Expert says disability service providers unprepared for NDIS registration

A LEADING risk management and auditing organisation says the majority of disability service providers seeking registration with the NDIS Quality and Safeguards Commission have been under-prepared, and lack knowledge of their regulatory obligations.

It is providing guidelines to Victorian, Queensland, NT, Tasmanian and ACT providers to help them expedite their registration before July 1.

SAI Global has audited more than 200 providers looking to meet their NDIS obligations since July 1 last year, with many more conducted to other State and Federal standards over the past 16 years. Since the new audit requirements commenced July 2018 in South Australia and NSW, more than 100 providers have been unaware of their requirements for NDIS compliance.

Nathan Temple, national human services programme manager at SAI Global, said, “Providers looking for registration this July need to prepare now, as many have already had to make improvements to their internal systems and documentation to obtain NDIS approval. Many are also looking to ‘purchase systems’ but don’t realise they need to have suitable implemented systems that suit the scale and size of their organisation.”

Mr Temple said the lack of clarity on what is required for registration has been challenging for many, and that greater transparency around the process is needed.

"Plenty of information is available – but the challenge for providers has been keeping up with the regulatory changes alongside running their operations," he said. "Partnering with a quality audit provider who can work closely with your team is the first step to understanding your obligations.

"Certification and verification has improved processes and procedures for numerous providers, which are improving outcomes for participants. We’re hoping our guidelines may clarify the steps involved for all providers seeking registration before 1 July.”

SAI Global has clarified the 10 steps disability service providers need to take to obtain NDIS registration this July:

1. 1. Know when you can begin offering your services to NDIS participants. In a soon-to-be competitive market, most disability service providers will seek to offer their services to NDIS participants as soon as they can. Provided they are registered with the NDIS Commission, providers in NSW and South Australia could offer their services from 1 July last year; providers in Victoria, Queensland, Tasmania, the ACT and NT can offer their services from 1 July this year; and West Australian providers can service NDIS participants from 1 July 2020.
   2. Important state approval deadline for Queensland providers. Queensland disability service providers seeking to work with NDIS participants under the current Human Services Quality Framework (HSQF) had until 1 April 2019 to register for this process. If their application for HSQF assessment and approval was not submitted by this date, they will need to revisit the process via the NDIS Commission, detailed below.[1]
   3. Important state approval deadline for Victorian providers. Victorian disability service providers seeking to work with NDIS participants under the current Victorian Department of Human Services (DHSS) will not be able to gain State approval, if they didn’t commence the registration process before 1 March. Instead, they will need to begin a new application with the NDIS Commission from 1 July.[2]
   4. Know how to register with the NDIS. Service providers can register with the NDIS Commission by completing and submitting the application form on its website (www.ndiscommission.gov.au/providers/application-form). A provider’s self-assessment forms part of this application process, and will help to advise what kind of audit the provider will need: verification or certification.
   5. Know whether you will need verification only, or certification. All providers seeking registration will need to be audited, to ensure they meet the regulatory obligations set by the NDIS Commission. Sole traders and partnership organisations need a verification audit only, as they provide services that are considered in the lower risk registration groups. A verification audit – required once every three years – is a desktop audit of the provider’s documents and records, including the provider’s police checks, Working With Children checks, processes and procedures. Companies and incorporated associations (and any provider of higher-risk services) will need a certification audit. This includes a Stage 1 audit to ensure systems and processes are in place, a Stage 2 Certification Audit which includes a review of system documentation, a review of records to ensure systems are implemented, site visits (for multi-site organisations), staff records, participant interviews and file reviews. Certified organisations will require annual surveillance audits and a re-certification audit every three years.
   6. Engage an approved quality auditor. The audit will need to be conducted by an NDIS-Approved Quality Auditor. Providers should ensure that the auditing organisation has appropriately qualified auditors in their State to minimise travel expenses and ensure they are confident in their knowledge and audit approach.
   7. Prepare for your audit. The audit will identify any service gaps that might comprise the best interests of NDIS participants, or any lack of understanding of the new regulations. It’s best that providers have conducted a thorough self-assessment of their policies, procedures and processes before their audits, and that they commence their audit at least three months prior to their registration expiry date (if registered). This will give them the time to put the necessary measures in place before going to market. It’s best that Victorian and Queensland providers seeking to offer their services from 1 July organise their audit now.
   8. Allocate resources and time to make improvements after the audits. The majority of audits by SAI Global have required the provider to make improvements to their documents, processes or procedures before they are verified or certified as an NDIS provider. To ensure a smooth process, it is best that the provider allocate the people and the time to make improvements before registration.
   9. Expect 1-2 weeks for the Commission to approve the registration. The auditor will make the certification recommendation to the NDIS Commission, which will then make the decision to approve the provider’s registration. The audit is just one key component of its decision.
   10.  Receive your certificate of registration. Providers will receive their certificate of registration from the NDIS Commission, after which they can begin offering their services, provided it is from the deadline set for providers in their State by the Commission. The certificate of registration will include details such as the range of supports and services the provider is registered to provide, and certain conditions to follow.

    www.saiglobal.com/en-au/ndis 

   [1] NDIS, ‘Apply for NDIS registration under current HSQF process by 1 April,’ (15 March 2019): https://www.nds.org.au/news/apply-for-ndis-registration-under-current-hsqf-process-by-1-april; and NDIS, ‘QLD – Registering as a provider’: https://www.ndis.gov.au/providers/quality-and-safeguards/qld-registering-provider.

   [2] NDIS, ‘VIC – Registering as a provider’: https://www.ndis.gov.au/providers/quality-and-safeguards/vic-registering-provider.