The NDIS National Quality and Safeguard Framework provides an outline about how the Commonwealth Government will support people with disability to exercise their right of choice and control. It also provides insights into what the National expectations will be regarding regulation and safeguarding requirements for registered service providers.
Currently, each State and Territory has its own Quality and Safeguards requirements to register as an NDIS provider.
The plan is that SA and NSW will move to the National Framework in 2018 followed by most of the remaining States and Territories in 2019 with WA coming on board in 2020.
The NDIS is now a competitive market. The Framework strives to reassure participants that there is quality control through setting high Standards for registered service providers while being mindful not to stifle business growth through over regulation.
The Framework is a big picture document but there are clear messages for services providers.
Here are my top 10.
- Participants will be encouraged to use online platforms to share information about service providers. Group forums and performance rating mechanisms are examples of this. Empowering participants to recommend or not to recommend services to their peers is a powerful quality assurance tool and a strong incentive for service providers to perform well.
- Providers will be audited for quality. The results of these audits will be made accessible to the public in a similar way as is done in the UK Care Quality Commission. Follow this link to get the idea. CQC Reports
- The Framework has a strong emphasis on complaints and incident management. This will have National oversight and the data will be collected to identify areas for systematic improvement. No details on how this will work as yet but service providers would be wise to ensure their system of complaints and incident management is robust.
- There will be 3 positions overseeing the NDIS Quality and Safety Framework. A Complaints Commissioner, Registrar and Senior Practitioner. The Senior Practitioner will also have new legislative powers relating to Reducing Restrictive Practice. These guys basically hold all the keys under their areas of responsibility. There is table in the NDIS National Quality and Safeguard Framework page 18 that gives a good run down on what each of these positions is responsible for.
- There will be a new legislative framework concerning Restrictive Practice. Here is a summary of the content planned for legislation. I would be advising any practitioners or larger services providers to review all policies, procedures, plans, credentialing, client information, consent processes and monitoring mechanisms relating to restrictive practice. As soon as the legislation is passed, update them.
· Rules and prohibition of certain practices
· Circumstances that must be met before providers can use restrictive practice
· Statuary powers to the Senior Practitioner
· Set competency standards for practitioners
· Set Standards and other requirements for providers
· Mandated transparency and accountability
· Prohibit NDIS funded provider using restriction contrary to legislation
· Information sharing
- There will be a nationally consistent worker screening process. The results of the screening process for an applicant will be valid throughout Australia. Breaches of Code of Conduct or other breaches or complaints relating to any worker will be monitored through the NDIS complaints area and the information will flow through to the Screening unit. No details about how this will work yet but ensure all policy, procedures and employment processes are compliant.
- There will be a mandatory orientation module. This is compulsory and applicable to providers engaged in delivery of supports including registered sole traders. There is a peak preview of may be in this modules on page 58.
- Registration requirements for what is considered low risk supports such as gardening or cleaning services, will undergo a periodic verification process covering the basics. ABN, Screening, credentialing, complaints management and reports etc.
- If you conduct what is considered high risk supports (this appears to include sole providers although I still find this area blurry} you will need to demonstrate additional compliance. My understanding at this stage is that a set of NDIS practice standards will be developed, using a module format and comprising of both core practice standards and specific practice standards. These Standards will be written in such a way as to link across to the NDIS Code of Conduct and the National Standards for Disability Services. This is a Quality Assurance Certification and will be tailored to the scope & size of the service and conducted by 3rd party auditors. When these details become available, this area may become clearer. There is a table on page 86 and another on page 88 that explains the verification and certification process.
“…the core practice standards will cover risk management, expected qualifications and competencies for employees, complaints systems, and effective and inclusive governance” My last but most important take home message. It is extremely important that risk management is a core part of business for service providers. Together with sound governance, providers will be much better placed to meet the challenges and opportunities presented by the NDIS.
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