ATSA was successful in getting through changes to the auditing requirements to be a provider for the NDIA. These changes have significantly reduced the cost of auditing to meet compliance, by thousands of dollars - for not just the membership, but the industry as a whole - a great win.

Now that NDIS Quality and Safeguards Framework has changed the compliance landscape for provision of disability services and the requirements for business who provide these services, you need to understand the effect of these changes. The NDIA Quality and Safeguards Commission has applied some major amendments to the NDIS Provider Registration and Practice Standards.

Although the changes are a great benefit, it only relates to the reduction of auditing cost, it does not take away the need for the correct policies and procedures to be in place. Therefore, do not be caught out in a misguided belief that the changes have removed administration of the NDIS Quality and Safeguard compliance. The necessity to have in place processes and procedures in line with the NDIS Quality and Safeguards Commission Rules, still exists. Some may consider this to be a burden, however in reality it is good business practice to have effective policies and procedures in place as it will reduce operational risk to your business.

For some businesses, time and resources to adhere to the requirements and to stay on top of the changes and the necessary record-keeping, will be a challenge. Some businesses will consider the business case to engage third-party expertise to ensure their approach satisfies the regulations and requirements.

At the time of the writing of this article the details of how the changes will be managed in respect to the shift from Certification to Verification audits is not known. In addition, it is still unclear on the requirements/documentation that businesses who only provide low risk supports need to submit. ATSA will notify its membership as information comes to hand. Regardless on how the changed requirements are applied, it is important for you to have an understanding of the stated changes as you consider your compliance process and procedures including how to administer them.

Here are the stated changes:

Expansion of requirement to notify the NDIS commissioner in the event of certain changes or events

• providers must provide the NDIS commissioner with notice of changes to:

  • their contact details

  • change in organisational scale regarding:

    • geographical area of support provision

    • service provision locations

    • significant change in participant numbers

    • significant change in workers

  • notice must be provided in an approved form, and when the change occurs or when the provider becomes aware the change will occur

• providers must notify the NDIS commissioner in the event of:

  • an event that affects their ability to comply with the conditions of their registration

  • a change that affects the ability of a participant to access their registered supports or services

  • financial difficulty in providing their registered supports or services

  • significant change in governance or organisation

  • an event relating to the suitability of their key personnel to be involved in providing registered supports or services

  • notice must be provided in the form approved by the Commissioner as soon as practicable after the event occurs

Mid-term audit for certain providers – (i.e. “high-risk” support providers)

Providers who qualify for a certification audit assessment are now eligible for a mid-term audit commencing no later than 18 months after the beginning of their period of registration.

This does not apply to:

• providers that are partnerships/sole traders

• providers registered for only Module 3 (Early Childhood Supports) or Module 5 (Specialist Disability Accommodation)

• transitioned providers

Repeal of requirements for providers that are “bodies corporate”

The biggest change for ATSA members is the repeal of requirements for organisations that are registered as a company. Companies will undergo audit based on their registration group requirements rather than organisational structure. This means companies can now be assessed under verification if they provide low risk registration groups only. Assistive technologies fall under the ‘low risk’ category which is great news for ATSA members.

This represents a huge change for providers as the type of audit an organisation has to undergo is now aligned to the supports and services delivered. You will need to make sure all existing policies and processes are aligned to NDIS Provider Registration and Practice Standards prior to undergoing registration, renewal or a surveillance/midterm audit.

• These amendments commenced 1 January 2020.

• Assessments of companies commenced before 1 January 2020 can ignore the repeal of requirements mentioned above.

• Updated reporting requirements apply from the commencement date for all registered providers regardless of registration date.

There are emerging providers who are offering professional services in this space to aid business to meet the NDIS Quality and Safeguards standards, one is Centro ASSIST. They have a well-developed and tested approach to simplifying NDIS compliance to facilitate safe, respectful and inclusive support provision. They have developed easy to use compliance solutions and tools for businesses to comply with the auditing requirements, reduce administrative burden and assist with onboarding new staff, saving time and resources.

If you wish for further information about Centro ASSIST and their service offering please visit our website here. If you have any questions or concerns in respects to the changes with the auditing requirements for NDIS Quality and Safeguards, please contact David Sinclair.

This article was published as part of the Assistive Technology Suppliers Australia March 2020 newsletter.