Every business that wants to register as a provider with the NDIS now has to undergo some form of audit.
There is a gradual roll out of this new process across Australia, starting with NSW and South Australia from July 2018 and other states to follow in each financial year.
I am compiling information about the NDIS audit process, hints and tips as quickly as I can and will post updates to this page as I learn more.
Please find below some FAQ’s and don’t hesitate to send me a question using the form below if I have forgotten something or you would like more information.
If you are seeking support in preparing for the audit we are now taking expressions of interest for businesses to trial a policy - to - practice solution that is currently in development with a planned roll out of mid - November.
REPORT AUDIT COSTS
The NDIS Commission are hoping to receive more information about how much the audit is costing businesses. Of course I volunteered to put our community to work to gather this vital data.
You can anonymously provide that information here and I will pass it on.
Q1. How do I become a registered NDIS Provider?
From the 1st July 2018 everyone who wants to become an NDIS Registered Provider in NSW and South Australia must now undergo some kind of audit. This means that someone independent will assess your business and determine whether you are meeting the required standards to be recommended for registration.
The other states will follow suit as they transition from state based regsitration under the NDIA to national registration with the newly formed NDIS Commission.
Registration is now completed on the NDIS Commission website.
Existing providers who are transferring to the NDIS Commission should have received log in information to the new NDIS Commission portal.
Q2. WHAT ARE THE TYPES OF AUDIT?
There are two types of audit for regsitration to the NDIS. There is a smaller, desktop audit and this is called Verification. There is a larger, site audit which is called Certification.
The type of audit that you have to complete will depend on
- your company structure (sole trader, company etc)
- the supports that your business plans to provide.
Q3. WHICH AUDIT WILL I HAVE TO COMPLETE?
If you are a sole trader or partnership and you DO NOT offer any of the supports which are deemed to be high risk - you will be required to undergo a Verification level audit.
If you are a company, or you offer high risk suppports (no matter what your business structure is) you have to undergo a Certification level audit.
Q4. WHAT ARE THE HIGH RISK SUPPORTS?
The supports that are considered to be high risk are
Support Coordination (middle level requires Certification of the Core module of the Practice Standards)
Specialised Support Coordination (level 3 - requires supplementary module Specialist Support Coordination audit + Core module)
Early Childhood Supports (this one has some variation. For a Company requires Core Module + Early Childhood Supports supplementary module. For sole Traders / partnerships there is a lighter load with Supplementary module required plus one part of the Core module)
High Intensity Personal Supports (Core + Supplementary module)
Specialist Behaviour Support (Core + Supplementary module)
Implementing Behaviour Support Plans (Core + Supplementary module)
Specialist Disability Accommodation (Core + Supplementary module)
Q5 WHAT IS MY BUSINESS AUDITED AGAINST?
Your business will be audited against the newly published NDIS Practice Standards.
The Practice Standards have been developed inline with legislation. They are rules that sit underneath the NDIS Act.
The NDIS Commission are the body which oversees Registered Providers are delivering services according to the Practice Standards.
The Practice Standards are organised in a series of modules. Businesses will be audited against how they are conforming to the modules that are relavent to their business.
The Core Module is the largest and any business requiring Certification level audit will be expected to be practicing in line with this module.
Businesses offering any high risk supports will be audited against the supplementary modules that are relevant to those supports.
Businesses requiring Verification will have to show through documentary evidence (this audit is done by desktop only) that they are practicing in accordance with the Verification module.
Q6. WHERE DO I START?
Registration to become an NDIS Provider begins on the NDIS Commission website. Please note that only NSW and South Australia are transferring in the 2018-2019 financial year. If you are based in another state please visit the NDIS website.
Registration begins with an online form and self assessment process.
The form begins with all the practical information about your business and your details. It asks about your key personnel and the supports that you want to register to provide.
Once you have entered this information you will see a screen which tells you which level of audit you have to have. It will also list the modules of the practice standards that you will have to be audited against.
Then the fun begins - you have to complete an online assessment against each of the practice standards that you will eventually be audited against. If your business has to undergo Certification the self - assessment process can be lengthy. Give yourself plenty of time.
Likewise, if you are new to the NDIS, even if you are completing the Verification module there is a good chance that you have some work to do.
If you are a business that is renewing your registration, you should have been given access to the NDIS Commission portal. The pages in the portal look a little different to those for newly registering businesses and it is a little bit clunky to use. Some of the fields will be pre - populated so be on the lookout for things that might have changed since you last registered.
Q7. HOW LONG DO I HAVE TO COMPLETE MY APPLICATION?
For new registrations, you have 60 days to complete your online self assessment from the time that you start.
There is no time frame for your business to complete the audit - however you will not be successfully registered until it is done.
Businesses that are renewing have 90 days following completion of the online self - assessment to gather quotes from the auditors. You then have 9 months from the renewal date provided to you by the NDIS Commission on your Certificate of Registration form for the audit to be completed.
I highly recommend that if you are on a deadline to complete your application, you do not leave it until the last minute.
Q8. WHAT DOES THE SELF ASSESSMENT INVOLVE?
