From 15th November 2021, the updated NDIS Practice Standards and Quality Indicators will come into effect.
In November 2021, the NDIS Commission provided further details regarding the previously announced updates to the National Disability Insurance Scheme (Provider Registration and Practice Standards) Rules 2018 and the National Disability Insurance Scheme (Quality Indicators) Guidelines 2018.
These changes will require the prompt attention and action of all NDIS Providers to ensure they comply with the new requirements.
In this blog we will uncover:
What The Changes Are
The Practice Standards and Quality Indicators have been updated to include three new Standards:
- Emergency & Disaster Management – applicable to all Providers on the Certification Pathway, this falls under Core Module Part 2 – Provider Governance & Operational Management.
- Mealtime Management – applicable to all Providers who provide supports to participants who require assistance to manage mealtimes (e.g. those with mild dysphagia etc.). This falls under Core Module Part 4 – Support Provision Environment.
- Severe Dysphagia Management – applicable to all Providers who provide high intensity supports to participants with severe dysphagia. This falls under Module 1 High Intensity Daily Personal Activities.
A number of significant changes have also been made to existing parts of the Core Module, the Verification Module, and Module 3 Early Childhood Supports:
Core Module
- Risk Management
- HR Management
- Continuity of Supports
- Support Planning
- Service Agreements
- Responsive Support Provision
- Transitions to/from a Provider
See all the changes to the Practice Standards here.
See all the changes to the Quality Indicators here.
- Safe Environment
- Waste Management
Module 3: Early Childhood Supports:
- The Child
Verification Module:
- HR Management
- Risk Management
What Action You Need To Take
It is important you review the updated versions of the standards as soon as possible.
We strongly recommend performing a self-assessment of your organisation against the updated requirements as soon as possible, and work to address any gaps to ensure full compliance by your next audit.
When You Need To Take Action By
As a result of these changes, please be advised that your organisation will need to take prompt action to ensure the new requirements are complied with, particularly if you are due to undertake your next audit soon.
The new Standards will come into effect immediately from 15th November 2021 for all Providers (new or renewing) undertaking Verification, Stage 1, Stage 2 or Re-certification audits, regardless of whether you commenced the application process prior to that date.
For example, if you have a Stage 2 audit booked for 16th November 2021, you will be assessed against the new requirements.
For registered Providers due for their Mid-Term audit, there will be a transition period for each of the 3 new standards:
- Mealtime Management standard – not applicable for mid-term audits between 15th Nov – 12th Dec 2021; will be auditable from 13th Dec 2021.
- Emergency & Disaster Management standard – not applicable for mid-term audits between 15th Nov 2021– 23rd Jan 2022; will be auditable from 24th Jan 2022 for all applicable Providers.
- This also includes the changes made to existing requirements under the Core Module, Module 3 and the Verification Module – Providers undertaking Mid-Term audits that include these Modules between 15th November 2021 – 23rd Jan 2022 will NOT be assessed to the new requirements; the new requirements will be auditable from 24th Jan 2022
- Severe Dysphagia Management standard – no transition period, will be auditable from 15th November 2021 for all applicable Providers but ONLY once the commission specifically lists Severe Dysphangia Management on the Provider’s NDIS Certificate of Registration, OR the Provider applies (via Variation or Renewal) to add this standard to their Registration.
What Happens If You Are Not Able To Fully Implement the Changes By Your Next Audit
Our auditors will assess your organisation’s level of compliance against the new requirements through a combination of review of your organisational policies and procedures, records, staff and participant files, as well as interviews with staff and participants, and tours of your service delivery locations (where applicable).
Audit findings may be raised where your organisation does not yet meet the new requirements, which will require your action within the necessary timeframes depending on the severity of the issues, while taking a proportional approach based on the size and complexity of the organisation and the level of risk to staff and participants.
I have an upcoming Stage 1 / Stage 2 / Re-certification / Verification audit that is commencing on or after 15th November 2021 – do the new Practice Standards and Quality Indicators apply immediately?
Yes, for Providers undertaking Stage 1 / Stage 2 / Re-certification / Verification audits on or after 15th November, all of the new Practice Standards and Quality Indicators apply immediately and must be assessed at the audit (where applicable). This includes:
- Core 2.9 Disaster & Emergency Management
- Core 4.4 Mealtime Management
- Module 1.3 Severe Dysphagia Management
- Updates to existing Core Module standards (e.g. risk management, HR management, safe environment etc.)
