The Australian Government has always taken a firm stance on fraud and non-compliance in the National Disability Insurance Scheme (NDIS) – and with the multi-agency Fraud Fusion Taskforce (FFT) investigating billions of dollars of payments made to NDIS providers, the focus on integrity has never been sharper.
Formed in late 2022, the FFT is co-led by the National Disability Insurance Agency (NDIA) and Services Australia, and has a raft of other member agencies, including the Australian Federal Police and the Australian Taxation Office. The Taskforce works to prevent and disrupt fraud against government programs – like the NDIS – and includes intelligence sharing, prosecution and other regulatory actions.
With safeguarding of participants, their funding, and the Scheme at the centre of the NDIA’s remit, the Agency has become increasingly vigilant when it comes to the conduct of NDIS providers.
To ensure people with disability can continue to access the vital supports they need, the NDIA has in place a number of compliance tools and guardrails that not only protect participants but also maintain the integrity of the Scheme.
Enter the payment integrity audit, designed to change behaviour in the NDIS by scrutinising claims and making providers accountable for the invoices they submit.
One of many tools in the NDIA’s fraud and non-compliance toolkit, a payment integrity audit is – in essence – a request from the Agency for more information about a claim.
It’s important that NDIS funding isn’t misused and it’s a legal requirement that it’s spent in accordance with participant plans, so the NDIA is increasingly using payment integrity audits to:
The Agency audits claims submitted by both registered and non-registered providers for supports provided to self managed, plan managed and Agency managed participants. The vast majority of audits take place before a claim is paid, but occasionally the NDIA investigates post payment.
When an invoice is submitted to the NDIA, the Agency’s systems run automated checks that look at key data points in a claim. Based on the information identified through those checks, the NDIA may ask a provider, a plan manager or both to provide more information to substantiate the claim.
The NDIS Act provides the Agency with powers to obtain information, recover debts, and bring legal proceeding against providers for non-compliance. In addition to denying a claim before it’s paid, the NDIA can continue to review future claims.
Payment integrity audits are conducted by a dedicated team at the NDIA – not by planners or local area coordinators – and current areas of focus include claims related to Short Term Accommodation, Supported Independent Living, support coordination, and some allied health supports.
As part of a payment integrity audit, the Agency checks flagged invoices and asks providers to substantiate their claims by providing some or all of the information below:
There’s no doubt that audits can be time consuming for providers, so it’s best to act quickly.
It’s your responsibility to act within the Agency’s requirements.
If your client is plan managed by us and the NDIA lets us know it’s auditing one of your claims, we’ll contact you and our experts will act swiftly to provide the Agency with the information it needs to complete its audit.
If the NDIA needs information we don’t hold – like rosters and timesheets – Agency staff will get in touch with you directly.
Typically, you’ll receive a request for information email from the NDIA which includes an explanation of what’s being audited and a reference number. If you’re notified that one of your claims is being audited, gather all available evidence to support the claim and provide it to the Agency as swiftly as possible. If you need more time, you can ask the NDIA to extend its deadline.
Once it has all requested information in hand, the Agency will consider the matter and make a decision. If it’s satisfied, it'll add the claim to the next payment run and let us know when it will be paid – and we’ll communicate that to you. If it isn’t satisfied, the NDIA may reject your claim.
The timeframe of audits is up to the Agency, so if you're awaiting an outcome and want to know what’s going on with the process, it's best to contact the NDIA directly.
When it comes to compliance, the best line of defense is to have your paperwork in order so you can clearly and accurately substantiate every NDIS claim.
Keep vital records, registrations and qualifications up to date, make sure to have service agreements in place with your clients, and review your invoices before submitting them for payment so you know they include all required information. Compliant invoices should include:
Before providing supports, check that your client has the necessary funding – in the correct funding categories – and ask them to email us a copy of the service agreement they have with you so you and they can be sure the funding is there when it comes time to claim.
My Plan Manager’s market-leading technology supports us to conduct payment integrity checks, ensure correct use of client funds, and enforce the NDIS Pricing Arrangements and Price Limits.
Every claim we receive undergoes 30+ automated checks to ensure it’s compliant with NDIA requirements, and that’s a great start when it comes to audits!
Don’t be lax about record keeping, be accurate, and be sure to have your paperwork in order, because the NDIA may request documentation before or after payments are made if it needs more information to substantiate a claim. These requests can be made randomly, so vigilance is key.
