After our Quality & Safeguarding workshops, we often reflect on how well NDIS providers have embraced the new NDIS Quality and Safeguarding Framework. The sector by and large are ready for change and see the value in a new national Framework underpinned by human rights principles. Yet, there is one sticking point that has been difficult to get past: this requirement for ‘bodies corporate’ delivering low risk supports to be certified due to their legal structure. The amount of times we hear providers say: ‘but I was advised by my accountant to operate under a company structure. What happened to mutual recognition? Now I have to pay X times amount for an onsite audit. How is this proportionate?’ Unfortunately, some providers have been considering deregistration and only working with Plan or Self-Managed Participants because of these requirements. The requirement for certification with annual surveillance was intended to strengthen service provider quality. But if it leads to deregistration it might actually diminish the level of oversite a verification style audit might have achieved.
Well, the NDIS Quality and Safeguards Commission has listened to the sector’s concerns. They have released a Provider Alert saying that whilst certification audits will still apply there will be changes to establish more proportionate audits.
The updates include:
giving flexibility on the number of auditors who attend site inspections and interviews as part of a Certification Audit
giving flexibility on the minimum time required to undertake a Certification Audit for small businesses
allowing for off-site auditing for some Certification Audits (for example businesses offering products to NDIS Participants)
removing the requirement to have annual follow-up audits during the three year registration period (known as Surveillance Audits), if the provider is a body corporate but providing supports that would usually require a Verification Audit.
This is a HUGE win for smaller providers delivering low risk supports. We are still working our way through the guidelines and will incorporate these changes in to our upcoming Quality and Safeguarding workshops. The Commission has provided advice about requesting updated audit quotes for those that have already commenced the process. You can read the full briefing here.
There has also been some changes for sole traders/ partnerships providing the Early Intervention Supports for Early Childhood and Therapeutic Supports combination. This has been a hotly debated issue as therapeutic supports only require verification under a sole trader/partnership structure but if added to an Early Childhood registration (a common combination) they must be certified against the core module. If you haven’t read the updates you can review them here. We have also updated the auditing model tool that we sent out yesterday.
We are pretty excited about these changes because we think it will enable more small providers to stay registered. Diversity in the NDIS marketplace is essential to choice and control, and we want to ensure it is a place for all types of providers, not just those with deeper pockets. These changes also demonstrate the Commission really is committed to working with the sector, in building this national and proportionate approach to quality and safeguarding.