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Question: A new manager has started in our organisation and has said we’re not collecting enough evidence about shifts and services delivered to be compliant with NDIS requirements. Our workers do very basic case notes for most, but not all, shifts. We don’t want to be non-compliant but we also don’t want to create unnecessary work for ourselves. What documentation does the NDIA expect us to collect?
Your new manager is correct! So you should probably thank them… for all the extra work they have just created for you.
The NDIA actually has quite clear guidelines on what records and documents they expect providers to collect as part of, and to evidence, service delivery.
These aren’t legal requirements: they aren’t mandated in the Practice Standards or the NDIS Act. But they are what the NDIA wants, and will facilitate prompt payment of claims, and might well save your bacon in the event of a Payment Integrity Audit.
The record keeping requirements are outlined on the NDIA’s page about invoicing and record keeping. They outline that the NDIA expects providers to keep records on:
- Participant’s name
- Participant’s reference number (previously NDIS number)
- Date(s) and total hours and/or quantity of the support delivered
- Support type (i.e. the kind of service being delivered)
- Location of support being delivered
- Service Agreement containing the schedule, cost, quantity, type and quality of supports to be delivered and their location; as well as the expected outcomes for the participant (note: take a look at our Service Agreements Refresh workshop if you want to dive into how to make agreements that reflect the most recent NDIA changes)
- Approved quotes as appropriate
- Evidence of support quantity
- Evidence of support type
- Staff rosters
- Final report or assessment.
This is expected for all services.
These requirements relate to what evidence a provider is collecting. We’re not going to go into what info needs to be on an invoice - that’s a discussion for a different day.
Additional requirements for specific services
The NDIA also adds extra things they expect providers to record and collect if they deliver specific services. Again, this is for each individual instance of service delivery. A few examples include:
- For Assistance with Self Care Activities, the NDIA expects a support log and service agreement.
- For Assistance to Access Community, Social and Recreational Activities, the NDIA expects a support Log, a case note and a service agreement.
- For Group Therapy supports, the NDIA expects a roster (which the NDIA defines as ‘the activities engaged in, staff to participant ratios and record that a participant attended as scheduled’), a case note and a service agreement.
- For Short Term Accommodation, the NDIA expects a service agreement.
- For Employment Preparation and Support in a group setting, the NDIA expects a roster and a service agreement.
The full list is here: Documentation by support type (PDF). I really recommend you download it and start embedding these requirements into your systems and expectations.
Before anyone says it: yes, the NDIA isn’t consistent in how they name Support Types and even Support Categories in other documents, like the Pricing Arrangements and Price Limits. The NDIA isn’t consistent in their communication and expectations: in other words, water is wet and the sky is blue. That’s business as usual at this point.
Why would we do all this extra work?
Well, there’s a range of reasons:
- These documents and records are the first things the NDIA asks for in Payment Integrity Audits, which are happening more frequently these days. And this evidence is also just generally useful to be paid smoothly and promptly.
- There have been legal cases where these records are requested. That’s not a time you want to be caught short!
- It’s good practice to have these records not only for NDIA purposes but also for quick and accurate responses to participants' questions.
- Gaps in records can raise red flags for the NDIA.
Also note that these are the minimum expectations of the NDIA. There’s nothing stopping providers from having more in place, if you decide it would be beneficial.
Any tips?
Of course! A few things to try:
- The NDIA provides samples of Support Logs and Rosters, in both pdf and docx format. Look for them at the bottom of the invoicing and record keeping page. These can be a template to start making your own standardised templates and forms.
- Include record keeping requirements in training and induction for staff. You could even embed them into your recruitment questions to ensure new staff are ready to hit the ground running.
- Lean on your existing software systems for support- some CRMs and rostering systems have advanced record keeping templates, auto-prompts, voice-to-text functionality and even AI support.
- Map the services you deliver to the NDIA’s expectations on record keeping. If you go above and beyond, make sure there’s a good reason why.
- As always, make sure all this information is secure.
