Provider Webinar: Compulsory registration and your NDIS business - A path through uncertainty
What’s changing and how to navigate the changes
The NDIS Provider and Worker Registration Taskforce, led by human rights lawyer, Natalie Wade, recently provided advice to the Australian Government on the design and implementation of a new regulatory model for NDIS service providers.
Termed a ‘graduated, risk-proportionate regulatory model’, this new framework has been earmarked to be ‘immediately implemented’, with changes to the NDIS Provider Registration and Practice Standards Rules 2018 happening this month (October) and these changes will directly affect:
Platform providers, Hireup, Mable etc
Supported Independent Living (SIL) providers, and
Support Coordinators.
This webinar unpacks exactly what these changes are, how they’ll affect business as usual for affected providers and give you a framework to work through to either get up to speed or make sure you’re on the right track.
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Links and further information:
NDIS Provider and Worker Registration Taskforce Advice
Summary of Taskforce recommendations
Factsheet: What does this mean for Providers
Factsheet: What does this mean for Workers
Factsheet: What does this mean for Participants who self-direct
NDIS Provider Registration and Practice Standards Rules 2018
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Hi, everyone, welcome.
We're just going to let everyone in and give everyone a minute to rock up and then we will jump in.
Hope everyone's got their cup of tea or water or lunch as lunch breaks would be happening right now.
We'll get started really shortly.
There doesn't seem to be much more movement.
Let's let's kick off.
Hi everyone, welcome to the Kenora webinar, Compulsory registration and your NDIS business, A Path Through Uncertainty.
My name is Yvette, I'm part of the team here at Kenora, and I'm also joined by Erin who will be manning the chat If she pops up at one point, there she is.
If you're a Kenora member, you may already know us as coaches within the community.
I'm sure you are all fully aware.
The NDIS Provider and Worker Registration Task Force, led by prominent human rights lawyer Natalie Wade, recently provided advice to the Australian Government on the design and implementation of a new regulatory model for the NDIS for NDIS service providers, termed a Graduated Risk Proportionate Regulatory Model.
This new framework has been earmarked to be immediately implemented with changes to the NDIS Provider Registration and Practise standards rules happening this month, which is October for anyone watching the replay.
And these changes will directly affect platform, platform providers, examples of higher up and Mabel etcetera supported independent living providers and support coordinators.
So we are here today to unpack exactly what these changes are, how they'll affect business as usual for providers, and give you a framework to work through to either get up to speed or make sure you're on the right track, whether or not you're one of the affected providers or if registration might be in the near future for your business to do this.
Thankfully, we are lucky enough to be joined by Angela Harvey of Supporting Potential, who is all over these changes and works with providers organisations to strive for and maintain best practise and compliance in the NDIS sector.
Angela, thank you so much for being here today to share your insights.
Thanks for having me a bit.
I love speaking to the Kenora community.
We're so glad, so glad.
All right, just before we get started, a brief background on Kenora.
Excuse me, if you're not already a member, Kenora is a safe and supportive online community where you're able to get support for your NDIS questions from us coaches and our community of thousands of NDIS participants, their families and service providers.
You can also list your services on our provider marketplace.
If you're already a Kenora member, you may be aware that we record these sessions and share the replay of the webinars and any resources that we speak about on Kenora.
If you're not already a member, don't worry, we'll send you the replay and resources direct to your inbox.
All right, housekeeping for today's webinar, if you would like to set up closed captions, go to the top of your screen and click More than, select Language and Speech, and finally turn on Live captions.
While you are at the top of your screens, there is a chat button.
Please click on that now and you'll see that we have an anonymous interactive poll in there that we would love for you to indicate where your business is sitting at the moment with these impending changes.
This is also where you can ask any questions as we go.
Erin will be monitoring the chat for any questions that come up and we will answer them at the end of the webinar or she might pop in if there's anything relevant as we're going through.
All right, as we do every time with these webinars, I would like to do a acknowledgement of country in the spirit of reconciliation.
Gnora acknowledges the Traditional custodians of country throughout Australia and their connections to land, sea and community.
We pay our respect to their elders, past, present and future.
We acknowledge the culture, diversity, knowledge and experiences of First Nations people and celebrate their contributions and specifically those living with disability, their families, carers and individuals dedicating themselves to a career in supporting people with disability.
Amazing.
So if you're just joining us now, the aim of today's webinar is to bring everyone up to speed on the compulsory registration requirements for some NDIS service providers, what the investment will be for these businesses and in terms of in terms of time, money and focus and a checklist to work through for those businesses that are looking to make the required steps towards registration.
All right, let's let me get rid of these slides because I don't think we'll need them for a bit.
Angela, thank you again for being here.
Can we just start with a general overview of what the situation is at the moment?
I know I've just done an intro, but from your perspective, what does the foreseeable future look like in the NDIS registration, NDIS provider registration space?
So as you mentioned before, this has come about off the back of the NDIS review which got finalised in November of last year.
One of the recommendations in that was a risk proportionate registration scheme and one of the very first actions that the government took in response to the NDIS review was to create a task force focused on registration.
So what we saw in the original NDIS review was a four tiered process essentially where it's worked its way through the risk of potential harm to the participant and then graded the providers accordingly.
But what we saw when the task force headed by Natalie Wade came out was that they've gone for a far more detailed approach to what that's going to look like.
And the government has issued a decree that all supported independent living providers, support coordinators and platform providers must be registered.
Now, they have not provided a timeline for when this is to occur.
They have also not said if it is going to be registration as we know it now or if there will be changes to that process moving forward.
They have and Natalie Wade and the remainder of the task force were very clear on this.
They acknowledged that the registration process as it is now will probably not be effective moving forward.
