Proportionate response to requirements under the NDIS Quality and Safeguards Commission
If you’ve been out and about in the sector recently hearing about the NDIS Quality and Safeguards Commission, it is likely you will have heard the term 'proportionate' being used in relation to a registered provider’s approach to meeting their obligations.
The NDIS Quality and Safeguards Commission expects that each provider’s approach to meeting requirements will be proportionate to their size and the risk associated with the supports delivered. The term proportionate accompanies many other often-used terms in the NDIS, including: human rights, choice and control, national consistency, presumption of capacity, efficiency and effectiveness. In the context of the NDIS Quality and Safeguards Framework, 'proportionate' describes how meeting regulatory requirements for workers and providers are tiered, and ensures regulation is relative to the level of risk associated with the type of support provided and the needs of the participant.
In order for an organisation to apply for, or renew, their NDIS registration status with the NDIS Quality and Safeguards Commission, the organisation must be audited against the NDIS Practice Standards. Registration requirements under the NDIS Commission are outlined on the Commission’s website and further detailed in the NDIS Practice Standards.
The way the auditor will approach the review of an organisation will be proportionate to the size of the organisation and the complexity of supports delivered. This, in practice, will mean that a smaller provider with fewer workers and participants is not expected to present the same evidence as a national provider with a large workforce and many participants. Auditors will ensure that the way an NDIS provider demonstrates they have met each standard is appropriate for their size, scale, and the supports they deliver.
Smaller providers delivering standard supports may be required to fulfil a verification audit. This type of audit is described by the Commission as a 'lighter touch desktop audit'. Large organisations and those delivering complex supports may be required to fulfil the detailed certification audit. The Commission will also consider the legal type of the organisation as well as the size, scale and supports delivered when deciding the appropriate auditing requirements and will inform each provider which type of audit is required by their organisation.
The cost of audit will also be informed by the size and scope of the audit. The NDIS Commission is monitoring information about audit costs and timeframes carefully, and surveying providers to gather intelligence about actual experiences with auditors.