Complete all 10 modules and the knowledge checks. Sign and generate your completion record at the end of Module 10.

KS1 - NDIS Framework & OCC Overview

Key Stakeholders Training  |  Module 1 of 14  |  NDIS Act 2013 - Provider Governance & Registration

📚 Training Framework Reference

Mandatory Training Framework & Staff Induction Index

Location: 05_Compliance_Quality / Training / Mandatory_Training_Framework.docx and Staff_Induction_Index.docx

These documents set out OCC's full training schedule, mandatory completion timeframes, and record-keeping requirements for all staff. As a key stakeholder, you are responsible for ensuring this framework is implemented across the organisation. Review both documents alongside this training pathway.

Open Care Connect (trading as Open Care Community Services Pty Ltd) is a registered NDIS provider located at 32 Ranfurlie Circuit, Melton West VIC 3337. Our ABN is 22 668 873 694 and our NDIS Provider ID is 4-JU2I9UJ. Our website is https://opencareconnect.com.au/. As a key stakeholder, you carry collective responsibility for everything we do - from the quality of a single support session to our standing with the NDIS Quality and Safeguards Commission.

Leadership at OCC means making decisions that consistently align with our vision: to provide quality and inclusive services that empower individuals with disabilities to thrive. Our mission is to passionately deliver comprehensive and accessible services tailored to the unique needs of individuals with disabilities - through collaboration, advocacy, and innovative support.

Governance is not just policies and paperwork. It is how we demonstrate, to participants, families, the Commission, and the broader community, that we are worthy of their trust.

Our Values

The following six values are taken directly from OCC's Participant Handbook (V1.1, approved 01 March 2026). They are not aspirational statements - they are behavioural commitments that every team member is expected to demonstrate.

Value What It Means in Practice
Putting People First with Respect We prioritise and tailor our services, respecting and valuing the unique needs of individuals with disabilities. You are at the centre of everything we do.
Empowerment and Growth through Empathy We are dedicated to fostering independence, inclusion, and empowerment, listening empathetically to the needs of everyone we support.
Celebrating Diversity We embrace and honour the diverse backgrounds and contributions of all individuals. We deliver culturally safe and inclusive services.
Dedicated Assistance and Listening We actively listen and support individuals with disabilities, helping them achieve their aspirations and goals. We hear you before we act.
Team Collaboration for Excellence Through collaborative efforts across our team, we ensure high-quality and accessible services for every participant.
Accountability and Responsibility We hold ourselves accountable for our actions and decisions, ensuring transparency and trustworthiness in all we do.

Our Organisational Structure

OCC operates under a defined management structure documented in GOV-ORG-001. Five core management roles ensure clear accountability and appropriate segregation of duties.

Role Primary Accountability Reports To
Director Ultimate accountability for NDIS compliance, financial management, quality delivery, regulatory adherence, worker screening sign-off, induction authorisation, incident oversight, and board reporting NDIS Quality and Safeguards Commission
Client Services Manager Participant onboarding, support plan development, service quality in the field, face-to-face assessments, family communication, participant satisfaction Director
Quality and Compliance Manager Audit scheduling and execution, document control, compliance calendar management, policy maintenance, training coordination, CI Register management Director
Operations Manager Rostering, shift management, worker supervision, participant file management, WHS coordination, transport and vehicle oversight Director
HR/Finance Manager Recruitment, worker screening coordination, payroll (fortnightly), leave management, superannuation obligations, performance management, SCHADS Award administration Director

The current core team: Kubir Khanal (OCCS001, Director), Kamal Dhimal (OCCS002), Devi Phuyel (OCCS003), Manoj Khadka (OCCS004), Sumnima Baral (OCCS005). Support worker Kul Chandra Adhikari (OCCS006) commenced on 06 March 2026.

Segregation of Duties

Segregation of duties means no single person controls all aspects of a critical function. The person who recruits a worker should not be the same person who approves their worker screening clearance. The person who schedules an audit should not manage the team being audited. This protects participants, protects the organisation, and protects individual staff from unfair accusations.

