The EFQC Enquirer: 13 April 2026

In this edition

EFQC Update

• EFQC April Update – What We’re Seeing Across the Sector

Important Sector & Regulatory Updates

• Emergency Preparedness Is Not Optional: What NDIS Providers Need to Be Doing Now
• New NDIS Commission Video: Bringing Individual Rights into Everyday Practice
• NDIS Integrity & Safeguarding Reforms: A Defining Shift for Providers

Ask the Experts

• Preparing for Your NDIS Self-Assessment With Sharon Floyd, Director – Engels Floyd Quality Consulting

EFQC Update

EFQC April Update – What We’re Seeing Across the Sector

It has been an incredibly busy start to the year for the Engels Floyd team, with a significant increase in new enquiries from providers across the country. We are seeing a clear shift in the sector, with many organisations actively seeking support to strengthen their systems, prepare for audit, and better understand how to operationalise compliance in practice — not just on paper.

In March, we delivered our free 1-hour workshop: Get NDIS Registration Ready, which was extremely well attended. It was fantastic to connect with so many providers who are either considering registration for the first time or looking to get ahead of upcoming regulatory changes. The level of engagement and the quality of questions reinforced what we are hearing across the sector — providers are wanting clear, practical guidance on what registration really requires and how to avoid common pitfalls.

We are also closely watching the upcoming May Federal Budget, with strong indications across the sector that it may include further NDIS reform activities. While details are yet to be confirmed, the ongoing direction of reform continues to point towards increased oversight, stronger compliance expectations, and the continued expansion of mandatory registration.

For providers who are currently unregistered, this is a timely opportunity to start thinking about your registration status and future positioning in the market. Early preparation will be critical — particularly given the timeframes and the level of evidence required to demonstrate that systems are not only in place but operating effectively.

If you are unsure where to start or want to check your readiness, we are offering a complimentary consultation to talk through the registration process and how we can support you. Our focus is always on practical, tailored guidance that aligns with how your organisation actually operates.

Important Information

1. Emergency Preparedness Is Not Optional: What NDIS Providers Need to Be Doing Now

Recent global and local events are a timely reminder that disruption can occur quickly and with little warning. From international tensions impacting fuel supply chains to ongoing natural disasters across Australia, providers need to be asking a critical question:

“If something changed tomorrow, could we continue to safely support our participants?“

Across the sector, we are still seeing many providers with emergency and business continuity plans that exist on paper—but are not operationalised, tested, or understood by staff. This is one of the most common gaps identified during audits.

Under the NDIS Practice Standards—particularly within Governance and Operational Management—providers are required to have documented and tested emergency and disaster management arrangements. Importantly, auditors are not just looking for the document. They are looking for evidence that your systems:

• Reflect your actual service delivery model
• Consider the individual needs of your participants
• Are understood and implemented by your workforce
• Have been tested and reviewed

What This Means in Practice
Emergency preparedness is not just about large-scale disasters like floods or bushfires. It also includes more immediate and realistic risks such as:

• Fuel shortages impacting staff travel and service delivery
• Workforce disruptions or sudden staff unavailability
• Power outages or IT system failures
• Localised emergencies affecting participants’ homes or communities

For many providers, fuel shortages alone could significantly impact the ability to deliver community access, transport, or in-home supports. Without a clear, practical plan, this can quickly lead to missed supports and increased risk for participants.

What We Recommend Providers Do Now

Rather than viewing emergency planning as a compliance requirement, providers should treat it as a core operational system.