And the NDIS Quality and Safeguards Commission has been holding consultation events over the last six weeks, Yeah, whereby they've been seeking guidance from service providers, people with disability, people sort of sitting adjacent to the sector like myself.
Yeah.
So is that the consultation with community as part of changing to the rules, changes to the rules?
Right.
OK, cool.
I was cuious about that.
Yes.
So basically what they've been doing is the NDIS Quality and Safeguards Commission has been inviting people, they've been advertising predominantly through LinkedIn.
It has been hugely well advertised and trying to get a position is actually quite challenging as well.
They've been in hot contention.
But if you have been able to go, basically they've just been segmenting people into tables with an NDIS Quality and Safeguards Commission advisor and pretty much just asking for feedback on what are the main quality challenges that are affecting the sector at the moment.
And how do we actually work to a scheme whereby people with disability are provided with their choice and control whilst ensuring that they are appropriately safeguarded.
And I think at the crux, that's what this whole mandatory registration process is all about, is making sure we have oversight of those that are actually working with vulnerable people, as well as trying to make sure that the services that they receive are of a quality nature, are actually helping them to achieve their goals and probably at the end of the day, are a valuable use of taxpayer money.
Yeah.
I mean, yeah, that's what it come boils down to with all of their reforms.
Sure.
So the purpose of the practise standards, which is the the rules that are currently being revised right with the consultation.
So that is terms of practise and safeguarding practises.
Is that that basically the way the practise standards are developed at the moment?
And I am clear on at the moment because we don't know what the changes are going to be, but at the moment you have a core module which is made up of four components.
So the four components are the rights and responsibilities of people with disability, your governance and operational management structures, your provision of service and then your service provision environment.
Then in addition to those, we've got a few specialty spaces.
So if for example, you are a behaviour support practitioner, you would be required to do Module 2, which is the provision of behaviour support.
If you're implementing behaviour support plans with your restricted practises, you'd be Module 2A, which is implementation of behaviour support plans.
If you're a specialist support coordinator, so Level 3, you're required to have that as a separate module as well.
And basically the way it's broken down is that within each of those areas there is a whole bunch of outcomes.
So they're fairly broad statements that say what a provider needs to do.
And then there's a whole bunch of indicators that sit underneath that.
Now those indicators are still reasonably vague, but the the kicker for the vagueness comes in when you do actually go through audit and you get a different type of auditor that has prioritised different parts of that wording, right.
OK.
But ultimately, so I mean the examples that you use, so behaviour, behaviour management or behaviour and specialist support coordinators, they're they're currently registered, required to be registered providers, correct?
Not currently, so not OK, Sorry, I'm not up to speed then.
So if you are prescribing a restricted practise, yes, Yeah, but not carrying them out, That's right.
Oh, if you're carrying them out, you also need to be registered for Module 2A.
Yes.
OK.
Registration is only officially required at the moment for SDA providers.
Uh huh.
And providers of providers who are involved in restricted practises is probably the easiest way to put it, right.
Yeah.
Everything else is voluntary.
As acts of that, however, we know that they've basically drawn a line in the sand that says silk providers, the port coordinators and platform providers will need to be registered.
Yeah.
OK.
So while there is a clear vagueness in the how those outcomes are measured in an audit situation, they won't necessarily change too much in terms of what expectations for providers are.
Look, I don't think the expectations will change.
I think particularly if you're already providing a really good quality of service, the the practise standard shouldn't scare you too much.
Yes.
What will need to happen is that you probably the biggest effort you'll need to make is that you're documenting what is the service you're providing.
So you have a full suite of policies and procedures.
You're keeping accurate notes.
Yeah, which once again, if you're running a viable business, even if you are a sole trader who's perhaps administering support coordination services, you would have those things in place already.
Yeah, but perhaps it's just not as formal as it may need to be under a registration perspective.
Sure.
OK.
So say you are a smaller operator, say you're a independent support coordinator, you're fully across the practise standards and you're aware of the outcomes that are expected for your clients.
If you are currently unregistered, are there any curveballs in there that they need to be aware of going into this compulsory registration.
Like it's did it literally just come down to documentation of business practises?
Yes, I'm not.
So it like the first step is that process of being very familiar with the practise standards.
So in total, I think they're in the core modules alone, there's 230 different indicators.
Goodness.
So that's a lot of things that you kind of have to make sure that you've covered in some way, shape or form.
Yeah, but from there you've also then got all your documentation, you've got all the other information that you then need to collect on each participant that you're providing support with.
One of the things that I will frame quite strongly is we've seen a very big push from the Commission lately of rejecting organisations for registration when they've just used commercial off the shelf policies and procedures without tailoring them.
Yeah, for sure the auditors have been going through with those organisations.
The auditors will pick the box to say yes, these meet the compliance requirements and then the Commission is the one that's actually not providing registration because they're not believing that the provider actually understands what it means to deliver quality.
Yeah, totally.
So I'm not saying don't buy a commercial off the shelf package, because let's face it, they are compliant, those documents are compliant and they will save you a hell of a lot of time, Charlie.
But make sure that you go through whatever it is that you purchased, tailor it to your organisation and what it is you want to deliver and how you want to deliver it, and then publish.
Yeah, make sure that it reflects reality as well.
Yeah, exactly.
Like policies should for the most part be fairly consistent across our sector.
Policies are your way of saying this is how as an organisation I'm going to make sure I meet my legislation and regulation requirements.
Yes.
So because we're all talking to how we're going to make the same thing, there's not that much variability.
Totally variability will come into play when you start developing your procedures.
Yeah, for sure.
So when you say across the sector, all of their policies and procedures should be fairly similar and it's really just how you go about your day to day that will change across businesses.
And now today we're talking about support coordinators, seal providers and platform providers.
Do all service providers in the NDIS space need to be moving towards this level of even if they don't need to be registered, like is that something that will be in their foreseeable future and therefore they need to be across it?