In practice: A governance decision

The Operations Manager discovers a support worker has been using a participant's personal phone to complete progress notes - a data security risk. The correct response: notify the Quality and Compliance Manager to assess the policy breach; consult the HR/Finance Manager about whether this is a conduct matter; brief the Director given the compliance implications; implement a corrective action; document the decision and rationale in the CI Register. No single person resolves this alone.

Director Sign-Off Authority

The Director holds sole sign-off authority over three critical areas: (1) authorising new staff to work with participants after completing induction; (2) approving all participant service agreements before services commence; (3) signing off on significant incidents reported to the NDIS Commission. These are legal requirements under our registration conditions - not preferences.

As a key stakeholder, governance means:

  • You understand your specific portfolio and escalate decisions outside it to the Director
  • You escalate anything affecting participant safety, quality, or compliance before acting
  • You document your decisions, rationale, and actions
  • You hold OCC's six values as daily behavioural standards - not just statements
  • You understand that our governance structure exists to protect participants, not to create bureaucracy

Knowledge Check

Who holds ultimate accountability to the NDIS Commission?

The Director. Each manager is accountable for their portfolio and reports to the Director. All decisions affecting participant safety, quality, or compliance are escalated to the Director before action is taken.

What does OCC's vision statement say?

OCC's vision, as stated in the Participant Handbook V1.1 (March 2026), is: 'to provide quality and inclusive services that empower individuals with disabilities to thrive.'

KS2 - NDIS Practice Standards

Key Stakeholders Training  |  Module 2 of 14  |  NDIS Practice Standards - Registration Groups

Our NDIS registration is a continuous, legally binding commitment to meet the standards set by the NDIS Quality and Safeguards Commission. If we fail to meet these standards, the Commission can impose conditions, suspend, or cancel our registration - meaning we could no longer provide services to NDIS participants.

OCC is registered under the National Disability Insurance Scheme Act 2013 (Cth). Registration is governed by the National Disability Insurance Scheme (Provider Registration and Practice Standards) Rules 2018 (Cth).

🔗 Authorised Source

NDIS Practice Standards

Source: ndiscommission.gov.au/rules-and-standards/ndis-practice-standards

The NDIS Practice Standards and Quality Indicators document (Version 4, November 2021) sets out every outcome and quality indicator registered providers are assessed against.

Our Eight Registration Groups

The following registration groups are confirmed from OCC's NDIS Initial Scope of Audit document (02 November 2023). OCC must only deliver supports within these categories.

Code Registration Group (Official Name) What It Covers
0102 Assist Access/Maintain Employ Employment-related support - helping participants find, maintain, and succeed in employment. This includes job skills development, workplace modifications, and employment coaching.
0104 Assist Personal Activities High High intensity daily personal activities - complex personal care tasks that require specialised training, such as management of medication, complex bowel care, enteral feeding, and wound care. Only workers with HIDPA-specific training may deliver these supports.
0106 Assist-Life Stage, Transition Support during major life transitions - leaving school, entering employment, moving from home, or other significant changes in a participant's life circumstances.
0107 Assist-Personal Activities Standard daily personal activities - personal hygiene and care, meal preparation, domestic assistance, and other routine daily living supports.
0108 Assist-Travel/Transport Assistance with travel and transport - supporting participants to travel independently, use public transport, and access the community safely.
0117 Development-Life Skills Development of daily living and life skills - building participants' capacity for independent living including cooking, budgeting, managing a home, and using community services.
0120 Household Tasks Household tasks - cleaning, laundry, gardening, home maintenance where these tasks support the participant's independence or are necessary for safe and healthy living.
0125 Participate Community Community participation - supporting participants to engage in social, recreational, and community activities, build relationships, and participate in their community.
⚠ Critical rule

You may only arrange or approve supports within OCC's registered groups. Registration group 0104 (High Intensity Personal Activities) requires workers to hold specific HIDPA training before delivering those supports. The Director must confirm a worker's qualifications before they are rostered for 0104 supports.

