This guide is one of a set of guides that work together to provide guidance on NDIS registration for services-for-one. This information has been written for NDIS Approved Quality Auditors.
Background
This document is based on:
- findings from a trial audit of a service-for-one that was completed in April 2021
- feedback from families
- the requirements for NDIS Approved Quality Auditors, as explained in the NDIS Approved Quality Auditors Scheme Guidelines 2018 (AQA Guidelines).
A service-for-one is an individual arrangement where staff are employed directly to support a person with disability using their NDIS funding. It does not include employing staff through other disability services or agencies.
Services-for-one often provide support for people with complex behaviour support needs when other service models:
- have not been successful
- are not the most appropriate model of support for the person.
What are the benefits of supporting someone in a service-for-one?
There are many benefits of providing support through a service-for-one, including:
- being supported in a way that best suits a person’s needs
- having opportunities for creativity that may not be available in larger services
- being in control of the way services are provided
- being away from people or environments that can cause the person distress or trauma
- having options for support where access to services is limited
- having more flexibility in the use of the funds in the person’s plan
- the lack of competing demands leads to greater ability to apply the supports in
a more individualised way - a better quality of life for the person with disability because their services are completely individualised.
Some services-for-one use restrictive practices. This means they must be registered with the NDIS Quality and Safeguards Commission (the NDIS Commission), and they must do a certification audit.
Given the unique features of services-for-one, this document provides guidance on:
- the audit methodology
- evidence
- audit planning
- conduct of audits
- composition of audit teams
- audit duration
- how to engage with the person, family members and workers.
This guide provides supplementary information that will be useful to auditors and Approved Quality Auditors when completing audits of services-for-one.
Approved Quality Auditors and auditors should read this document when assessing services-for-one, as well as the NDIS (Approved Quality Auditors Scheme) Guidelines 2018 and ISO/IEC 17065:2012 Conformity assessment – Requirements for bodies certifying products, processes, or services.
The major headings we use in this guide are the same as those in the NDIS (Approved Quality Auditors Scheme) Guidelines 2018.
This guide is informative.
Standards and process requirements
6. Applicants
No additional requirements.
7. Applicable NDIS Practice Standards and assessment method
No additional requirements.
Note: Schedule 1 – Schedule 7 to the National Disability Insurance Scheme (Provider Registration and Practice Standards) Rules 2018 set out NDIS Practice Standards as applicable for services-for-one in relation to a certification audit.
8. Application for Audit
No additional requirements.
9. Audit Application Review and Assessment Process
(1) Before completing certification or verification audits, the approved quality auditor will review the initial scope of audit document.
Note: The initial scope of audit document will identity one person as receiving support.
(2) The approved quality auditor will check that the scope is accurate with the service- for-one.
10. Audit Program
No additional requirements.
11. Composition of the audit team
(2) The Commissioner may, on request or on their own decision, provide one-off special approval for an audit team of a particular audit to include one auditor. This will only occur if the Commissioner is satisfied that there are exceptional circumstances, and issues a notice to that effect, to the approved quality auditor.
(3) An approved quality auditor should request special approval from the Commission in writing. This request should provide details for why they are seeking special approval. They should do this no later than 10 working days prior to the planned date of the stage two audit.
Due to the nature and small size of services-for-one, one auditor is likely to be more practical and less intimidating. The two clauses above (taken from the Approved Quality Auditors Scheme Guidelines).
(4) Wherever possible the composition of the audit team should include personnel who:
- have demonstrated understanding of the services-for-one model
- have been evaluated as demonstrating appropriate soft skills and emotional intelligence in addition to the relevant competencies
- understand the proportional approach to gathering evidence, particularly where sensitivities are evident. Refer B.11. this document.
12. Verification audits
No additional requirements.
13. Certification audits
No additional requirements.
14. Stage One Audits
No additional requirements.