The indicators from the task force have suggested that yes, there will be mandatory registration across the board.
Now what that's going to look like is still slightly in the works, but what it's suggesting at the moment is your your mainstream service providers that are providing extra supports to people with disability or organisations that are already under a an accreditation scheme like your appra registration, those types of things.
You will probably be on a lower registration requirement simply because they're registered elsewhere and there are safeguards elsewhere.
Exactly, exactly or what you're providing is considered to be low risk.
18:49
So if you're providing incontinence aids for example, you don't need to be registered for that provided you're a proper mainstream business and you're meeting your asset requirements.
19:01
Yeah, totally.
19:02
Where they are going to come to having more in depth registration requirements.
19:08
And it's still to be seen whether this will come in, in the first round of making sure that still providers, support coordinators and platform providers.
19:17
We don't know if they're all going to have to meet the same standards.
19:22
But I would suggest that yes, as a scheme we should all be getting prepared to have some sort of process and making sure we can demonstrate the quality service that we're actually providing.
19:35
And I would say it's good practise anyway.
19:37
So it's a a process where with space fax, I know there's been a lot of contention over registration and I know registration in its current form is not ideal.
19:49
But if we were to apply this in a different setting, so for example, you get to choose whether you want to register your car or not.
20:01
By registering your car, you are able to get fined for speeding.
20:07
What's the incentive then?
20:09
Exactly.
20:10
And that's the issue we've got at the moment is there isn't an incentive.
20:13
Yeah, totally.
20:14
So organisations have to see this as A tag of quality.
20:18
And it's basically an equaliser across our sector to make sure that we're all acting in an ethical world now.
20:27
So it doesn't become a core or organisations that are doing that already have the the interests of their their people at their heart.
20:34
And yeah, people being an administrative process only organisations that are potentially not doing the right thing by people with disability don't probably have to worry.
20:47
Yeah, OK.
20:48
So in terms of across the board, across the sector, all the different service providers everywhere from your large organisation, across different service offerings all the way down to your sole traders like independent support worker sort of situation.
21:07
While the the extent of the documentation needed will vary because of what you're actually delivering, the expectation to have that documentation will be there regardless.
21:25
Exactly.
21:26
Yeah, yes, you need to have ways of addressing things like how have you actually communicated with your participants what their rights are in terms of the service they're getting from them.
21:38
Now that's going to look different business to business, but all businesses have to have some sort of documentation which outlines how they do that.
21:45
Yeah, totally.
21:47
And to be like in terms of your your day to day, how you go about your business, the fact that you've at one point, even if you are an independent sole operator, the fact that you've thought about that at some point and decided that that's how you're going to deliver your services.
22:05
That is essentially your policies and procedures.
22:08
It's just taking the time to now make sure that it is in concrete documentation essentially.
22:15
Exactly.
22:16
And it's putting it out there to say this is how Angela Hardy's organisation is going to do totally.
22:20
This is how we operate.
22:23
I will point out though that under the current registration scheme, which until we get other information, I think is the best thing that we can go off, it is a proportionate model.
22:35
So the more complex your services, the bigger you are, the more detailed and in depth your registration process should be.
22:43
Yeah, So, yeah, yeah.
22:45
So I am a quality auditor myself as one of the rules for quality auditing is basically that they have to look at the square root of the total number of participants you have rounded up to the nearest whole number.
23:01
So for example, if you're an LWB of the world and you've got thousands of participants, so the auditors will be looking at hundreds of your participant files and speaking to hundreds of your participants to actually work out.
23:14
Are you delivering a quality service?
23:16
If you're a sole trader that maybe only has two or three participants that you you're seeing on a regular basis, that's less work, but you only need to, the auditors will speak to one participant, look at one lot of files.
23:32
So it is.
23:33
So essentially it's understanding the audit process and what's actually involved.
23:38
That's the scary bit because the majority of quality providers are doing the thing.
23:44
It's just having the paperwork to say that you are doing the thing.
23:48
Exactly.
23:50
Now the the process is not necessarily a straightforward, an easy process, but perhaps I can take a little bit of the fear out of the process for your listeners.
24:01
So what you need to do to get registered is your first step is to go into the NDIS quality and safeguarding portal and under the applications tab, you need to make an application for registration.
24:15
What that's then going to do is it's going to ask you a whole bunch of questions on who your organisation is, what type of services you provide.
24:24
It will link back to the price guide, so it will ask you which codes you're currently claiming because that will then inform what services you need to be reviewed for sure.
24:34
If they need to go through and provide 200 words or less against each outcome of the practise standard, sure.
24:42
How you meet that now, that should be reflective of what you've got in your policies and procedures in life.
24:51
Yeah.
24:51
So it could be a relatively simple cut and pay.
24:56
Yeah, totally.
24:56
If you've already done that work, you've got that ready to go.
24:59
Yeah, exactly what that then does is at the end of that, when you hit submit, you will get a what they call the scope of audit document and PDF.
25:09
It just comes straight from the Commission and it will give you your audit number.
25:15
Yep.
25:16
You then need to go and approach a whole bunch of different quality auditors.
25:22
So there's a list on the commission's website.
25:24
I think they're up to about maybe 30 or 40 options.
25:28
When the registration process first kicked in, there was only six options for quality auditors.
25:35
Shop around.
25:36
OK, so do not just go to one provider and ask for a quote.
25:41
I have just done this for one of my other sister companies.
25:44
Yep and for the exact same thing I got a quote range from $3000 to $14,000 for the exact same thing.
25:54
That is the range.
25:57
It's quite the range and I don't know what you're getting extra for spending $14,000.
26:06
So do your work, shop around often when they can actually deliver the service and what it's going to look like.
26:15
So sometimes when you get those bigger prices, it's because they're going to spend days and days on site.