The NDIS Practice Standards - Core Module

The Core Module applies to all registered providers delivering higher-risk supports. It contains four standards, each with quality indicators that approved auditors assess. As a key stakeholder, you are responsible for demonstrating OCC's compliance with each standard.

Standard What It Requires OCC Responsibility
1. Rights and Responsibilities Participants understand their rights and the provider's responsibilities. Informed consent is obtained. Decision-making support is provided. The complaints process is explained. Director, Client Services Manager - service agreements, rights charter, complaints process
2. Governance and Operational Management The provider has sound governance, qualified staff, documented systems, financial management, and risk management frameworks. Director, Quality and Compliance Manager - GOV-QMF-001, risk register, governance framework
3. The Provision of Supports Supports are planned, delivered, and reviewed in partnership with the participant, reflecting their goals, needs, and preferences. Client Services Manager, Operations Manager - support plans, progress notes, plan reviews
4. Support Provision Environment The environment in which supports are provided is safe, accessible, and appropriate for the delivery of the support. Operations Manager - WHS, vehicle checks, risk assessments in participant homes

In addition to the four core standards, OCC's registration requires compliance with Core Module Standard 4.3 (Management of Medication) and Core Module Standard 4.5 (Management of Waste), due to providing high intensity personal activities (registration group 0104).

High Intensity Daily Personal Activities (HIDPA)

Because OCC is registered for group 0104 (Assist Personal Activities High), workers delivering these supports must hold specific competencies for each high intensity task. These include complex bowel care, enteral feeding, tracheostomy management, subcutaneous injections, and wound management. The HR/Finance Manager and Director must ensure only appropriately trained workers are rostered for 0104 supports. OCC's HIDPA Module policies are held in the Policies and Procedures folder.

Certification Audits

The NDIS Commission requires registered providers to undergo certification audits by an approved quality auditor. For OCC, this means an initial registration audit and recertification every three years, plus surveillance audits between certification cycles. The Quality and Compliance Manager coordinates audit readiness. All key stakeholders must participate fully and provide honest, transparent responses to auditors.

Knowledge Check

How many registration groups does OCC hold, and which one requires specific HIDPA training?

OCC holds eight registration groups, confirmed in the NDIS Initial Scope of Audit (02/11/2023): 0102, 0104, 0106, 0107, 0108, 0117, 0120, and 0125. Registration group 0104 (Assist Personal Activities High) requires workers to hold HIDPA-specific training and competency for each high intensity support task before delivering those supports.

The NDIS Practice Standards Core Module has how many standards?

Four. Standard 1 (Rights and Responsibilities), Standard 2 (Governance and Operational Management), Standard 3 (The Provision of Supports), and Standard 4 (Support Provision Environment). These are set out in the NDIS Practice Standards and Quality Indicators document (Version 4, November 2021). OCC also has additional obligations under Core Module Standards 4.3 (Medication) and 4.5 (Waste).

KS3 - Quality Management Framework

Key Stakeholders Training  |  Module 3 of 14  |  NDIS Quality Framework - Continuous Improvement

Quality management at OCC is not a compliance exercise. It is how we ensure that every participant receives the standard of support they deserve, every time. Our Quality Management Framework (GOV-QMF-001) sets out the systems, processes, and accountabilities that keep us operating to the standard required by the NDIS Commission and expected by our participants.

The QMF is built on a continuous improvement model. This means that quality is not a destination - it is a process of ongoing monitoring, reviewing, identifying gaps, and improving. Every core team member has a role in this cycle.

The Continuous Improvement Cycle

OCC's quality management follows a Plan-Do-Check-Act (PDCA) cycle: we plan what quality looks like, we implement those plans, we monitor and audit to check whether we're meeting our standards, and then we act on what we find to improve. The CI Register (Continuous Improvement Register) is the central tool for capturing and tracking improvement actions across all areas of the business.

