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Hi! Welcome to the first edition of our new quality and safeguarding newsletter. In this newsletter we will be delving in to the finer detail of quality and safeguarding in the NDIS with a view to improving quality and safeguarding literacy and reducing some of the angst. Our articles will focus on issues we identify through our consulting work and workshops, mixed with some stuff we just think is really important. If you have an article idea please email us and we will see if it something we can write about. Guest contributions will also be considered. In today’s edition we reflect on some of the common questions we’ve been fielding around the NDIS Practice Standards. We will drill down further in to the detail in future editions.
What do we need to know about the NDIS Practice Standards?
Our quality team has been working with providers in each state and territory to try and help them decipher and apply the NDIS Practice Standards. Some providers are getting a little hot and bothered, particularly if they’ve waited until audit time to take a good look at them. So don’t leave it until the eleventh hour, start reviewing the standards with your staff now. They are nothing to be concerned about but they are different. There is a strong outcomes focus and a real emphasis on accessibility and addressing communication barriers. There is also an expectation that risk management will be proportionate and support dignity of risk. Another change is that the standards are modular and vary according to your organisational structure and types of service you provide. If you aren’t sure check out this handy tool.
Do we need new policies and procedures?
Probably, or at least you will need to update what you have. We really recommend doing a gap analysis against the standards. This is where you examine all the evidence you have to meet the outcomes and each quality indicator. It is a really good visual tool to see where you have gaps, which areas your organisation is focussing and where you could potentially streamline and even reduce administrative burden. There are some big changes in things like reportable incidents, complaint oversight, restrictive practice, behaviour support, code of conduct and mandatory worker requirements. You need to get across these and develop robust systems to ensure you meet them. The NDIS Quality and Safeguards Commission is also producing loads of resources to assist you, so get on their website and take a look.
Do we just need to reference new legislation?
Another common approach is just to add the new legislation to existing policies and procedures. Many providers do this over time and procedures end up looking like a pot luck dinner and no one really knows what is bubbling away in there. This can be problematic because if we aren’t clear about which legislation we need to meet, we cannot develop proper systems and controls to implement it or monitor changes. Furthermore, there is a strong emphasis on governance and quality management systems in the new standards. So you need to be able to define your system and explain how you identify and meet all your obligations. If you go off track or find yourself shoehorning old processes it can be really useful to go back to the NDIS Quality and Safeguarding Framework to reflect on the intent of the changes.
What about the small guys?
But I am such a small provider, isn’t this overkill? True proportionality is a widely shared concern and it is still a work in progress. That said, even small providers need to document their organisation’s expectations and processes to ensure consistent, informed, quality practice. Even if you only have a handful of staff, what happens if you were suddenly out of action? Would services be able to continue? Providers have an obligation to ensure continuity of support so documenting your processes is important. Just don’t overcomplicate it, make it relevant and useful to the work that you do. We will be publishing an article on quality and safeguarding for allied health professionals soon.
Can you sell us an NDIS manual?
We get asked this a lot. There are a number of compliance products available that promise to look after an organisation’s compliance for them. We understand the appeal, everyone is still spinning from NDIS transition and now we have to adapt a new quality framework! We generally prefer to work with organisations to help them tailor their systems because in order to comply with the NDIS practice standards you need to do stuff like achieve outcomes, understand what keeps people safe and take action. I recently heard the NDIS Commission Registrar comment that these are practice standards not policy standards. Purchasing a policy manual is a bit like buying a cookbook, whilst aesthetically pleasing, it is not going to improve your cooking skills if you don’t use it.
Some organisations might find some of these policy products useful in setting the foundations to build out their procedures. Just ensure you have confidence in the authorship, the Commission iterates that it does not endorse these products so do your own due diligence. If you decide to purchase one as a template, you still need to understand what is in it, develop systems for implementation, identify responsibilities and ensure adequate training. Keeping in mind, the NDIS practice standards are modular and tailored, there is no one size fits all. So if you are an equipment manufacturer that stocks a medication administration procedure you might run the risk of signalling to an auditor you haven’t read your procedures. The new quality and safeguarding requirements are forcing action. There is no takeaway pizza option, only those meal kits where you have to purchase the fresh ingredients and do the prep and cooking.
Where do i start?
Do a gap analysis against the practice standards. It is a great way to understand what you don’t have, what you might need to change and to ensure you understand what the standards mean to your organisation. Get on the Commission’s website and make sure you understand the NDIS Code of Conduct and all the mandatory requirements too – this will also help you interpret and apply some of those practice standards. It is a big undertaking to implement, yes, but if you engage your whole organisation in the quality process it will likely have great benefits for all.
