Comparison of aged care and NDIS requirements

Aged care and NDIS similarities and differences

Terminology

Provider suitability

Both Aged Care and NDIS providers must demonstrate suitability to provide services. This includes that they:

• understand responsibilities
• comply with quality standards and legislation, policy and procedures
• have governance and finance systems in place
• have suitable key personnel.

Key personnel suitability

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.

Accreditation and registration information

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.

Who makes accreditation and registration decisions

Application

Assessment or audit process

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)
• collection of evidence 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
• conducting an exit interview at the end of the audit
• preparing an audit report/performance assessment report outlining compliance with quality standards
• decision by Commission
• issue of a registration/accreditation certificate
• publication of registration/accreditation online
• 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.

Audit

Timing of initial audit

Timing of re-accreditation/certification audits

Costs

Assessor or auditor

Sample size

Site

Audit ratings

Audit report

Compliance

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.

Comparison of Aged Care Quality Standards and NDIS Practice Standards

NDIS Practice Standards

The NDIS Practice Standards are modular. Providers are required to comply with the modules that are applicable to the NDIS supports and services they deliver.

• Residential aged care providers will be required to comply with the Core Module of the NDIS Practice Standards which comprises 24 Practice Standards and 123 Quality Indicators.
• Supplementary modules may apply if providers are delivering complex, specialised supports that are funded through the NDIS as part of a participant’s NDIS plan (for example, complex health care supports or supports involved in implementing behaviour support plans involving restrictive practices).
• Each module consists of high-level, participant-focused outcomes for each NDIS Practice Standard. Each outcome has several quality indicators that auditors will use to assess a provider’s compliance with the NDIS Practice Standards.

Aged Care Quality Standards (ACQS)

The Aged Care Quality Standards comprise a set of 8 Standards, each having an overarching consumer outcome, organisation statement and a related set of requirements.

The NDIS Commission has compared the Aged Care Quality Standards against the NDIS Practice Standards to show how current ACQS requirements are similar, have some similarities or are different to the requirements of the NDIS Practice Standards. The results of this comparison appear in Table 1: Standards Comparison Tool.

Where requirements are the same, it is likely that existing evidence of compliance with Aged Care Quality Standards will work towards meeting NDIS compliance requirements.  Even though the requirements may be the same, Auditors may require residential aged care providers to show evidence of these during the audit process.

Where requirements have some similarities, or are different, it is likely that extra evidence will be required as part of the NDIS audit process.

Broad commonalities between ACQS and NDIS Practice Standards

Around half of the requirements of the NDIS Practice Standards in the Core Module are the same as those of the Aged Care Quality Standards. There are several broad commonalities across both sets of Standards, which include the requirements for:

• elements of organisational systems covering:
  • feedback and complaints
  • incident management
  • compliance
  • risk
  • continuous improvement
  • governance
  • information management
  • human resource management
• support provision processes including:
  • assessment
  • planning
  • review of supports
  • 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).

Differences between ACQS and NDIS Practice Standards

• The NDIS Practice Standards (and associated Quality Indicators) are more specific than the Aged Care Quality Standards.
• Certain NDIS Practice Standards for Governance and Operational Management also require compliance with a specific set of Rules e.g. NDIS (Incident Management and Reportable Incident) Rules 2018 and NDIS (Complaints Management and Resolution) Rules 2018.

Standards that are different where you might have to review your systems for NDIS registration:

• personal information/consent of participants
• access to an advocate
• processes for allegations/incidents of violence, abuse, neglect, exploitation and discrimination
• some specific and extra NDIS governance requirements, including quality management, risk management and human resource obligations
• NDIS participant input into governance
• extra 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.

NDIS Core module

The NDIS Practice Standards in the Core module covers four areas: Rights of participants and responsibilities of providers; Governance and operational management; the Provision of supports and; the Support provision environment.

Rights and responsibilities

The NDIS Practice Standards in this part of the Core module include:

• Person centred supports
• Individual values and beliefs
• Privacy and dignity
• Independence and informed choice
• Violence, abuse, neglect, exploitation and discrimination.

More than half of the Quality Indicators in this part of the NDIS Practice Standards are similar to ACQS requirements.

For Quality Indicators that have some similarities to ACQS requirements, residential aged care providers should review the evidence they have in place to show how they:

• Incorporate legal and human rights into everyday practice.
• Support NDIS participants to engage with their support network and chosen community.
• Make sure NDIS participants understand and agree to what personal information is collected and why, including recorded material in audio and/or visual format.
• Make sure NDIS participants have enough time to consider and review their options at any stage of support provision.
• Make sure NDIS participants always have access to an advocate, including where allegations of violence, abuse, neglect, exploitation or discrimination have been made.
• Act upon allegations and incidents of violence, abuse, neglect, exploitation or discrimination, including making records, and in line with NDIS (Incident Management and Reportable Incidents) Rules 2018.

