Human Resource Management

Why do I need this document?

• The HR Register keeps all personal and professional information in the one place for you and all personnel involved in your business. Even if you are a sole trader it will ensure all relevant information is in one place and enable you to easily find information when required. 
• It reminds you what you need to check when employing or contracting additional personnel.  
• It ensures your due diligence, if something does go untoward your insurer will want to know you have done these pre-employment checks. 
• It allows you to match staff skills and services with the needs of your participants e.g. second languages, skilled at using assistive technology, Makaton, Auslan, different NDIS registration groups.  

Why the auditors like it 

They can: 

• see at a glance (i.e., without having to look at a range of documents) that you and anyone working for you has the right to work in Australia and the appropriate qualifications, experience and checks are in place to provide services to NDIS participants 
• see that requirements are current 
• easily do the checks they need to do, e.g., look up your AHPRA registration or worker screening details 
• see you consider the communication needs of your participants by recording the communication skills of your team members 
• see you have systems in place to ensure your compliance if you employ additional personnel. 

Next steps 

• Complete the listed details for all relevant personnel within the HR Register tab of the combined compliance register or alternative system you have chosen to use 
• GET CONSENT from any employees or contractors to share this information with the auditor for the purpose of completing NDIS registration. 
• SIGHT original documents and STORE copies for auditors upon request. 

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Why do I need this document?

We all need to complete registrations, subscriptions, memberships, insurances and activities to maintain the right to work in our professions and to remain safe at work. 

The Compliance Calendar provides a system to manage all your ‘must-dos’. Once set up, it lets you easily see what you have to do each month to maintain currency and your legal obligations. 

Why the auditors like it 

They can: 

• See you have a system in place to effectively manage your ‘must dos’, reducing your risk of being non-compliant with statutory requirements or having out of date insurance! 
• Look at one document and feel confident you have everything under control 
• Easily do the checks they need to do e.g., randomly ask you to show them a specific certificate of currency. 

Next steps 

• Customise the list of issues within the Business Compliance tab of the combined compliance register (or set up in your alternative system) to suit your business e.g., if you do not have rooms that you operate out of, you won’t need some of the fire safety items; if you don’t have equipment that needs calibration you can delete that item. 
• Once you have decided on what you need/want to track, RECORD due dates in the corresponding boxes e.g., if your Professional Indemnity Insurance is due on the 06/03/2020 put ‘6’ in the March 2020 column alongside ‘Professional Indemnity’. 
• MARK things you have done GREEN to show they are ‘completed’, AMBER to show something is ‘behind schedule’ or RED to show it is ‘not delivered’. Right click over the corresponding square to insert a comment explaining why you are behind schedule or stopping an activity to document any anomalies. 
• REVIEW the Compliance Calendar Sample for an idea of how it works. 

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Why do I need this document?

The NDIS Commission’s Module’s, Practice Standards and Code of Conduct require providers and workers to understand and comply with various policies and apply various principles in their practice. One way of ensuring this occurs is for regular training to occur on key issues. This training is in addition to your CPD requirements for professional registration and/or membership (although you may be able to use some of the training for CPD points). 

The Training & Competencies tab of the combined compliance register provides a clear list of what training is required and how often and records what you have completed. It includes training on policies such as Privacy, Incident Management and Risk Management but also on topics such as the NDIS Code of Conduct and Dignity of Risk. You may also need to add topics to the plan if you are providing some specific supports to NDIS participants. 

• If you work on your own, a lot of this training will be informal e.g., reviewing the NDIS Code of Conduct and reflecting on how you apply the code to your delivery of services. Consider arranging to meet up with your peers to discuss some of the training topics together. 
• Small practices might like to consider covering one topic a month as part of a team meeting. 
• For larger organisations you will need to keep records of who attended the training and how you provided the training to any staff that missed out.  

You may wish to regularly review the training and competencies completed and frequency dates to see when refresher training is required or set up a separate training plan so you can more easily identify when training is required throughout the year and ensure you have proactively planned time to complete the training.  

Why the auditors like it 

• They can see you understand what you must do each year and have a system in place to remember what training you plan to do. 
• It prevents them from having to engage in long conversations with you to find out what training you are doing. 
• They have specific training topics they can ask you/your team about. 

Next steps 

• Customise the training and competencies tab within the combined compliance register (or set up in your alternative system) to suit your business  
• FILL IN the completed date when training is undertaken 
• UPDATE your professional CDP record to show the auditor you are maintaining your relevant professional development. 