15. Stage Two Audits
When determining audit duration, you will need to consider time for onsite observations. For example, as there is only one person, it is important to take note of how they interact with their surroundings and supports. Evidence sources may be limited, particularly if you do not have consent to talk to the person.
16. Audit Reporting
No additional requirements.
17. Review
No additional requirements.
18. NDIS Provider Certification or Verification Decision
No additional requirements.
19. NDIS Provider Certification and Verification documentation
No additional requirements.
20. JAS-ANZ Register
No additional requirements.
21. Mid-term audit
No additional requirements.
22. Recertification and reverification
No additional requirements.
23. Changes Affecting NDIS Provider Certification or Verification Decisions
No additional requirements.
24. Termination, Reduction, Suspension or Withdrawal of Certification Verification Decisions
No additional requirements.
25. Records
No additional requirements.
26. Complaints and appeals
No additional requirements to ISO/IEC 17065:2012
27. Provisional audits
Do not apply for services-for-one.
28. Approved Quality Auditor’s Auditors and Personnel
No additional requirements.
29. Management of Competence for Personnel Involved in the Certification and Verification Process
No additional requirements.
30. Competence Requirements for Auditors, including auditors with technical expertise
The approved quality auditor will ensure that all their auditors (other than consumer technical experts) understand how the family-centred model of support works for many services-for-one use, which is different to ‘traditional’ service models.
31. Audit Team Roles
No additional requirements.
32. Auditors with Technical Expertise
No additional requirements.
33. Consumer Technical Experts
No additional requirements.
34. Evaluation Processes
No additional requirements.
35. Mechanism for Safeguarding Impartiality
No additional requirements.
36. Transitional Matters-Surveillance (monitoring) and mid-term audits
No additional requirements.
Annex A – Code of Conduct for Approved Quality Auditors (normative)
No additional requirements.
Annex B – Audit methodology and sampling (normative)
B.1: Evidence Based Auditing
No additional requirements.
B.2: High Risk Registration Classes/Groups
No additional requirements.
B.3: Sample Methodology
No additional requirements.
B.4: Sample Size
Worker files and interviews
It is important to recognise that there could be up to 20 workers in some services-for-one supporting the one person. Many people require support 24 hours a day, seven days a week. Using a sample of workers to interview would still apply. This means that audit teams should still aim for interviews with a representation of workers, team leaders, managers, and governing body personnel. This will include family members in most services-for-one.
Participant files and interviews
Annex B of the Approved Quality Auditors Scheme Guidelines addresses sampling requirements for NDIS providers. In the case of services-for-one, there is only one person, which means the principles of sampling will not apply to the person’s files and interviews. The person is still ‘opted in’ to the audit process, unless the person does not want to take part. The service-for-one would need to record that decision. We have included some tips below about audit planning, which may make the person more comfortable with being part of the audit. Although interviews with the person are effectively mandated in the NDIS AQA Scheme, some people may choose not to communicate with you directly or at all.
Communication may also take place in other ways. For example:
- observation
- allowing you to access to their room
- showing you their goals and plans in a way that is meaningful to them.
Tips:
- Taking appropriate guidance from the organisation and support staff is essential
to ensuring the person is not adversely affected by your presence. - Understand individual needs and that those needs will be different for each person.
- Be flexible about the audit and communication methods used for the person and with workers. This may mean that the audit day is not a standard workday from 9am to 5pm. It could vary depending on the availability of board or committee members and workers, as well as on the routine of the person. For example, a 9am start time may not work if a person is usually getting ready for their day at this time. If board members are working, interviewing representatives may need to take place outside their working hours.
B.5: Sample Composition – files and interviews
For most services-for-one there would be one site where the person resides, which may have ‘head office’ operations managed on the site. Some services-for-one may have the head office off-site in separate accommodation. For younger people, the service-for-one is likely to be provided within the family home.
B.6: Sample Size and Composition – attendance at site
No additional requirements.
B.7: Random Sampling
No additional requirements.