26:22
You probably don't want that either.
26:25
So now that we're actually in the audit process, you've engaged an auditor, they will work with you to say, OK, well when are we gonna do it?
26:34
And you're booking your audit date.
26:37
The first step of the process is that they will review your policies and procedures.
26:43
So usually audits are conducted over two days.
26:47
Day one, Part A is to go through your policies and procedures and say from a paperwork perspective, do you make the legislation and the regulations?
26:57
Yep.
26:57
At the end of part A, they will give you feedback.
27:01
So they should say to you, Oh no, look, this policy doesn't address this particular area of the standards or you've missed this or the the really common ones that we're seeing at the moment are things around emergency and disaster management.
27:15
So you don't have a policy on how you're going to provide services and employment in emergency and disaster management.
27:22
And please go away and create a policy totally.
27:25
So you do have time in that space to go in and do got your IS cross your T's fixed up in your ones day two Part B is the are you doing what you say you do right.
27:38
So this is where they will come in and speak to you as the the head of the organisation and find out what is your understanding of quality and say regarding what is your understanding of things such as dignity of risk versus duty of care, human rights frameworks.
27:56
How do you actually ensure that you're meeting your incident reporting requirements, for example?
28:01
And then they will go out and speak to your staff.
28:05
So if you do have staff, they'll go speak to your staff.
28:09
They'll also speak to any participants that you're currently supporting.
28:12
So as I said, that's the square root of the total number.
28:14
So that might be only one person or it might be a whole bunch depending on the size.
28:21
And essentially all they're trying to do is gauge are you providing a good quality service?
28:25
Yeah, verifying that you're doing what you say you're doing, that you're doing what you're saying you're doing.
28:32
So then you'll have a close out meeting that day and the auditor should be coming to you basically saying either yeah, you've nailed it, ticked all the boxes, we will make a recommendation, or here's some non conformity.
28:51
Now nonconformities can be a minor one off little issue.
28:56
Or if you get 3 minor nonconformities in the one outcome area, it actually automatically becomes a major nonconformity.
29:05
Now you if you're gonna have nonconformities, you'll want the minor ones.
29:09
Basically what happens if you get a minor nonconformity is they will give you a spreadsheet of your nonconformities and you'll be asked to how you're gonna fix it.
29:17
Yeah.
29:18
And when you're gonna fix it by and then you provide that back to the auditor and they will either come back to you and say no, not good enough, we need more information or change your approach, whatever it is or Yep, thank you very much and we will check this again at your midterm audit.
29:35
So in 18 months time, essentially if they're major non conformances though, you basically get three months to fix it and then they're gonna come back in and double check.
29:44
Yeah, so that's going to incur an extra cost for you as a business, especially going to have to have a secondary audit, right.
29:54
But in the meantime, you can still operate as per usual.
29:57
Yes, in that.
29:58
You can still operate as usual.
30:00
It would be a fairly serious circumstance if the auditor goes to the Commission and says, look, people are at significant risk here, we need to stop them from operating.
30:10
So I have been providing audit support now for three years through this company.
30:16
Haven't seen it happen yet.
30:18
I've been contacted by people to say, hey, we've got 60 odd non conformities, make them go away for me and they're still allowed to function.
30:30
And just to be clear, I didn't provide support to that organisation because I just wanted them to go away, not provide quality service.
30:36
Yeah, but yes, so the fact that they were still operating tells me that it, it's got to be pretty big.
30:45
Yeah.
30:45
Strange.
30:48
OK, So hi, Erin.
30:50
Yes.
30:53
Mute.
30:53
Hi.
30:54
Sorry, I was going to leave this question to the end, but I thought just while we're talking about time frames, I just quickly asked this one.
30:58
Angela, is there a time limit?
31:01
And it's here's the part that you probably, oh, I think, oh, wait, she's gone.
31:05
Oh, the Internet's gone.
31:07
Angela, sorry.
31:08
Your your Internet is a bit choppy and you've frozen.
31:14
And we were just about to ask you a question, but I think you might have been talking that whole time.
31:19
Erin's just jumped in with a question.
31:21
I don't know why I've frozen.
31:23
Yep.
31:24
Can you hear me?
31:25
OK, I can hear you.
31:26
Yep.
31:26
Yep.
31:27
That's better.
31:27
Yep.
31:28
Yep.
31:29
Sorry to hear.
31:31
That's all good.
31:32
Just a quick question.
31:32
I thought I'd jump in with it.
31:33
Now while you're talking about time frames and things like that, I was going to wait till the end, but Holly, just wanted to know, is there a time limit from when you receive the scope of audit to engaging an auditor?
31:44
Like does that kind of expire at any point or do you have, you know, as much time as you need to find an auditor?
31:53
I'm going to turn my video off just in case.
31:55
It seemed to stop as soon as I came on.
31:57
So I'm going to turn mine off and hopefully that'll help.
32:05
I can sort it here, but no.
32:06
So you've got.
32:07
Look, I would say do it sooner rather than later.
32:10
Yeah, there's no limit.
32:14
Oh, I think you're cutting in and out again, Angela.
32:18
Sorry.
32:18
You've got a lot of technology.
32:19
Yeah, I love it.
32:20
So that you find a different spot.
32:23
I can hear you.
32:24
Just can't see you right now.
32:25
Oh yes, you're moving.
32:29
I am moving.
32:30
Yep.
32:31
Just trying to find a little quiet space.
32:36
Nice branding, plug in the background noise.
32:38
Yes, yes.
32:40
Well, I'm at the NDIS Reform Summit at the moment, so very cool trying to get the groundwork of what's going on in our world.
32:49
That's awesome.
32:49
So the time limit, yes, is basically you get 12 months from the point that you submit your scope of audit.
32:57
You got 12 months to have engaged the auditor and conducted your audit.
