Part C: Comparison of Aged Care and NDIS registration and audit requirements (Residential Aged Care Toolkit)

Key similarities and differences between the aged care and NDIS audit and registration/accreditation requirements are identified below.

Aged care and NDIS registration and audit requirements: similarities and differences

Comparison of terminology in aged care and the NDIS
Aged care NDIS
Consumer Participant
Quality assessor Approved quality auditor
Assessment Certification audit
Accreditation Registration
Comparison of the Aged Care Quality Standards and the NDIS Practice Standards
Similarities Differences
There are some commonalities across Aged Care Quality Standards and NDIS Practice Standards in areas of requirements for:
  • some aspects of 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, and management of individual risks
  • support and respect for individual choice, independence, privacy, dignity, culture and diversity
  • infection control processes
  • safe environments
  • High Intensity Daily Personal activities (complex health care supports)
(Refer Standards Comparison Tool)		 There are some differences across Aged Care Quality Standards and NDIS Practice Standards in areas of requirements for:
  • personal information/consent of participants 
  • access to an advocate
  • processes for allegations/incidents of violence, abuse, neglect, exploitation and discrimination
  • some specific and additional NDIS governance requirements, including quality management, risk management and human resource obligations
  • NDIS participant input into governance
  • additional requirements for complaints and incident management in line with associated NDIS Rules
  • continuity of support
  • emergency and disaster management planning (at governance level and inclusion in support plans and service agreements)
  • links with other providers including health care and allied health providers
  • mandatory training (complaints, incidents, NDIS Practice Standards, emergency and disaster management, PPE, behaviour support, mealtime management)
  • emergency plans for waste management
  • behaviour support and restrictive practices in line with associated NDIS Rules
(Refer Standards Comparison Tool)
Comparison of code of conducts in aged care and the NDIS
Aged care NDIS
 A Code of Conduct for Aged Care is being introduced from 1 December 2022. NDIS providers and workers must adhere to a code of conduct that regulates the care they provide.

Both Aged Care and NDIS providers must demonstrate suitability to provide services including that they understand responsibilities, demonstrate compliance with quality standards and legislation, policy and procedures, have governance and finance systems in place and have suitable key personnel.

In both aged care and the NDIS, the suitability of key personnel is considered, including criminal and ASIC checks. The key differences are identified in the following table.

Comparison of key personnel requirements in aged care and the NDIS
Aged care NDIS
In aged care, key personnel also includes those undertaking or planning to undertake nursing duties and responsibility for day-to-day operation.

In the NDIS, key personnel requirements only apply to people responsible for governance.

Key personnel requirements do not extend to nursing or day-to-day operation (unless such positions are responsible for organisational governance).

In both aged care and the NDIS, the accreditation and registration information will include:

  • company detail and structure
  • organisational care types
  • key personnel
  • business plan
  • sub-contracting arrangements
  • police checks.

The key differences are identified in the following table.

Comparison of accreditation and registration information requirements in aged care and the NDIS
Aged care NDIS
Includes the legal corporation. Includes any legal entity (individual, partner or corporation).
Comparison of who makes accreditation and registration decisions in aged care and the NDIS
Aged care NDIS
Aged Care Quality and Safety Commission (ACQSC)  NDIS Quality and Safeguards Commission (NDIS Commission) taking into account recommendations of the approved quality auditor, suitability assessment of the provider and its key personnel and other information.
Comparison of application process in aged care and the NDIS
Aged care NDIS
Must be in writing using the approved form. Must be made using the approved form, which is an online application.

Similarities in the assessment and auditing process include:

  • self-assessment by the provider against quality standards
  • provider needs to show demonstrated knowledge of quality standards, legislation and policy and procedures
  • desktop review of application of suitability and accreditation/registration information
  • assessment of the quality standards including governance, finance, and management arrangements
  • assessment/audit (desktop and on site/off site) by registered assessors/auditors collecting evidence to determine performance against quality standards
  • audit will consist of an entry/initial meeting, request for documentation, identification of staff and consumers/participants for interviews and viewing of records (including incidents)
  • evidence is collected through interviews, documented evidence and observations
  • site sampling of evidence and interviews of staff and consumers/ participants/ representatives/ advocates based on the scope of the assessment, provider size, risks and issues 
  • exit interview is conducted at the end of the audit
  • audit report/performance assessment report outlining compliance with quality standards is prepared
  • decision by commission
  • issue of a registration/accreditation certificate
  • publication of registration/accreditation on line
  • must provide a continuous improvement/corrective action plan for any non-compliance/non-conformances arising from the audit and show they have corrected them.