The Agency says that re-submitting a claim that’s been held for review is non-compliant behaviour – and resubmitting it within 14 days of the initial claim being made may trigger an even deeper review.
We understand there are times when duplicate claims are submitted by mistake, and if we spot one, we’ll flag it with you and let you know why it can’t be paid.
The aim of the FFT is to disrupt bad practice and fraudulent providers and it’s reportedly received tens of thousands of tip-offs since it was formed.
If you suspect someone is doing the wrong thing with NDIS funds, you can report your concerns. Find out how by clicking here.
If you have any questions about payment integrity audits, our friendly team is here to assist. You can call us on 1800 861 272 from 8am-5.30pm (SA time), Monday to Friday.
Like most service providers, you’ll have experienced delays with a payment or two in your time, and you’ll be well versed in the woes those delays can cause.
In the National Disability Insurance Scheme (NDIS), although most providers are in the business of supporting people to live better lives, getting paid keeps the lights on and services running, which makes swift processing of claims pretty important too!
But with the National Disability Insurance Agency (NDIA) focused on stamping out fraud and non-compliant behaviour, its staff take a closer look at claims these days, which means it can take anywhere from two to 10 working days for funds to be released and payments made.
To help your invoices make their way through the queue as quickly as possible, we looked over some of the most common mistakes made in the claims we see and pulled together five quick tips for compiling quality invoices.
It’s a requirement of the NDIA that Supported Independent Living (SIL) supports are claimed from SIL funding and not from general Core Supports.
SIL must be stated in a plan and funding must be used in the way it’s prescribed by the NDIA. Be sure your client has SIL stated in their plan and use the correct SIL codes when claiming.
Line items let the NDIA know which budget category should pay for the supports you provide.
The NDIS Pricing Arrangements and Price Limits document contains more than 800 line items for providers to claim from, and the document changes from time to time, so we often see claims with line item codes that no longer exist.
To help you get paid in the shortest time possible, be sure the line item code you’re claiming against is up to date and applicable to the supports you delivered.
We often see invoices using a date range with one total charge, and sometimes they’ll state a quantity of hours that’s more than the number of hours in a day, which usually happens if there are multiple workers providing support to a client at the same time.
Whenever you submit an invoice, be sure to break down each support and include information such as:
You also need to include a separate unit price and quantity for extra costs, like travel. This makes it clear when something is an additional cost and not a charge for supports that’s higher than the price stated in the NDIS Pricing Arrangements and Price Limits.
Be sure to check your client has the budgets and categories that are applicable to your services, and make sure they have sufficient funding to cover your fees.
For example, if a provider invoices for personal training when their client doesn’t have appropriate funding in the Improved Health and Wellbeing category in their NDIS plan, the NDIA will reject the claim.
It’s also good to put a service agreement in place to reduce the likelihood of a claim being rejected (you can send us a copy of the agreement once it’s signed).
We recommend you invoice regularly because, when you do, your cashflow is less likely to be impacted if there’s something in a claim that prevents payment.
The NDIA says claims for Agency-managed participants need to be submitted within 90 days from the end of a service booking – but invoicing for supports as they’re provided, regardless of how your client’s NDIS funding is managed, is good business practice and it helps to keep money coming in too!
Developed to support providers just like you, our invoice tracker helps you check the status of your invoices as they progress from submission to payment. Status information is usually available 24 hours after you submit a claim.
You’ll find the My Plan Manager invoice tracker here.
If you have any questions, our friendly team is here to assist. You can contact us on 1800 861 272 from 8am-5.30pm (SA time), Monday to Friday, or email us at enquiries@myplanmanager.com.au.
The National Disability Insurance Scheme (NDIS) is founded on the ideals of the free market, with people with disability being active consumers who’re able to make choices about where they spend their funding to receive the support that suits them best.
But choice and control doesn’t have the same impact when choice is limited.
And choice could become challenging, it seems, with 21 per cent of providers who responded to a national survey detailed in the National Disability Services (NDS) State of the Disability Sector Report, saying they’re considering getting out of the sector entirely.
Their considerations could be linked to the fact that half the provider respondents to the survey reported they made a financial loss in the 2023-2024 financial year, while just 13 per cent broke even. Additionally, 80 per cent of respondents said they were concerned they wouldn’t be able to continue providing NDIS services at the rates outlined in the current NDIS Pricing Arrangements and Price Limits (the Price Guide).