33:02
Yeah.
33:03
So it's not a, it's not a rushed process.
33:05
It's quite involved.
33:06
It's not a rushed process.
33:07
No.
33:08
Yeah, yeah, OK.
33:11
But you will get a if, like me, I started the registration process a few years back and never followed through on it.
33:20
And you get a letter from the Commission saying we've denied your registration application, usually about two years later.
33:26
Yeah.
33:26
OK.
33:26
So it's a, it's not a rush process, but it does need to have ends tied up if you don't pursue up.
33:37
That's right.
33:38
Yeah.
33:38
Cool.
33:38
All right.
33:40
OK.
33:41
So time limits, processes you're up.
33:46
Did you have further to add in terms of you're going through the auditor engaging auditor day 2?
33:52
But I feel like that was a fairly comprehensive Yep.
33:56
So that's day 2.
33:57
The thing that providers will need to be aware of is that an auditor does not grant you registration.
34:04
So an auditor will make a recommendation on whether you should be registered or not.
34:09
That then goes back to the Commission to make a decision.
34:12
Now at the moment the wait times for that process for new providers is about a year.
34:23
Wow, cool.
34:24
OK, Yep.
34:27
So don't expect anything to happen fast, I guess is Yep, Yep.
34:31
OK.
34:32
So even in terms of say, all right, the government is consulting with the sector this month and say they close consultations and then they make their recommendations next month.
34:43
And then it becomes you've, you've got to start the registration process within the next 12 months.
34:50
It's it's literally going to the web, the Commission website, registering, filling out the thing, getting your scope of audit and then going through that process essentially at the moment if they don't change how that process works, yes, right.
35:07
That's cool.
35:08
OK, that's now look, I would be hoping a very strong recommendation that if you know this is your space and you're gonna keep playing in this space for a long time to come and you are in one of those targeted areas of still support coordination or a platform provider.
35:23
Yep, start the process now.
35:26
What we know and once again this isn't a known fact.
35:30
This is me trying to read between the lines.
35:32
But when registration first came in in 2018, organisations that were accredited through this state based scheme, so had some form of registration, were pushed to the back end of the NDIS registration process.
35:47
I suspect they will do something similar here.
35:49
When they do introduce new standards and new requirements for registration.
35:54
If you're an existing registered provider and you've already got the tick in the box, you'll be allowed to sort of have that reprieve.
36:02
Which knowing the way that they're going in terms of increasing quality, I would say having that extra time obviously is probably not a bad thing.
36:13
Yeah, for sure.
36:14
Yeah.
36:15
OK, OK.
36:16
So that is the that's demystifying the audit process for becoming a registered provider.
36:28
In terms of how that affects the day to day operating for a service provider, do you feel like there would be impacts on the day to day operations of providers?
36:40
Not the daily operations, but I think it'll probably mostly impact things like when you're on boarding a new participant or off boarding a participant, the the rules around those two processes are fairly strict.
36:56
Yeah.
36:57
In terms of what the support planning actually look like, yeah.
37:00
Now particularly support coordination, I've worked with a few support coordination companies that have been of the view that the core modules don't apply to them because this they are support coordinators.
37:12
So when it says tell us what this person's support plan is, their response is, well, we just provide support coordination.
37:19
That's not sufficient.
37:21
Yeah, right.
37:21
They need to actually be stating what are the support coordination services you are going to provide this person to meet their goals.
37:28
Sure.
37:28
Yeah.
37:29
Are you trying to work with them to find a new silk provider?
37:34
Are you trying to work with them to get them employment, specifically what it is and how you're going to engage with them to deliver your service?
37:41
Yes, right.
37:42
And if we try to take that step back and compare that to just regular business, it would be the same as when you go, for example, and meet your personal trainer, you sign up to a contract, you know how often you're going to meet them, how long your sessions going to go for, whether they're going to give you a meal plan or anything like that.
38:02
You have that detailed knowledge upfront.
38:04
And that's all that the support planning process is trying to drive to.
38:08
Yeah, OK.
38:09
By saying I'm providing support coordination isn't going to be enough.
38:12
Awesome.
38:13
OK, that's good to know.
38:14
So on boarding, off boarding in terms of having a detailed understanding of what support provision is in terms of your service delivery.
38:25
But then in terms of I think you mentioned it very briefly before, but so like incident reporting and crisis reporting.
38:38
So but majority of that is in your already documented policies and procedures.
38:44
But maybe it's just being aware of if there are gaps in your service provision at the moment in terms of your obligations in that regard.
38:53
Like is that, I mean that's not affecting your day to day, it's maybe just tightening what should exist.
39:01
So for example, at the moment, incident reporting, if you're not a registered provider, you've got no requirement to tell anybody that an incident's occurred.
39:10
However, as a registered provider, you now need to be aware that if it meets one of the seven criteria, so death, abuse, neglect, serious harm, yeah, unauthorised use of restricted practise or sexual misbehaviour, then you have to report it to the Commission and you have to do that within 24 hours being becoming aware of it.
39:32
Yeah.
39:33
So those are the types of things that shift in terms of complaints.
39:39
Complaints you just simply need to be making sure that your participants know that they have a right to make a complaint.
39:45
They know that they can make a complaint internally to you or they can externally go directly to the Commission.
39:51
Yep.
39:53
And then you part of that is having a complaints handling process as well, which is documented and can show that process.
40:02
Exactly.
40:02
And that doesn't have to be laboursome, no.
40:06
Whether or not it's communicating with them to work through a resolution or contacting relevant yeah but it's just having that documentation to show that that's what you do.
40:14
I'm gonna approach it who's gonna do it What happens if the complaints about you as the the business owner or key person what are you gonna do to interest and but yeah mm hmm yeah OK cool.
