Common Nonconformances in NDIS Module 1 Audits

Three gaps account for most of what I’ve seen come up in reviewing NDIS audit reports which included Module 1: training delivered by the wrong person, training that’s generic but not participant-specific, and no ongoing competency assessment for workers. For registered NDIS providers delivering high intensity supports, meeting the High Intensity Support Skills Descriptors is an ongoing, participant-specific exercise.

Disclaimer: The Approved Quality Auditor scheme guidelines require input from registered nurses for all Module 1 audits, which I’m not. The following comes from extensive experience reviewing NDIS audit reports, interpreting the NDIS Practice Standards, and working alongside and learning from excellent Module 1 auditors. If you need specific high intensity guidance for your organisation, please get in touch and I can recommend some great consultants who specialise in this area.

Training delivered by someone who doesn’t meet the requirement

Workers don’t need to be a nurse or other health practitioner to deliver Module 1 supports, but the person training them does. Every indicator across all eight categories uses close to the same wording: training must be delivered by an appropriately qualified health practitioner, or by a person who themselves meets the relevant high intensity support skills descriptor. The same phrasing repeats from complex bowel care through to complex wound management – it isn’t a general expectation being read into the standard, it’s the specific test each indicator sets and that the auditor is looking at.

Severe dysphagia management is the one exception, where training for severe dysphagia management must only be delivered by an appropriately qualified health practitioner. The ‘or person who meets the skills descriptor’ alternative available everywhere else cannot be used here.

A common gap is a provider using whoever is available internally to run training, a senior support worker or team leader, without checking whether that person actually meets either bar. The training itself might be thorough and well delivered, but it doesn’t satisfy the indicator if the trainer’s own competency was never established, or if it’s severe dysphagia training delivered by anyone other than a health practitioner.

Something to note: neither the standard nor the skills descriptors say how a provider is meant to verify that a non-practitioner ‘meets the expectations of this skills descriptor’ well enough to train others. The health practitioner pathway ties to an external, checkable qualification, but the other pathway doesn’t, it’s a judgement call the provider makes about their own worker, with no defined assessment method or evidence threshold attached to it. Further clarification on this issue has not been published by the Commission as of the time of writing. Providers in this case should document how they reached that judgement, not just assert that it was made.

Stopping at general training, without adding the participant-specific layer

General training in each support type is the starting point. Every skills descriptor’s training section builds on it explicitly, workers need general training in the procedure itself, how to manage a tracheostomy, how enteral feeding equipment works, how to recognise a dysphagia-related incident, before anything participant-specific is relevant at all. The standard’s own wording frames it as an addition, not a substitution: workers are trained in the specific needs of each participant they support, in addition to general training in the procedure.

As well as general training, the phrase ‘relating specifically to each participant’s needs’ appears in the training indicator for every one of the eight categories, and it’s doing the same job each time, requiring a second layer of training on top of the general procedure, not instead of it.

Participant-specific training requirements differ by category.

• For complex wound management, the participant-specific training has to relate to the needs affected by that participant’s own wound care regime, the standard names showering, toileting and mobility as examples.
• For severe dysphagia, it has to follow the participant’s individual preferences for food, fluids, preparation techniques and feeding equipment, set out in their plan.
• For subcutaneous injections, a documented written or phone order from the prescribing health practitioner authorising the specific medication a trained worker may administer, and a basic understanding of that participant’s related health condition, not just the injection technique.

A worker who’s completed solid general training on a support category, without the participant-specific training on top, hasn’t met the indicator, even when the general training was thorough and delivered by the right person. Each participant’s plan is different, and the standard expects a second round of training to reflect that difference.

No competency assessment, and no refresher when one’s due

The outcome indicators require appropriate policies and procedures, including a training plan for workers, for each high intensity category a provider delivers. The skills descriptors states that providers are responsible for ensuring workers’ skills and knowledge stay current, with an annual competency review recommended, and reassessment where a worker hasn’t delivered a support for more than three months, or a participant’s plan has changed.

A one off training record isn’t evidence that competency is current or that a training plan exists, this is an ongoing process.

Resolving these gaps

For each participant receiving a high intensity support, a provider should be able to produce:

1. An individual support plan for that specific support, developed with the participant and overseen by a relevant health practitioner, not a generic policy covering the support category.
2. Records showing the participant’s health status is reviewed regularly by an appropriately qualified health practitioner.
3. Training records showing the worker was trained against that participant’s specific plan, risk factors and preferences, not just the general procedure.
4. A record confirming the trainer’s own qualification, either as an appropriately qualified health practitioner or someone who themselves meets the relevant skills descriptor.
5. A date for when the worker’s competency was last reviewed, and evidence of reassessment where it’s been more than three months since they last delivered that support, or the participant’s plan has changed.
6. Where relevant, evidence that the plan was communicated, with the participant’s consent, to their support network, other providers or relevant agencies.