Helping providers to help participants
In this edition:
- EFA’s Insights into the NDIS Activity Report
- NDIS Participant Plan Variations
- Upcoming EFA Training
EFA’s Insights into the NDIS Activity Report
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.
On November 17th EFA is conducting a workshop on NDIS Restrictive Practices & Behaviour Support for Implementing Providers which delves into this subject in detail. The workshop is facilitated by a very experienced clinician so you are in good hands!
Behaviour Support (page 17)
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.
We will explain more regarding the PBS Capability Framework and regulated restrictive practices in our NDIS Restrictive Practices & Behaviour Support for Implementing Providers on November 17th.
Reportable Incidents (page 14)
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.
Our upcoming Incident Management workshop on October 14th on NDIS Incident Management Essentials is definitely worthwhile considering!
Compliance Activity (page 18)
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.
Remember, EFA is facilitating an NDIS Incident Management Essentials workshop on October 14th which could benefit your business, plus we are also running our popular Internal Audit training on 11 November 2022.
NDIS Participant Plan Variations
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.
Attached is the actual amendment and a link to the announcement and explanation on the NDIS Commission site. 2022 NDIS legislation amendments – July update | NDIS.
Upcoming EFA Training
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.