40:26
So day to day not huge impact, just extra considerations and dotting IS and crossing T's essentially Yeah, yeah, cool.
40:39
We've also I mean you touched on financial impacts in terms of engaging an auditor.
40:48
So now these and just because I'm in my nice little bubble of Canora and I can provide support to participants and service providers, but my experience on the ground is very limited in terms of these auditors are private consultants.
41:04
They're not commissioned by the they're not commissioned by the Commission or the NDIA.
41:14
They're they're independent auditors, but they've been recognised by the Commission as being quality auditors.
41:23
Yes.
41:24
So for an organisation to provide auditing of NDIS businesses, they need to be registered with an organisation that's called Jazz Ants.
41:33
OK, so basically it's the auditing accreditation body of Australia and New Zealand.
41:39
But for you to specifically as an individual auditor be able to go out and physically audit a provider, you need to have completed the the NDIS Quality and Safeguards Commission Quality Auditor course.
41:51
Yes, Now that's a three day course.
41:56
Mm Hmm.
41:57
Four days.
41:57
If you don't have any experience with actually engaging with people with disabilities, they, they teach you how to take an extra day on.
42:04
Sorry, no, let's yeah, let's just take an extra day on to teach you how to communicate with people with challenging behaviours and a day is all you need.
42:13
Yeah.
42:14
And look, I guess that's probably my underlying message is you across the board when it comes to auditors, you will get a different breadth and depth of knowledge.
42:24
Mm Hmm.
42:27
I so we provide a lot of audit support to companies to get them through.
42:32
The advice that I always give my clients is if the auditors asking you to change something on a form or add something to a policy, if it's quick and easy for you to do it, just do it.
42:42
Even if you don't think it's necessarily right, it'll make your life easier.
42:46
However, if it's something that's going to be challenging for you to implement or you think it's going to create an ongoing risk to your business, that's when you to be honest, you need to reach out to a professional like myself and get assistance with how do you actually go back and argue your case for why that's not a non conformity.
43:07
Sure, OK, right.
43:08
So engaging an auditor to go through this process for registration, that's an investment in terms of being audited essentially to say that you have everything in place and you do what you say you do for the reason of safeguarding and quality control.
43:28
That's one cost.
43:29
But then say coming to some Someone Like You for pre audit support or post audit support, whatever it is that you would provide that will be and and and I mean you're a for want of a better term.
43:42
I should know this, but a consultant in the NDIS space.
43:45
Yeah, yes.
43:46
OK.
43:47
So and you provide audit support to service provider organisations.
43:53
Yeah.
43:53
So that would be yes, it's an extra cost, It is an extra cost, but it is a lesser extra cost than trying to navigate the audit process and getting a whole bunch of non conformities that you then have to go back and get re audited for and fixed.
44:10
The other advantage to it is it takes the, the pressure off a little bit because I, I have been told that I am one of the harshest auditors going around.
44:23
And if it gets through me, you are going to sail through the form audit.
44:26
But the difference is I'm going to present it to you nicely.
44:29
We're going to have a conversation and I'm going to try and teach why this is important.
44:35
What's the reason behind this particular outcome?
44:37
How can you address it in a way that's going to suit your business needs as opposed to coming at it with a a blunt knife and saying it needs to look like this?
44:49
I think that there's a real advantage to the fact that the standards are vague and that means that you can develop your own processes to suit what you want your business to be.
44:59
Yeah, for sure.
44:59
So you've got some goal posts, but you can still move around within those goal posts.
45:04
Yeah.
45:04
Awesome.
45:04
Exactly.
45:05
OK, So in terms of this, that would be the pathway for registration.
45:11
What are the considerations for people and their businesses that are at the moment thinking, heck no, this is too much?
45:19
I don't want to go through this process.
45:22
I'm just going to hedge my bets and just kind of wait to see what the deal is and kind of hope that registration for my type of business is not on the cards.
45:32
What do they need to be looking for or be aware of?
45:37
That may be the implications of waiting and seeing.
45:45
Waiting and seeing isn't the worst strategy in the world at this point.
45:48
We've seen that nothing happens quickly.
45:50
Yes, as I said, it was November last year that they released the NDIS review, and they only came out with it, what, a month ago, six weeks ago, that mandatory registration will be coming in for these three groups.
46:02
So nothing happens fast.
46:04
Yeah.
46:05
And as I highlighted before, my hunch is that if you've already got registration, you'll be kicked to the back end of the line when they do make it mandatory and when they do change the standards.
46:16
But that might not be factual.
46:19
Yeah.
46:19
What I would be saying though is just create, make sure you've created a, a, a funnel for yourself of gathering the appropriate information.
46:29
So that might be using Kenora, it might be signing up to other newsletters and blogs and things like that.
46:36
Staying on LinkedIn is a great source of information because people will often go there first to usually criticise what the, what's happening the government's doing.
46:46
Yeah, but at least that gives you a heads up.
46:49
So you don't want to be in the position where you've been provided thousands of dollars worth of services and then all of a sudden the agency's not paying any of your invoices anymore because, well, guess what?
47:02
You were meant to get registered and you haven't.
47:04
Yeah, Yeah.
47:06
That would be a quick turn around and quite new, But yes, that we, we it could happen.
47:12
Yeah.
47:13
So I guess it is that thing of wait and see.
47:15
Just don't bury your head in the sand and think it's not going to happen.
47:18
Yes, yeah, yeah.
47:19
Still be aware.
47:20
Wait and see is a strategy, but it's not the tactic for sure.
47:24
All right, So I'm just aware that we're getting to our time and I wanted to you've created a checklist in terms of preparation for the audit process.
47:46
I'm just wondering if, yeah, sorry, I'm just making sure that my click throughs actually work.
47:53
So a six step process for current service providers to work through in preparation for the registration process.