The self - assessment requests that you provide, in 300 words or less, information as to how your business will meet the relevant Practice Standard.
It is broken down into each section of the Standards and you will be asked for a response for each section. There are 22 sections in the Core Module.
Each Supplementary module has several sections.
There are 4 sections in the Verification Module.
Please note that you can write whatever you like in each section.
If you have attachements that you feel answer the sections well enough you can write in here 'see attachments'.
Q9. WHAT DO I ADD AS ATTACHMENTS?
As of today (3rd October 2018) you can only add 7 attachments.
The case could be made that perhaps you add worker screening attachments now and provide your policy documents to the auditor when the time comes. This might give you some additional time to get your documentation in order.
Confirmed with the NDIS Commission 10th October 2018 - documents can be supplied directly to the auditor. It is not compulsory that they are uploaded to the application.
Q10 WHAT WILL THE AUDITOR BE LOOKING FOR?
When it comes to the Certification level audit, the auditor will be looking for evidence that you are delivering services in line with the Practice Standards. Please note that policy alone will not be enough without an evidence trail that you are actually practicing in the way that your policy states. This evidence might be documentary or it might be in the form of interview.
Clients and staff will be interviewed in the Certification level audit.
The Verification audit is completed using documents alone which are uploaded or emailed to the auditor. They will have to show that your business is meeting the Standards relevant to the Verification module of the Practice Standards.
Q11 HOW MUCH DOES THE AUDIT COST?
There is no way to get around it - the audit can be expensive.
Businesses are reporting a wide range in price. The NDIS Commission are asking us to provide data on this wherever possible. Please see the link on this page if you are able to anonymously share your quotes so that we can pass that information along to the NDIS Commission.
Q 12 WHY ARE AUDITS SO EXPENSIVE?
To start with, the NDIS Commission have laid down some pretty strict Rules for the auditors.
This includes that the auditors have to be approved; they have to be accreddited by the auditing body JAS - ANZ; they must audit in pairs; they must take a technical expert along for some of the high risk groups such as a Registered Nurse with regards to High Intensity Personal Supports.
The auditors are also highly regulated including having to have an independent audit on themselves every year which is expensive.
They carry significant risk in that if they pass a business through an audit that is later found to be in breach of the Standards or where a serious incident occurs their audit will come under scrutiny.
They are also in high demand.
Remember too if you are not located in a metro area you will also have to cover their travel and accommodation costs.
Q13 WHY WOULD I REGISTER?
People who receive funding from the NDIS can manage that funding in three different ways.
- The NDIA manages the funding: Providers deliver their supports and then log into the NDIS Portal and draw down their claims. Only NDIS Registered Providers can do this. As of October 2018 this is the largest part of the market.
- A Plan Manager manages the funding: the Provider delivers the supports, they invoice the Plan Manager and the Plan Manager draws down the money from the NDIS. A Provider DOES NOT have to be registered to support people who use a Plan Manager however the Plan Manager is subject to the NDIS rules which can mean that the Provider will need to comply with some of the rules too, including pricing.
- the Participant self manages the funding: the Provider delivers the supports, the person pays the bills and then draws down the funds from the NDIA. A Provider DOES NOT have to be registered to support people who are self managing and are only expected to conform to the NDIS Code of Conduct and to have a Complaints System in place.
In short if you would like to offer supports to the whole market you will need to be registered.
Q 14 WHAT HAPPENS IF I FAIL AN AUDIT?
The auditors provide a rating and a report which will tell you if you have anything that's not conforming. Sometimes it will be a quick fix that you can do via email. Larger non conformities will have a more significant fix and can be at your additional cost, so getting it right the first time is always best.
Q 15 WHAT ARE THE POWERS OF THE COMMISSIONER?
The auditing rules document is one that I suggest you become familiar with. In the situation of a significant non-conformity the Commissioner has all kinds of powers such as dictating further audits at your cost and suspending your registration. As a business owner you should be aware of this before progressing your registration.
Q 16 HOW OFTEN WILL I HAVE TO UNDERGO AN AUDIT?
Those businesses who require an audit at the Verification level will have to complete this every three years.
Those businesses who require the Certification audit will have to complete the full audit in their first year followed by a surveillance audit the year after. This is still a site audit however is about 50% of the cost and overview of the full audit. The full audit must be completed every three years in order for registration to be renewed.
Q 17 DO I HAVE TO ENGAGE AN AUDITOR BEFORE I COMPLETE THE ONLINE APPLICATION?
The answer to this is no.
In order to gather extact quotes from auditors, you will need the scoping document that is generated AFTER you submit your online assessment.
You send this scoping document to the auditors and they quote based on the information in that document.
Renewing registrations have 90 days after submitting the online assessment to engage an auditor. The auditor has 9 months to complete the audit from the expiry date on your Certificate of Registration.
I recommend that you gather quotes from ALL auditors as prices are being reported that vary enormously.
Q 18 WHAT ARE THE TIMELINES FOR THE COMPLETION OF REGISTRATION
Please see our blog post for this information here
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