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All registered providers must conduct pre-employment checks for workers in line with the worker screening requirements which are based on the NDIS Practice Standards – Worker Screening Rules 2018. This helps ensure that key personnel and workers in these roles do not pose an unacceptable risk to the safety and wellbeing of NDIS participants. 

 Not all workers require screening checks.  

 TASK 

To determine which of your employees / staff / workers require a check download the NDIS worker screening risk assessment template document available below, and conduct a risk assessment for each of your staff. 

This document must be completed and stored for all staff to ensure compliance with worker screening record keeping requirements.  

 When conducting risk assessments also consider: 

Students: 

• “Secondary school students on a formal work experience placement with a registered NDIS provider do not need an NDIS worker screening clearance or acceptable check to be engaged in a risk assessed role. This is provided they are directly supervised by another worker who has an NDIS worker screening clearance, or who has an acceptable check.” (reference) 
• See requirements related to Tertiary and TAFE students here 
• The worker screening system requires an application within one State or Territory but is now a national scheme and checks apply nationally. However, some States and Territories may have additional requirements in place and/or have identified alternative acceptable checks which meet the Commission’s requirements in place of the NDIS Worker Screening Check clearance. 
• You can see acceptable alternative checks here 
• You should check here to see if there are any additional requirements in any States or Territories you will provide services. 
• Contractors: Requirements related to contractors are noted here 

Once you have determined which staff need a check: 

• You can use the Worker Screening Database to determine if staff and/or prospective employees have already had a check and the outcome (cleared or excluded) of the check. 
• To request access to the NDIS Worker Screening Database before you are registered you need to complete an application form. 
• Refer to the Quick reference guide – Unregistered Provider – Request access to the NDIS Worker Screening Database for assistance. 
• Once you are registered you can access the Worker Screening Database via the NDIS provider portal. 
• Ask remaining staff to undergo a worker screening check – the link to the relevant worker screening unit in your state or territory can be found here
• When making an application, workers will need to nominate an employer to verify that they intend to engage the worker to deliver NDIS supports or services. Most application forms will allow workers to search for their employer using their Employer ID. This is the best way to find the employer and make sure the correct one has been selected.  
• Organisations can find their Employer ID and provide it to workers by doing the following: 
• Enter the NDIS Commission Provider Portal 
• On the Portal entry point screen, use the drop down menu to select the Provider name. In the Role drop down, select Registrant 
• Once you are in the NDIS Commission Portal, select the My Registration tile 
• On the left side menu, towards the top you will be able to see your Registration Id. This is the Employer Id that you can advise your workers to use when applying for the NDIS Worker Screening Check 

Once staff have completed their checks: 

• You will receive notification as the employer and a number related to their check to record 
• You should record this number in the HR register along with any other relevant details related to their check as per the required record keeping requirements 
• If you complete the registers provided in this resource your requirements should be met, however, you must remember if anything changes about the staff members position to update your records – the requirement is within 20 days.  

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In addition to the worker screening checks, there are specific requirements related to ensuring the identity of your personnel, their right to work in Australia and their level of qualifications and experience and how this relates to the services they provide to participants on behalf of your business. Workers must have Proof of Identity and Right to Work checks 

There are differences in the requirements dependent upon whether your business is set up as a Body Corporate (Incorporated or Pty Ltd) or Individuals and Partnerships. You need to refer to the Verification module – September 2021, locate the heading related to your business structure and see the detailed requirements to understand how you meet these relevant headings within the compliance register.

The NDIS Code of Conduct is intended to promote safe and ethical service delivery by setting out expectations for the conduct of both NDIS providers and workers. 

 All registered NDIS providers and their employees must comply with the code at all times. 

See here for information related to: 

• Who else the Code applies to 
• A summary of what the Code requires 
• Guidelines to help NDIS providers and workers understand their obligations under the Code were updated in September 2023 and are now available. 

 A free Worker Orientation Module is available to help workers understand the NDIS Code of Conduct.  

The module It takes about 90 minutes, and a certificate of completion is provided by the system once you have done so.

Task: 

• All registered providers and their workers must complete the module to support compliance with the Code 
• You and each employee must access the module here and complete it so you receive a certificate of completion 
• Collate these completion certificates within your management system and provide a copy for each relevant worker / employee to the auditor. 

Why do I need this document?