Governance and operational management

The NDIS Practice Standards in this part of the Core module include:

• governance and operational management
• risk management
• quality management
• information management
• feedback and complaints management
• incident management
• human resource management
• continuity of supports
• emergency and disaster management.

Around a quarter of these requirements are the same as ACQS requirements. Most of these requirements have some similarities, and a few are different to ACQS requirements. 

For Quality Indicators that have some similarities or are different to ACQS requirements, residential aged care providers should review the evidence they have in place to show how they:

• Meet corporate governance requirements specific to the NDIS.
• Provide NDIS participants with opportunities to contribute to governance.
• Make sure organisational risk management systems cover off on specific risk categories.
• Document an Internal Audit program.
• Advise NDIS participants about consent and management of their information.
• Make sure the complaints management and resolution system fully meet the requirements of the ‘Rules’. For example, advise participants they can complain directly to the NDIS Commission, mandatory worker training.
• Make sure the incident management system fully meets the requirements of the ‘Rules’ for NDIS Reportable Incidents and mandatory worker training.
• Implement Human Resource Management systems that address mandatory NDIS worker orientation requirements, NDIS worker screening, NDIS training, how workers are identified in response to emergency or disaster.
• Explain and agree alternative arrangements for continuity of supports with NDIS participants.
• Make sure the governing body develops, tests and reviews emergency and disaster management plans and trains workers in implementation of these plans.
• Have appropriate insurance as part of risk management.
• Have a quality management system that meets the requirements of legislation and the NDIS Practice Standards.
• Make sure the governing body consults with NDIS participants and their support networks about emergency and disaster management plans.

Provision of supports

The NDIS Practice Standards in this part of the Core Module include:

• access to supports
• support planning
• service agreements
• responsive support provision
• transitions to or from a provider.

Most of the NDIS Quality Indicators are similar to ACQS. This high level of alignment recognises the commonality in support provision requirements and processes.

For Quality Indicators that have some similarities to ACQS requirements, residential aged care providers should review the evidence they have in place to show how they:

• Review support plans at least annually, and update support plans where progress is different from expected outcomes and goals.
• Anticipate responses to support plans for individual, provider and community emergencies and disasters.
• Set out arrangements in service agreements for providing supports in the case of an emergency or disaster.
• Provide supports based on the least intrusive options.
• Develop links with other providers (with NDIS participant consent) including health care and allied health providers.

Support provision environment

The NDIS Practice Standards in this part of the Core Module include:

• safe environment
• participant money and property
• medication management
• mealtime management
• waste management.

Most of the NDIS Quality Indicators are similar to ACQS requirements. This high level of alignment recognises the commonality in requirements which promote safety. 

For Quality Indicators that have some similarities to ACQS requirements, residential aged care providers should review the evidence they have in place to show how they:

• Undertake work with other providers (including health care and allied health providers) to identify and manage risks.
• Make PPE available to NDIS participants and workers (where required) and train workers in use of PPE.
• Support NDIS participants to use their own money as they determine.
• Make sure NDIS participants requiring mealtime management have their individual mealtime management needs assessed by appropriately qualified health practitioners.
• Train workers responsible for providing mealtime management and make sure they can manage related emerging and chronic health risks.
• Have an emergency plan in place for clinical waste or hazardous substance management issues.

NDIS Module 1: High intensity daily personal activities

Residential aged care providers may wish to include Module 1 in their application and audit to be registered for registration group 104 High intensity daily personal activities and provide these supports where they are funded through the NDIS as part of a participant’s NDIS plan:

• complex bowel care
• enteral feeding and management
• severe dysphagia management
• tracheostomy management
• urinary catheter management
• ventilator management
• subcutaneous injections
• complex wound management.

Within this module, most of the NDIS Quality Indicators are similar to current ACQS requirements. This high level of alignment recognises the commonality in clinical/complex health care requirements.

The partially met areas relate to specific requirements for:

• severe dysphagia management
• subcutaneous injections.

NDIS Module 2a: Implementing Behaviour Support Plans

Residential aged care providers may wish to include Module 2a in their audit to be approved for the implementation of regulated restrictive practice while delivering support to a NDIS participant:

• behaviour support in the NDIS
• regulated restrictive practices
• supporting the assessment and development of behaviour support plans
• behaviour support plan Implementation
• monitoring and reporting the use of regulated restrictive practices
• behaviour support plan review
• reportable Incidents involving the use of a restrictive practice
• Interim behaviour support plans.

Within this module, most of the NDIS Quality Indicators have some similarities to current ACQS requirements. There are no requirements which are the same as ACQS requirements, and some which are different. This is largely due to the complex and specific compliance requirements of Module 2a and the associated NDIS (Restrictive Practices and Behaviour Support) Rules 2018.