At a minimum, your organisation should be able to demonstrate:

1. Participant-level planning
   You have identified which participants are most at risk during a disruption and what specific supports they require to remain safe. This should be documented, current, and accessible.
2. Clear continuity strategies
   You know how you will continue delivering critical supports if your usual workforce, systems, or transport options are disrupted. This may include contingency staffing, prioritisation frameworks, or alternative delivery methods.
3. Workforce preparedness
   Your staff understand what to do in an emergency. This goes beyond induction—it includes practical guidance, communication pathways, and confidence in responding to real situations.
4. Testing and review
   Your plans have been tested. This could be through scenario discussions, simulations, or reviews following real events. Evidence of testing is often what separates compliant providers from non-compliant ones at audit.
5. Governance oversight
   Emergency and business continuity planning is actively monitored, reviewed, and improved at a leadership level—not filed away and forgotten.

Using Available Sector Resources
There are a number of practical resources available to support providers in strengthening their emergency preparedness.

The NDIS Commission’s Emergency Management Provider Alert is a useful starting point. It provides guidance on how to:

• Plan for participants’ individual needs during emergencies
• Prepare and train staff for effective responses
• Maintain continuity of supports during disruption

In addition, the Resources for NDIS Emergency and Disaster Management (R4NED) website offers practical tools and guidance to support planning, preparedness, and response across a range of emergency scenarios.
While these resources are valuable, they should be used as a foundation only. Providers must ensure their plans are tailored to their own service model, participants, and operational risks—not adopted as generic templates.

The Key Risk for Providers

The NDIS Commission is increasingly focused on whether providers can demonstrate continuity of supports in practice, not just intention.
Where providers cannot show how they would respond to disruption—or where plans are clearly generic and not implemented—this can lead to non-conformities during audit and, more importantly, real risks to participants.

Final Thought
Emergency preparedness is ultimately about safeguarding the people you support.

In a changing environment—whether driven by global events, fuel supply challenges, or natural disasters—providers who invest in practical, embedded systems will be far better positioned to respond confidently and maintain continuity of care.

If you would like support reviewing or strengthening your emergency and business continuity arrangements, please contact us to discuss how we can assist. Our team can work alongside you to ensure your systems are not only compliant – but genuinely operational.

2. New NDIS Commission Video: Bringing Individual Rights into Everyday Practice

The NDIS Commission has recently released a new video as part of its Code of Conduct education series, focusing on individual rights—a core expectation for all providers and workers.

While most providers are familiar with the concept of choice and control, what we continue to see across the sector is a gap between understanding the principle and consistently applying it in day-to-day practice.

This latest video is a helpful reminder that respecting individual rights is not just about intention—it’s about how supports are actually delivered. It highlights what it looks like when participants are actively involved in decisions about their supports, when their preferences are genuinely listened to, and when they feel safe to speak up if something isn’t right.

What This Means for Providers and Workers

For providers, this is a timely opportunity to reflect on how well your organisation is embedding these principles in practice.

For workers, it reinforces that everyday interactions matter. Supporting individual rights is often demonstrated through small, consistent actions—how choices are offered, how communication is adapted, and how autonomy is respected.

Why This Matters

The NDIS Commission continues to place strong emphasis on participant-centred practice, and this is increasingly reflected in audit and compliance activity.

It is no longer enough to state that your organisation supports choice and control—providers must be able to demonstrate how this is embedded across service delivery.

To support this in practice, we’ve developed a simple reflection checklist for management and workers. It’s designed to prompt practical thinking about how individual rights are upheld in everyday interactions and can be used in team meetings, supervision, or training.

Staff Reflection Checklist: Supporting Individual Rights in Practice

Use this checklist to reflect on how you support participants’ rights in your day-to-day work.

Choice and Control
☐ Do I offer real choices to participants, not just limited options?
☐ Do I respect the participant’s decisions, even if they are different to my own preferences?
☐ Do I check in with the participant before making decisions that affect them?

Supporting Decision-Making
☐ Do I explain information in a way the participant can understand?
☐ Do I give the participant enough time to make decisions?
☐ Do I support the participant to involve others they trust if they want to?

Respect and Communication
☐ Do I listen actively to what the participant is saying (verbal and non-verbal)?
☐ Do I respect their culture, values, and preferences in how supports are delivered?
☐ Do I adapt my communication style to suit the participant?

