NDIS Quality and Safeguards Framework: Best practices for preventing compliance toothaches

Just like the recall letter for a dental check-up NDIS providers in SA and NSW have recently received their letter from the NDIS Commission outlining the start date for registration renewal. TheNDIS quality application for renewal will involve a self-assessment followed by a field audit conducted by a NDIS Commission-approved NDIS quality auditor.

While some providers are already expected to start the process by October, others are due for their check-up in 2019. Most providers are aware that the new Quality & Safeguards Framework has introduced a list of requirements however we have noticed some misconceptions about compliance which we aim to brush away:

Misconception # 1: You only brush your teeth when you see the dentist.

Those who have their recall date next year may be under the impression that they have time to implement the new standards. Having successfully completed an ASES or ISO audit not long ago, you might think you have demonstrated that your organisation has implemented NDIS quality procedures and practices. However, this does not prove that your organisation and your workers have fully adopted the new Code of Conduct, rules for complaints and reportable incidents, behaviour support oversight, or that you can demonstrate outcomes towards all applicable practice standards. These rules are effective since July 1st 2018 and apply to any registered NDIS provider in SA and NSW. Failing to comply can put your registration at risk and may result in civil penalties.

Misconception # 2: You only brush your teeth to impress the dentist

“Will the auditor be happy with this?” is one of the most common questions we hear. While it’s nice and necessary to get a stamp of approval from the auditor this should not be the primary motive for implementing the new rules. The standards are designed to achieve genuine person-centred practice, good governance, effective quality and risk management, a continuous improvement commitment and – ultimately – to provide quality supports and keep your customers safe. So when implementing a new practice or policy, the question you should be asking is ‘how will this help us to deliver quality services and safeguard our customers?’

Misconception # 3: You should only see the dentist when you have problems

We still get surprised when providers do not know when they are due for renewal. If you ignore and miss the re-registration date your organisation will lose its registration. The expiry date on the Commission letter states when your organisation needs to commence but not complete the online renewal application. Once you start the process of self-assessment you have 60 days to complete and submit. The self-assessment will ask you to explain how your organisation meets the outcomes of the service standards applicable to your service delivery. When you submit the self-assessment you will receive an ‘Initial Scope of Audit’ document that you present to an approved quality auditor in order to get a quote for the field audit. You have 60 days to identify and engage an auditor who needs to link themselves to your application. Arranging and undergoing the field audit soon could buy you more time for rectifying non-conformities. Be aware that auditors are already heavily booked up.

Misconception # 4: Having white teeth equals having healthy teeth

Just because management has not been made aware of any recent incidents or complaints, does this mean your organisation is delivering safe and high quality services? You won’t find out until you have the right processes and procedures in place to identify, record, report and respond to complaints and incidents. Regularly reviewing complaints and incidents statistics will reveal systemic issues. Identifying risks to your customers and in the workplace will help to prevent incidents from happening. Screening and training workers will equip your workforce to make the right choices when delivering services. Does your organisation live up to its values? Empowering and involving your staff in making suggestions for improvement will create a culture of quality. Seeking regular feedback from customers and ensuring they know who they can talk to if unhappy can help to focus on improving the way you do things. Lastly, establishing and measuring quality and safety indicators can improve focus and accountability.

Misconception # 5: If your gums bleed you brush less often

“We have been too busy to even think about the new standards”. Being busy is a symptom of ongoing change. Navigating the NDIS, implementing NDIS plans, growing your workforce, modifying your services and coping with the financial pressure puts enormous strain on providers. Putting time and resources towards risk and quality management will ensure your service delivery remains safe, of high quality and competitive. After all, the way to gain good reputation is to endeavour to be what you desire to appear.

Compliance requires time, effort and resources. About 40% of providers in SA have a designated staff member for quality and safeguards framework oversight (Source: NDS 2018). Many organisations struggle to find this extra resource under the current NDIS price structure and we strongly believe the NDIA will have to acknowledge this extra cost. As with good oral hygiene, prevention can help organisations to get on top of problems before they become serious. Who in your organisation keeps up with the new regulations and supports the organisation in implementing them?  Who is overseeing your quality and safety management framework and ensures your organisation engages in continuous improvement?

Misconception # 6: Dental treatments are always painful and uncomfortable

Agreed, audits are painful. Sometimes auditors expose what we already know, other times they unveil some hidden or systemic issues. The audit should highlight areas you need to work on and possibly highlight the risks and shortcomings that you should no longer ignore. A good auditor can offer suggestions for improvement and help you avert more serious consequences.

Besides, passing an audit with flying colours may justify the hard work that you put in everyday and validate that you are on the right path.

By far the biggest pain of the application renewal and the audit will be the cost. Have you budgeted for this expense? Keeping people with disability safe and having a positive impact on their lives is a moral obligation for providers. Supporting providers and offering incentives for upholding their NDIS registration should be the obligation for the regulator.

Misconception # 7: Once you have seen the dentist you do not have to focus on oral hygiene

Although your registration will be valid for three years the NDIS Commission expects providers to undergo an annual surveillance audit. The short timeframe will require you to actively monitor and regularly review your compliance requirements.

Also, having passed an audit does not mean that NDIS quality and safety is truly embedded in your organisation. Does everyone in your organisation understand why compliance matters? As with teeth your customers are vulnerable and your reputation precious. Compliance requires on-going effort, focus and consistency and needs to be part of everyone’s job.

If you do have some compliance toothaches, CBB is available to provide advice and support that may save you having to undergo painful work down the track.

NDIS consultant

Dr Ellen Schuler
NDIS Transition Consultant
Email: eschuler@cbb.com.au
Phone: 1300 763 505