There’s a real sense of accomplishment in passing an NDIS audit. And a massive sense of relief — NDIS audits are stressful for so many reasons. The good news: there are ways to reduce the stress of NDIS audits. We’ve compiled this list of tips to make NDIS audits less stressful and more effective.
1. START PREPARING EARLY
The ideal is to begin organising early — as early as possible. Establish a schedule that spreads the tasks across the entire audit cycle. Stay on top of your Quality Management tasks throughout the year and you’ll have fewer issues at audit. It’s that simple. Except that it’s often not that simple.
If it’s your first audit, you won’t have lots of time. Make sure you’ve completed most of your preparations before booking an audit date. Watch our YouTube Video on the NDIS Audit Process: Certification Audits, which will explain the process step by step.
All providers should begin preparing no less than 2-3 months before the audit is due.
Start by identifying the audit evidence you’ll need and where you can get it. Most of this information should be recorded in your self-assessment (conducted during the registration process). Then it’s a matter of collecting the materials mentioned.
There will be issues that arise along the way. Maybe your policies need reviewing and/or updating. Maybe staff got out of routine and stopped following the required processes in everyday service-delivery practice. Maybe there were significant changes in personnel, or to the service, or the supports being offered. Maybe some incidents or complaints slipped by without a proper response.
Avoid the temptation to simply put these issues in the too-hard-basket. Someone will need to attend to whatever issues you uncover. Place the issues on your Continuous Improvement Plan and manage it from there. That is, create a record to take to audit.
Be honest about what you can achieve in the limited preparation time. A few weeks doesn’t give you time to properly assess the needs, review your current approaches, and put improvements in place. Nor for proper consultation with staff and participants.
So, as part of your audit preparation, establish an Audit Review Schedule for managing Quality throughout the next audit cycle. And a credible plan for implementing the schedule.
2. LISTEN TO YOUR PROCRASTINATION
Anyone who has launched a business in the NDIS marketplace is a make-things-happen and make-things-better kind of person — not a procrastinator! So, if you’re finding it hard to get started on NDIS Quality Management, your procrastination might be telling you something. You’ve doubtless brought real skills to your NDIS business, but it’s possible that they don’t include Quality Management — not yet.
Many NDIS service providers have entered the NDIS marketplace with limited experience of community sector Quality Management. Even for those with experience, the NDIS Quality and Safeguarding Framework and audit process can be daunting. It takes time and practice to understand the requirements and effectively prepare for audit.
The NDIS requirements aren’t always clear. The NDIS Practice Standards can be quite tricky to understand — especially the Core Module.
Audits aren’t a matter of just ticking boxes — they’re about developing the best possible process for your needs. We’ve published a detailed reference for gathering evidence and preparing for Certification Audits. The NDIS Audit Guide: Practice Standards Core Module discusses strategies for meeting each of the NDIS requirements.
If you’re ready to do the work but simply don’t know where to start, our compliance training program Practical Audit Prep shows you the techniques and gives you the tools. You’ll learn NDIS Quality while working on your own compliance system and preparing for audit. It addresses the entire NDIS Practice Standards: Core Module step by step.
3. START WITH AN INTERNAL AUDIT
When you establish your Audit Review Schedule, aim to conduct an internal audit halfway through your audit cycle (around the 9th month). They’re a compliance requirement and the very best way to start preparing for audit. They provide a clear overview and a basis for developing a sound strategy — while leaving plenty of time to fix issues or make improvements. Spaced across the remaining months, tasks can be structured and planned effectively.
Internal audits should be conducted by someone who is not directly responsible for the area under audit. They must also have the skills — both managerial and practical —needed to make the assessment. In truth, this is not feasible for many provider organisations due to limited staff capacity and/or capability, leaving the organisation vulnerable to untreated risk and non-compliance. Fortunately, these and other problems can be overcome by outsourcing internal audits.
A reliable NDIS Quality specialist will know what to look for, what auditors look for, and what is likely to be most effective. A fresh perspective is always valuable — more so when it draws on current and long-term sector experience.
Working with an NDIS Quality specialist gives providers greater confidence and clarity about which strategies to pursue, how to avoid wasting time, and where to invest their energy. Even just making an enquiry can put your mind at rest. If you find someone that you can relate to, it’s good to know how they can help.
4. USE STAGE 1 TO PREPARE FOR STAGE 2
Areas of concern identified in the Stage 1 NDIS Audit should be addressed before Stage 2 begins. To develop strategies, try thinking about how the following relate to your specific issues:
- Risks: What kinds of risk are associated with the area of concern? Are there risks to NDIS participants, staff, the organisation, to compliance with requirements? If so, how serious are the risks and what risk treatments could be applied? Document your analysis.
- Documentation: Are you failing to document compliance? Is it a problem of faulty policy, processes, stakeholder understanding, or staff practice? To serve as evidence, documentation should address each stage of a process: from policy… to implementation… to practice… to review.
- Continuous improvement: Transfer areas of concern from Stage 1 to a Continuous Improvement Plan and deal with them methodically. If you fix the problem, that’s good. You’ll also demonstrate a commitment to methodically managing your NDIS Quality and Safeguarding requirements. And that’s very good.
5. CONDUCT RISK ASSESSMENTS
Risk Management is a large part of Quality Management, so it attracts more non-conformances than other audit areas. It also tends to be poorly understood. So, it’s worth investing some time in learning about Risk Management and checking your processes to see how effective your Risk Management strategies are.
The NDIS Practice Standards require providers to manage risks in all aspects of their service and service delivery. That means dealing with a lot of risks. All the risks, everywhere.
