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I am a Support Coordinator trying to assist a participant to find a provider that will administer insulin. We have been going round in circles for months - almost every provider has told the participant that a Support Worker legally cannot give the insulin injection, that it must be an Enrolled Nurse or sometimes even a Registered Nurse. The person’s NDIS Plan does not have the budget for this. Are these providers correct - can Support Workers administer insulin?
Insulin can be dangerous or even fatal if administered incorrectly, so there can’t be a ‘she’ll be right’ approach to who does it, eyeballing dosages and infection control. Yet, it’s also dangerous or even fatal for a participant not to get the insulin they need! Therefore, it’s vital to look at the conditions that would allow insulin to be administered in a safe way.
The bottom line is yes, Support Workers can administer insulin injections, under the delegation of Registered Nurses (RN). As in, there is no explicit law or NDIS rule to stop someone with the title of ‘Support Worker’ doing so when all other requirements are met. There are quality and training requirements that registered providers need to meet for Support Workers to administer subcutaneous injections. The NDIA can also build people’s plans based on this High Intensity support being delivered by Support Workers. The challenge is that some providers can’t offer this service (due to insurance limitations) or don’t like to offer this service (due to risk appetite). Let’s look at when Support Workers can administer insulin, and the conditions a provider needs to meet.
Please note: to the continued disappointment of my father, I am not a doctor or a lawyer. This is general information, and you should seek medical / legal advice for specific and technical enquiries.
NDIS Commission Skills Descriptors
One of the ways we know that Support Workers can administer insulin injections is because the NDIS Commission has training requirements for Support Workers from registered providers to administer injections. The Commission acknowledges that this practice has some inherent risks, even when delegated by a Registered Nurse. So outlines the extra requirements in the High Intensity Support Skills Descriptors. For subcutaneous injections (which is the delivery method for insulin), the provider must ensure that the injections are overseen by a relevant health practitioner. But that practitioner does not necessarily have to administer them. So, a Registered Nurse (RN) might train Support Workers, complete a support plan that is detailed and involves the person, identify risks, and design processes for incidents and emergencies.
The NDIS Operational Guidelines also state that the Registered Nurse maintains the ultimate responsibility for the tasks they delegate. The RN has responsibilities to consider within their APHRA scope of practice, including those outlined in the Nursing and Midwifery Board Decision Making Framework.
I encourage every provider to use the Skills Descriptors (and the relevant Practice Standards) as a live document to inform and shape service planning. We also have some excellent on-demand eLearning about remaining compliant with the High Intensity Supports Skills Descriptors, free when you’re a DSC On-Demand member!
NDIS funding for tasks delegated by a Registered Nurse
In fact, it’s not only that the NDIA and NDIS Commission ‘allow’ Support Workers to complete support tasks that are delegated by a Registered Nurse: they build people’s NDIS Plans based on that happening. The NDIA has an Operational Guideline on how they determine what hours are funded as Standard Intensity compared to High Intensity, and it’s all based on the number of tasks delegated by a RN for a Support Worker to complete.
Insurance and risk
So, if you calmly explain all this to those providers, will it result in them being willing to have their Support Workers administer insulin?
Probably not. Because the reason, practically, is usually something outside of all these facts. Usually, the barrier is the insurance coverage a provider has, or their internal policies and procedures outlining what they will deliver. Sometimes it comes down to whether they can easily access an RN to do the required training and perform the required oversight. Or sometimes it’s the provider’s own risk appetite (there is no doubt that administering insulin brings extra risks - that’s why we have the Commission’s Skills Descriptors), and sometimes it’s another reason completely.
It’s definitely worth asking some pointed questions about a provider’s understanding of the Skills Descriptors, including what they are registered to deliver. It’s also a good idea to go into a Planning Meeting asking for extra Capacity Building funds so the provider will be able to bill for the time it takes to train Support Workers to administer the insulin, particularly if you suspect the dollars in a person’s NDIS Plan might be a barrier for providers safely delivering this support.
But as I so often explain to my children, you can be technically right and still end up facing the same challenges. And this is a problem many participants face, especially in thin markets, with no simple solution.
And to reiterate: administering insulin can be a risky business that can create serious health risks and death. We’re not talking about Flintstone’s Gummy Multivitamins here. So, while Support Workers can administer it, the RN should be fully aware of their responsibility. And everyone else involved should still be 100% sure that best practice is being followed, the provider has systems in place to identify and respond if things go wrong, and that the requirements in the High Intensity Skills Descriptors are being strictly adhered to.