Among other things, the Human Resource Management Practice Standard wants to know you have “the relevant expertise and experience to provide person-centred support” to NDIS participants. We have found that developing a Service Delivery Model for your business is a great start! 

By spending a bit of time writing a Service Delivery Model that reflects how you deliver your services it shows you understand the Code of Conduct and person-centred support. It also tells others your values and practice standards. This document is not just for the auditor it can become a key marketing document for you, showing potential clients how you operate. So think about how and where you may use this document or where else in your system you may prefer to communicate this information. Some providers choose to include it in service agreements. 

Of all the documents we provide, we anticipate this one will require the most of your attention. It is really important it reflects your practice and how you operate. 

When writing your Service Delivery Model consider including the following: 

• Defining what you mean by person-centred support and ensuring you use person-centred language throughout – some providers prefer to write this document as if speaking to the participant rather than in 3rd person 
• How you meet the needs of participants and their family (if practical and if directed by the participant to do so) 
• Respecting the participant’s cultures, beliefs and values 
• Working with trusted/appointed decision makers 
• Communicating with participants in a way they understand and encourages their involvement 
• The professional model or framework you use to direct your intervention. In our sample Service Delivery Model, we have used the Occupational Performance Model by Chris Chapparo and Judy Ranka. Only use it if it really suits your practice – there are many other models available for different professions, your professional associations competency standards framework is another good option to utilise 
• Dignity of risk 
• Culture of continuous improvement and the importance of feedback. 

Why the auditors like it 

• They get a feel for the type of practice you are. Remember for a Verification audit, auditors do not come on site – they need to know you understand person-centred supports and actually do provide them. 
• They can see what you say you are doing in your Service Delivery Model links back to your Annual Training Plan e.g., you say you respect the cultures, beliefs and values of your clients and you have an annual training event correlating to this. 

Next steps 

• LOOK at the Sample Service Delivery Model and use it as a guide to write your own. Keep it to a max of one page. 
• GET FEEDBACK from some of your participants – does it reflect what you do? 
• ONLY INCLUDE things in your Service Delivery Model that you actually do now and can demonstrate and/or implement new ways of working which address the aspects listed for inclusion above. For example, if you say you understand and respect the culture, beliefs and values of your participants make sure you have evidence of how you are doing this e.g., is it a question on your initial assessment or intake form and what do you do with the answers? 

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Why do I need this document?

The Document Control Register helps you to manage policies, forms and assessments and ensures you are working on the most recent edition (not a photocopy of some form that is three years out of date!).

It is not an absolute requirement but auditors’ feedback is that it is very good idea. Having this register and keeping it up to date will really help with your next audit. It gives you a comprehensive list of all your QMS documents for audit. This not only means you can easily check if documents are up to date, but the auditor can see what documents you have and can readily request them as needed. It saves a lot of time at audit (and likely some cost).

To make this system work you need to make sure you:

• Have document footers showing the date the document was developed. The dates will need to be updated once you do your annual reviews (refer to your Compliance Calendar and Annual Training Plan). This will mean you are ready for your next audit in three years’ time.
• Decide on a numbering system that makes sense to you and your team. This becomes more important once a service starts to grow and/or if you decide to add current assessments etc. to the Register

If there is more than one person on your team, the Document Control Register becomes more important as it will assist all providers to be using the correct form. This is good practice for all documents but critical for documents you give your participants (e.g. Service Agreement and Support Plans) as these need to comply with NDIS Rules and Terms of Business (which tend to change).

The Register enables a provider on your team to register a document and have it available to all your team members. This will provide consistency across your team and prevent providers reinventing forms that already exist.

Why the auditors like it

They love registers!

They can see:

• You have a system to keep track of different versions of your documents
• You regularly review policies and other documents
• You are serious about quality management

Next steps

• OPEN the Document Control Register
• CUSTOMISE it to reflect the policies and forms your organisations uses. You can expand it to include your assessments as well
• EDUCATE your team on the process of introducing a new form or assessment
• UPDATE the register it when you do your annual reviews – refer to your Compliance Calendar and Annual Training Plan
• UPDATE all your team if/when changes occur – and make sure they delete old copies
• ARCHIVE your old copies for possible future reference – this may prove critical if a complaint arises or any litigation commences

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The ‘spiel’ is the text you will insert when completing the self-assessment to apply for registration via the Commission’s portal. You will need to have confirmed your ways of working, which documents you will utilise and what you will call them before completing this ‘spiel’.  

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