How to Write an NDIS Continuity of Supports Policy

Continuity of supports is one of the standards in the provider governance and operational management division of the NDIS Practice Standards Core Module, which you'll be audited against if you're on the Certification pathway. The current indicators are in section 18 of the NDIS (Quality Indicators for NDIS Practice Standards) Guidelines 2018. Its outcome is that each participant has access to timely and appropriate support without interruption.

There are five indicators:

Day-to-day operations are managed in an efficient and effective way to avoid disruption and ensure continuity of supports.
In the event of worker absence or vacancy, a suitably qualified and/or experienced person performs the role.
Supports are planned with each participant to meet their specific needs and preferences. These needs and preferences are documented and provided to workers before they start working with each participant, so the participant's experience is consistent with their expressed preferences.
Arrangements are in place to ensure support is provided to the participant without interruption throughout the period of their service agreement. These arrangements are relevant and proportionate to the scope and complexity of the supports delivered.
Where changes or interruptions are unavoidable, alternative arrangements for each participant's continuity of supports are explained and agreed with them, and delivered in a way that's appropriate to their needs, preferences and goals.

Your continuity of supports policy and procedure should set out how you meet each of these, as your organisation actually operates.

Continuity of supports and emergency management

Emergency and disaster management is a separate standard in the same division. Its first indicator requires measures that enable continuity of supports critical to the safety, health and wellbeing of each participant before, during and after an emergency or disaster.

Your continuity of supports policy covers everyday disruption, such as a worker calling in sick, a vacancy, or a change in your capacity. Your emergency and disaster management plan covers continuity during an emergency. Cross-reference the two so they don't contradict each other. Our free Emergency and Disaster Management Plan builder covers the emergency side.

Day-to-day operations

The first indicator is broad, so use your policy to describe the operational arrangements that keep supports running. Depending on your service, this could include:

how rosters or appointments are planned, and how far in advance
how you check you have capacity before taking on a new participant or increasing someone's supports
how cancellations and changes are communicated to participants and workers
who is responsible for monitoring whether supports are being delivered as agreed

Keep this specific to your service. A therapy practice with booked appointments and a personal care provider with daily rostered shifts will describe very different arrangements.

Worker absence and vacancy

Under the second indicator, when a worker is absent or a role is vacant, a suitably qualified and/or experienced person needs to perform the role. The indicator refers to "the role", which can include management and key personnel roles as well as frontline support.

Your procedure should cover:

how an absence is reported, and who arranges cover
how you decide a replacement worker is suitable for the specific participant and the supports involved, including any training or competency the support requires
how the participant is told about the change, and how their preferences about who supports them are taken into account
who covers key roles, such as the person responsible for incident management or complaints, when that person is away

If you're a sole practitioner, describe what happens when you're unavailable: whether supports are rescheduled, whether you have an arrangement with another provider, and how participants are told.

Documented needs and preferences

The third indicator links continuity to support planning. Each participant's needs and preferences should be documented and given to workers before they start working with that participant.

Make sure your policy says where this information is kept (for example, in the participant's support plan) and how a worker accesses it before their first session or shift. This includes a replacement worker covering at short notice.

Arrangements for the service agreement period

The fourth indicator asks for arrangements that keep supports going without interruption for the whole period of each participant's service agreement, proportionate to the supports you deliver. In practice, this brings together the arrangements described above: your day-to-day operations, cover for absences, and documented preferences. Your policy should show how they work together for the length of a service agreement, not just shift to shift.

Support planning connects here too. Section 20 of the Guidelines requires participant risk assessments to consider how much participants rely on your services to meet their daily living needs, and how their health and safety would be affected if those services were disrupted. Use that information to decide which participants need the most robust continuity arrangements.

Alternative arrangements when disruption is unavoidable

The fifth indicator applies when a change or interruption can't be avoided. Any alternative arrangement needs to be explained to the participant and agreed with them, and delivered in a way that suits their needs, preferences and goals.

Your procedure should cover how alternatives are offered and explained (in the participant's preferred way of communicating), how agreement is recorded, and what happens if the participant doesn't agree with what's proposed.

When you stop or change the supports you provide

The NDIS Commission's guidance on stopping the services you provide says providers need to manage the transition efficiently, communicate the change, and support affected participants. That includes:

notifying affected participants in an accessible way
supporting participants to transition to a provider of their choice, following a transition plan
notifying the NDIS Commission through the Registered providers portal as soon as possible
notifying the NDIA by emailing provider.support@ndis.gov.au

Include this process in your policy, so it's ready if you need it. Moving participants to or from your service is also covered by the Transitions to or from a provider standard in the provision of supports division of the Core Module.

Notifying the Commission of significant changes

Registered providers must notify the NDIS Commission of events that significantly affect their ability to deliver the supports and services they're registered to provide. The Commission's examples include a significant increase in wait times, and a significant shortfall in available workers.

These obligations sit in sections 13 and 13A of the NDIS (Provider Registration and Practice Standards) Rules 2018, with further detail in the NDIS (Registered NDIS Provider Notice of Changes and Events) Guidelines 2019. Name the person responsible for deciding when a notification is needed and making it.

Managing continuity risks

Staff shortages, a key person leaving, and losing access to a venue or vehicle are all risks to continuity of supports. Record them in your risk register with the controls you've put in place, and review them alongside this policy. Our free Risk Register Builder can help you start.