Why does this matter to participants? Well… because, if providers can’t cover their expenses – including staff training, compliance, recruitment, retention, filling vacancies or finding new clients – they’re at risk of shutting up shop, leaving participants with less choice or, even more critically, at risk of being unsupported.
And all of this is happening against the backdrop of the rising cost of living that’s impacting all Australians. Utility bills have gone up, insurance premiums have increased, petrol prices have surged, and yet many items in the Price Guide have remained the same for at least five years.
Weigh all that up and the maths is simple – it costs more today to do business.
NDS CEO, Michael Perusco, says the State of the Disability Sector Report shows it’s vital the National Disability Insurance Agency works with providers to achieve policy settings so providers can continue to serve and support people with disability and their loved ones.
"We are particularly concerned about the likely closure of some long-standing services across the country. This will leave people with disability with fewer options and some with very complex needs will have no other options at all,” says Mr Perusco.
"These organisations are acting as the safety net for people, particularly when there are no suitable alternative federal, state or non-government supports available.
"It is incredible to see the adaptability and resilience of many service providers in a tough environment as they continue to work hard to support to people with disability, but they too need support to keep going.”
So, what does the future hold?
The NDS survey found almost all providers (96 per cent) are working hard to improve productivity and 51 per cent want to expand their operations, but they can’t do that much longer under current conditions without government support.
“What’s needed is assistance with innovative measures to improve productivity, fair funding that supports sustainable services, and action to build a stronger workforce and provide more employment opportunities,” says Mr Perusco.
There is a will and a drive to work smarter and be creative to find solutions for participants. But no-one operates in a vacuum and NDS warns that the Federal Government – which controls much of the way the NDIS operates – must support effective operations for providers. Meanwhile, it says state and territory governments must ensure foundational supports are in place, in order to contribute to the sustainability of the NDIS.
The Scheme is Australia’s biggest social reform since Medicare. And that means we owe it to each other and the people with disability who are participants – or who will join as participants – to get it right, now and in the future.
By now you’ll know all about the National Disability Insurance Scheme’s (NDIS) new spending rules and how they’ve changed the way funding is allocated and used.
The National Disability Insurance Agency (NDIA) has defined the supports participants can’t and can’t purchase, and clarified the rules around requesting a substitute – known as a ‘replacement support’.
The question is, what exactly is a replacement support, what can it replace, and when?
The NDIA defines a replacement support as a service, an item, or equipment a participant would like to use instead of the NDIS support or supports in their plan, with the Agency confirming replacements are substitutes and not additional supports.
Currently, the list of replacement supports is limited to:
Replacing an approved support with a standard commercially available household item may be considered when there’s clear evidence that the need relates specifically to a participant’s impairment.
You can discover more about impairments and how they relate to NDIS eligibility here.
A replacement may also be considered if it’s seen to increase ‘whole task’ independence and reduce or remove the need for a support worker or disability specific assistive technology (e.g., a blender to prepare meals aligned to a modified diet).
The NDIA may consider a replacement when a participant needs a device or app to meet communication and accessibility needs arising from disability. An example could include a non-verbal participant utilising a tablet to communicate with their loved ones and service providers.
Any smart device used for tracking purposes could be considered a restrictive practice and needs to be considered in this context.
The NDIA needs to be satisfied that a replacement support will provide the same or better outcomes and cost the same or less than a support that’s already included in a participant’s plan. Participants must apply for – and receive – approval of a replacement support before purchasing the support. To do that, they can fill out an application for a replacement support, or provide the NDIA with information to support their request by email or via a phone call to the Agency. Only some supports can be replaced and only if the NDIA agrees in writing.
If an application for a replacement support isn’t approved, the participant must wait 12 months before they can request it again. The NDIA’s decisions about replacement supports aren’t reviewable, meaning participant can’t seek to have the decisions reversed.
To keep up to date with changes to the NDIS as they come up, be sure to bookmark and visit these pages:
Summary of legislation changes | NDIS
Frequently asked questions about legislation
Provider reports are powerful devices in the National Disability Insurance Scheme (NDIS) that can make or break funding requests. Delivered well, they can demonstrate to the National Disability Insurance Agency (NDIA) where a participant’s at and the impact their disability has on their daily life – and they can assist with securing funding for supports that allow people to live as independently as possible.