Note: These AQA Scheme requirements for sampling only apply to workers. This is because there is only one person, so sampling does not apply.
B.8: Incidental Sampling
No additional requirements.
B.9: Interviewing
Interviewing the person who uses services-for-one requires understanding of the unique features of services-for-one and the family-centred model.
The person using services-for-one may have had traumatic or difficult experiences in previous services, or in the community generally. It is essential that audit planning for services-for-one considers a range of factors to achieve effective engagement. As advised by one family: “With his extraordinary anxieties, building trust with a few highly attuned and trusted communication partners provides him with a source of security and is vital to his wellbeing”.
A detailed audit plan is essential. Effective planning before the audit should include making sure everyone is aware of:
- what will be happening
- who is going to be involved in the audit
- how they will be involved.
The service-for-one may also ask the auditor to video themselves as an ‘introduction’ to the person. You should provide this if asked.
You also need to know about any triggers that could be harmful to the person, or to the auditor and other stakeholders involved in interviews. Triggers could include words, actions, or expressions that the person may find upsetting. Auditors should confirm any triggers, or other things to note with the service-for-one before talking with the person. Things to note might include what the person is interested in to help build rapport. Before you speak to the person, you must have permission.
Audit planning should also consider:
- if any interpreters are required
- what communication methods work best, for example compic, communication board, lite-writer
- if the person wants to be supported while talking to the auditor, and if so, by whom.
Tips:
- Be respectful of the organisation, the person with disability, their environment, and personal preferences. The environment or choices may appear different to what you would usually see in other services, but may be in line with the specific needs and choices of the individual.
- Depending on the person, being calm or using a quiet, respectful speaking tone could
be helpful. - Many services-for-one with younger children operate as a family-centred model. This
is based on caring for their child and giving them the best life possible. It is unlike other support models, which are based on large service providers that have often provided limited or no options for a person with complex needs. - Be aware that you may see some behaviours of concern. Understand this and aim to work through these situations with the staff.
- Audits by their nature do not always run smoothly. It is important to be prepared for the unexpected and be accepting of this. The more time spent audit planning, the smoother the audit will run.
Note: These AQA Scheme requirements only apply to workers. This is because there is only one person, so sampling is not applicable.
B.10: Family, Friend, Carer or Nominee
No additional requirements.
B.11: Collection of Audit Evidence
Evidence-based auditing applies to audits of services-for-one in the same way as other types of service. The person’s experiences of supports will be a key part of the triangulation of evidence.
The audit team should:
- Be able to consider evidence based on proportionality. Proportionality refers to what services-for-one need to do to register and meet the NDIS Practice Standards. Services-for-one need to make sure what they do is in proportion to the size, scale, and type of supports they provide.
- Be able to consider evidence in different ways, such as:
- videos or other methods for communication and training
- task lists or forms instead of more formalised policy documents.
- written instructions about how to work with the person in a way that demonstrate respect for their individual needs, rather than policies that specifically follow the NDIS Practice Standards.
- Be open minded about how information and documents are presented and maintained. Documented evidence is required as part of demonstrating conformity, however, this may be presented in different ways and formats depending on the organisation and the individual. If a simple Word document is fit for purpose, there is no need for a complex system.
- Consider evidence around cancellation or withdrawal of supports in the NDIS Core Module Division 3 (Provision of supports), which you should handle sensitively. It is unlikely in services-for-one that there would be cancellation or withdrawal of supports. Talking about this could upset the person, given that they have sometimes had negative experiences with other service providers. Also, evidence from the service-for-one about cancellation or withdrawal of supports, may not be as obvious as other mainstream providers. This is just one example of how services-for-one can be different and the unique sensitivities involved.
B.12: Ratings
No additional requirements.
Annex C – Timeframe for correcting nonconformities
No additional requirements.
Annex D – Registration classes/groups exempted from sampling requirements
No additional requirements.