIS registration and compliance contact us for a chat.
Hosanna Compliments EFA
Linda Yalda from Hosanna Community Care based in Melbourne recently provided this glowing feedback to EFA. This was received after EFA provided Hosanna tailored consultancy support on auditing, quality management, and standards.
Linda wrote; “EFA is very honest, passionate, qualified, highly skilled and approachable team that has always supported us to continually improve.” Accordingly in Linda’s words to EFA; “You are the best!”
This type of feedback is not only beneficial to help us know that we are on track and meeting provider’s needs efficiently but also that we ease the load for the providers that we work with. And if we at EFA can improve your systems and ultimately improve outcomes for your participants, then we are fulfilling our purpose. What do others have to say about their experience with EFA?
Dedicated NDIS Minister Announced
Following on from a change of Government recently, on May 31st Bill Shorten was announced as Labor’s first ever dedicated Minister for the NDIS. Bill will also be Minister for Government Services. Bill said “It is my great honour to serve people with disability…I will work every day to make Australia better. I look forward to the work and I won’t let you down.”
On June 22nd Bill Shorten visited the NDIA Braddon office to meet the NDIA staff delivering the Scheme to make an important NDIS announcement and to release the latest NDIA Annual Pricing Review.
Bill claims the review is a win-win situation. From 1st July 2022 price limits for all NDIS supports delivered by disability support workers will increase by 9 per cent, including a 2 per cent temporary loading in 2022-23, and all current NDIS plan budgets will be automatically increased to account for these price limit changes.
Further information is available in the associated media release: https://bit.ly/3bm4Y8M .
While all care has been taken in the preparation of this material, no responsibility is accepted by Engels Floyd & Associates for any errors, omissions or inaccuracies. The material provided in this resource has been prepared to provide general information only. It is not intended to be relied upon or be a substitute for legal or other appropriate professional advice. Engels Floyd & Associates accept no responsibility for any known or unknown consequences that may result from reliance on any information provided in this newsletter, or any external websites referred to.
EFA Supporting Residential Aged Care NDIS Providers
Increasing Participant Engagement in Auditing
Karen Pritchard, Power Packed With Positivity
Have you noticed those quirky, engaging, and motivating social media posts that EFA has been posting lately? That’s the wondrous work of one of EFA’s newest team members, Karen Pritchard, our Digital Marketing Coordinator. Karen loves her work as she loves life. A creative, lateral thinker who brings a sense of humour, gratitude, and loads of fun to all that she does. No negativity there! Expect the unexpected with Karen, and it will come accompanied by one of her famous off the cuff comments.Karen and I caught up recently. What really is the source of her contagious joyousness?
What do you love about your work? Karen: My Team – First and foremost! All our heads, hearts and intentions are in the same place. I feel we all skip to the beat of the same drum.Generally I feel lucky in life. I have a lot of gratitude. I tried part time work for a while and now I’m back to working 5 days a week between EFA and another company. I’m even busier and I love it! And I have 100% autonomy, something creative people need.(Karen is so switched on with balancing her priorities. She told me that she regularly schedules a ‘no phone/screen time’. And this is a definite. She does not compromise on that for herself. That’s something most of us could do with!)
What are the highlights of your life to date? Karen: I’m so proud that I’m finally working in a job I love to do. It’s no longer about working in a job just for the money. Even on the weekends I like popping into work online and doing some work, not because I need to catch up but because I just love it. It feels as though I am doing good and that’s important to me. EFA is not a big multinational corporation. It’s all about Australians helping Australians. Doing good by keeping it local. I like working for a company with those values.(Such a refreshing perspective! What did Confucius say: “Choose a job you love and you will never have to work a day in your life.”)
What three words would you use to describe yourself? Karen: Fun. Loud. Worrier. LOL – That’s me – Always going straight for the catastrophe jump. I go from nought to a million in an instant. I think that comes from being an over thinker. I’m what I would coin a loud introvert.(Is the “catastrophe jump” as Karen calls it merely the result of a wild imagination……. Then again I think there are many of us that do the catastrophe jump when something unexpected happens.)
What is the best piece of advice you have received? Karen: “Life is a journey not a destination.” It’s the journey that matters.Sometimes we all just need to pause to smell the roses. Of such value too is; “Smile at someone!” It makes a difference and being a brighter person encourages the same in return from others.(So many wisdoms in response to one question. Smiling makes a massive difference. Have you ever noticed that if you smile at a stranger? And how many of us are always wanting to jump to the final outcome, to finish a task, wishing away days and weeks. It feels so good just to stop and breathe. It’s like pressing reset on your phone.)
What is the most courageous thing you have done? Karen: I can do job interviews as cool as a cucumber. I can speak to crowds without any butterflies.The most courageous thing I have done was to apply to be a member of the Charity Taskforce Advisory Council. This group is made up of high flying executives and CEOs and applying for ‘li’l me’ to join this committee of high profile people was daunting. Speaking up with highly successful and already connected personalities is scary. But I told myself; “…. You know what! I am as able as them to do this role.” And I did join that council so I could add the voice of the small charity sector.Together we will be guiding on the development of a charity donation platform that pulls together donors, workplaces and the community. It helps to share and celebrate the ‘goodness feeling’ that comes from collaborative giving. A bit a background if you’re curious – this platform encourages workplace giving (regular pre-tax donations direct from your pay) We like to say, it doesn’t matter how much or how little, but every bit counts. If you’ve not heard of workplace giving and want to know more, head to the Workplace Giving Australia website to discover all the benefits for employees, organisations and the causes you care most about.(You go girl! We are always the best person to back ourselves. How amazing does it feel when you step out of your comfort zone?)
What accomplishment are you most proud of? Karen: Growing pumpkins! I have been dedicating spare time to growing a veggie garden for the past nearly 5 years and I love growing pumpkins. I talk to them and they all have individual personalities – no kidding! My pumpkins are organic and every late summer they completely overtake the backyard. (A whizz at social media and a green thumb! Looks like halloween is at Karen’s.)
What could you not live without? Karen: My iPhone. Seriously! It enables me to do things that normal-sighted people take for granted. Besides the obvious benefits of my iPhone I can listen to audio books, the radio, and podcasts. Listening to content is just the same as reading it, but the main benefit is you can be doing chores around the home while reading. Boom! there is a life hack for you! A must for everyone, get the Borrow Box app, connect it to your local library and start listening. It really makes those dull jobs fly quick.(BTW Karen has 97% sight loss. That doesn’t slow her down one iota. Her energy, passion and zest for life is compelling.)
If you could sit over dinner with anyone who would it be and why? Karen: Well, it can’t be just one person. I’m making the most of the opportunity.
Elon Musk. I’m curious if he’s as the media purports him to be.
Princess Diana, undoubtedly an iconic mover and shaker who left a lot of unfinished business. The ripple effect of her being here on earth is still playing out in our world currently.
Marilyn Monroe, a woman who was manipulated and used as a possession. Does she have substance to her compared to how she was portrayed. Who was she really?
The current Pope. We could discuss the Da Vinci Code. And one of my ancestors such as my great great grandmother or grandfather. I don’t know much about my ancestors and I would like to be able to find out who they were and what made them tick.
Of course, the whole EFA team would be at the dinner as well. We’d be situated on a hill, under a flowering arbor of purple wisteria at a large round table. The warm air gently blows around our feet and dapple sunlight plays patterns on our faces. We’re eating the most amazing food and OMG, the chairs are so comfortable, it turns out to be the longest (and memorable) lunch ever! (Wow! I want to be there too! Imagine the intensity of conversation flowing around the table well into the twilight hours. The Pope with Princess Di – the mind boggles!!)
What song do you HAVE to sing along with when you hear it? Karen: YMCA by the Village People. To me that song is all about happiness without judgement.(And when Karen’s around….”there’s no need to feel down” LOL)Karen is the sort of person you just want to hang out with once you meet her. As Karen says herself; “I’m way too busy creating memories to do housework.” I think that is an important life lesson we could all hang onto and run with. Don’t forget to do all the things that you love and usually everything else can wait, and if those routine things don’t get done does it matter in the scheme of life anyway.It seems that life in company with Karen would be fun, spontaneous, and adventurous. I get the feeling that life in Karen-land is never dull.
EFA Supporting Residential Aged Care NDIS Providers
Currently across Australia there are about 627 residential aged care providers supporting NDIS participants within their facilities. These facilities are required to undergo NDIS registration as well as maintain their aged care accreditation.
Navigating those compliance requirements can be a quagmire for residential aged care facilities initially, but help is on the way. EFA in collaboration with our partner, ARTD Consulting have been asked by the NDIS Commission to develop resources, training and education for these residential aged care providers undergoing NDIS registration. NDIS auditing and registration requisites can also be daunting for providers so it’s important to have up to date resources to bridge that uncertainty and to build confidence in residential aged care providers.
We will also be providing resources and information to support NDIS participants living in residential aged care engage in NDIS audit processes.
To ensure you have access to the information and resources as they become available ensure you receive our newsletters and/or follow EFA on Linkedin or Facebook.
Increasing Participant Engagement in Auditing
One area of note in the latest industry Communique of the NDIS Quality and Safeguard Commission is the need for greater representation of participants in the registration and auditing processes.
Furthermore, the Communique mentions how it seeks to introduce measures to increase participant involvement and contribution in the (audit) registration process and to facilitate the provision of educational resources and provider quality information that informs participant decision making.
This particular objective is one that EFA has particular expertise in. Take a browse through our EFA team profiles. Three of our team members are NDIS participants themselves, including one of the founders and Directors of EFA. Communicating with and maximising the engagement of NDIS participants is one of our key attributes. In fact, earlier this year we were asked to speak on best practice about that topic at a national forum.
EFA is currently providing regular training/workshops to NDIS providers to promote participant engagement. Please contact us if you’d like to have a tailor made session for your organisation.
Additionally, we are passionate about making information accessible to people with disability. At EFA we believe it is essential to ensure that all individuals are provided with appropriate information to support a rights based, person-centred approach. If you need help with accessible documentation we can assist you.
While all care has been taken in the preparation of this material, no responsibility is accepted by Engels Floyd & Associates for any errors, omissions or inaccuracies. The material provided in this resource has been prepared to provide general information only. It is not intended to be relied upon or be a substitute for legal or other appropriate professional advice. Engels Floyd & Associates accept no responsibility for any known or unknown consequences that may result from reliance on any information provided in this newsletter, or any external websites referred to.
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