Provider webinar - Module Six - Registration Decision and Compliance - video transcript

Presenter: Sharon Floyd

Presented on 12 October 2022

Welcome everybody, I’m Sharon Floyd here to present Module six in this series of webinars designed for Residential Aged Care providers to provide some information about NDIS registration. This particular module is about the registration decision and ongoing compliance requirements.

The registration decision is actually made after the audit and is made importantly by the NDIS Quality and Safeguards Commission. So, the audit team although they make a Certification decision, do not actually make the registration decision.

Once the audit is complete, the audit team will require you to close out any non-conformances that you may have had during the audit as per what was identified in your ‘Corrective Action Plan’ that you would have been required to provide back to the audit team to address any of those non-conformances. So make sure that you are working toward closing them out within the required timeframes.

So after the audit, so while you’re working on any particular non-conformances, if you do have them, the audit team, the audit body rather would have actually forwarded the audit report to the NDIS Commission, they need to do that within a month of completion of the audit.

The NDIS Commission receives the audit report, goes through it very carefully and at the same time actually undertakes what’s called a Suitability assessment of your Key Personnel. So, back when you would have actually gone through the online application renewal process, you would have been required to identify those Key Personnel. And they are individuals involved in basically governing and managing your organisation, and the Commission will undertake individual suitability checks on those individuals, just to make sure they’re fit for purpose, in terms of running an NDIS business. The NDIS Commission then considers the Certification recommendation by the audit team as part of making this registration decision.

So once the Commission has been through that process and decided upon a registration status it will, if successful issue with a certificate of registration. Which will identify the registration groups, plus the period of registration, which typically is a three-year registration cycle and any conditions that the Commission may include as part of the providers registration, and that will be individual for each provider.

Those registration details appear on the Commissions provider register, which is publically available on the NDIS Commissions website. Unlike Aged care requirements, your audit report will not appear anywhere publically.

So, once you actually have been registered by the Commission, congratulations firstly. You then are involved in an ongoing registration cycle and ongoing compliance requirements. So, this slide tries to summarise what those compliance requirements are.

So, Year one is when you actually would be going through your initial Registration Certification audit, your registration renewal which you would have just completed if you’ve got that registration certificate.

18 months down the track, you actually have a midterm audit, so it’s an abbreviated form of audit, which it’s a bit of a check in by the audit team and we’ll describe what that involves shortly.

And then three years after the decision, the date that the commission makes its registration decision you are required to undergo another Recertification audit.

So the midterm audit happens 18 months after the registration decision by the Commission and it certainly takes less time than a re-certification or an initial certification audit. So, what the audit team are required to do at a minimum is to actually assess you against what is called the Governance and Operational Management Components of the ‘Core Module’ of the NDIS Practice Standards. If you’re familiar with particular part of that Core module, you’ll know that there is a fair bit in there around governance and HR, risk management, complaints etcetera.

If you are involved in delivering high-risk supports, for example Behaviour support, then those modules are included in the midterm assessment, midterm audit. And, if you did actually have any non-conformances from your initial audit then those particular areas are going to be looked at by the audit team in the respect of how they were actually, what non-conformances there were, what corrective action that you identified as part of your Corrective action plan. The Commission can also ask the audit body to look at any particular standards if they have any issues or concerns.

So, three years down the track you’ll have the re-certification audit, which basically is a mirror image of your initial certification audit. So there’s again a stage one desktop audit and a stage 2 onsite audit. And, also, a self-assessment would be required so you will go and do a new self-assessment to identify how you’re demonstrating your compliance against those relevant NDIS Practice Standards.

That three yearly re-certification audit can’t actually happen earlier than 6 months prior to the registration expiry date and In fact the NDIS Commissions portal won’t actually let you get in to kick start that process until that six months period has commenced. Just a reminder with the recertification audit the audit team is going to be looking very carefully at continuous improvement so they’ll be expecting to see that there has been ongoing improvements since that last audit. 

If your registration decision was unsuccessful, whether it’s the initial certification audit or your recertification audit, you would be given written decisions as to why and you can request a review of that decision within three months. And, again there’s also avenues available to you through the Administrative Appeals Tribunal, if following review the application was still unsuccessful.

So, the registration and certification cycle is ongoing and it’s an opportunity to keep on top of your quality and safeguarding and continuous improvement activities on an ongoing basis with ultimately the outcome of continually improving outcomes for your NDIS participants.

If you did want any further information about the registration cycle or the registration decision and ongoing compliance requirements, have a look at Part D of the Residential Aged Care Provider Toolkit for more information.

Thank you for listening and I hope you found this useful.