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Allied Health / ECEI
Quality & Safeguarding
Dealing with Audit Anxiety: An Allied Health Perspective
Most Allied Health Professionals (AHPs) are registered and regulated under the Australian Health Practitioner Regulation Agency (AHPRA). This includes demonstrating ongoing professional development, recency of practice, criminal history declarations and professional indemnity insurance. This means that AHPs should already have some quality and safeguarding systems in place that are relevant under the NDIS. I know the word ‘audit’ word tends to get everyone a bit nervous but today I want to tell you, you probably got this more covered than you think!
The NDIS quality and safeguarding requirements are about raising the bar in service quality, and generally speaking, AHPs are experts in delivering safe, competent and person centred practice. So preparing for audit should be about drawing on evidence of the great work you already doing, using Practice Standards as the guide. Here are a few tips for preparing for audit:
Find out which modules you must complete based on your Registration Groups. Find the Practice Standard under each module and look at the related outcomes and indicators.
Examine your systems, practices, documents and records and match them against the Standards.
List your gaps and make a plan to fill them.
Sounds simple right? I have some more tips so keep reading.
Understand what you do well
AHP’s traditionally have strong practices in place around:
Demonstrating choice and control and person centred practice by facilitating goal setting, confirming Participant understanding, incorporating Participant preferences and providing choice about location of therapy.
Providing education through a variety of methods including verbal, written, video, infographic and repetition.
A strong grounding in informed consent including providing options, explaining risks and asking questions at appropriate times.
A strong commitment to safe practice and reducing harm.
Mandated ongoing professional development.
So find evidence in your case notes, information sheets and training registers and start ticking off some of those Practice Standards.
Only register for the services you actually deliver
The quickest way to reduce your audit preparation workload is to de-register from the registration groups you are not providing. You can always add new registration groups in the future. AHPs can register for everything below, but it doesn’t mean you should register for everything below.
Therapeutic supports
Specialist positive behaviours supports
Early childhood early intervention
Specialist support coordination
Specialised hearing services and hearing services
Exercise physiology and training
Specialised driver training
A heap of assistive technology and consumables: custom prosthesis, home modifications, assistive products for personal, car and safety, personal mobility equipment, vehicle modifications, vision equipment, assistive equipment for recreation and assistive products in household tasks.
Join an Allied Health social group
You are not alone. The registration group with the largest numbers of approved providers is Therapeutic Supports. It grew by 5 % in the last quarter to 7541 providers, and is continuing to grow. Whilst this may mean increased competition, it also represents a large pool of potential comrades. Join a social media group specific to the NDIS and Allied Health to ask questions, be inspired and find like-minded AHPs you may be able to pool resources with.
An opportunity to engage with all stakeholders
Most business owners are already regularly reviewing and improving their service and business model to ensure success and viability. Use the audit process as an opportunity to prioritise a system review. Don’t do it alone - engage with staff and Participants about how to do things better. Validate that your practices are safe, evidence based, person centred, efficient and meeting NDIS Practice Standards. Extra work today will likely reap benefits for everyone in the future.
Beware the pitfalls of purchasing procedures
The idea of purchasing a package of procedures to meet compliance is so attractive but we have seen many organisations come undone at audit time with this approach. Consider whether a purchased procedure can reflect the unique practice at your workplace. Procedures should reflect the work you do – and auditors will be looking for evidence that your practice matches your documented procedure. That said, if you are looking for more guidance on implementation within the allied health context, the Allied Health NDIS Registration Support website supports AHPs with registration and includes templates and policies that you can customise to your organisation’s needs.
Verification v certification
As of the 1st January 2020, more AHP providers can use the verification pathway for audit. This is great news because the verification process is generally easier and less expensive. Verification is the audit process that applies to Providers who deliver lower risk services and supports.
Certification will still apply to AHP providers working in the higher risk areas of Early Childhood, Specialist Support Coordination and Behaviour Support and more specific quality and safeguarding requirements will need to be met.
If you aren’t sure which pathway applies to you, contact the Commission.
There are only four Standards in the Verification Module:
Human resources: Think employment checks, staff qualification register and annual checks for registration. Also keep a register of who has completed the NDIS online orientation training.
Incident management: You will need a procedure for this one. It needs to include your definition of an incident and your reporting process including timeframes and when to inform the NDIS Commission. Your procedure should also include how you will communicate with the Participant and your processes for recording, investigating and learning from incidents.
Complaints management: You will also need a procedure for this one. Your staff and Participants need to know how to give feedback or make a complaint to your organisation and to the NDIS Commission.
Risk management: This is the big one for AH. It includes getting appropriate insurance but also identifying and reducing risks. Here is a quick list to get your thinking started about risk management:
Infection control
Home visits
People manual handling
Other manual handling like lifting wheelchairs into a car
Competency for high risk tasks
Participant information sheets such as exercise programs and therapy instruction
Documenting conversations about risk with Participants
AHA delegation
In-service programs
Supervision
I want to end where I started:
Allied Health - you probably got this more covered than you think!
Don’t just look for evidence that you meet the Practice Standards in your policies and procedures. Review case notes, information you give your Participants and have on your walls and website, staff registers, staff meeting minutes and the way you conduct orientation and support your staff. Prioritise your list and anything you don’t get to now, put in your continuous improvement plan to work on later. Embrace the audit process as an opportunity to do things safer, more efficiently and to a higher standard.
Good luck with your audit preparation and may it bring your business prosperity.
