If you’re a registered NDIS provider on the Certification pathway, your three-year registration period includes a mid-term audit. This article covers what gets assessed and when to expect it.
Who Has to Have One
Mid-term audits apply to registered NDIS providers on the Certification pathway. If you completed a Verification audit for your initial registration, mid-term audits don’t apply to you.
There are two exceptions. First, providers whose only Certification-pathway registration group is Specialist Disability Accommodation (0131) are exempt. Second, sole traders and partnerships whose only Certification-pathway group is Early Intervention Supports for Early Childhood (0118) are also exempt. If an SDA or early childhood provider is also registered for any other certification groups, the exemption doesn’t apply and a mid-term audit is required.
When to Expect It
The legislation is clear that a mid-term audit must commence no later than 18 months after the beginning of the period for which your registration is in force.
Note: Your registration doesn’t come into force when your certification audit is completed or when the report is submitted by you auditor. It comes into force when the NDIS Commission makes its decision and confirms your registration. Depending on the Commission’s processing workload, there can be a gap of months to more than a year between your audit and that decision.
Your mid-term audit window is 18 months after the Commission’s decision, not 18 months after your audit. If your audit was completed in January and the Commission confirmed your registration in July, your mid-term audit needs to commence by January the following year, not July.
Your Approved Quality Auditor will contact you to schedule the mid-term audit.
What a Mid-Term Audit Looks Like
A mid-term audit always involves a site visit. It uses the same certification methodology as your initial Stage 2 audit (same interview intensity, same evidence requirements) but covers a smaller scope so it’s generally shorter.
The sample size for participant and staff interviews is calculated using the square root of the total sampleable number, multiplied by 0.6. So a provider with 100 sampleable participants would have a sample size of √100 × 0.6 = 6. If you’re a larger provider with multiple sites, the audit will cover your head office plus a sample of additional sites (using the same formula).
What Gets Assessed
Every mid-term audit assesses the Provider Governance and Operational Management section of the NDIS Practice Standards These nine outcomes are assessed regardless of anything else:
- Governance and operational management
- Risk management
- Quality management
- Information management
- Feedback and complaints management
- Incident management
- Human resource management
- Continuity of supports
- Emergency and disaster management
These are the organisational backbone standards, the systems and processes that underpin how your whole operation runs, and are assessed at every audit.
Previous corrective actions
In addition to the standards above, any standard for which your previous audit identified a need for a corrective action plan also comes back into scope at mid-term. If you had a non-conformance against a participant support standard or a supplementary module standard at your initial audit, that standard will be assessed again at mid-term to confirm the corrective action has been implemented and sustained.
Standards specified by the Commissioner
The Commissioner can also specify additional standards to be assessed at a particular mid-term audit by written notice to the provider. This is relatively uncommon but worth knowing about.
Adding Registration Groups at Mid-Term
If you’re considering expanding your registration to cover additional Certification-pathway groups, the mid-term audit is a practical time to do it, as it can be folded into the mid-term audit rather than requiring a separate audit. Adding a new Certification-pathway group outside of an audit cycle would mean commissioning a standalone audit which is an additional cost and process.
Mid-term Non-Conformities
As with any certification audit, the mid-term audit can result in minor non-conformities or major non-conformities.
Major non-conformities carry a specific legislative consequence: if a major non-conformity identified at a mid-term audit is not downgraded or closed within three calendar months, the result is automatic suspension of your certification decision.
How to Prepare
The mid-term audit is designed to confirm that the systems you demonstrated at your initial certification are still functioning, and that any gaps identified at that audit have been genuinely addressed.
Some practical tips:
Know your corrective action status. If you had any non-conformances at your initial audit, review your corrective action plans before the mid-term. Not just whether you implemented the changes, but whether you can demonstrate sustained implementation with evidence.
Review your Part 3 systems. Work through each of the nine governance and operational management standards and ask whether your current practice reflects your documented systems. Documentation can often stay static while processes change on the ground, so this is a good opportunity to get up to date.
Check your HR records. Make sure your worker screening checks, qualifications and any other required checks are up to date.
Review your incident and complaints data. Auditors at mid-term will look at what’s happened in your incident and complaints registers since the initial audit, and trends, patterns, and evidence of continuous improvement are all relevant.
Get your evidence organised. Know where everything is before the auditor arrives.
The Connection to Recertification
Your mid-term audit feeds directly into your recertification audit, which occurs at the end of your three-year registration period. Any corrective actions that remain open or unresolved from mid-term will be reviewd again at recertification. Treating the mid-term as a genuine checkpoint rather than an administrative hurdle makes the recertification process a lot smoother.
The mid-term audit requirements are set out in section 21 of the Approved Quality Auditors Scheme Guidelines and section 13B of the National Disability Insurance Scheme (Provider Registration and Practice Standards) Rules 2018. Your Approved Quality Auditor can advise on timing and scope specific to your registration.
