What the NDIS Human Resource Management Standard Requires

The NDIS Practice Standards set the same Human Resource Management outcome for Verification and Certification providers: each participant's support needs must be met by workers who are competent in relation to their role, hold relevant qualifications, and who have relevant expertise and experience to provide person-centred support.

If you're completing a Verification audit, you'll need to meet 5 specific indicators, while the Core Module includes 11.

Verification audit requirements

• Records of worker identity, right to work, pre-employment checks, qualifications and/or experience are maintained.
• Workers complete the mandatory NDIS orientation module, and records of continuing professional development are maintained.
• Each worker is trained, and has refresher training, in infection prevention and control standard precautions including hand hygiene practices, respiratory hygiene and cough etiquette.
• Each worker who provides supports directly to participants is trained, and has refresher training, in the use of PPE.
• PPE is available to each worker, and each participant, who requires it.

Three of the five are about infection control, which does tend to be a gap for some Verification providers who aren't aware of the evidence required.

Records. A file per worker holding proof of identity, proof of the right to work in Australia, the NDIS Worker Screening Check clearance, any professional registration or qualification the role relies on, and the certificate of completion for the NDIS Worker Orientation Module.

If you're a sole trader, you're the worker. The standard applies to you. Self-assessments from sole traders that leave Human Resource Management effectively blank on the basis that there are no staff are relatively common, and unfortunately may earn you a non-conformity. Your own identity documents, your own right to work, your own screening clearance, your own qualifications, your own orientation module certificate and your own CPD log are the evidence you'll need. If you engage contractors or occasional relief workers, they are workers for the purposes of this standard and need the same file.

Professional development. No number of hours is prescribed for CPD. The indicator asks for a record, so a dated list of what you did, what it covered and how long it took is fine.

Infection control and PPE. Both training indicators require refresher training, which means a single certificate from three years ago isn't enough. Make sure you have training record/s showing the initial training, the refresher interval you have set, and the date of the most recent refresher. Free training is available through the [Australian Commission on Safety and Quality in Health Care] (https://www.safetyandquality.gov.au/elearning/infection-prevention-and-control-and-hand-hygiene-elearning).

Core Module requirements

Certification providers are assessed against the system as a whole.

The indicator	What satisfies it
Skills, knowledge, responsibilities, scope and limitations of each position are identified and documented	A position description for every role, including the ones held by directors
Records of worker pre-employment checks, qualifications and experience are maintained	The worker file, built the same way as on the Verification pathway(described above)
An orientation and induction process is completed by workers, including the mandatory NDIS worker orientation program	The Commission's module certificate, plus your own signed and dated induction record
A system to identify, plan, facilitate, record and evaluate training and education, which identifies mandatory training and covers obligations under the Practice Standards and the NDIS rules	A training plan or matrix, attendance records, and evidence that the training worked
Timely supervision, support and resources are available, relevant to the scope and complexity of supports delivered	A supervision schedule, and records that supervision did occur
Worker performance is managed, developed and documented, including feedback and development opportunities	Completed performance reviews on a regular cycle
Workers with capabilities relevant to responding to an emergency or disaster are identified	A document naming people against capabilities: first aid, contingency planning, infection control
Plans are in place to identify, source and induct a workforce if workforce disruption occurs in an emergency or disaster	Named arrangements for where extra workers would come from, and how they get screened and inducted quickly
Infection prevention and control training, including refresher training, is undertaken by all workers involved in providing supports	Training records showing the initial training and the date of the most recent refresher
Worker contact details are recorded and kept up to date	A worker register or database that gets regularly reviewed
Details of worker secondary employment, if any, are recorded and kept up to date	The same register/database with the question asked again on a cycle

Common gaps

Limitations for roles. A PD should also include what the role does not cover, so it's clear to the worker and the organisation what duties are out-of-scope.

Training evaluation. Training needs to be evaluated to make sure it's actually serving its purpose. This doesn't have to be sophisticated, and can include a competency check after training, or a documented observation that a common issue stopped recurring.

Evidence of supervision. Supervision should be proportionate to the services you're delivering (not just how many staff you have). A provider delivering personal care to participants with complex needs should have something more than an open-door policy for supervision. Small providers often have good informal supervision but no records of it, which is an easy fix.

Emergency worker induction. Make sure you have a process to confirm that workers recruited during an emergency get screened and inducted properly.

Secondary employment. Commonly skipped over. A quick addition to your induction records and worker files will meet this.

Worker screening is a legal requirement

The screening obligation for registered providers sits in the worker screening rules, not in this standard. Registered providers must ensure that workers in risk-assessed roles hold a current NDIS Worker Screening Check clearance and must maintain a record of those workers. My article on How NDIS worker screening works covers this in greater detail.

Make sure you have a system or process to track expiries, even if this is in your Outlook calendar. An expired worker screening check is not just a risk to you at audit time, but potentially represents a serious safety risk to the people you support.

What to have ready

For Verification:

• a worker file per person containing identity, right to work, screening clearance, qualifications, orientation module certificate, a professional development record, and infection control and PPE training records showing refreshers
• include evidence if possible that PPE is actually made available (photos of your PPE supplies generally suffice).

For Certification:

• position descriptions covering every role
• worker files
• an induction process with completed signed records
• a training plan with delivery and evaluation records
• a supervision schedule with records of supervision occurring
• completed performance reviews
• a document naming workers against emergency and disaster capabilities
• a workforce disruption plan including rapid induction
• infection control training records with refreshers
• a worker register or database holding current contact details and secondary employment.

If you still need your policies and procedures, both pathways are covered in our Paperbark NDIS toolkits. The free Verification Toolkit helps you build your Human Resource Management policy and the supporting worker records, and the Certification Toolkit covers the Core Module requirements.