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11 Tips for NDIS Audits

11 Tips for NDIS Audits
NDIS audits need teamwork. Consult with staff, participants and experts

There’s a real sense of accomplishment in passing an audit. But let’s be honest: NDIS audits are stressful for so many reasons. While Quality Managers feel it most acutely, stress can ricochet throughout an organisation with far-reaching effects — during preparations and on the day. The good news: there are ways to reduce stress of NDIS audits. We’ve compiled this list of tips to make NDIS audits less stressful and more effective.

1. START PREPARING EARLY

Begin organising your evidence early. You’ll be that little less exhausted on the day of the NDIS audit.

The self-assessment you conducted during the registration process is a great place to start. It’s simply a matter of matching your self-assessment responses to relevant evidence. If you’re unsure about how to do this, you’re not alone. The NDIS Practice Standards can be quite tricky to understand — especially the Core Module. Many providers have found our guide helpful. The PQplus Core Module Audit Guide explains NDIS Quality Management, the Practice Standards and has a commentary to help providers think through the requirements and supply evidence. It also provides tools to help prioritise your audit preparation.  

How early to begin? Ideally, audit preparation begins before the NDIS registration application is submitted, and continues month by month as routine Quality Management tasks are performed. In the real world, NDIS providers are launched into the audit cycle immediately upon registering for the NDIS, with routine Quality Management waiting until things settle down a bit. So where you can, allow as much time as possible and begin thinking audits immediately.

2. LISTEN TO YOUR PROCRASTINATION

Congratulations on launching a business in the new NDIS marketplace. You’re a go-getter, a trend setter, a 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.

If reading about NDIS Quality Management makes your head spin, it might be best to call an expert. Working alongside an expert to get your Quality System in order is the best way to learn Quality Management and prepare for your NDIS audit. The earlier your organisation seeks help, the more a consultant will understand your circumstances and the more help will be available.

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.  

3. USE STAGE 1 TO PREPARE FOR STAGE 2

If your Stage 1 NDIS Audit identifies areas of concern, begin addressing the issues before Stage 2 begins. Although your specific approach will depend on the area of concern, there are some common strategies that you can apply.

  • Risks: Think about the risks that the area of concern presents. Document your analysis. Are there risks to NDIS participants, staff, the organisation and compliance with requirements? If so, how serious are the risks and what risk treatments could be applied?
  • Documentation: Is the problem a failure to document compliance? A gap in your policies may imply further gaps throughout a process. To serve as evidence, documentation should address each stage of a process: from policy… to implementation… to practice… to review.
  • Continuous improvement: Areas of concern from Stage 1 of the audit should be transferred to a Continuous Improvement Plan and dealt with 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.

4. CONDUCT RISK ASSESSMENTS

Auditors report that providers tend to neglect Risk Assessments. The NDIS Practice Standards require providers to consider risk as part of their processes from policy formulation to reviews.

  • 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.

That’s a lot of risks. So document them in your Risk Register and tackle them methodically: identify the area, identify the risks, evaluate the risks, treat the risks where appropriate – if you decide to accept risks, document why.

The NDIS Commission has made certain risk treatments mandatory. For example, worker screening and Role Risk Assessments. This leads to the next point.

5. TAKE CARE OF THE OBVIOUS

As we’ve said, some NDIS requirements are more straight-forward, even mandatory. Even so, it’s surprising how often organisations neglect them.

  • 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.

6. 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.

Posters can be useful too. Posters and brochures must be easily accessible. That means accessible language, displayed in an accessible location. The Department of Social Services website provides free posters about rights and services. You’ll need to add information to some of the posters (e.g., the poster about complaints has a picture of a person and a blank speech bubble. Auditors will expect more details about how to make complaints).

Consultation with staff is important too. Stage 2 Certification audits evaluate the entire service, so all staff play important roles. See TIP 9, below.

Communication with auditors means that all processes need to be documented. 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.

7. UNDERSTAND RESTRICTIVE PRACTICES

Even if your organisation does not deliver Behaviour Support, it’s important to understand restrictive practices. Your staff may be applying restrictive practices (or even prohibited practices) without be 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. 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.

8. HAVE THE EVIDENCE READY.

Have your audit evidence organised and ready to present. Your auditor will be well impressed, and even relieved – go on, ask us how we know this. The more you understand 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. 

9. 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.  

10. CONFIRM, CONFIRM, CONFIRM (…NICELY)

NDIS audit evidence is drawn from all sectors of the organisation and all service-delivery sites. Quality Managers may need to 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.

11. HAVE A ‘PLAN B’

As if Stage 2 Certification Audits weren’t stressful enough, things always go wrong. The auditor will only be on-site for a limited time, and must have evidence to form an evaluation. So wherever you are relying on people or technology, build in a Plan B.

If you think that this is just Quality Management hysteria, here are some 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 11 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. The most important thing is to start early and get help early if you need it.  

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