So, what does that mean for you? Well, put simply, preparing A-grade reports in a complex ecosystem where change is a constant is a huge responsibility. But NDIS providers do incredible work, and we know you’re more than ready to step up to the plate to support your clients.
The NDIA doesn’t have a template for provider reporting, but there are tips for crafting documentation to support the best outcomes for individual participants – as Linda Grant, one of our Community Engagement and Partnerships Managers, explains.
Previously a support coordinator and a delegate at the NDIA, Linda has seen hundreds – if not thousands – of provider reports across the years, so she’s well placed to offer up guidance drawn from the ones that worked and the ones that didn’t.
If you’re a provider looking to sharpen the vital skill of report writing, be sure to consider Linda’s insights before drafting your next report.
The NDIA uses evidence to support decisions when allocating funding for NDIS supports, and provider reports often hold the key to providing that evidence. It’s a reasonable expectation that providers of most capacity building supports will report on supports delivered and progression towards – or achievement of – a person’s goals, as well as providing recommendations for the future. These reports are generally requested when a participant has an upcoming plan reassessment, or if they’re alerting the NDIA to a change in their circumstances.
Reports are also required when Level 3 and 4 assistive technology and home modifications are needed.
With stricter spending rules now in place in the NDIS, provider reporting is more essential than ever to ensuring specific supports are included in a participant’s plan.
We explore how participants can secure the funding they need here.
The NDIS support catalogue indicates when report writing is in and out of scope.
Including the information below in a report can help to paint a clearer picture of the participant and pitch a stronger case for the funding and supports they need.
Reporting structure is vital too and can influence the NDIA’s funding decisions. Be sure to clearly:
The NDIA requires providers to think about and document instances of support in terms of outcomes, not outputs. An output details an instance of support, such as ‘Carly went to the city and had a coffee’, whereas an outcome details the result of an activity and its impact. An example is below:
“Carly went into the city today. She ordered a coffee and paid for it herself. She needed prompting to wait to receive her change. Outcomes included increasing money handling skills and the opportunity to develop social skills in her community.”
Using objective, rather than subjective, language to communicate observations in provider reports is vital!
Subjective information includes personal perspectives, feelings and opinions, whereas objective language is factual and impartial.
Subjective language can look like this:
Objective language looks more like this:
The Agency uses key phases in the objects and principles of the NDIS Act and its reasonable and necessary criteria. These key phrases include:
Using these key phrases, where relevant, can create a stronger report that communicates to the NDIA in the Agency’s own language that’s tied to its principles.
Reports should be written in plain English without jargon and clinical language. They should be easily understood by the participant, their informal supports, and the NDIA representative. Don’t assume the NDIA representative has a specialist background or understands complex industry speak!
Reports need to describe the positive or negative impact of the service, support or equipment on the person’s ability to live an ordinary life – in language that’s understandable to anyone.
Also consider these points:
Provider reporting is a vital tool in NDIS, and we hope Linda’s tips have added value. If you want to know more, be sure to check out NDIS provider reporting 101.
Are you confused about what you can buy with your National Disability Insurance Scheme (NDIS) funding, or what your plan covers? Do you worry about incurring debt by making purchases that the National Disability Insurance Agency (NDIA) won’t pay for?
If that sounds familiar, you’re not alone!
With new legislation tightening up spending in the NDIS, and the disability landscape shifting shape once again, keeping on top of which supports the Scheme will and won’t fund is no easy task.
That’s why it's more important than ever to be proactive and ask for the supports you need, so they can be stated in your plan and funded accordingly.
Linda Grant, one of our national team of Community Engagement and Partnerships Managers, previously worked as a support coordinator and has extensive experience of helping people with disability to secure vital funding.
We spoke with her to find out how ask for the funding you need. Here’s what Linda had to say.
Previously, there seemed to be a lot more flexibility in how ‘reasonable and necessary’ was interpreted. We saw the likes of the NDIS ‘Can I buy it?’ checklist – a layperson’s guide of legislation s34 – Reasonable and Necessary, which made it easier to understand what people could and couldn’t use their NDIS funding for.
The NDIS supports lists, which were recently introduced, have created a lot of uncertainty for participants, their families, service providers, and support coordinators – pretty much everyone. I expect the intention of this change was the appropriate use of NDIS funds, but now there’s a real hesitancy around spending, and many worry the changes have created such fear that some people may be going without necessary supports because they’re unsure if they meet the NDIA’s requirements.
The good news is, there are steps you can take to spend funding with confidence.
