NDIS providers currently have three main options when setting up their Quality Systems. They can write their own NDIS Policy Manual, compile policies and procedures from available documents, or purchase a Manual from a consultant. This article discusses the pros and cons of each option, some tips for getting the best result, some things to aim for, and some things to avoid.
At PQplus, we’ve seen the problems and benefits each option. Overall, we believe the best option for most providers is to engage a Quality Management specialist — provided that they choose carefully. Whatever option they choose, we encourage NDIS providers to own, use, and personalise their Policy Manuals.
Purchase Policies from a Consultant
The NDIS marketplace is expanding and the number of consultants is growing. Unlike the rest of the NDIS marketplace, consultants are not regulated or held to a standard. It’s up to NDIS providers themselves to insist on the service they need and deserve. PQplus encourages providers to contact several consultants before purchasing a Policy Manual. We’ve created a fillable PDF to help them conduct due diligence.
We’ve seen a variety of policies offered for purchase: the good, the bad, the stolen, and the just plain weird. The variety is so wide that it’s impossible to meaningfully discuss the pros and cons. Instead, we’ll discuss the ideal and suggest some Dos and Don’ts.
Familiarity with content: If it’s clearly organised, a purchased Policy Manual can become familiar in a fraction of the time it would take to write. But you shouldn’t have to figure things out for yourself. We think consultants should take the time to explain how the Policy Manual is organised.
Do spend quality time with your Quality Management System.
Don’t be afraid to ask how the Policy Manual works.
Relationship: NDIS providers are responsible for their Quality System. Ideally, purchasing a Policy Manual would establish a good relationship with the consultants who constructed the Quality System. Consultants should be available after the purchase to answer questions, or assist where needed. After all, you’ve put a lot of trust in them.
If you don’t think you’ll need a consultant, you probably will! So, no matter how you source your policies, it’s worthwhile contacting several consultants to see who you could work with.
Do check out the help available, who you can work with, and the services they provide.
Don’t get into a relationship with a consultant who is only interested in sales.
Scope: For various reasons, good Policy Manuals will have some unexpected content. Important content – not fluff.
Firstly, a manual might contain policies beyond the organisation’s scope. These ‘extra’ policies can help as services expand or when the unexpected happens. Behaviour Support policies, for example, can help providers deal with unexpected incidents of ‘behaviours of concern’ or set the scene for expansion into providing that support. Good policy writing responds to opportunities that exist in the sector.
Secondly, good policy writing responds to risk. Each policy area contains generic risks, and policies should respond to risk wherever possible. This can also help providers and staff consider the risks specific to their circumstances.
Do ask about the policies a consultant supplies – do they charge extra for specialist policies?
Do check out the consultant’s experience.
Don’t assume you won’t need a Behaviour Support policy – IMHO all providers should have them.
Compliance: In the first instance, compliance means that your Policy Manual provides responses to all the NDIS registration self-assessment questions. Compliance becomes more complex at the Certification Audit. Auditors check that your policies match your service-delivery, incident management, continuous improvement, and so on. Compliance is about what you do, not what you have. And compliant policies are policies that contain sufficient guidance to ensure compliant service delivery.
Do ask consultants for sample policies and check the amount of guidance they contain.
Clarity: It is the provider’s responsibility to ensure staff understand relevant policies. Policies that are easy to understand help staff to implement policies in daily practice. And to demonstrate this understanding to auditors.
Do ask consultants for sample policies and check for readability.
Don’t assume that staff understand policies (confirm it).
Usability: Policy Manuals are meant to be used. Organisations must be able to edit, revise and add to their policies as needed. When purchasing a Policy Manual, providers probably aren’t thinking about writing policies!
One of our clients had bought a locked PDF. When an auditor found problems with the Policy Manual, the client could do nothing – the consultant had “forgotten the password” and refused to help!
Don’t purchase policies in a format that can’t be edited.
Do use your policies! It’s the pathway to audit success!
Write your own Policy Manual
Familiarity with the content. Write your own manual and you’ll be streets ahead in this regard. So long as your manual is systematically organised, you’ll be able to locate the exact policy at any time, and impress staff, NDIS participants and auditors alike.
Bespoke policies. No-one knows your organisation like you do. You can write policies to suit. In terms of compliance, this means you’ll be able to base your policies on the NDIS requirements – in particular, on specific risk assessments.
Good practice. No matter how you establish your Policy Manual, you will need to review, revise and add content where necessary. Writing your own policies is good practice and will give you a sense of control, right from the start.
Low Cost: Home grown policies cost only the time they take to write. So if you have plenty of time spare, then this can be an added advantage.
