How to Write an NDIS Participant Money and Property Policy

Participant money and property is one of the standards in the support provision environment 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 25 of the NDIS (Quality Indicators for NDIS Practice Standards) Guidelines 2018.

The outcome is that participant money and property is secure and each participant uses their own money and property as they determine. There are three indicators:

• Where the provider has access to a participant's money or other property, processes to ensure that it is managed, protected and accounted for are developed, applied, reviewed and communicated. Participants' money or other property is only used with the consent of the participant and for the purposes intended by the participant.
• If required, each participant is supported to access and spend their own money as the participant determines.
• Participants are not given financial advice or information other than that which would reasonably be required under the participant's plan.

Who the standard applies to

The first indicator applies where you have access to a participant's money or other property. That can include handling cash for shopping, holding a bank card, managing a participant's belongings in shared accommodation, or using a participant's property while supporting them.

The second and third indicators aren't limited in the same way. Supporting a participant to spend their own money, and not giving financial advice beyond what their plan reasonably requires, can apply to any provider whose workers support participants in daily life.

If your organisation doesn't handle participant money or property, your policy can say so. Then say what workers should do if a participant asks them to hold money, use a bank card or PIN, or look after valuables.

Managing, protecting and accounting for money and property

The first indicator asks for processes that are developed, applied, reviewed and communicated. Your procedure should cover:

• what kinds of access to participant money and property your workers have, and in which settings
• how you get and record the participant's consent, including for what purpose the money or property will be used
• how transactions are recorded (for example, receipts kept and matched against cash handed over and change returned)
• how records are checked or reconciled, how often, and by whom
• how participant property is recorded and kept safe, for example an inventory of belongings in a shared living setting
• how participants (and, with their consent, their support network) are told about these processes

Money or property can only be used with the participant's consent and for the purpose the participant intends. Write this into the procedure as a rule workers follow.

Supporting participants to spend their own money

The second indicator is about the participant's control. Where support is needed, participants are supported to access and spend their own money as they determine. Describe how workers support this in practice, such as helping a participant budget, go shopping, or use an ATM, while leaving the decisions with them.

This connects to the Independence and informed choice standard, which requires each participant's right to the dignity of risk in decision-making to be supported. Our article on writing a dignity of risk policy covers this in more detail. A participant may make spending choices a worker wouldn't make. Your policy should say how workers can raise a genuine concern about a participant's safety or wellbeing without overriding their choices.

Financial advice

Under the third indicator, participants aren't given financial advice or information beyond what would reasonably be required under their plan. Make clear in your policy where that boundary sits for your workers, and what they should do if a participant asks for advice they can't give (for example, referring them to an appropriate service).

Gifts and conflicts of interest

The NDIS Commission's Code of Conduct guidance for providers (April 2024) says providers should have internal policies and guidance for declaring and avoiding conflicts of interest, and for accepting and giving gifts. The worker guidance says workers may give or accept gifts of minor value, such as a card or a box of chocolates, but should follow their provider's policy on gifts.

Your money and property policy is a sensible place to set out your gift rules, or to cross-reference a separate gifts and conflict of interest policy. The Governance and operational management standard also requires perceived and actual conflicts of interest to be proactively managed and documented, including through organisational policies.

Preventing and responding to financial exploitation

The Code of Conduct requires providers and workers to take all reasonable steps to prevent and respond to all forms of violence against, and exploitation, neglect and abuse of, people with disability. The Violence, abuse, neglect, exploitation and discrimination (VANED) standard requires policies, procedures and practices that actively prevent exploitation.

Your money and property processes help prevent financial exploitation, so make sure this policy lines up with your VANED policy. Describe what workers should do if they suspect a participant's money or property is being misused, by anyone, and handle it through your incident management system. Check whether the matter also needs to be notified as a reportable incident.