There are also differences, identified in the following table.

Comparison of the assessment and auditing process in aged care and the NDIS
Aged care NDIS

1. Accreditation

  • Accreditation and re-accreditation decisions are made at the service level
  • Initial desk assessment of application, compliance checks and review of continuous improvement plan
  • ACQSC delegate makes decision on accreditation
  • One year accreditation

2. Re-accreditation

  • Application process and checks as per accreditation process 
  • Unannounced site audit
  • ACQSC delegate makes decision on accreditation and, if accredited, the accreditation period.
  • Application submitted online, initial scope of audit document generated based on information in the application
  • Provider must engage an approved quality auditor to undertake audit against the relevant NDIS Practice Standards for the NDIS supports and services being delivered to meet registration requirements
  • Non-conformities against the NDIS Practice Standards are identified by the audit team
  • NDIS Commission undertakes suitability assessment of the applicant and key personnel.
  • NDIS Commission delegate makes a decision on the application and whether any additional conditions of registration are imposed.
Comparison of auditing in aged care and the NDIS
Aged care NDIS
  • Re-accreditation visits are unannounced
  • All sites must be visited in person (on site auditing)
  • Provider plans with their chosen approved quality auditor when the certification audit will be conducted
  • Remote auditing is allowed under certain limited circumstances 
  • Only unannounced on the specific request of the NDIS Commission
Audit requirements are set out in the NDIS (Approved Quality Auditors Scheme) Guidelines 2018
Comparison of initial audit in aged care and the NDIS
Aged care NDIS
Audit prior to expiry of one year accreditation Audit completed before decision on an application for registration
Comparison of re-accreditation/certification audits
   
  • Initial one year accreditation with ongoing risk based monitoring an unannounced assessment contact prior to expiry of initial registration period. 
  • Up to three yearly accreditation once audit is complete.
  • Ongoing risk based monitoring with review audits as required.
  • Three yearly registration cycle once NDIS Commission decides on registration.
  • 18 month mid-term audit.
Comparison of costs
Aged care NDIS

No audit feed. Application fee to be paid when lodging application.

Auditor costs paid by NDIS provider. Providers are encouraged to seek quotes from approved quality auditors to get the best value for their audit. The NDIS Commission does not set auditor costs.

There is no application fee.

 

Comparison of assessors/auditors in aged care and the NDIS
Aged care NDIS
The Aged Care Quality and Safeguards Commission allocates an assessment team. You choose your own auditor from a list of approved quality auditors on the NDIS Commission website.

 

Comparison of audit sample size in aged care and the NDIS
Aged care NDIS
  • Site sampling of evidence and interviews of staff and consumers/participants and representatives based on the scope of the assessment, service size, risks and issues (proportionality).
  • Minimum 10% of consumers or representatives of consumers.
  • A site sampling methodology is applied. Sampling requirements are set out in the NDIS (Approved Quality Auditors Scheme) Guidelines 2018.

 

Comparison of site audit requirements in aged care and the NDIS
Aged care NDIS
  • Per service accreditation
  • Registration is at organisation or legal entity level (not each site)
  • Where high risk registration groups are delivered, at least one site should be sampled.

Site sampling requirements are set out in the NDIS (Approved Quality Auditors Scheme) Guidelines 2018.

 

Comparison of audit ratings in aged care and NDIS
Aged care NDIS
Assessment of met or not met against each assessed requirement of the Quality Standards Ratings of 0-3
  • 0 – major non-conformity
  • 1 – minor non-conformity
  • 2 – conformity
  • 3 – conformity with Elements of Best Practice
Audit ratings are set out in the NDIS (Approved Quality Auditors Scheme) Guidelines 2018.

 

Comparison of audit reporting in aged care and the NDIS
Aged care NDIS
  • Publicly available
  • Not publicly available

Audit reporting requirements are set our in the NDIS (Approved Quality Auditors Scheme) Guidelines 2018.

 

Both the Aged Care Commission and the NDIS Commission undertake ongoing monitoring of compliance and quality of care through activities including self-assessment reviews, complaints and reportable incident monitoring.