We’re seeing plans coming through that are a lot more prescriptive than they were in previous years, meaning there’s less flexibility around how funding can be utilised. When supports are written into a plan from the start, there’s certainty that the NDIS will fund them.
There’s more focus now on getting the planning right to ensure participants are set up for success in their new plans.
It’s difficult to give a definitive list of supports to request, as everyone’s support needs are different. If a participant requires supports that are on the list of ‘Supports that are not NDIS supports’, I highly recommend working towards having those written into a plan.
When I was a support coordinator I’d often ask: ‘If you could put your disability aside, could you complete the task independently?’. If they could, then it was evident support was required as a direct result of disability.
Also, it’s great when participants have strong support at home, work and in the community. We want to support, for example, an adult child and their mother to have the relationship they’d have if the child didn’t have disability. Would you still be performing personal care for your 22-year-old son if he didn’t have disability? Not generally, so it’s about making sure he has choice.
If you’re in doubt about a support, but unsure about whether or not it will be funded, I say ask for it, because it’s always better to have a support funded and ready for when and if you need it.
Talk to your support network and find out what supports might assist you – such as therapies (like occupational therapy and physiotherapy), support workers, meal preparation and transport. Think about what’s worked well and what hasn’t. Then work with your support coordinator or others in your support network to ensure those supports are considered for the new plan period – and make sure to allow sufficient time for reporting (i.e. functional capacity and end of plan reports) from allied health professionals. It’s important that reports are written in a way that identifies any gaps in supports, how supports can assist, and why they’re most appropriately funded by the NDIS. This approach ensures you’re heading into a plan reassessment fully equipped to leave with a plan that best suits your needs.
There are some great guides out there to assist providers with report writing, including these two:
Tips for excellent NDIS report writing
Three to four months before a plan reassessment is the best time to start, but many plans are automatically rolling over. In short, flag the change in support needs as soon as you can. If the support needs are due to a change in circumstances, you can contact the NDIA to discuss what option may be best for you.
A support coordinator (if you have one) is a great person to assist and if you have a significant change in a particular area, such as housing, there are specialist support coordinators out there who can help.
Participants who don’t have funding for support coordination can liaise with a Local Area Coordinator, Early Childhood Early Intervention partner, or the NDIA directly, as well as turning to family members, friends, and the community. And don’t forget, your plan manager can assist too.
Fundamentally, all supports need to be approved by an NDIA delegate, but many alternative supports can assist you to navigate that pathway, so you’re set up for success.
My Plan Manager’s NDIS experts support people to understand their plans, how they can use them, and how to manage their funding, and participants can also get support from our online community – Kinora – which connects people with disability and their supporters to peers, NDIS experts, disability sector professionals and service providers.
There are some amazing resources available on the NDIS website to support you with preparing for your planning meeting and creating your NDIS plan. If you’re already connected with providers, work with them to source the evidence you need – current functional capacity assessments are always a good option to take along to your planning meeting (current usually means less than two years old). Be sure any reports you present from your providers highlight any gaps in supports, include recommendations on how to fill them, and detail what those supports will help you to achieve.
Under the new legislation that came into effect on 3 October 2024, the NDIA has compliance powers for circumstances where it believes a provider and/or a participant wrongly spends NDIS funding. This includes the ability to raise a debt. The NDIA has previously been able to raise a debt, however the new legislation makes the Agency’s powers clearer. The long and the short of it is that you should do everything you can to have the supports you need included in your NDIS plan, so you know they’ll be funded.
The NDIS educators at DSC have explored the topic of debt in an informative article you can find here.
And don’t forget, at My Plan Manager we’re here to help. We’re all about uncomplicating the NDIS, and if you have a tricky question about your plan – like how to use it or what it can fund - our friendly team is ready to assist. You’re never alone with us in your corner!
You can email us at enquiries@myplanmanager.com.au or call us on 1800 861 272 from 8am-5.30pm (SA time), Monday to Friday.
Updated 13 February 2025
Change can be confusing at the best of times – and in the National Disability Insurance Scheme (NDIS) it’s usually accompanied by a lot of new terminology as well.
In recent times, you may have heard about something called a ‘Notice of Impairments’ – and you may be wondering what it’s all about.
Don’t worry, we’ve got you covered.
The 2024 introduction of new legislation governing NDIS brought with it a raft of changes, including the introduction of a new tool known as a Notice of Impairments.
