NDIS providers in NSW and SA will lead the transition to the NDIS Quality and Safeguarding Framework over the next 12 months. On 12th July 2018, the NDIS (Approved Quality Auditor Scheme) Guidelines 2018 was released and we have summarized they key points and changes relevant to providers here. These changes are mostly relevant to NDIS providers that will need to undergo Certification. (For more information about the difference between Verification and Certification, please see our last update.)
Registration Renewal and Timeframes to Achieve Certification
Existing providers who have had their registration transferred to the NDIS Commission will most likely have received a letter that contains a Certificate of Registration. This certificate will display a registration expiry date. It states that every provider should commence the registration renewal process prior to this expiry date by submitting an application for renewal using the NDIS Commission’s online portal, as well as completing a self-assessment. A Condition of Registration listed outlines that providers should have successfully completed the certification process within 9 months of the registration expiry date. To clarify, this means that providers do not need to be audited prior to the registration expiry date.
Initial Scope of Audit Document
Once a provider has completed the registration application or renewal process, the NDIS Commission’s system should automatically generate an initial scope of audit document. This document can be provided to Approved Quality Auditors (certification bodies like Global-Mark) to calculate an audit plan, duration and quote for a provider, however further information* will be required from the provider to ensure all information is correct and complete. This may require the Approved Quality Auditor to update the Commission’s system with the agreed final scope.
*Further information may include number of sites, geographic coverage of services provided, number and roles of staff, number of participants per registration group, demography of participants, types of services provided.
Certification
Certification is a two-stage process that involves off-site and on-site audits against NDIS Practice Standards – Core Module, and any other modules relevant to the NDIS provider’s services.
- Stage One – is an off-site audit that reviews the provider’s self-assessment and associated documents that are submitted to the NDIS Commission’s portal, to ensure that a provider is adequately prepared for a Stage Two audit and may identify potential or actual non-conformities.
- Stage Two – is the subsequent audit (generally on-site) that evaluates the effectiveness and implementation of the NDIS provider’s systems in addressing all relevant modules or parts of the NDIS Practice Standards. It will involve key evidence gathering methods such as interviewing participants, workers, management and reviewing participant and worker files, documented records, physical environment and so on.
The purpose of Certification is to determine or confirm whether a provider is compliant with NDIS Practice Standards and other relevant NDIS Quality and Safeguards Rules, and to identify any opportunities for improvement.
Certification decisions regarding NDIS providers will be issued to the NDIS Commission, to make a recommendation for consideration when the NDIS Commission makes a registration determination. The certification cycle (3 years) will align with the date of registration and registration period.
Provisional Audits
Provisional audits will apply to a provider that wishes to become an NDIS provider and has developed systems and processes to deliver NDIS supports and services, but has not yet commenced service delivery (does not yet have clients). Provisional audits can include an off-site stage one and an on-site stage two audit, or can combine these audits as one on-site audit. There is usually an additional on-site stage two audit once the provider has commenced delivering services (within 12 months).
Note: this is only applicable for providers who are required to undergo Certification.
Opt Out Sampling Methodology
The scheme states that “providers will need to advise all their participants that are automatically enrolled into the audit process (i.e. they may be contacted by the audit team for interviews, and/or have their files, records or plans reviewed to ensure compliance with the standard). In the event that a participant does not want to participate in this audit process, the provider needs to document and respect that decision, and communicate it to the auditor.”
In other words, all participants may be selected as a part of the audit process, unless they have specified that they do not wish to be involved. The provider should have a process to gain and document consent (or lack of consent) for each participant they provide services to.
This is a summary of the key changes expected that are relevant to providers. If you would like to have a read yourself, the NDIS (Approved Quality Auditor Scheme) Guidelines 2018 is a public document available on the legislation register.