47:59
Did you want to, did you want to talk to this or we've essentially covered a lot of it really, but maybe just talking to this this checklist as we go would be helpful briefly, OK, because I'm just aware that I want to leave a little bit of time at the end if for any more questions.
48:17
But yes, so internal audit, one of the standards actually explicitly states that all registered providers must have their own internal audit schedule and conduct an internal audit at least annually.
48:33
So what that basically means in a nutshell is that you've got to have some form of document that says I'm going to do an internal audit of this many participants and this many employees at this time, and then you have a document to show what you did.
48:48
Yeah, great.
48:50
It is probably the number one area where existing registered providers fall over.
48:56
They will go to audit and the auditors say show us your internal audit and they won't have done it.
49:00
Yeah.
49:02
So it's actually like doing inventory, but like for a retail business, it's just inventory.
49:06
So just checking that you've got all of the things and doing all of the things essentially.
49:10
Yeah, Exactly.
49:11
So you have a support plan.
49:12
Do you have a service agreement?
49:14
Have you got notes for this person's support?
49:17
All of those types of things.
49:19
Yeah, that's all it is.
49:20
And then doing it right.
49:21
All right.
49:23
Staff training and development.
49:25
So staff training and development tends to be another catchy one in that there are some mandatory things that organisations need to train their staff on.
49:34
So obviously everybody needs to have the worker orientation module that's done by the NDIS Quality and Safeguards Commission, but there's other things in there such as infection prevention and control.
49:46
That's one that they they definitely want to see certificates for at least annually.
49:51
You've also got to have mechanisms for making sure your staff do know about complaints handling, incident management.
49:57
And the other one that isn't mandated, but I'd strongly recommend is risk.
50:03
So it's making sure that everybody on your team actually knows what a risk is and how they should effectively be responding.
50:11
These don't have to be difficult.
50:15
So we've got an online learning platform where we've taken each of the standards and we've made 15 minute modules about what the standard actually is.
50:24
And how would you possibly look at like applying that in daily practise?
50:30
So it's not skewed to still providers or independent support workers or support coordinators, it's just in general knowledge and what do you need to consider?
50:40
Yeah, and as I said, they're done in 15 minutes.
50:42
So I don't think organisations need to be spending a lot of time and money to train their staff.
50:48
They just need to have a way of making sure that they've got a record of how they've communicated information.
50:53
Yes, sure.
50:54
All right, policy updates.
50:58
So this is, this is one of my favourites because I've come across many auditors who have different perceptions on this particular 1.
51:08
So basically the, the standard says that you have to have a process of ensuring continuous improvement of your policies and procedures.
51:17
So basically that just means you have to review it and demonstrate that you've reviewed it.
51:22
I think the best way to do that is with the the version control boxes on the bottom and just put your new date in and if you've made changes.
51:30
However, I have come across auditors that have told me that you must review your policies within like in the six months leading up to an audit.
51:39
I've had them say that you've got to do it annually.
51:42
My tip is whatever you write into your quality policy of how frequently you will review your policies, that's what you've got to do.
51:51
Yeah.
51:51
There is no legislated requirement for how frequently you should update your policies, but you need to be sure that you're you're reviewing.
51:59
I feel like that's something that you would tack onto your internal audit.
52:02
So you're going through your things and then just making sure that there's any updates that are required for each of the things at the same time.
52:07
But yeah, and I always, I'm a fan of the the evolving updates.
52:13
So for example, if you're providing a service and you've had an incident, which isn't a bad thing 'cause it's they're a great opportunity for learning what are the things that have gone wrong?
52:24
And then go back in and look at your policies and your procedures and see, have I got this right in this document because this still happened.
52:33
Was it just the people weren't following the policy and procedure, which is a fair play because that might then tell you you need to do more training or have I gotten something wrong?
52:43
Yeah.
52:43
And then you go in and you change it.
52:44
Then you go to the version control at the bottom and that's your new date.
52:47
Yeah.
52:48
So in real time, essentially.
52:49
So just follow up of an incident and closing that loop.
52:53
Yeah.
52:54
Cool, cool.
52:56
Yeah.
52:56
Documentation.
52:57
That's nice.
52:57
I find that saves a lot of time.
52:59
Yeah.
53:04
Look, I think we've gone through, Yeah, we've paid enough.
53:06
Yeah.
53:06
I feel like that's been having it, having home technology solutions.
53:14
Look, you can't underestimate the the value that a technology solution's going to give you A and once again, they don't have to be expensive.
53:23
Don't go in thinking that by going with the big expensive ARP solutions that you're going to get a better product.
53:31
Yeah, you're probably not.
53:33
And in my experience, there is not a good end to end disability system out there at the moment.
53:41
So be very clear on what you want to achieve out of it.
53:44
Is it just something that you can easily make sure that you've got all your participant information in one spot?
53:50
Do you want to be able to roster from it?
53:51
Do you want to be able to claim from it?
53:52
What is it that you actually want?
53:56
And then look for that.
53:57
Yeah.
53:59
And then follow it through.
54:00
So it does what you want it to do.
54:02
Exactly.
54:02
That's going to save you a lot of time and money in the long term.
54:05
Yeah.
54:06
Because using paper based documents and diary notes and things like that are going to get you in trouble in an audit.
54:12
Yeah, that will be hard for sure.
54:14
All right.
54:14
And then pre audit preparation, which we also touched on, we have.
54:20
Yep.
54:20
Yeah.
54:21
So mock audits, compliance cheques and then speaking to professionals that are in the space to make sure that you are positioned well.
54:30
Yeah, that's all right.
54:31
Yeah, great.
54:32
All right, I'm going to stop sharing now.
54:34
And Erin, are there any other questions that have come up as we've been going along?
54:40
Yeah, we've had a couple.
