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SIL

NDIS Audit Evidence Requirements for the New SIL Standards

by Penny Halpin |

The NDIS Commission has published the SIL Practice Standards that registered SIL providers are now required to be audited against. There are four outcomes included: Supported Decision-Making, Safeguarding, Practice Governance, and Agreements about tenancy, housing and support arrangements.

In your audit, the evidence generally comes from four places: your documents, your records, what an auditor observes in the service delivery environment, and what your workers and participants say when asked. Policies and procedures set your foundation, but there needs to be additional evidence that this actually reflects how you operate in practice.

The tables below set out, for each outcome and indicator, examples of the kind of evidence that may help demonstrate it, and where that evidence could come from from.

Note: This list is not exhaustive! But may help you to get started as we grow nearer to launch of the new standards.

Supported Decision-Making

Participants making their own decisions about their home and daily life, with the information and support to do so.

IndicatorExamples of evidenceEvidence type
1. Accessible information to express will and preferences• A communication profile for each participant
• Records that information was provided in their preferred format (Easy Read, visual, interpreter)
• The approach recorded where every worker can find itRecord, Document, Interview
2. Dignity of risk and informed choice• Records showing the options and the participant’s choice
• Participants reporting that they are freely able to make their own choices, even if there are risksRecord, Interview
3. Informed decisions about mainstream services• Records of support to access or decide on mainstream services
• Liaison or referral recordsRecord, Interview
4. Policies and procedures for how workers support decisions (a-f)• A procedure outlining worker obligations regarding supported decision making
• Participant records of their preferred support approach
• Cultural considerations recorded
• Records where a nominee is involved and the participant kept centralDocument, Record, Interview
5. Workers trained, with refresher training• Training records
• Content showing that the training covers developing the participant’s ability and understanding impact
• Workers able to describe the approachDocument, Record, Interview

Safeguarding

Keeping participants safe from harm while preserving their choice and dignity of risk, including the risks that arise between people who share a home.

IndicatorExamples of evidenceEvidence type
1. Workers meet the Code of Conduct in the home• Worker code of conduct or agreement
• Induction and supervision records
• Respectful support seen in the home and described by participantsDocument, Record, Observed, Interview
2. Balancing dignity of risk with safety, consistently• Safeguarding policy
• Shift notes or risk assessments recording participant choices
• Records that participants were consulted
• Handover records showing a consistent approachDocument, Record, Interview
3. Workers can identify, assess and respond to harm• Training records in de-escalation, trauma-informed practice and positive behaviour support
• Incident records showing that incidents are responded to in a timely manner
• Workers can describe how they would respondDocument, Record, Interview
4. Strengthening formal and informal safeguards• Rostering that supports consistent relationships
• Records of supporting family and community contact
• Participant accountsRecord, Interview, Observed
5. Understanding the impact of risky decisions• Records of conversations about potential consequences
• Informed-decision recordsRecord, Interview
6. Worker responsibilities and collaboration set out• Safeguarding procedure defining responsibilities
• Role descriptions
• Records of collaboration or case conferences with consentDocument, Record
7. Safety between participants in shared living• A shared-living safety plan
• Individual safety plans
• Records of responding to conflict or harm between participants
• Participant consultation recordsRecord, Document, Interview
8. Safeguarding reviewed and improved• Supervision and training updates
• Governance minutes showing safeguarding was reviewedRecord, Interview

Practice Governance

Whether your workers are trained, competent and supported to deliver good practice, and whether participants have a real say in their home, including who they live with.

IndicatorExamples of evidenceEvidence type
1. A system for worker development and training• A training plan and needs analysis
• Supervision and mentoring records
• Cultural safety and positive behaviour support training recordsDocument, Record
2. A trauma-informed home environment• Workers describe trauma-informed practice
• The home environment as observed
• Participant accountsObserved, Interview
3. Workers assessed as competent, not just trained• Competency assessments or observation sign-offs
• Training records
• Supervision notesDocument, Record, Observed
4. Documented vision, values and approach• A documented vision and values
• Service delivery procedures
• Evidence the values are reflected in practice and reviewedDocument, Record
5. Participant choice about the home and co-tenants• Co-tenant compatibility or matching assessments
• Consultation records before placing a new tenant
• House meeting recordsRecord, Interview
6. Governance oversight of emergency planning• Emergency plans tailored to each participant
• Drill and rehearsal records
• Governance review of emergency planningDocument, Record

Tenancy, Housing and Support Arrangements

Keeping a participant’s home secure and separate from their support, so that a support issue can never cost them their housing.

IndicatorExamples of evidenceEvidence type
1. Separate service and tenancy agreements• The separate service agreement and tenancy agreement
• Sign-up records (where you provide both)Document, Record
2. Participant understands the distinction service delivery and tenancy• An Easy Read explainer
• Records that the distinction was explained
• The participant can describe that one is not contingent on the otherDocument, Record, Interview
3. Conflict of interest identified and managed• A conflict-of-interest policy specific to housing and support
• A conflicts register
• An accessible version for participantsDocument, Record
4. Concerns raised without fear of retribution• A complaints process
• An explicit assurance that housing is not affected
• Advocacy or legal referral recordsDocument, Record, Interview
5. Participant supported in their tenancy (a-i)• Accessible tenancy information
• Records that the right to change provider was explained
• The participant has keys and controls their private space
• Where limits apply, a behaviour support plan and least-restrictive authorisation
• A signed copy of the agreement on file
• Building and tenancy law compliance recordsDocument, Record, Observed, Interview
6. Service agreement sets out the required matters (a-f)• A service agreement covering concerns, co-tenant conflict, changes, vacancies, behaviours that risk a tenancy, and visitors
• Records showing those terms are applied, such as vacancy consultationDocument, Record

If you’re just getting started on developing policies and procedures for SIL, a good tip is to start from how you actually operate – document your day-to-day, do a gap analysis against the standards, and adjust your current practice and documentation to fill any gaps.

The new standards will be a big change for a lot of providers, but overall good for the sector and, hopefully (and most importantly), for the people being supported.

About the author

Penny Halpin

Penny is an NDIS Lead Auditor who has worked in certification since the first audits in 2018, and was previously a Senior Manager at an Approved Quality Auditor with technical review across thousands of audit reports. She built the Paperbark tools to help providers create documentation that reflects how they actually work.

More about Penny →