Stage What Happens Who Is Responsible
Plan Set quality objectives, develop policies and procedures, create audit schedule Quality and Compliance Manager, Director
Do Implement policies, deliver training, execute support plans, follow documented procedures All staff, Operations Manager
Check Conduct internal audits, collect participant feedback, review incident data, monitor compliance calendar Quality and Compliance Manager, all managers
Act Address findings, update policies, implement corrective actions, update CI Register Quality and Compliance Manager, Director sign-off on significant actions

Document Control

Every policy, procedure, form, and register at OCC follows our document control protocol. This ensures staff are always working from the current version of a document, and that outdated versions cannot cause errors or compliance failures.

The OCC document naming convention is: OCC_[DocumentName]_V[X.X].docx - for example, OCC_StaffHandbook_V1.1.docx. Version numbers use whole numbers for major revisions (V2.0) and decimals for minor updates (V1.1). Documents are reviewed annually or when legislation changes. Superseded documents are archived with a clear date stamp and must not be used for active processes.

Document Code Document Name Review Cycle
GOV-ORG-001 Organisation Chart Annual or upon structural change
GOV-QMF-001 Quality Management Framework Annual
GOV-BPL-001 Business Plan Annual
CM-QAS-001 Quality Audit Schedule Annual
HR-TMI-001 Mandatory Training Index Annual or upon regulation change
INC-IRF-001 Incident Report Form Annual or upon Commission requirement change
CMP-PFS-001 Participant Feedback Survey Annual

Monitoring and Performance Indicators

The Quality and Compliance Manager monitors a set of key performance indicators across the year. These include: percentage of incidents reported within required timeframes; percentage of complaints resolved within 28 days; percentage of staff with current mandatory training; and participant satisfaction scores from the bi-annual feedback survey (CMP-PFS-001). These indicators are reported to the Director quarterly and form part of our evidence base at audit.

Quality improvement in practice

Following a review of incident data for the first quarter of 2026, the Quality and Compliance Manager identifies that three of five incident reports were completed more than 24 hours after the event. This is a compliance gap. The CI Register is updated with an action: refresher training for all support workers on incident reporting timelines within four weeks. The HR/Finance Manager coordinates the training. The Quality and Compliance Manager monitors completion and reviews the next quarter's data for improvement.

Knowledge Check

What is the CI Register used for?

The CI Register (Continuous Improvement Register) is used to capture all improvement actions identified through audits, incident reviews, complaint analysis, participant feedback, and staff feedback. It records the issue, the action required, the person responsible, the due date, and the completion date. It is the central evidence document for our continuous improvement process and is reviewed at each audit.

What does the document naming convention OCC_[DocumentName]_V[X.X].docx mean?

OCC identifies the organisation; DocumentName is a short descriptive name; V[X.X] indicates the version number where whole numbers (V1.0, V2.0) indicate major revisions and decimals (V1.1, V1.2) indicate minor updates. Using consistent naming means staff and auditors can always identify the current version of any document.

KS4 - Compliance Calendar

Key Stakeholders Training  |  Module 4 of 14  |  NDIS Commission - Reporting & Compliance Obligations

Compliance at OCC is not something we do at audit time. It is built into how we operate every day, every week, every month. Our Compliance Calendar 2026 contains 20 scheduled compliance activities across the year, assigned to specific role owners with defined frequencies. As a key stakeholder, you are responsible for executing and evidencing the activities in your portfolio.

The compliance calendar is maintained by the Quality and Compliance Manager and reviewed at the start of each quarter. If an activity cannot be completed on time, the responsible manager must notify the Director and document the delay and its reason in the CI Register.

