An Attempt by the NDIS Commission to Ascertain Proportionate Approach to the Audits

It’s no surprise that there has been a host of smaller NDIS providers, delivering low risk services that have been unhappy about the registration and audit process under the NDIS Commissions Quality and Safe Guarding framework. In particular the audit costs and complexity.

We are pleased to say that the NDIS Commission has acted upon the feedback of providers and reassessed the process for small scale providers offering low risk services. 


To be a registered NDIS providers are required to undergo an audit against the NDIS quality and safeguarding framework to register or renew their registration.

To do this, NDIS Providers are required to engage an Approved Quality Auditor (AQA) to conduct a certification or verification audit.

The AQAs conduct audits against the NDIS Commission Practice Standards. These standards are based around two important parameters:

1.) The size and scale of the organisation.

2.) Complexity as well as risk involved in the services provided to the NDIS participants.

In the past, the requirements for providers didn’t make a clear distinction between the large-scale organisations (which deliver high-risk services) and the small-scale organisations and individuals (who are involved in low-risk services). Due to this reason the small-scale organisations and individuals had to involve in the audit process which wasn’t always relevant for their specific services. The audit process became, therefore, time-consuming and expensive.

What are the changes

Recently NDIS Commission acted upon the concerns raised by small-scale organisations and individuals delivering low-risk services and brought a change in the Guidelines, which has been notified via an alert to the concerned parties.

The update brings the proposed following changes in the overall Certification Audit process:

  1. The ability for an AQA to only have only 1 auditor (rather than 2) to conduct the onsite component of the stage 2 audit 
  2. Flexibility on the number of days required for audit
  3. Allowing the option of remote or offsite audits to low risk service, such as organisations offering products to participants.
  4. Review of the surveillances audit component

What does this mean?

It basically means you will be providing evidence more suitable to your business type. You will still need some policies, and will still be required to complete a self-assessment and application form via the commissions portal (or PRODA for renewals) but the burden of evidence is much less.

It also means that you will have a significant reduction in the audit price.

What registration groups does this apply to?

Whilst the NDIS Commission hasn’t provided a list, PROVIDERplus has discussed the changes with several AQAs and has been told that the change will apply to anyone who would be considered a verified provider if they were a sole trader, but has been classified as a certified provider based on being a Body corporate.

The below list is the registration groups that are the list of groups that are currently verified for sole traders or partnership.

If you are have a company business structure, but are a small provider and offer the following services, you will be affected positively by this change. 

  • Assist travel transport
  • Equipment supply (Assistive products, personal mobility equipment, vision equipment, Assistive equipment for recreation, Assistive products household tasks)
  • Therapeutic Supports
  • Accommodation and tenancy
  • Community Nursing Care
  • Innovate Community Participation
  • Interpreting and translating
  • Exercise physiology
  • Home modifications
  • Household task  

When will these changes come into effect?

Whilst many changes to the guidelines have come into effect, we believe that there are more changes to come.

Some of the changes proposed require an amendment to the specific legislation, and this process will take time.Whilst PROVIDERplus can’t give an exact timeframe we would expect that these changes won’t be directly applied by the AQAs until Early 2020.

Still have questions? Book a 1:1 Consult here with PROVIDERplus to discuss your specific situation and how we might be able to assist.