NDIS Registration Groups: What is the difference between High and Low Risk?

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Overview

Identifying the correct NDIS Registration Groups you fall under is essential as a provider. This article breaks down the difference between High and Low Risk Registration Groups and why this is important.

In 2018, the NDIS sector commenced its transition to the NDIS Quality and Safeguards Commission in New South Wales and South Australia; with this transition reaching it’s finalisation in December 2020 in Western Australia.

This transition introduced the National Framework to NDIS Provider Registration, removing this responsibility from the NDIA and individual states and territories management, across to a nationally consistent approach – adhering to the NDIS Practice Standards and Quality Indicators.

The National Framework has created two terms to be commonplace in disability sector lingo: Verification and Certification. Although they may sound similar, share some similar processes and serve the same function (determining the eligibility of a provider to adhere to the NDIS Practice Standards), these two processes are vastly different.

This update won’t go into the nuances of the registration process for either Verification or Certification. Instead, it will highlight what the actual difference is between high and low risk registration groups, as this is an area of confusion many providers still experience.

What's the Difference?

NDIS Registration Groups

Essentially, NDIS registration groups are split into two groups based upon the level of risk that they present within their service delivery. Supports that present a small risk to participants, fall into the low risk registration group category and supports which present higher risk fit into the high risk registration group category.

Low Risk NDIS Registration Groups

Low risk registration groups typically involve less direct or interpersonal contact with NDIS participants to deliver them, such as Assistance with Travel/Transport Arrangements, the provision of disability support products or Home Modifications. These services differ in terms of what they offer, staff providing the service and how much engagement with participants is involved; but the commonality here is that the level of actual contact involved with participants to deliver the support is relatively small.

However low risk registration groups can also involve higher levels of direct interpersonal contact provided by a qualified professional who is a current member of a professional regulatory body. Therapeutic Supports (eg. OT supports being provided by an Occupational Therapist who is a member of AHPRA or speech pathology supports provided by a Speech Language Pathologist registered with Speech Pathology Australia) and Community Nursing Care (eg. nursing supports provided by a Registered Nurse who is a member of AHPRA)

Sounds simple right? The concept of dividing registration groups based upon their risk level makes sense but it does result in some confusion. For example, you are not alone if you naturally assumed that Community Nursing Care would have been classified as a high risk registration group. The reason certain registration groups are classified as low risk even though they require more direct physical contact and engagement with participants is because it is an expectation of the professions delivering the supports are appropriately registered with their relevant professional regulatory body. Their registration ensures the completion of their qualifications and currency of their knowledge and skill through ongoing compliance requirements such as professional development (also referred to as CPD).

Keep in mind though, that just because a registration group is classified as low risk, does not mean that there are either no risks or that risks present are not significant. There will always be risks involved in any kind of service provision, however the risks presented in lower risk registration groups are less than those that classify as a high risk registration group.

High Risk NDIS Registration Groups

High risk registration groups usually involve the delivery of supports to participants that involve high levels of direct, physical and intensive interpersonal contact between staff and the participant (such as Assistance with Daily Personal Activities). The types of tasks associated with these supports also generally have more risks attached to them, due to the nature of the support (eg. High Intensity Daily Personal Activities or Specialist Positive Behaviour Support). This is why providers registering for high risk registration groups are required to undergo Certification audit with an onsite visit from the auditor.

Although some high risk registration groups must be delivered by staff with professional qualifications and registrations to professional regulatory bodies, the reality is that a lot of these groups don’t have this requirement. This means the onus to ensure the safety of the participants receiving supports under these high risk registration groups falls upon you as a provider – through having solid quality management systems in place.

Making it Work in Your Business

Providers must ensure the quality management systems they have in place are current and actually utilised in everyday practice. Hiring staff with the appropriate qualification, skills, knowledge and experience is only one part of the quality management systems related to hiring.

As a provider, it is your duty to ensure the identification, worker screening and right to work in Australia is also compliant with the supports you intend that staff member to deliver on behalf of your business. Having a quality management system in place means that once you complete these checks, you then have processes in place to check in on the status of staff in future.

Help ensure your service delivery, regardless of your high or low registration group classifications, is being provided by staff with the appropriate skill and knowledge and that as a provider, you are checking in with both your staff and participants. There could be risks present you didn’t account for during an initial risk assessment. Checking in will provide you with an opportunity to put measures in place to mitigate that risk and hopefully prevent the worst case scenario from occurring.

Provider Institute Best Practice Tip

Providers can support their own knowledge of the difference between registration groups by preparing a list of the registration groups they currently offer, those they intend to offer in the future and those they are interested to find out more about. Once this list is prepared, assign the following information to each registration group:

  • Is it a low risk or high risk registration group?
  • Does it require a Verification or Certification audit?
  • What modules within the NDIS Practice Standards does the registration group require adherence to?
  • Date of registration group or approval or intended timeframe which registration group will be officially added to service offerings and entered into the NDIS Commission’s portal.

The purpose of this document is to prepare a brief snapshot for providers as to which audit process they will require. Providers with only low risk registration groups will only require a Verification audit. However the inclusion of any registration group deemed to be high risk, will automatically require providers to under a Certification audit. If providers can flag early on which type of audit they need to undergo (even in the future), they can begin to plan and make arrangements so when audit time comes around, providers are more prepared and empowered to undergo audit.

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