Speaking Up and Safety
☐ Do I encourage participants to share feedback or concerns?
☐ Do I respond respectfully and take concerns seriously?
☐ Do participants feel safe to say “no” or express dissatisfaction?

Everyday Practice
☐ Do my actions promote independence rather than doing things “for” the participant?
☐ Do I regularly reflect on my practice and look for ways to improve?
☐ Would the participant say they feel heard, respected, and in control?

3.  NDIS Integrity & Safeguarding Reforms: A Defining Shift for Providers

The passing of the National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Bill 2025 marks a significant step forward in strengthening protections for NDIS participants and reinforcing the integrity of the scheme.

While the sector has seen ongoing reform, this legislation represents a clear shift in how compliance will be monitored, enforced, and responded to. The expansion of powers for the NDIS Quality and Safeguards Commission signals a move towards stronger oversight, earlier intervention, and increased accountability across all parts of the provider ecosystem.

What Has Changed

The reforms introduce a number of critical changes that providers need to understand:

• Substantially increased civil penalties, with fines exceeding $15 million in cases where participants are harmed
• Introduction of criminal offences, with potential imprisonment of up to five years
• New powers enabling the Commission to ban consultants and auditors who provide poor or misleading advice
• Greater ability to act against misleading promotion and unsafe or non-compliant practices

These are not minor adjustments—they reflect a fundamental strengthening of enforcement mechanisms within the NDIS.

The Real Shift for Providers

This is not about more documentation.

It is about stronger enforcement and real accountability.
Providers must now be able to demonstrate, at any point in time, that their supports are:

• Safe
• Participant-centred
• Delivered in line with the NDIS Practice Standards

What This Means in Practice

Providers should expect:

• Stronger enforcement — the Commission has greater authority and is expected to use it
• Earlier intervention — issues may be addressed before they reach audit or formal compliance stages
• Greater accountability — across leadership, governance, and frontline service delivery

This is a significant shift in how compliance will be experienced across the sector.

What Will No Longer Be Sufficient

The following approaches are unlikely to meet expectations under this strengthened framework:

• Treating compliance as something to prepare for at audit
• Policies and procedures that are not implemented in practice
• Generic systems that do not reflect actual service delivery
• Reliance on external advice that is not grounded in operational reality

What Is Now Expected

Providers must be able to clearly demonstrate:

• Systems that are embedded and operating effectively
• Evidence of safe, quality support delivery
• Active leadership oversight of governance, risk, and compliance
• A culture of continuous improvement and accountability

What Providers Should Do Now: 5 Practical Steps

In light of the new integrity and safeguarding reforms, providers should be taking proactive steps now to strengthen their systems and reduce risk.

1. Test Your Systems — Not Just Your Documents
   Review whether your policies are actually being followed in practice.

Ask: If an auditor observed us today, would they see this in action?

2. Focus on High-Risk Areas First
   Prioritise areas such as incident management, behaviour support, restrictive practices, and participant safety. These are key focus areas for the Commission.
3. Check Your Evidence
   Ensure you can clearly demonstrate:

• How supports are delivered safely?
• How risks are identified and managed?
• How decisions are made and documented?

Good systems without evidence will not meet requirements.

4. Strengthen Leadership Oversight
   Governance is now firmly in scope.
   Leaders must be able to show active oversight of quality, risk, and compliance—not just delegation.
5. Invest in Workforce Capability
   Your staff are your system in practice.

Make sure they understand:

• What good practice looks like
• What is expected under the Code of Conduct
• How to respond in real situations

Bottom Line
These reforms reinforce a message that has been building across the sector:
Compliance is no longer an event.

It is how your organisation operates — every day or as we call it ‘Being Audit Ready at All Times’!

Providers who invest now in strengthening their systems, embedding practice, and building workforce capability will be far better positioned to navigate this new regulatory environment.

