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If you have had a good look at the NDIS Practice Standards you may have noticed that they are quite different from what our sector has seen before. Yet, they are actually kind of cool (in a quality and safeguarding kind of way). What we find exciting is that they focus on Participant outcomes instead of services. That is why we are all here after all, so it really makes sense.
The NDIS Quality and Safeguards Commission has released them in this format, which has unfortunately left some providers more puzzled than they were before. So let’s take a look at the structure. During the self-assessment process, you will be advised on which modules you will need to meet depending on your registration groups and organisational structure. Essentially, within each module there are a number of Practice Standards, within each Practice Standard there is an outcome and each outcome has a number of indicators. Kind of like Russian dolls.
The indicators tell us how we can demonstrate to the auditor and the Commission that we are achieving the desired outcome for Participants so we want to start looking closely at those.
So, from outputs to outcomes, is it just the same thing in a shiny new suit? We don’t think so. DSC have had the privilege of supporting organisations in gap analyses to get ready for re-registration and it has become apparent that the goal posts have shifted significantly.
Many organisations have come armed with a suite of extensive policies and procedures that might have once been praised by auditors. But how are these going to hold up in an NDIS environment? Let’s take a look at the Practice Standard for privacy and dignity as an example.
Your organisation needs to ensure that each Participant accesses supports that respect and protect their dignity and right to privacy. If your systems are not delivering on this outcome, they need to be reviewed.
Remember, the indicators give the auditor markers to establish how a provider can meet that standard. For example, let us say that Happy Valley Disability Service has an extensive privacy policy that cites all the legislation, and was reviewed by the organisation’s solicitor to ensure it covered all compliance requirements. Happy Valley’s staff and Participants might not fully understand it because it was written for another audience. That aside, Participants receive it in their welcome pack and staff sign off on it at induction. What evidence do you think Happy Valley could provide to the auditor that they meet these indicators? Potentially, they could demonstrate consistent processes, but might be caught out on the other two requirements.
On the other side of town, we have Sparkly Support Co. They have really simple processes that they use to explain to each Participant their right to privacy, confidentiality and dignity. They have written down their expectations and processes clearly to ensure staff are aware of how to consistently apply these principles and they provide training to ensure everyone understands. Sparkly Support provides information in a way that is tailored to individuals. They realise that a person’s personal information is their own and are diligent about seeking informed consent. Naturally, they use a variety of techniques to achieve this outcome, because this is the only way to effectively achieve results in the diverse NDIS environment. When the auditor assesses the Sparkly Support Co. system, they can see that the process is functional, consistently applied and that Participants’ feedback suggests they are happy with the outcomes.
The Practice Standards are full of indicators that require information to be delivered in a way people understand and give Participants more choice and control over their information, supports and self. As one person at a recent workshop exclaimed “wow, do you mean people actually have to understand these policies!?” What a novel idea.
The other thing to be mindful of is that documented processes are only one part of the audit, there is also a requirement that people actually do the things they say they do and that they achieve positive outcomes for Participants. So before signing up to a suite of policies, make sure they reflect your practice and achieve the required (and desired) outcomes.
This is a really good time to step back, look at what you’ve got and map it against these outcomes and their associated indicators. You might be surprised how much might need to change, and, how much you may no longer need.
Yes, it is going to be painful in the short-term. It’s a lot of work to get our heads around yet another set of standards. However, if we do it right the first time, it will hopefully lead to better systems that produce higher quality services for Participants. In other words, the reason we are all here in the first place.
I liken it to cleaning out a cluttered cupboard that has decades worth of odds and ends. You get everything out, only to realise how much work you have to do. But if you invest in getting the cupboard organised, you throw out what you don’t need, you’ll end up with a much more organised and functional cupboard with everything at your fingertips. That way you can get on with the business of running a really successful organisation that helps people with disability live bloody good lives…and you’ll know exactly where to find things when the auditor comes to the door.
