Mandatory Registration deadline approaching and what you need to know

After a number of discussions with the Quality and Safeguards Commission, I was under the impression that mandatory registration was coming but would be a streamlined process to cater for small providers and to minimise backlog, which has been a problem for the Commission in the past. 

Unfortunately, July 1st is quickly approaching and no such simplified registration process has been presented to us. So, what do we do?

Simply put, we need to refer to the Commission's own website and follow their lead on compulsory registration. I encourage you to make sure you understand how this will affect you and your business and consider some options which may or may not suit you. 

What providers will now need to be registered?

• Specialist Disability Accommodation (SDA)
• Specialist Behaviour Support Services
• Supports or services to NDIS participants with NDIA (agency) managed funds
• Plan management Services
• Support Coordinators 
• Psychosocial Recovery Coaches
• Supported Independent Living (SIL) Providers
• Platform providers (website or app that connects participants to providers)

Documents attached to this article are for the mandatory registration for Support Coordinators and Psychosocial Recovery Coaches and further documents will be available on the links page provided.

What options do you have if you have been providing COS services to NDIS participants and you do not want to (or cannot) become a registered provider?

• One option is to leave the sector - obviously this is an extreme decision not to be made lightly, but if mandatory registration is going to cause you more problems than it is worth, perhaps you would like some help to exit your participant list and help them to transition to a new provider. 
• You could also seek out a reputable company who has already gained registration and ask them if they would consider employing you and taking on your participant client list. Although there are very few full time COS roles available, it is often more attractive an option to have someone else paying your super and tax and going through the audit process. If you want to talk about this, let me know if I can assist you to find some companies to apply to.
• If you want to remain self-employed, you could consider a contractor situation whereby you take your client list to a registered provider company and work with them for a 60/40 or 80/20 split of your income. They would take on the burden of invoicing, audits etc and you would still be responsible for your own business costs including superannuation and tax. Again, if you want to talk about how this might work for you, please book in a time to discuss this with me. 

Ok - so maybe you have come to the conclusion that you need to be registered (and all that entails). What next?

If you are a subscriber to MVC 24/7, you would have seen the article on how to register for PRODA and PACE. This is your first step. You cannot complete the application for registration without your PRODA number. 

There are many businesses out there looking to help you to take on and complete the registration process. This will cost you money - in some cases, a lot of money. If you are overwhelmed by the process and have enough money to spend, by all means, get someone else to do the work for you, but remember, they will still need your input and support, so you will never NOT be involved in the process entirely. 

The steps you need to be aware of are these:

1. Application - https://www.ndiscommission.gov.au/provider-registration/apply-registration#paragraph-id-7665  Submitting an application is free. You will need to have all of your business details ready to complete this form. This will include:
   - Your contact details and your key personnel
   - Your corporate structure
   - Your service profile
   - Your coverage areas
   - The registration groups you wish to apply for
   - All of the support services your organisation delivers
   You will need to meet certain requirements to prove your suitability including meeting the standards for code of conduct and record keeping. It is important to be familiar with the NDIS practice standards.
   Certification is for providers of high risk supports and they will be expected to complete some core modules specific to the risk in addition to being able to show qualification documents, policies and procedures, complaints and incident registers
   Verification is for lower risk groups who must be able to show qualifications, policies and procedures documents as well as complaints and incident registers.
2. Audit - It will be your responsibility to engage an auditor. You can ask around, Google options or go to Centro Assist for help to find an auditor who suits your needs. Your auditor should be ready to give you a list of each step of the process and all of the information they require. Those who are better prepared for this step will have better outcomes. Make sure your documentation is ready and proof of functionality is clear. Ask us for help if you are unsure. You do not need to submit an audit immediately with your application but the sooner you do, the sooner you will get to the next steps.
3. Assessment - Your auditor will hopefully let you know how you did but when the process is over, they will submit the findings to the NDIS Commission via the online portal. The Commission will then assess your application, considering your suitability, that of your key personnel and your organisation using the information you have provided. These are done on a case by case basis and as a result, some decisions can take much longer than others to be processed. 
4. Outcome - If your application is successful, you will receive your certificate of registration. You must comply with all conditions of registration including the NDIS practice standards and code of conduct. The NDIS must tell you if your application has not been successful and why. You can review this decision or improve the areas of concern and try again. 
5. Ongoing compliance - Ongoing compliance issues must be adhered to by all personnel in your organisation and include:
   - Practice Standards and conditions of registration
   - NDIS code of conduct
   - In-house complaints and resolution management plan
   - In-house incident management plan and to notify NDIS Commission of all reportable incidents
   - Ensuring all workers are screened through national worker screening
   - Meeting all behaviour support requirements where applicable
   
   
   

Please download and read over the Supported independent living (SIL) and support coordination registration - Consultation paper  but please be aware, this is NOT a step by step for  registration, it is simply an FYI and may answer some of your questions about why and what regarding the need for mandatory registration for these types of providers. Use the link below to begin your application process: https://www.ndiscommission.gov.au/provider-registration/apply-registration#paragraph-id-7665