NDIS Module 2 vs Module 2A: Which One Applies to You

In the NDIS Practice Standards and when it comes to audits, Module 2 and Module 2A are different modules for different providers.

Module 2 (Specialist Behaviour Support) is for providers who develop behaviour support plans, while Module 2A (Implementing Behaviour Support Plans) is for providers who carry out the regulated restrictive practices a plan sets out. The NDIS Commission's page on the implementing module outlines where it applies.

Developing a plan versus implementing one

Module 2, Specialist Behaviour Support. This is for providers who assess behaviour and write the actual behaviour support plans. A plan can only be developed by a provider registered in this space, and the work must be completed by a behaviour support practitioner the Commission has assessed as suitable. A support provider can't write its own participant's plan unless it holds this registration, even if it employs qualified practitioners.

Module 2A, Implementing Behaviour Support Plans. This module is for providers who deliver supports and, in doing so, use regulated restrictive practices contained within a behaviour support plan. If a participant's plan sets out a restrictive practice and your staff are the ones applying it, you're considered an 'implementing provider'.

The five regulated restrictive practices are seclusion, chemical, mechanical, physical and environmental restraint. If you use any of them in delivering supports, Module 2A applies to you.

Implementing providers and BSP practitioners both must be registered

Neither support can be delivered by an unregistered provider. Developing behaviour support plans and using regulated restrictive practices are both rightfully considered high-risk supports, and can only be providered by registered providers. Developing plans requires registration group 0110 as outlined below, while using a regulated restrictive practice requires being a registered provider assessed against Module 2A. Module 2A not being its own registration group does not mean the support can be delivered unregistered.

Module 2 is a registration group, while Module 2A is not

Module 2 corresponds to the registration group 0110 Specialist Behaviour Support. It needs to be selected when you go through the application process (or your registration must be varied if you add it in between audits).

Module 2A doesn't connect to any registration group - there is no group you apply for to become an implementing provider, and you shouldn't select 0110 (unless you're also developing plans). Module 2A attaches to whatever registration you already hold the moment you use a regulated restrictive practice in delivering a support.

A SIL provider, a personal care provider or a support worker registered under their own support-type groups all become subject to Module 2A by using a restrictive practice, and you're assessed against it at audit on top of the core module.

Which one applies to you

If you assess behaviour and write behaviour support plans, you need Module 2 and registration group 0110.

If you deliver supports and carry out a restrictive practice set out in a plan developed by a behaviour support practitioner, Module 2A applies to you, regardless of which groups you are registered under.

Most support and SIL providers are not developing plans, and only need Module 2A. Most behaviour support practitioners, particularly smaller providers, are unlikely to also be implementing the restrictive practice and will only require Module 2.

When it isn't clear

If you're not sure whether what you do brings you under Module 2A, you need to promptly speak to the NDIS Commission and confirm with them (your auditor may also be able to provide some guidance). Using a regulated restrictive practice without the right authorisation and plan in place is a reportable incident and needs to be managed as such.