Compliance Activity Categories

Frequency Examples Owner
Monthly Progress note audits (random sample), incident register review, mandatory training currency check, complaints register review Quality and Compliance Manager
Quarterly Internal audit (rotating focus areas), board/director report, participant satisfaction review, WHS inspection Quality and Compliance Manager, Director
Bi-Annual Participant satisfaction survey (CMP-PFS-001), full policy review cycle, staff file audit, full mandatory training report Quality and Compliance Manager, HR/Finance Manager
Annual Full internal audit, external certification audit (when due), business plan review, SCHADS Award compliance check, document register review Quality and Compliance Manager, Director

How Compliance Is Evidenced

Evidence of compliance is what protects OCC at audit. For every scheduled compliance activity, there must be a dated record: an audit report, a completed checklist, meeting minutes, a training completion record, or a survey result. The Quality and Compliance Manager maintains a compliance evidence folder that is made available to auditors on request. Do not rely on memory - document everything.

Compliance in practice

In March 2026, the Quality and Compliance Manager conducts the Q1 internal audit with a focus on documentation practices (progress notes and incident reports). They review a random sample of 10 progress notes from the previous month. Three are found to be incomplete - missing the participant's goal reference and the worker's signature. This is documented in the audit report, an action is added to the CI Register, and refresher coaching is provided to the workers involved within two weeks. The Q2 audit will include a follow-up check on documentation quality to confirm improvement.

NDIS Commission Reporting Obligations

Compliance is not just internal. Certain events must be reported to the NDIS Commission within specific timeframes. These are non-negotiable legal obligations:

Event Reporting Timeframe Who Reports
Reportable incidents - death, serious injury, abuse or neglect, unlawful sexual or physical contact, sexual misconduct Within 24 hours of becoming aware Director or Quality and Compliance Manager via NDIS Commission portal
Reportable incidents - unauthorised use of a restrictive practice (without harm) Within 5 business days of becoming aware (24 hours if harm occurred) Director or Quality and Compliance Manager via NDIS Commission portal
Change in key personnel Within 30 days Director
Change to scope of registration Before change occurs Director
Provider ceasing operations As soon as practicable Director
Significant changes to financial position Within 30 days Director

🔗 Authorised Source

NDIS Commission Reportable Incidents

Source: ndiscommission.gov.au/providers/registered-providers/incident-management-and-reportable-incidents

All registered providers must have an incident management system and report certain incidents to the Commission.

Knowledge Check

What must happen if a scheduled compliance activity cannot be completed on time?

The responsible manager must notify the Director immediately and document the delay and its reason in the CI Register. A revised completion date must be agreed and monitored. Recurring delays in compliance activities would be a red flag at audit.

What is the timeframe for reporting a reportable incident to the NDIS Commission?

Within 24 hours of the registered provider becoming aware of the incident. This includes death of a participant, serious injury, abuse, neglect, sexual misconduct, or unlawful use of restrictive practices. The Director or Quality and Compliance Manager submits the report through the NDIS Commission online portal.

KS5 - Quality Auditing

Key Stakeholders Training  |  Module 5 of 14  |  NDIS Practice Standards - Certification Audits

Auditing is how OCC tests whether our systems and practices are actually working - not just whether our policies say the right things. The Quality Audit Schedule (CM-QAS-001, V1.2) sets out eight specific audit types conducted throughout the year. As a key stakeholder, you will either conduct audits, participate in them, or be accountable for audit findings in your area.

Internal audits are conducted by OCC personnel. External certification audits are conducted by an approved quality auditor appointed by the NDIS Commission. Both types produce findings that must be addressed and evidenced.

The Eight Audit Types

Audit Type Focus Frequency Lead
Documentation Audit Progress notes, incident reports, support plans - completeness, accuracy, timeliness Quarterly Quality and Compliance Manager
Staff File Audit Worker screening, mandatory training currency, employment documentation, induction completion Bi-Annual HR/Finance Manager
Participant File Audit Service agreements, support plans, consent forms, communication logs, plan review currency Bi-Annual Client Services Manager
Financial Compliance Audit NDIS price guide adherence, invoice accuracy, SCHADS Award payroll compliance Annual Director, HR/Finance Manager
WHS Compliance Audit Hazard registers, incident records, vehicle checks, manual handling records, PPE availability Annual Operations Manager
Incident Management Audit Incident report quality, reporting timeframes, Commission notification compliance, corrective action completion Quarterly Quality and Compliance Manager
Complaints Management Audit Complaints register completeness, resolution timeframes, participant satisfaction follow-up Bi-Annual Quality and Compliance Manager
Policy and Procedure Review Currency and accuracy of all policies against current legislation and Commission requirements Annual Quality and Compliance Manager, Director