Cost in time: Writing policies can delay the registration process and the cost of that delay, in terms of lost business, should be considered. And any problems with your Quality System will be revealed during the audit, and you’ll need to fix them quickly – which is rarely convenient.
Then there’s the time consumed by the writing itself. Let’s assume that a manual has a minimum of 30 policies, and that policies each take an average of 10 hours to develop, and that the policy writer’s time is valued at only $25 per hour: the real cost of writing a minimal policy manual is $7500. (The graph below shows variations on that estimate while retaining the conservative assumption of 10 hours per policy).
TIP: On the other hand, purchasing policies from a consultant can result in unexpected costs. Before rushing out and spending money, read the discussion, below.
Poor readability. There’s no rules about style, and auditors are not literary critics. But readability can suffer for many reasons. It makes sense that compliance will be easier if policies are well-organised and easy to understand. We’ve all read policies that are difficult to comprehend. Much of the NDIS material could be a whole lot clearer! When writing policy, we risk making the same errors by using official-sounding language. Easy-to-read policy is not easy-to-write.
TIP: Think about style before writing too much. Get hold of some effective policies or government literature. Model your writing on passages that are clearly organised and easy to read.
Limited scope. Expertise comes from specialisation. Few experts in delivering disability services are also experts in policy, and fewer still in policy writing. When they’re written with a comprehensive knowledge of the sector, Policy Manuals can be valuable management tools. Writing a full NDIS Policy Manual requires a lot of research. So, before you begin, it’s best if you know what to research.
TIP: Be realistic about what your experience allows you to achieve.
Too much detail. For new NDIS providers, it’s unlikely that policies will be over-cluttered, but it’s worth mentioning. Policy Manuals can get mired down in too much detail – especially if policy writing becomes a knee-jerk response to incidents or events.
NDIS policies can indeed respond to incidents, but they should consider a range of other factors, such as: an assessment of risk, feedback and complaints, best practice, legislation and outcomes-related data (as appropriate). Greater detail and staff guidance may be required where risks are greater, legislation is more complex, or organisational structures are more complicated. There are no hard-and-fast rules, however. And, as we said, it’s more likely that new providers will have too little detail where it’s needed.
TIP: Do your policies reflect the risks involved in delivering your services? Think about risk and keep a record of your assessments and risk treatment plans in a Risk Register. We predict that auditors will be more and more interested in risk management in the next few years.
Compiled Policy Manuals
Many providers use policies they’ve brought over from other businesses or downloaded from the internet. These might be complete or compiled from individual documents. They may come from another field, such as commerce, industry or clinical practice. Or they might be from the community sector outside of the NDIS. In short, these are rarely suitable except, possibly, as models for policy writing.
Cost and time: Whether using free documents or documents already at hand, these will save time and money, initially – see the entry in CONS).
Style: While the style will not be uniform throughout a compilation, this is not a problem unless it affects readability. Policies of a high standard will make later editing easier. Model your writing on the policies you find most well-organised and readable.
TIP: If you find something to model your policies on, ask others to read a small section and then recount what it says. If they can’t, maybe it’s not as clear as you think it is.
Unsuitable to the NDIS: Policies drawn from other fields are rarely appropriate for use in the NDIS. Even policies drawn from related fields. This is because policies required by NDIS service providers should by written with reference to the NDIS Practice Standards, with specific content and with a specific approach. Disability and mental health services may still operate under state requirements, and their policies reflect those standards.
The NDIS Practice Standards apply to both service management and service delivery. The overlap with industry and commerce is fairly small. Even where policy content overlaps, there are important differences in the way NDIS providers are required to think about safety, staff management, information management, risk management and governance.
While disability and mental health standards share much more with the NDIS Standards, there are important differences that polices should reflect. Policies copied from disability service providers may omit NDIS requirements or adhere unnecessarily to state-specific standards. Further, even large community organisations make mistakes. So copying from a disability service’s policies risks creating inappropriate policy or replicating policy errors.
Cost and time: The time and money saved initially may be lost later in the audit cycle. When an audit reveals problems, you’ll have a limited time to remedy the errors. Of course, this is true regardless of how the policies are sourced.
Each of the three options has its strengths and weaknesses. Writing your own policy allows you to take control of your Quality Management, but writing a complete Manual incurs a significant cost in time. Model your policy formulation on any documents you’ve got access to, but don’t assume they’ll work in the NDIS environment. A professionally developed Quality Management System can be the start of a great working relationship if you choose a suitable consultant.
There’s a time for each option. Think them through carefully and avoid creating problems that will emerge at audit.