Developed in response to recommendations made by the NDIS Review – as well as requests from people with disability for clarity around Scheme access – the Notice is designed to provide you with information about how you meet the NDIS’ disability or early intervention requirements, or both.
But what else does the Notice mean and who does it affect? Here’s what we know so far.
Everyone who’s joined the Scheme since 1 January 2025 has been told what impairment or impairments made them eligible for the NDIS, with the information outlined in their Notice.
People who were accessing NDIS supports prior to 2025 will receive their Notice when they move to a new plan, and the Agency will let them know if any further information is needed, and whether there will be any changes made to their supports.
So, for now, there’s nothing you need to do.
In the past, NDIS eligibility was based solely on whether or not a person had a diagnosed disability, but under the new legislation, things have changed.
These days, to become an NDIS participant, you need to meet the Agency’s disability or early intervention requirements, or both. That means you must provide the NDIA with evidence of one or more impairments that are likely to be permanent and show how your disability impacts your daily life.
Under the new system, there are six categories of impairment:
If the NDIA agrees your disability spans multiple categories (e.g. intellectual and physical), then your Notice will clearly state that.
To find out more about the Agency’s approach to impairments, click here.
You or your nominee (if you have one) can ask the NDIA to vary your impairment category if it’s not right, or if things have changed.
It’s likely you’ll need to provide evidence to support your request and if the NDIA doesn’t agree with you and decides not to make a change, you can ask for that decision to be reviewed.
The NDIA understands that everyone is different and even people with the same diagnosis can have different impairments and support needs.
Under the new system, every NDIS participant will have a support needs assessment, which means the Agency will look at your disability-related support needs and use the information gathered to decide the funding you need and what it should be spent on.
The support needs assessment process is still a work in progress. The NDIA has committed to co-designing it with the disability community, so keep an eye on the NDIS website for more information.
We’ll keep you updated too, as soon as we know more.
Invoicing and record keeping. They may not be the most exciting parts of life as a National Disability Insurance Scheme (NDIS) provider, but they’re vital.
Whether you’re a fan of hard copy documentation or you opt to keep evidence of your service delivery and claims in electronic form, one thing is clear – maintaining full and accurate records is a must.
We spoke to Angela Harvey, Managing Director of boutique NDIS consulting agency, Supporting Potential, to find out why.
Here’s what she had to say.
By Angela Harvey – Managing Director, Supporting Potential
In the dynamic field of disability services, the importance placed on defensible documentation is greater now than ever before.
While some may view it as a bureaucratic pain, documentation is a fundamental aspect of practice for providers of NDIS supports – one that safeguards participants and protects providers from consequences that can potentially become legal.
Defensible documentation comprises records that are clear, accurate, and comprehensive.
Currently, in the NDIS, the rules around record keeping vary depending on whether a provider is registered with the NDIS Quality and Safeguards Commission or not.
However, the introduction of uniform standards is expected, and that means every provider should take the opportunity now to focus on getting their house in order.
The National Disability Insurance Agency (NDIA) requires providers to maintain complete, truthful, and accurate records to support their claims, including:
Service agreements are contentious, because the NDIS Practice Standards only require participants to have a clear understanding of the supports they’ve chosen and how they’ll be provided.
So, while it isn’t stated that service agreements need to be documented in writing (except for those related to Specialist Disability Accommodation), the NDIA ‘recommends having a written service agreement so participants and providers are clear about what each party has agreed to.'
Separately, the Commission mandates that registered providers maintain records across a raft of areas, such as:
Recent legal cases highlight the importance of robust documentation, with courts and regulatory bodies examining NDIS provider records closely to ensure compliance with standards and the protection of participant rights.
Inadequate documentation can lead to severe consequences for providers, including fines and service suspensions. In several cases around the country, providers have faced significant penalties – not only for the absence of support documentation, but also for failing to document essential details that a reasonable person would expect to be recorded.
There’s been an uptick in the number of requests for support our team has received from providers who thought they had appropriate systems and documentation in place, but later found themselves needing to take remedial action following compliance investigations undertaken by the Commission. Examples include providers that:
While requirements around record-keeping can sometimes feel overwhelming, it’s important to remember that defensible documentation not only serves legal and compliance requirements, but also offers significant operational benefits to providers. Value delivered includes:
To ensure documentation is defensible, providers should provide regular staff training on the importance of documentation and the techniques to be applied to it, use technology to streamline data collection and management, and conduct regular audits to identify improvements and ensure compliance with the NDIS Practice Standards.
