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Behaviour Support Practitioners Suitability Assessments

Therese covers what the new self-assessments will look like and the effort involved.

By Therese Morgante

Updated 15 Apr 202415 Feb 2021

In December 2020, the NDIS Commission (the Commission) released some much welcome details on the national implementation of behaviour practitioner suitability assessments, which have helped paint a picture of how Behaviour Support Practitioners will be assessed.These new details follow the Positive Behaviour Support Capability (PBS) Framework released in July 2019 and the Self-assessment Resource Guide for the Positive Behaviour Support Capability Framework (October 2020).

With all these documents, we are now starting to see a outline of what suitability assessments for behaviour support practitioners will look like, but there are still a few missing pieces of the puzzle.


The current state of play

Registered Behaviour Support Providers (registration group 110) seeking to register a Behaviour Support Practitioner (Practitioner) are required to complete a Notification of Behaviour Support Practitioner (S29) form. The information requested in this form focuses largely on demographic data and some brief details on education and experience. The registration of practitioners through this form relies largely on an assessment of capability by the Behaviour Support Provider (that is, not enough detail is captured to enable the Commission to make an adequate assessment). In practice, notification takes approximately 2–4 weeks, following which Practitioners are considered ‘provisionally suitable’ until they undergo an assessment against the PBS Capability Framework.

While we don’t know the exact date, the Commission’s recently released information indicates that this process will be phased out, requiring all new Practitioners to undergo the self-assessment process. We are also unsure how long the self-assessment process is going to take. Given that we hear from a lot of participants, Behaviour Support Providers and individual Practitioners about the extensive waiting lists for behaviour support (in excess of six months in some places), we are concerned that the new process may delay the time it takes to register new practitioners. 


The self-assessment

The Commission has released the proposed dates by which Practitioners need to commence preparing their self-assessment:

 As each state goes online, Practitioners will be sent an email notifying them that they must submit their self-assessment within 12 weeks. Practitioners who don’t submit within the timeframe will have their ‘provisional suitability’ withdrawn (they will no longer be able to provide NDIS behaviour support services). Practitioners who submit within the timeframe will maintain their ‘provisional suitability’ until they receive an outcome from the Commission.

The self-assessment requires Practitioners to: 

A)        Review the PBS Capability Framework and determine the level at which they are seeking registration (Core; Proficient, Advanced or Specialist)

B)         Undertake the self-assessment at all levels below, including the one they are seeking registration for (for example, a Practitioner seeking to register at an Advanced level must also complete the Core and Proficient self-assessments)

C)         Provide evidence to support their self-assessed capability rating

D)        Seek endorsement from their supervisor following their self-assessment

E)         Attach the following documents:

a.          Curriculum Vitae

b.          Continuing Professional Development Plan

c.           Professional Learning Goals Achievement Record

d.          Supervision Agreement & Supervision Record

Review by the Commission 

Following receipt of the self-assessment from the Practitioner, the Commission will, as soon as reasonably practicable [a direct quote from the NDIS (NDIS Behaviour Support Practitioner Application) Guidelines 2020], consider the application and associated documents and thereafter notify the Practitioner in writing that:

  • They are considered suitable;
  • They are considered unsuitable (the Commission will give the Practitioner the opportunity to respond before making a final determination); or
  • The Commission did not have enough information to make a decision regarding suitability.

There is some additional information in the Guidelines about what the Commission might do when determining suitability (for example, ask for more information or speak to a supervisor), as well as the process for how the Commission might revoke one’s suitability status.

Implementation - opportunities and challenges

Behaviour Support Services is one of the only services funded under the NDIS that mandates the registration of both providers and individual practitioners—and for good reason. When supporting people who are subject to restrictive practices, it is critical that the people funded to oversee their use are skilled and experienced. The cost to people with disabilities and their families is just too high if things go wrong.

The self-assessment tool is extensive. When completed as intended, it will provide a rich resource to support Practitioners in their professional development and enable Behaviour Support Providers to offer reflection and feedback opportunities that can enhance the quality of services provided.

The self-assessment (including evidence gathering), however, represents a significant investment of time and resources. The Behaviour Support Providers and individual Practitioners we have spoken to often commented that the compliance requirements of the Commission (for example, supervision) are not adequately funded by the Agency, thereby making compliance a real challenge.

The Guidelines state that the Commission will only provide feedback on a self-assessment when requested by the individual Practitioner. The process for and the skills of the personnel undertaking the suitability review remain unclear, and when the extensive work put into a self-assessment is reduced to a single- or double-word outcome – ‘suitable’ or ‘not suitable’ – it’s difficult to see how this will generate buy in.

The other key issue is the timeframe. Without any clarity on when the Commission will notify Practitioners of the outcome, there is a real concern that we will we see a repeat of the audit/registration process wherein providers invested heavily to ensure both quality and compliance, yet they were left, sometimes for more than 12 months, without an outcome. This will inevitably lead to frustration, with Behaviour Support Providers and individual Practitioners reducing their investment in a process that is not prioritised by the Commission.

The Commission’s self-assessment process entails a lot of effort from Behaviour Support Providers and individual Practitioners. We believe there is a lot to be gained by people with disabilities, their families and the sector in general if the process is implemented effectively. 

NB: In preparing this article, we put a number of questions to the Commission including: 1) when the provisional registration process is expected to cease; 2) the timeframes for notifying Practitioners following submission of their self-assessment; 3) who will be undertaking the suitability reviews; and 4) a couple of other queries. We’ll let you know when we hear back from them.

Authors

Therese Morgante

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