This is a Residential Aged Care transition guide to the NDIS written by professional NDIS consultants at Provider+. This guide should be used as a resource tool along with NDIS resources linked to this article.
I Am a Residential Aged Care Provider do I Need to Register For The NDIS?
on 1 December 2020, Residential Aged Care (RAC) providers supplying services to NDIS participants in their facilities automatically became registered NDIS providers. If this describes your circumstances, you must now decide whether to renew your registration or stop providing services to NDIS participants.
If you are a Residential Aged Care provider that has acquired NDIS participants after 1 December 2020, you may also need to register with the NDIS Commission. For more information please go HERE.
Commonalities Between RAC and NDIS Standards
General
Around half of the NDIS Practice Standards requirements in the Core Module are the same as those of the Aged Care Quality Standards.
There are several broad commonalities across both sets of standards, which include the requirements for:
Organisational systems covering:
- Feedback and complaints
- Incidents management
- Compliance
- Risk
- Continuous improvement
- Governance
- Information management
- Human resource management
Support provision processes including:
- Assessment
- Planning
- Review of supports
- Management of individual risks
Support and respect for:
- Individual choice
- Independence
- Privacy
- Dignity
- Culture and diversity
- Infection control processes
- Safe environments
Audit Processes
Commonalities across the aged care and NDIS audit processes include:
- Both approaches require providers to demonstrate compliance with quality standards.
- Both processes require an assessment of provider and key personnel suitability.
- Both processes require providers to demonstrate knowledge of quality standards, legislation, policy, and procedures.
- General audit processes and methodology.
Assessment against quality standards and quality indicators, review of policy and procedures, interviews with staff and participants, site sampling, review and outcome findings by the relevant Commission.
- 3-year audit cycle.
Comparison Tables
| Aged Care | NDIS |
|---|---|
| Terminology | |
| Consumer | Participant |
| Quality Assessors | Approved Quality Auditor |
| Accreditation | Registration |
| Aged Care Quality & Safety Commission (ACQSC) | NDIS Quality & Safeguards Commission (NDIS Commission) |
| Residential Aged Care Provider | NDIS Provider |
| Key Personnel- Includes persons responsible or likely to be responsible for nursing services or day-to-day service operations | Key Personnel |
| Care and Services Plan | Support Plan |
| Aged Care | NDIS |
|---|---|
| Costs | |
| One-off application fee with no additional auditing costs | Auditor costs that must be met every 18 or 36 months, depending on the registration type |
| No audit fee | Auditor costs paid by provider |
| Application fee paid when lodging application | No set audit costs |
| No application fee |
| Aged Care | NDIS |
|---|---|
| Site Visits | |
| As per service accreditation | Not each site but one site should be sampled – refer to NDIS (Approved Quality Auditors Scheme) Guidelines 2018 for exact requirement |
| AGed Care | NDIS |
|---|---|
| Audit Ratings | |
| Assessment Met or Not Met against each assessment Quality Standards requirement | 0 –major non-conformity |
| 1 – minor non-conformity | |
| 2 – conformity | |
| 3 – conformity with Elements of Best Practice |
| Aged Care | NDIS |
|---|---|
| Audit Report | |
| Publicly available | Not publicly available |
| Aged Care | NDIS |
|---|---|
| Code of conduct | |
| When providing care, supports and services to people, I must: | The Code of Conduct requires workers and providers who deliver NDIS supports to: |
| a) Act with respect for people’s rights to freedom of expression, self-determination and decision-making in accordance with applicable laws and conventions | Act with respect for individual rights to freedom of expression, self-determination, and decision-making in accordance with relevant laws and conventions |
| b) Act in a way that treats people with dignity and respect, and values their diversity | |
| c) Act with respect for the privacy of people | Respect the privacy of people with disability |
| d) Provide care, supports and services in a safe and competent manner, with care and skill | Provide supports and services in a safe and competent manner with care and skill |
| e) Act with integrity, honesty and transparency | Act with integrity, honesty, and transparency |
| f) Promptly take steps to raise and act on concerns about matters that may impact the quality and safety of care, supports and services | Promptly take steps to raise and act on concerns about matters that might have an impact on the quality and safety of supports provided to people with disability |
| g) Provide care, supports and services free from: (i) All forms of violence, discrimination, exploitation, neglect and abuse (ii) Sexual misconduct | |
| h) Take all reasonable steps to prevent and respond to: (i) All forms of violence, discrimination, exploitation, neglect and abuse (ii) Sexual misconduct. | - Take all reasonable steps to prevent and respond to all forms of violence, exploitation, neglect, and abuse of people with disability - Take all reasonable steps to prevent and respond to sexual misconduct. |
| Aged Care | NDIS |
|---|---|
| Modules | |
| Module 1 High-Intensity Personal Daily Activities Review: | |
| Severe dysphagia management | |
| Subcutaneous injection | |
| Module 2a Implementing Behaviour Support Plans | |
| Build entire policy and procedure to meet standards |
Similarities
| NDIS STANDARD | Areas RAC providers need to review to meet NDIS compliance requirements |
|---|---|
| Standard 1 Rights & Responsibilities: | More details are required by Aged Care to meet NDIS: |
| Person-centred supports | Legal and human rights are incorporated into everyday practice |
| Individual values and beliefs | NDIS participants are supported to engage with their support network or chosen community |
| Privacy and Dignity | NDIS participants understand and agree to what personal information is collected and why, including audio and/or visually recorded material |