54:41
Yeah, so and they kind of have been answered, but Jessica put a comment earlier on in the conversation talking about like how a support coordinator supposed to have the time and I think money as well to do all of the auditing requirements.
54:57
Obviously you're kind of gone over that.
54:58
There's such a big range.
55:00
But I just thought if you have any sort of final tips on maybe for those smaller, you know, independent sport coordinators that are maybe going to really struggle finding the time and money.
55:07
Is there any just sort of quick tips on, you know, ways to make it a bit easier on themselves or save a bit of money?
55:13
What's what's your recommendation there?
55:15
I know that's a hard one to answer.
55:17
Yeah, look, I think there's build a network around you.
55:22
So if you've got other independent support coordinators that are are working around you all chip in some money and buy an off the shelf policy and procedure pack and then take it away and tweak it yourself and make it what you want it to be.
55:36
So yeah, don't be giving consultants the same money over and over again when you can have your little conglomerates people.
55:44
Yeah, yeah.
55:45
And once again, consider do you need to be independent or is there is there the opportunity for you guys to actually merge together and have a an organisation of five so that it's only one registration cost?
55:58
Yep.
55:59
I don't think there is a, a nice neat solution to minimising.
56:05
Yeah, the actual number.
56:06
It's just how do you actually navigate it so that it suits you best?
56:10
Yeah, totally.
56:11
Yeah, totally.
56:12
And I am aware too that the one of the big areas of the NDIS task force was cost and that they were saying that they appreciate that it can be prohibitive for smaller organisations.
56:25
So I wouldn't be surprised if something comes out in that space in amongst all of these changes.
56:31
But at the moment we don't know any light at the end of the tunnel.
56:35
Sorry.
56:35
Mm Hmm.
56:37
Just on those, you know, off the shelf sort of compliance packages that you mentioned there.
56:41
Holly had a question as well about those tweaks to make it personalised for your own business.
56:47
Could you go back to those providers that you purchased it from and ask them to help tailor it?
56:51
Or is it better just to kind of do that yourself?
56:54
What's, what's the best thing to do there?
56:56
Different service, different organisations that provide those products will have different ways of doing it.
57:01
So we, for example, have an off the shelf product that we sell.
57:05
It's more expensive than others because we will actually work with you to tailor it.
57:09
So we'll be talking to you about what is the way that you provide your service.
57:12
OK, well, we then want to tweak this particular policy to make it read like this.
57:18
Others will just give you the OK, go on, put your credit card details in download and yeah, over and done with.
57:25
It's over to you.
57:26
We're not interested anymore.
57:28
Then there's products like, for example, Centro Assist, which they give you the it's a system that you can then go in and edit yourself.
57:38
So it's, once again, broad range.
57:42
Yeah.
57:42
And it all comes down to how much, A, how confident are you to do it yourself?
57:47
B, how much time do you want to contribute to this?
57:51
And C, how much money do you actually want to spend?
57:53
Yeah, totally.
57:54
Yeah.
57:54
Yeah.
57:56
Just something that popped into my head.
57:58
Then I'd be interested to get your take on it using things like ChatGPT to help write procedures and things like that.
58:06
Would you recommend that or no?
58:10
Cuz it can be really useful.
58:11
But, and I'm not gonna lie, I've played around with testing out ChatGPT to write some of this stuff.
58:18
Yeah, and it gives you a good foundation, but once again, you want to make sure that you are really familiar with the practise standards and you can interrogate the response that ChatGPT has given you and Go hasn't met the requirements.
58:34
Yeah, you've got to verify for sure.
58:35
Yeah.
58:35
Yeah, exactly.
58:36
I think it will give you a good head start, but it's just making sure that you haven't missed something in there.
58:42
Yeah, Yeah, Yeah.
58:44
Same with the templates.
58:45
Yeah.
58:45
That's awesome.
58:46
Thank you.
58:47
Great.
58:48
Angela, I think we've come to the end of the webinar.
58:51
Or is there any other what's a wisdom or a a note that you would like to to leave our viewers with today?
58:59
Look, I just say don't stress.
59:01
Yeah, it is a it's going to be a process and the sector is changing rapidly at the moment and everybody's nervous.
59:11
But as I mentioned before, nothing is happening quickly and there are organisations out there that can help you and hold your hand.
59:19
So know who you can rely on form your networks and just try and ride it out.
59:25
And remember if you're delivering a great quality of service to the people that you're supporting, you probably don't have much to worry about.
59:32
Yes, I would say there will be people around you that will help you navigate the technicalities and the details.
59:38
It's just having those conversations with people.
59:40
Yeah, that's right.
59:41
Yeah.
59:42
Amazing.
59:43
Thank you so much, Angela.
59:45
Well, we've made it to the end, in case you're not already aware.
59:48
Everyone, you can keep this conversation going on Kenora in the dedicated providers only channel.
59:54
You can use the platform for any excuse me words, collaborations, ideas and troubleshooting of the NDIS or general business issues and get peer LED input just from everyone that's showed up here today as well as guidance from the Canora coaches and our other experts such as Angela.
1:00:13
Thank you all for coming today.
1:00:15
We'll be sending out an email to you all and anyone that registered to this webinar with a link to the video replay and any and all of the resources and references to the changes that are current.
1:00:27
I'm Yvette.
1:00:28
That was Aaron in the chat.
1:00:29
And we have been joined today by the amazing Angela Harvey from Supporting Potential.
1:00:33
Thank you so much Angela.
1:00:35
Your knowledge and generosity is hugely appreciated.
1:00:39
Thank you so much.
1:00:39
Most welcome.
1:00:40
Thank you very much for having me.
1:00:41
Enjoy the summit.
1:00:42
We'll see you soon.
1:00:43
Bye.
1:00:44
Thanks everyone.
Navigating through your own NDIS business challenges and still have questions?