If you would like support understanding what these changes mean for your organisation, or reviewing your current systems against these expectations, please contact us—our team can work with you to ensure your approach is not only compliant, but genuinely operational and aligned with the Commission’s expectations.

Ask the Experts

Ask the Experts — Preparing for Your NDIS Self-Assessment With Sharon Floyd, Director – Engels Floyd Quality Consulting

Q: What is the NDIS self-assessment and what is it actually asking providers to do?

The NDIS self-assessment is a mandatory requirement for both organisations applying for registration and those renewing their registration.

It sits at the very beginning of the audit process and is one of the first things auditors review to understand whether your organisation appears capable of meeting the NDIS Practice Standards.

At its core, the self-assessment requires you to assess your organisation against each relevant Quality Indicator and explain how your systems meet those requirements in practice.

It’s designed to help you identify:

• Gaps in compliance
• Areas for improvement
• Opportunities to strengthen your systems and safeguards

But more importantly, it asks you to step back and look at your organisation through the lens of the Practice Standards.

That means clearly describing:

• How your governance and operational systems work?
• How policies are implemented in real-world practice?
• How risks are identified and managed?
• How participants are safeguarded?
• How staff are trained, supported, and supervised?
• How incidents, complaints, and feedback are handled?
• How you monitor and improve your systems over time?

In simple terms, the self-assessment is not a checklist.

It is a clear, structured explanation of how your organisation operates—and how you know it is meeting the NDIS Practice Standards.

Q: Why does the self-assessment matter so much in the registration or re-registration process?

Because it sets the tone for everything that follows.

Auditors and the Commission use your self-assessment to:

• Understand your service model
• Identify potential risks
• Shape the audit approach
• Guide interview questions and evidence testing

If your self-assessment says one thing, but your practice shows another, that gap will be identified very quickly during audit.

In many ways, your self-assessment becomes the starting point of your audit story.

Q: What are the most common mistakes you see providers make?

There are a few recurring ones:

• Treating it as a “tick-box” exercise
• Copying from templates or other providers
• Providing Generic Responses
• Describing what should happen, not what actually happens
• Completing it without fully understanding the Practice Standards
• Having a consultant prepare it

One of the biggest risks is when the self-assessment doesn’t reflect reality.

If your staff can’t explain what you’ve written—or there’s no evidence behind it—that creates significant issues during audit.

Q: How important is it for providers to “own” the self-assessment process?

It’s critical.

This is called a self-assessment for a reason.

Providers who get the most value from the process are those who:

• Ask questions
• Seek to understand
• Take responsibility for their responses

At Engels Floyd, we don’t complete self-assessments for providers—we review them, challenge them, and strengthen them.

Because ultimately, when an auditor asks a question, the answer needs to come from you—not your consultant.

Q: How should providers approach the self-assessment practically?

Start by stepping back and asking:

• Do we understand how our systems work?
• Can we explain them clearly?
• Can we demonstrate them with evidence?

Then work through each Practice Standard with that mindset.

It’s also helpful to treat the process as a gap analysis, not just a requirement.

Where there are gaps—that’s your opportunity to strengthen your systems before audit.

Q: Is the self-assessment just for registration, or should providers revisit it?

While it’s required at registration and renewal, the best providers use it more regularly.

Completing a self-assessment annually—or even as part of internal audits—can be a powerful way to:

• Monitor compliance
• Identify risks early
• Drive continuous improvement

It becomes a live tool, not a one-off task.

Q: What is one key piece of advice you would give providers starting their self-assessment?

Don’t look for shortcuts.

Take the time to understand what you are writing and why it matters.

Because the real value of the self-assessment is not the document itself—it’s the capability you build in your organisation through the process.

Final Thought from Sharon

Self-assessment means ownership.

Ownership builds capability.

And capability is what ultimately supports safe, high-quality services for participants.

If you are preparing for registration or re-registration and would like guidance please contact us to discuss how we can support you.