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Responsive Communication, a Quality and Safeguarding Imperative

How well do you communicate with your customers with complex communication needs? Faye reflects on how effective communication not only makes good business sense, but just how central it is to an effective and compliant quality and safeguarding system.


Updated 15 Apr 202411 Dec 2019

Imagine for a moment that you receive a letter from your bank, your accountant or your GP containing important information, yet it is written in hieroglyphics, rendering it nonsensical to you.

Or that you hop on your mortgage provider’s website to check your statement to find it’s just a big black screen.

Or being invited to a meeting with your lawyer and they talk to you in Shakespearian language.  

Not only would it be extremely frustrating, but it wouldn’t make any sense. Why would they communicate critical information with you, a valued customer, in a way you could not understand?

Even worse, how could you make informed decisions about your own life and affairs, when the information is presented in a way that you can’t comprehend?

I’m sure you can see what I’m getting at here.

And yet, we see this all the time in the disability sector, particularly where communication needs are varied and complex.  

A person is defined as having complex communication needs if they are “unable to use speech to meet all of their communication requirements, given their age and culture.” (Porter & Kirkland, 1995)[1]. 

The ABS’s 2015 Survey of Disability, Ageing and Carers (SDAC), estimated that 1.2 million Australians had some level of communication disability. This ranges from people who effectively use communication aids and function without difficulty, to those who cannot understand or be understood at all[2].

Communication is a fundamental human right[3] and we are meant to be in the business of advancing human rights. Failing to address communication barriers is not only disrespectful, it’s poor business sense and can even be negligent.

Let’s break it down further as to why this is so important:

1.     Dignity and respect – yes, many organisations say treating Participants with dignity and respect is paramount, but what steps do you take to show this? How many organisations have Easy Read documents or an accessible website so that they can convey respect by communicating with the Participant directly instead of via their carer or guardian? What about the imagery that is used, does is it promote the valued status of the people who use the service?

2.     Inclusive and accessible – this is another term that is bandied around by organisations on the regular. However, an organisation fails to be truly inclusive when the Participant cannot be included in meaningful decisions about their life because the communication used is not accessible to them. When the basics cannot be understood, inclusion suffers.

3.     Person-centred practice – is widely adopted in the sector and means ensuring someone with a disability is at the centre of decisions which relate to their life. It’s a process that involves listening, thinking together, coaching, sharing ideas, and seeking feedback. It is part of the ethos of the NDIS which is based around meeting the specific needs of the individual with a disability.

Given this, do you know what your Participants’ communication preferences and needs are? Do you know which Participant have complex communication needs and how they are best supported to make decisions? Is all of your communication done via their guardian or carer? How do you listen to Participants and share ideas? And, lastly, do your answers to these questions demonstrate that you are, indeed, truly person-centred?


But, if those things weren’t important enough, we also know that people with complex communication needs are more vulnerable to abuse, assault and neglect than others, as they are less able to report incidents. In light of The Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, it has never been more critical to ensure people with disability have a voice. Addressing complex communication needs is no longer just a thing nice to do, it is a fundamental safeguard in which we all have a role to play.

The NDIS Quality and Safeguards Commission has released the NDIS Code of Conduct, designed to work alongside other elements of the Quality and Safeguarding Framework to protect people with a disability and promote a safe and skilled workforce within the NDIS.

The Code of Conduct specifies that communication must be ‘in a form, language and manner that enables people with disability to understand the information and make known their will and preferences’.

It also is designed to ensure that people with a disability know their rights, know what to do if they are not happy with their supports and how to make a complaint. It is expected that people with disability are able to make informed choices about their services and supports, and who delivers them.

The Code of Conduct guidance material is definitive in what it expects of providers in relation to communication:

a. take reasonable steps to educate and support their workers to communicate in a form, language and manner that is accessible and appropriate for the individual and to use a range of communication tools to communicate with the people they support, using assistive technology and alternative forms of communication, such as email, text messages or symbols.

b. where the person speaks a language other than English or uses Auslan, match the person with a worker who speaks their language or uses Auslan (where possible), or provide supports using qualified interpreters, where these supports are covered by their NDIS plan.

c. confirm that the person with disability – and their families, carers or advocates (where relevant) – understands what has been explained, and is aware of potential benefits and risks associated with any part of a proposed plan for the delivery of supports and services.

d. respond to the will, preferences and concerns of the person with disability in relation to their supports and services – addressing requests or complaints where necessary.

e. where possible, provide consistent workers, so that they can build a good understanding of individual communication preferences and needs, particularly where an individual has complex communication needs.


But, wait, it doesn’t end there. Addressing communication barriers is woven throughout the NDIS Practice Standards and this will be assessed at audit. Requiring that “information is communicated to each Participant using the language, mode of communication and terms that the Participant is most likely to understand.”  This can be found in areas like service agreements, provision of supports, privacy and conflict of interest (just to name a few). Now is the time to start thinking about how you will evidence that you are communicating in a way that is best suited to the individual because failure to do can result in audit non-conformity.

Bottom line, compliance with the NDIS Practice Standards and Code of Conduct mean it’s no longer just an option to communicate with your customers in the way that suits them. The tide has turned and organisations can no longer put communicating with those with complex communication needs in the too hard basket. Under the NDIS, it is now a commercial and regulatory imperative.


1.     Know your customer, how they prefer to communicate and through which channels.  

2.     Get familiar with NDIS Practice Standards and Code of Conduct and what they have to say about your baseline requirements for communication as a provider. Then do better. It goes towards preventing abuse and neglect.   

3.     Remember, communication is a fundamental human right. We all want to be heard, understood and to have a say.

4.     Don’t just say you’re person-centred. Be person-centred.

5.     If you don’t know what to do, do some research and ask people who do!

[1] People living with complex communication needs

[2] Australians Living with Communication Disability, Australian Bureau of Statistics (2015),[email protected]/Lookup/4430.0Main+Features872015?OpenDocument



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