- Update to Module 3.1 “The Child”
- Updates to Verification Module
This is regardless of when (i.e. before or after 15th Nov 2021) the Provider submitted their application for registration (new or renewal).
I have an upcoming Surveillance (Mid-Term) audit that is commencing from 15th November 2021 – do the new Practice Standards and Quality Indicators apply immediately?
No, for Providers undertaking Surveillance (Mid-Term) audits on or after 15th November 2021, transition periods apply as follows:
- Mealtime Management standard:
- not applicable for mid-term audits between 15th Nov – 12th Dec 2021;
- applicable from 13th Dec 2021
- Emergency & Disaster Management standard:
- not applicable for mid-term audits between 15th Nov 2021– 23rd Jan 2022;
- applicable from 24th Jan 2022
- Severe Dysphagia Management standard:
- Nno transition period, will be applicable from 15th November 2021 – HOWEVER this standard is not to be audited until either:
- The Provider has formally applied for Severe Dysphagia Management with the Commission (either via Variation or via Renewal Application), OR
- NDIS Commission have added Severe Dysphagia Management to the Provider’s Certificate of Registration (auditors should check with Providers prior to audit whether they deliver Severe Dysphagia Management, and if so, has the Commission added it to their Certificate)
- Nno transition period, will be applicable from 15th November 2021 – HOWEVER this standard is not to be audited until either:
- Updates to existing Core Module standards (e.g. risk management, HR management, safe environment etc.):
- not applicable for mid-term audits between 15th Nov 2021– 23rd Jan 2022;
- applicable from 24th Jan 2022
- Updates to Module 3.1 “The Child”:
- not applicable for mid-term audits between 15th Nov 2021– 23rd Jan 2022;
- applicable from 24th Jan 2022
- Updates to Verification Module (ONLY if part of a Mid-Term Audit of the Verification Module with Modules 3 & 3A for Early Childhood Sole Traders/Partnerships):
- not applicable for mid-term audits between 15th Nov 2021– 23rd Jan 2022;
- applicable from 24th Jan 2022
If the new standards apply to a Provider at the time of their audit, are non-conformities to be raised if they fail to meet any of the new requirements?
Yes, non-conformities will be raised where a Provider does not meet the new requirements, if those requirements are applicable to the Provider at the time of their audit. The Provider will need to submit a Corrective Action Plan and Root Cause Analysis to the auditor as with any other non-conformity, and the non-conformity will need to be addressed within the applicable timeframe (90 days for Major Non-Conformity, 18 months for Minor Non-Conformity).
If a Provider had their Stage 1 audit prior to 15th November and has their Stage 2 or Re-certification audit after 15th November, are they still subject to the new standards?
Yes, Providers who have not yet completed the Verification or Stage 2 or Re-certification audit process are subject to all new standards (as applicable) from 15th November 2021 – no transition periods apply for these Providers.
If a Provider had an audit (Verification, Stage 2, Mid-Term or Re-certification) prior to 15th November and had Major Non-Conformities raised, will the new standards apply at the Follow Up audit if due after 15th November?
The NDIS Commission will consider this scenario and will get back to AQAs with advice.
If Severe Dysphagia Management applies immediately from 15th November 2021 to all Providers who deliver that type of support, does the Provider need to be audited against that standard at their audit?
For New and Renewing Providers (i.e. those due for Stage 2 or Re-certification) delivering Severe Dysphagia Management, this will need to be added to their Applications and audited accordingly from 15th November onwards.
For Providers due for Mid-Term audits, they will only be required to be audited for Severe Dysphagia Management if the Commission has added that support type to the Provider’s NDIS Certificate of Registration, OR if the Provider submits an application (Variation or Renewal) that includes Severe Dysphagia Management.
This means that, while technically there is no Transition Period for this standard, for most existing Providers they will likely not actually need to be audited to it until they are due for Renewal unless they apply for it as a Variation before this time.
However, Providers must still develop and implement their systems to meet the requirements of this new standard as soon as possible to ensure the safety of participants receiving these supports.