The Audit Process at OCC

Every audit follows a consistent three-stage process. In the planning stage, the Quality and Compliance Manager confirms the scope and dates with the relevant manager, prepares audit tools (checklists, sample selection criteria), and notifies any staff who will be involved. In the fieldwork stage, the auditor reviews documents, observes practices where relevant, and interviews staff. In the reporting stage, the auditor prepares an audit report with findings, ratings, and recommended actions. The Director reviews and approves all audit reports before they are filed.

An audit finding and response

The Q2 2026 Documentation Audit finds that six of 15 progress notes reviewed were completed more than 24 hours after the support session - a breach of our documentation policy. The audit report rates this as a 'moderate' finding. The Quality and Compliance Manager adds an action to the CI Register: all support workers to complete a documentation refresher session within three weeks, and the Operations Manager to conduct a spot-check of progress notes for the following four weeks. At the Q3 audit, the auditor will verify that the action has been completed and effectiveness assessed.

Preparing for an External Certification Audit

When the NDIS Commission schedules an external certification audit, the Quality and Compliance Manager leads OCC's preparation. This includes conducting a full self-assessment against each Practice Standard, compiling a document register and evidence portfolio, briefing all staff on the audit process and their roles, and ensuring the CI Register shows that previous audit findings have been actioned. The Director is the primary point of contact with the external auditor. All key stakeholders are expected to participate honestly and constructively in the external audit process.

⚠ Important

It is a serious breach of our obligations to withhold documents from, or provide misleading information to, an external auditor. All staff are required to be cooperative, honest, and transparent during any audit - internal or external.

Knowledge Check

How many audit types are in OCC's Quality Audit Schedule (CM-QAS-001)?

Eight audit types: Documentation Audit, Staff File Audit, Participant File Audit, Financial Compliance Audit, WHS Compliance Audit, Incident Management Audit, Complaints Management Audit, and Policy and Procedure Review. They occur at different frequencies - quarterly, bi-annual, and annual - as set out in CM-QAS-001 V1.2.

What happens after an audit identifies a finding?

The finding is documented in the audit report with a rating (minor, moderate, or significant) and a recommended action. The action is added to the CI Register with a responsible person and due date. The Director reviews and approves the report. The responsible manager implements the action within the agreed timeframe. The next relevant audit verifies completion and assesses effectiveness.

KS6 - Human Resources & Worker Screening

Key Stakeholders Training  |  Module 6 of 14  |  NDIS Worker Screening Act 2020 & SCHADS Award

Every person we recruit, screen, and employ represents OCC to the people we support. Getting human resources right - particularly worker screening and induction - is one of the most significant compliance obligations we carry as a registered NDIS provider. The HR/Finance Manager holds primary responsibility for this area, but the Director has final sign-off authority.

Worker Screening - The Legal Requirement

Under the National Disability Insurance Scheme (Worker Screening) Act 2020 (Cth), all workers in Risk Assessed Roles (RAR) at a registered NDIS provider must hold a current NDIS Worker Screening Check before they can work with NDIS participants unsupervised. This is not a discretionary policy - it is a legal requirement.

🔗 Authorised Source

NDIS Worker Screening

Source: ndiscommission.gov.au/providers/worker-screening

The NDIS Worker Screening Check applies to all workers in Risk Assessed Roles at registered providers.

Risk Assessed Roles (RAR)

The NDIS (Worker Screening) Act 2020 defines Risk Assessed Roles in three categories. All OCC support workers fall into at least one of these categories.