Reliable documentation supports an organisation's sustainability and effectiveness and ultimately aids in protecting the wellbeing of participants.
In an industry focused on supporting vulnerable people, the value of dependable and defensible documentation can’t be overstated.
For more information about invoicing and record keeping, click here.
It’s true, clients want providers with the skills and expertise to do a great job. But when it comes to delivering a great service, other factors come into play – with attributes like clear communication, honesty and consistency deeply impacting the overall client experience.
As providers, we strive to understand our clients so we can shape our service and meet them where they and their needs are at.
To help us and you make informed decisions, we spoke with National Disability Insurance Scheme (NDIS) participants and their families, inviting them to lift the veil on their experiences and tell us what clients really want from providers.
Alan lives in Brisbane. He joined the NDIS six months after it launched in Queensland and says becoming a participant in the Scheme has revolutionised his life.
“The NDIS in general has been a game changer in my life,” says Alan. “I’m now doing a lot more than I ever thought I’d do.”
“It’s just fantastic being on the NDIS. I don’t have to rely on family members or friends to take me places and do stuff with me. Instead, I employ professionals who support me to achieve what I want.
“I don’t have to feel guilty about it. I’m not putting people out to help me, I’m doing things with support workers that I would probably be doing on my own if I didn’t have my vision impairment.
“Life feels huge, unbelievable. I never thought I’d be doing half the stuff I’m doing now – everyday things that ‘normal’ people take for granted.”
Alan sources his support workers via a website where you can search for local providers, and he’s also found them through recommendations from people he knows.
He says he’s a good judge of character, and in his view, the most important things when it comes to staff are honesty and integrity.
“I look for honesty. If someone says they will do something, then they should do it,” says Alan. “Integrity is the same as honesty – just say, ‘I can’t do this’ or ‘I can look into doing that’. Just be honest. I don’t want people to pretend to be something they’re not.”
Alan can speak up if he thinks something isn’t right and he says he’s fortunate he has the ability to do so.
“For some people, employing their own staff is daunting, and for people that find it difficult to speak up for themselves, sometimes support workers do take advantage of them,” he says.
For more than 18 years, Scott’s been receiving support from a boutique New South Wales-based non-profit provider, and his parents, John and Rita, say the consistency of working with one provider has served their son best.
“When Scott was completing his final year of high school in 2006, we sat down with his school counsellor and teachers to plan for his future as an adult,” says John. “They suggested we look at post school options and gave us the names of a few service providers.”
“Remember, the NDIS didn’t exist in 2006. Post school options were funded by the New South Wales Government’s Department of Ageing, Disability and Home Care, and funding wasn’t guaranteed – you had to apply every year.”
The family visited open days held at provider facilities and attended some expos, before visiting Sunnyhaven Disability Services three times, and finding it was the best fit for Scott.
“Scott is active, with challenging behaviours, so we were looking for a facility and service provider that had room and space for Scott to move around, was willing to give him a chance, had supportive, caring and trained staff who could manage Scott and his behaviours, could keep him safe, had programs – including community access – that would help develop Scott’s social and life skills, and provided transport to and from the program,” says John.
“We believe, and still believe, that we made the right choice. Scott is very happy.”
Eventually, Scott moved into supported independent living (SIL) accommodation. Sunnyhaven provided support coordination for Scott and organised transport so he could stay with John and Rita in the family home at weekends.
“Using a provider with integrated services has made communication and support coordination much easier and less stressful for Scott and us,” says John.
He says having continuity of care for their son gives him and Rita peace of mind, knowing Scott will be well supported into the future, no matter what.
“Our son is safe, well cared for, and has programs that are tailored to his needs,” says John. “When the time comes and we are no longer here to look after Scott (or we become incapacitated), it is comforting to know that Scott is happy, has a safe place to live, and will be well looked after.”
Sally’s a permanent wheelchair user and has an intellectual disability. She lives in SIL accommodation and relies on family members to advocate for her.
Sally’s sister Kate shares Alan’s conviction that honesty and integrity are non-negotiables for providers in the disability sector.
“Clear communication, honesty, and transparency – they’re all a must, because they demonstrate a genuine commitment to doing the right thing,” says Kate.