It’s a big job that must be tackled methodically, and documented in your Risk Register: identify the area, identify the risks, evaluate the risks, treat the risks where appropriate — if you decide to accept risks, document why.
With an audit looming up, you’ll need to prioritise.
First of all, if you’re currently providing services to participants, complete a Risk Assessment for each participant that considers the following:
- Risks to NDIS participants, staff, the community and the organisation.
- Risk of injury, neglect and mistreatment, information security, continuity of supports.
- Risks arising from the support provided, from the support environment and, in some cases, external risks that may arise and impact NDIS participants’ wellbeing or security.
In prioritising other audit tasks, consider risk. Document your assessment and tackle the tasks associated with higher levels of risk.
The NDIS Commission has made certain risk treatments mandatory. For example, worker screening and Role Risk Assessments. This leads to the next point.
6. TAKE CARE OF THE OBVIOUS
It’s surprising how often organisations neglect even the more straightforward NDIS requirements.
- Worker screening and Role Risk Assessments
- Qualifications and experience, as appropriate
- Complaints mechanisms and records of complaint resolutions
- Incident management processes and records
- Restrictive practice records
- Insurances
There are all sorts of reasons why the obvious might be neglected. Often, everyone knows but assumes someone else will fix such an obvious problem. It might be worth asking how that happens in your organisation and how to avoid it in the future.
7. COMMUNICATION
Quality Management is all about communication. It’s a constant conversation with NDIS participants, staff, other organisations, auditors and the NDIS Commission.
The NDIS Practice Standards devotes a lot of attention to communication — in particular, ensuring that NDIS participants understand their rights and obligations, and the provider’s complaints mechanisms and incident management mechanisms. A Welcome Pack is a great way to begin communicating with NDIS participants. If you don’t have one, download our free Welcome Pack. It’s written in plain English and covers all the issues required in the NDIS Practice Standards (except for your organisation’s service details). And it’s simple to use.
Consultation with staff is important too. NDIS Certification audits evaluate the entire service, so all staff play important roles. See TIP 9, below.
Keep notes of your interviews, investigations and assessments. The process of reaching a decision is sometimes as important as the decision itself: for example, when investigating complaints and incidents, planning supports with NDIS participants, solving communication problems and working with advocates, planning changes to the supports provided, or assessing risk. If the organisation decides not to act, the process of reaching that decision may still be important.
8. UNDERSTAND RESTRICTIVE PRACTICES
Even if your organisation doesn’t deliver Behaviour Support, it’s important to understand restrictive practices. Your staff may be applying restrictive practices (or even prohibited practices) without being aware of it. There are sometimes fine lines between restrictive practices and safety measures, and staff may not recognise the difference. And restrictive practices are sometimes necessary in an emergency to prevent injury, or just to manage safety.
What staff don’t know, they can’t recognise, and they can’t report. Failure to report can leave the organisation open to trouble. Don’t be blind-sided on the day of the NDIS audit: get information about restrictive practices, discuss issues with staff and make sure everyone understands the reporting process.
9. HAVE THE EVIDENCE READY
Have your audit evidence organised and ready to present. Your auditor will be well impressed, and much relieved — go on, ask us how we know this! The more you understand the NDIS Practice Standards and NDIS audits, the more successful this will be. But if you don’t have a lot of experience, give it a try anyway — audits are learning experiences. And, while auditors generally want to see the same things, they each have their own style of working — so if you haven’t predicted everything correctly, don’t be disheartened.
Having the evidence organised beforehand means less scurrying about on the day. That leaves more time and energy to deal with the unexpected. If you’ve been regularly maintaining your Quality System and preparing methodically, you’ll know your Quality System inside-out. And if the auditor feels more evidence is required, you’ll be able to think more clearly, knowing what they already have in hand.
10. KEEP IT LIGHT
Audit stress is infectious. Don’t pass it on to others.
It may also help to remember that NDIS audits are designed to help your organisation improve, not to punish. Staff may be scared of requirements they don’t understand or of being ‘exposed.’ As much as possible, discuss your goals with staff members and include them in the process.
Ideally, Quality Management is an on-going process. It takes the time to consult with staff about how to improve their service-delivery experience. Your time constraints are likely less-than-ideal, but the more consultative the process, the less staff will be anxious.
11. CONFIRM, CONFIRM, CONFIRM (…NICELY)
NDIS audit evidence is drawn from all sectors of the organisation and all service-delivery sites. Quality Managers often rely on other staff to prepare materials. It’s worth confirming some days before the audit that the materials are in place, that arrangements have been finalised, and that the relevant consent has been granted.
12. HAVE A ‘PLAN B’
As if NDIS Certification audits weren’t stressful enough, things always go wrong. The auditor will only be on-site for a limited time and there’s a window of time to deliver the evidence they need. So, wherever you are relying on people or technology, build in a Plan B.
Is this just Quality nerd hysteria? Here are a few examples from our experience:
- Key staff are absent on the day or quit just before the audit
- Staff turn off their phones on audit day
- Participants who have agreed to be interviewed don’t show
- Internet service failures and documents cannot be retrieved
- Severe weather or other natural crises
While it’s not possible to plan for every contingency, it’s worth assigning assistants to key audit roles, arranging for back-up interviewees and making hard copies of example documents.
CONCLUSION
We know that NDIS audits are stressful, not least because there’s just so much material to prepare. Hopefully, these 12 TIPS will help you get there with enough energy to celebrate your success. Because the process is often as important as the outcome, the more methodically you can prepare the better. Start early and get help early if you need it.