Registration is coming: how to prepare!

With registration soon to become compulsory for Supported Independent Living (SIL), support coordinators and platform providers - and all the signs suggesting this is only the beginning - is it time for unregistered providers to start preparing?

The registration process is hard work. The NDIS Commission wants to see under the bonnet - how your organisation works and what participants and staff think of you. And, if anything has gone wrong, they want to know why it happened and what you did to resolve it.

Auditors are required to assess how effective your systems, policies and processes are in addressing relevant modules of the NDIS Practice Standards. Auditors don’t just consider the contents of your policies and procedures, but how these are implemented in practice. If you are undergoing a Certification audit, the auditor will also visit sample sites and interview some of your participants.

And the cherry on top – you get to pay for the pleasure!

What’s changing in the world of registration?

At the moment, for most providers, the decision about whether to register is up to you. Mandatory registration has only been required for plan managers, SDA providers, specialist behaviour support providers, and anyone implementing restrictive practices. You can provide all other services without being registered. Non-registered providers can’t provide services to Agency managed participants, but with most participants being primarily Self- or Plan- managed this hasn’t been a major problem for providers.

But you might not have a choice much longer.

Work is now happening behind the scenes to overhaul the registration system. In December last year, the NDIS Review recommended compulsory registration or enrolment for all providers. The government then appointed an NDIS Provider and Worker Registration Taskforce (the Taskforce) to advise on the issue. The Taskforce handed down their Report in September.

The Taskforce recommended four levels of registration, instead of the current two. These would be based on the risk level of the supports the provider delivers:

Advanced Registration - high-risk supports such as behaviour support and supports provided in a closed setting like SIL and supported employment.
General Registration - medium-risk supports which are provided in the community or a participant’s home, such as personal care, high-intensity daily personal activities, community access, therapy, etc.
Self-Directed Support Registration - supports are contracted directly by the participant or their representative.
Basic Registration - lower-risk supports, such as some sole traders and supports where social and community participation involves limited one-on-one contact with participants.

They also recommended compulsory registration for all providers, except those who support self-directed participants in lower-risk settings and mainstream retailers who sell off-the-shelf goods.

To date, the government hasn’t responded to all the Taskforce's recommendations. However, it has announced that, as a priority, it is proceeding with compulsory registration for platform providers, SIL providers, and support coordinators. To do this, the government is beginning to consult on changes to the NDIS (Provider Registration and Practice Standards) Rules 2018 and the Practice Standards.

Last week, the NDIS Commission released a Regulatory Reform Roadmap that outlined the timeline for registration for SIL providers, platform providers and support coordinators. The timeline includes:

October 2024- March 2025- the NDIS Commission will consult on mandatory registration for these providers.
April 2025- June 2025- decisions will be made and a transition plan established.
No earlier than July 2025- compulsory registration for these providers will commence.

For providers, reviewing and updating your systems and making changes takes time. And you no doubt already have a long to-do list. So, it may be a good idea to start preparing sooner rather than later.

To learn about changes to registration, check out our articles: Compulsory registration coming soon for some providers, Breaking: the Registration Taskforce Final Report, Deep dive into the Registration Taskforce Report: Your FAQs answered and The NDIS Commission's reform agenda- major changes ahead.

Some tips for registration

Understand the registration pathways

There are currently two registration pathways: Verification or Certification. The pathway providers use is based on which supports and services they are registering to provide - these are referred to as registration groups.

Understanding the registration pathways is really important as the requirements vary quite significantly between them. They each have their own Practice Standards and quality indicators that providers need to meet. And you don’t want to waste time and energy getting ready to register using the wrong Standards.

So - what’s the difference between them?

Verification is for providers who only deliver supports and services classified as a lower risk or complexity. The Verification section of the Practice Standards is only two pages long, with four Standards. Audits are conducted via desktop and happen less frequently (every 3 years).

In contrast, the Certification requirements span 14 pages, with 24 Standards. And that’s just to meet the basic level requirements; there are even more Standards if you want to provide higher-risk or complex services. Audits happen more frequently (every 18 months) and are more in-depth, including interviews with participants and workers.

Providers considering registration should go to- Understanding what is involved in an audit (NDIS Quality and Safeguards Commission) and download the Application Pack - Registration Requirements by Supports and Services document.

Know which Practice Standards are relevant to you

DSC has developed a free tool to assist providers in determining which are the relevant Practice Standards.

All registered providers must also comply with the NDIS Code of Conduct and the following NDIS Rules :

Provider Registration and Practice Standards
Complaints Management and Resolution
Incident Management and Reportable
Worker Screening

These are all available for download at legislation, rules and policies (NDIS Quality and Safeguards Commission).

Identify your gaps

Once you have determined which pathway, it’s a good idea to complete a gap analysis against the relevant sections of the Practice Standards. This allows you to test how well your organisation complies with the relevant Standards and where to focus your energy on improving.

To assist, DSC has developed a gap analysis tool. We’re giving providers 30 days of free access. You can find the tool here: Practice Standards: Gap Analysis (available free for On-Demand subscribers). Use the code: GAPANALYSIS

Consult with your Participants

Don’t be tempted to quickly write a whole lot of policies and procedures.

Talk to your participants first. Find out what works for them and what suggestions they have for changes in your organisation.

A number of the Standards also mandate consultation with participants (such as complaints, incidents and governance) so start talking early so they can help you when developing your policies and procedures.

Keep up to date with changes

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And if the whole registration thing is causing you stress, or you just want to learn more, make sure you check out our upcoming workshop Preparing for NDIS Registration.