“Transparency and authenticity go a long way. Providers, and certainly their staff, are human, and everyone understands that mistakes get made. But when those mistakes aren’t once-offs, and when they have significant impacts on a person who the provider is being paid to support, the provider can’t just hide and duck and weave – they need to get real.”
Kate says NDIS participants are ‘everyday people wanting to live ordinary lives’, and it’s vital providers get to know and understand what that looks like for each client.
She believes providers have a responsibility to come to work as ‘their best selves’, and to remember that good customer service is every bit as important within the NDIS as outside of it.
“If you go to work in a non-NDIS environment and bring your bad day with you, your clients and colleagues aren’t going to accept that, so why should a person with disability accept it? At the end of the day, providers should always remember that participants have a choice, and if you don't show up as the best provider, they’ll exercise their choice and find a better one,” says Kate.
“What makes a good provider is a real understanding of the client-provider relationship and what makes a terrible provider is one that positions themselves as the authority on another person’s life.
“The lines shouldn’t be blurred when it comes to who’s in the position of power. It’s the customer – the participant – who always comes first.
Sally has several providers in her world, including support workers, allied health professionals, and staff in a day options program, and Kate says it’s clear when Sally’s satisfied with their services.
“She might not be hugely verbal, but when things are going well, Sally’s mood lifts,” says Kate. “It’s evident when she’s happy. If she knows she’s going to see a provider she really likes, she just lights up, and she’s visibly happy anticipating their time together.”
“Sally’s recall isn’t great, but when she likes someone, she remembers their name or gives them a nickname, and she asks to see them, so we can tell she’s comfortable with them.
“We notice when she’s settled – she needs or wants less of us because she has more in her life. If we go to see her and there’s a provider there who she really enjoys spending time with, she’ll tell us it’s time for us to go – even if it’s only five minutes since we arrived!”
Kate adds that it’s equally clear when support is lacking, or when Sally isn’t feeling at ease. “When things aren’t going well, her mood is flat, she gets teary, and her behaviours escalate,” says Kate. “We know then that it’s time to look more closely at Sally’s environment and the people in it.”
While it seems relatively simple for clients to tell their providers what they want, getting clear on what they don’t want is a little more nuanced.
For Alan, providers that invest heavily in advertising leave him wondering whether they’re spending their money in the right places, and that makes him look even more closely at the rates they charge him for their services.
“There are big businesses that advertise on TV that charge top dollar for everything, because they can,” says Alan.
“I don't think a provider should charge top dollar just because they can. If you give a top service, then charge top dollar. Again, it's all about honesty.
“None of my support workers work for the maximum NDIS rate, they work for below it and that’s what they choose to do.”
Kate says that while everyone understands providers in the disability sector are businesses, and businesses need to make money, treating participants as a means to an end and failing to see them as ‘whole people’ raises a red flag.
“What grinds my gears is a provider that sees their clients as cash cows – regardless of the industry they’re in,” says Kate. “That’s even more of a concern for me in a sector dealing with vulnerable people.”
“People with disability are human beings – and at the flick of a switch, any one of us could become a person with disability. All it takes is a car crash, a medical incident, or a workplace accident.
“The line between ‘us’ and ‘them’ is a fine one and keeping it in sight is a powerful reminder to everyone to treat others as we’d like ourselves to be treated.”
John and Rita are also clear about the behaviours they won’t accept from Scott’s providers.
“Thankfully, nothing like this has ever happened, so this is hypothetical,” says John. “We wouldn’t want providers who have an unprofessional manner, who are unreliable, who don’t communicate, who don’t get back to you, or who don’t listen.”
“We wouldn’t like it if the images or services in the brochures didn’t match reality, or if the service feels unsafe, with untrained, unfriendly or aggressive staff or management.
“We wouldn’t like it if there were poor systems and procedures or poorly maintained facilities – and we wouldn’t like it if a provider wasn’t flexible, or was giving us the ‘take it or leave it’ attitude, cancelling last minute or not honouring the service agreement.”
Finally, for Rita and John, they want all providers to ensure they’re listening to all participants – especially people like Scott, who don’t use words to communicate.
“The current world is set up to listen to people who can advocate for themselves – and even then, it can be a long and exhausting battle of advocacy for people with disability,” says John.
“The most important thing we want all providers to understand is the dreams and goals and needs of people who don't use words to speak are just as important as everyone else's.”
Kate says her family’s experiences with supporting Sally have helped them to identify what makes a great provider.
Here are their tips for providers looking to set themselves up for success.
