Quality, Safeguards & the Pandemic

In response to the pandemic, the NDIS Quality & Safeguards Commission recently reminded providers of their obligations under the NDIS Code of Conduct and Practice Standards. Below are some of the questions Team DSC thinks providers should be considering in key areas. This list is not meant to cover all areas of Commission concern but is designed to assist you with prompts and a starting place for your organisational responses.

NDIS CODE OF CONDUCT

1.    Provide supports and services in a safe and competent manner with care and skill

Things to consider:

• Have staff received adequate training around safe hygiene practices?

• Do replacement staff have access to the relevant Participant information to deliver support? What does this look like?

• Do replacement staff have the required checks and skills to deliver the services? How do you know?

• What PPE is in place to enable staff to provide supports in a safe, hygienic way?

• What information is available to support Participants' understanding of safe hygiene practices?

2.    Promptly take steps to raise and act on concerns about matters that might have an impact on the quality and safety of supports provided to people with disability

Things to consider:

• Have incident management processes been updated to include quick notification of COVID-19 concerns? Have staff been briefed/trained to respond?

• Are there clear communication and reporting requirements in place for staff to report illness, self-isolation or quarantine?

• What process is in place to manage COVID-19 diagnosis for Participants - how is this communicated and how does it trigger your risk management response?

NDIS PRACTICE STANDARDS

3.    Governance and operational management including:

a.     Robust governance and operational management system

Things to consider:

• Is the reporting to the board around risk streamlined and responsive?

• Has your emergency response plan been updated to include responses to the pandemic?

• How are you monitoring and responding to the changing pandemic environment?

b.     Considering organisational risks, other requirements related to operating under the NDIS, participant’s and workers’ needs and the wider organisational environment in your strategic and business planning

Things to consider:

• Have you identified all the pandemic related risks to your business operations: financial viability, OH&S and information management and is there a clear plan (including a communication plan) outlining the steps required to mitigate?

• Does your pandemic plan address all the risks and associated mitigation?

• Has your incident management process been updated to include COVID-19 reporting? Has it been streamline for ease of access by staff and Participants?

c.     Identifying and managing risks, both to participants and workers

Things to consider:

• Have you identified all the pandemic related risks to Participants and staff?

d.     Analysing, prioritising and treating risks to the organisation, including participants, work health and safety risks and risks associated with providing supports

Things to consider:

• Does your pandemic management plan include a plan to analyse, prioritise and treat risks to the organisation: financial liability, Q&S compliance, mandatory reporting (including under the National Notifiable Disease Surveillance System), business operation continuity, workplace health and safety?

e.     Ensuring continuity of support so that participants access timely and appropriate support without interruption, including that disaster preparedness and planning measures are in place to enable the continuation of critical supports before, during or after a disaster.

Things to consider:

• Are critical supports identified and alternate arrangements in place in the event of a Government directed lockdown, how long can they be maintained?

• What is in place for the transfer of Participant care if you are unable to ensure continuity of support? Note: this will require notification to the Commission if enacted.

4.    Provision of supports environment, including:

a.     That each participant must access supports in a safe environment that is appropriate to their needs. This includes, where relevant, you working with other providers and services to identify and treat risks, ensure safe environments, and prevent and manage injuries

Things to consider:

• What hygiene, distancing and respiratory practices have you implemented to keep Participants environment safe?

• Where Participants have multiple providers, is there a shared plan to maintain their services in a safe environment? Is this easily communicated and can be acted upon simultaneously by all parties?

• Have you identified what constitutes an unsafe environment and is there a plan to mitigate?

b.     Verification standards include a requirement for risk management, including managing work health and safety, which requires protecting the health, safety and wellbeing of workers and others who may be affected by work activities – including NDIS participants.

Things to consider:

• Do you have a plan to manage the pandemic which identifies the risk to Participants, workers and your organisation?

• Does the plan enable you to act on issues of health, safety and wellbeing of Participants and staff?

DSC has released a Guide for NDIS Support Providers: Developing a Business Continuity Plan in Response to COVID-19. This guide can assist providers to address many of the obligations raised in the Commission's Provider Alert.