| Independence and informed choice | NDIS participants have sufficient time to consider and review their options at any stage of support provision |
| Violence, abuse, neglect, exploitation and discrimination | NDIS participants have access to an advocate at all times, including when allegations of violence, abuse, neglect, exploitation or discrimination have been made |
| Allegations and incidents of violence, abuse, neglect, exploitation or discrimination are acted upon, records are made, and action is taken in line with NDIS (Incident Management and Reportable Incidents) Rules 2018 | |
| Standard 2 Governance & Operational Management: | More details are required by Aged Care to meet NDIS (approx one-quarter of NDIS quality indicators are similar) |
| Governance and Operational Management | RAC must meet NDIS-specific corporate governance requirements |
| Risk management | NDIS participants contribute to go corporate governance |
| Quality management | Organisational risk management systems cover specific risk categories |
| Information Management | Documented Internal Audit Program |
| Feedback and Complaints Management | NDIS participants are advised about consent and personal information management |
| Incident Management | The complaints management and resolution system fully meet the requirements of the ‘Rules’ (e.g. participants being advised they can complain directly to the NDIS Commission and mandatory worker training) |
| Human Resource Management | The incident management systems fully meet the requirements of the NDIS Reportable Incidents Rules and mandatory worker training |
| Continuity of Supports | Human Resource Management systems address- Mandatory NDIS worker orientation requirements, NDIS worker screening, NDIS training, how workers are identified in response to emergencies or disasters. |
| Emergency & Disaster Management | Alternative arrangements for continuity of support are explained and agreed upon with NDIS participants |
| The governing body develops, tests and reviews emergency and disaster management plans and ensures workers are trained in the implementation of these plans | |
| Appropriate insurances are in place as part of risk management – professional indemnity, public liability and accident insurance | |
| Their quality management system meets the requirements of legislation and the NDIS Practice Standards | |
| The governing body must consult with participants and their support networks about their emergency and disaster management plan | |
| Standard 3 Provision of Support: | More details are required by Aged Care to meet NDIS (the majority of NDIS quality indicators have a high level of commonality) |
| Access to supports | Support plans are reviewed at least annually, and support plans are updated where progress is different from expected outcomes and goals |
| Support Planning | Support plans anticipate responses to individual, provider and community emergencies and disasters |
| Service Agreements | Service agreements set out arrangements for support provision in case of emergency and disaster |
| Responsive support provision | Supports are provided based on the least intrusive options |
| Transitions to or from a provider | Links are developed with other providers (with NDIS participant consent), including healthcare and allied health providers |
| Standard 4 Support Provision Environment: | More details are required by Aged Care to meet NDIS (the majority of NDIS quality indicators have a high level of commonality) |
| Safe environment | Work is undertaken with other providers (including health care and allied health providers) to identify and manage risks |
| Participant money and property | PPE is available to NDIS participants and workers (where required), and workers are trained in using PPE |
| Medication management | NDIS participants are supported to use their own money as they determine |
| Mealtime management | NDIS participants requiring mealtime management have their individual mealtime management needs assessed by appropriately qualified health practitioners. Workers responsible for providing mealtime management are trained and can manage related emerging and chronic health risks |
| Waste management | An emergency plan is in place for clinical waste or hazardous substance management |
| Module 1 High-Intensity Daily Personal Activities | This area has synergy in most areas to a high level, but the following only partially meet specific requirements and need reviewing: |
| Complex Bowel Care | Severe dysphagia management |
| Enteral Feeding and Management | Subcutaneous injection |
| Severe dysphagia management | |
| Tracheostomy management | |
| Urinary catheter management | |
| Ventilator Management | |
| Subcutaneous Injections | |
| Complex Wound Management | |
| Module 2a Implementing Behaviour Support plans: | |
| Behaviour Support in the NDIS | RAC Providers need to create a full suite of policies to meet requirements in order to meet Module 2a requirements |
| Regulated Restrictive Practices | |
| Supporting the Assessment and Development of Behaviour Support Plans | |
| Behaviour Support Plan Implementation | |
| Monitoring and Reporting the Use of Regulated Restrictive practices | |
| Behaviour Support Plan Review | |
| Reportable Incidents involving the use of a Restrictive Practice | |
| Interim Behaviour Support Plans |
The ACQS and NDIS Practice Standards Comparison Tool
The ACQS and NDIS Practice Standards Comparison Tool can help determine how the Aged Care Quality Standards link to the NDIS Practice Standards (and each Quality Indicator).
Please Note:
All applicable Quality Indicators for an NDIS Practice Standard are considered during an NDIS audit, it is vital to look at these individually.
We highly advise you to refer to the Evidence Guide (Part I) for suggested ways to demonstrate these requirements.
The following Standards Comparison Tool will enable RAC providers to pinpoint where further evidence may be required to gain the assurance they need to meet the NDIS Practice Standards.
The following ratings (and colour coding) have been used in the Standards Comparison Tool:
