National Disability Insurance Scheme News

Dual NDIS and Aged Care Registration Requirements for Residential Aged Care (RAC) Providers

This article provides an update on NDIS RAC ‘modified audits’. Legislation was amended in April 2023 to allow for these type of audits.


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.

After 1 December 2020, RAC providers were required to apply for registration with the NDIS Commission as a new applicant in the following circumstances:

•         they receive direct funding from the NDIA to deliver supports and services to NDIS participants; and/or

•         they develop behaviour support plans; and/or

•         they implement regulated restrictive practices; and/or

•         they operate Specialist Disability Accommodation; and/or

•         they deliver plan management supports to NDIS participants.

Given that most of the NDIS participants RAC providers support receive direct funding from the NDIA, they will be required to register with the NDIS Commission.  As such, dual registration with the Aged Care Quality Commission and NDIS Commission is required for RAC providers resulting in dual compliance requirements.

Modified RAC audits

The NDIS Commission has considered that the existing aged care audit process through the Aged Care Quality and Safety Commission is a ‘comparable quality audit process’ for NDIS registration purposes. This means there is scope for some eligible RAC providers to undertake a modified NDIS RAC audit  which will minimise duplication in compliance requirements. To decide if a modified NDIS RAC audit is applicable, the AQA needs to consider a range of factors including the most recent aged care accreditation audit, the RAC provider’s plan for continuous improvement, status of any complaints, and any sanctions for non-compliance with aged care responsibilities.  

RAC providers will need to discuss this option with their Approved Quality Auditor to review if they are eligible for this pathway. Authorisation from the NDIS Commission is then required before the modified NDIS RAC audit can take place.

How EFA can help

EFA in partnership with ARTD, were recently involved in a project with the NDIS Commission assisting Residential Aged Care (RAC) providers supporting NDIS participants during their NDIS registration processes. This included the development of a Residential Aged Care Provider Toolkit including a number of fact sheets, tools, resources and webinars to not only support RAC providers but also NDIS participants, auditors and other stakeholders when undertaking audit activities as part of their mandatory registration renewal process.  Our involvement means we have an excellent understanding of the NDIS RAC modified audit requirements. We encourage RAC providers to review these resources and see how they may help you in your NDIS registration process.

If you require any assistance understanding your NDIS obligations and preparing for your NDIS audit please contact us on 0478 616 207 or for a complimentary consultation.

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