Category Who It Covers OCC Examples
Category (a) Workers who deliver NDIS supports directly to a participant All support workers, including Kul Chandra Adhikari (OCCS006)
Category (b) Key personnel - those who make decisions affecting participants' lives, or are responsible for operational management Director, all managers (OCCS001-OCCS005)
Category (c) Workers who have more than incidental contact with participants in the course of their duties Admin staff, transport drivers, anyone regularly in participant environments

A person in a Risk Assessed Role cannot commence working with NDIS participants until their screening check application has been submitted and they have received either a clearance or an approval to commence work pending clearance. The screening authority in Victoria (Victorian Department of Justice and Community Safety) makes the RAR determination within 20 working days of a complete application. The check is valid for five years.

The Five-Stage Induction

OCC uses a structured five-stage induction process (HR-TMI-001) for all new staff before they are authorised to work with participants independently.

Stage Timing Key Activities
Stage 1: Pre-Commencement Before first day Signed employment contract, Worker Screening Check application submitted, 100 points of ID verified, mandatory training commenced, right to work confirmed
Stage 2: Day 1 First day Workplace tour, introduction to team, access to systems, OCC values and culture briefing, Code of Conduct sign-off, photo ID issued
Stage 3: Week 1 Days 2-5 OCC policies and procedures overview, participant file system training, incident reporting process, supervision meeting with manager
Stage 4: Weeks 2-4 First four weeks Supervised practice with participants (where applicable), mandatory online training completion (NDIS Worker Orientation Module, infection control), first formal supervision session
Stage 5: Sign-Off End of induction period (approx. 4 weeks) Director reviews induction checklist and confirms all requirements met; Director signs off authorising the worker to deliver supports independently
⚠ Director sign-off is mandatory

No support worker may deliver supports independently until the Director has reviewed the completed induction checklist and provided written sign-off. This is a non-negotiable requirement under our NDIS registration conditions. If the Director sign-off has not been completed, the worker must only operate under direct supervision.

Employment Conditions - SCHADS Award

OCC support workers are employed under the Social, Community, Home Care and Disability Services Industry Award 2010 (SCHADS Award, MA000100), the modern award that governs employment conditions in the disability sector. As a key stakeholder, you must understand the key provisions of this award to ensure OCC meets its legal obligations as an employer.

🔗 Authorised Source

SCHADS Award - Social, Community, Home Care and Disability Services Industry Award 2010 (MA000100)

Source: fairwork.gov.au/employment-conditions/awards/awards-list

The SCHADS Award sets minimum pay rates, penalty rates, allowances, and leave entitlements for support workers.

Key Provision Details
Pay cycle Fortnightly (every two weeks)
Superannuation 11.5% employer contribution as at 2026 (legislated rate)
Probation period 3 months for all new employees
Overtime Applicable when hours exceed the maximum ordinary hours defined in the award
Penalty rates Applies for work on weekends, public holidays, and outside ordinary hours
Shift allowances Applicable for certain shift types - refer to the current SCHADS Award schedule
Annual leave 4 weeks per annum pro-rata (full-time equivalent)

Staff File Requirements

Every staff member must have a complete file maintained by the HR/Finance Manager. This file must contain: signed employment contract; current Worker Screening Check status (clearance or approval); copy of 100 points of ID; evidence of all mandatory training completions (dates and certificates); signed copy of the OCC Code of Conduct; completed induction checklist with Director sign-off; and current professional registration certificates (where applicable). Staff files are audited bi-annually.

Knowledge Check

What is the NDIS Worker Screening Check and how long is it valid?

The NDIS Worker Screening Check is a background check required under the NDIS (Worker Screening) Act 2020 for all workers in Risk Assessed Roles at registered NDIS providers. It assesses whether a person poses an unacceptable risk to people with disability. The check is conducted by the state or territory screening authority (in Victoria, the Department of Justice and Community Safety) and is valid for five years from the date of clearance.

Who must sign off on a new worker's induction before they can work with participants independently?

The Director must review the completed induction checklist and provide written sign-off authorising the worker to deliver supports independently. This applies to all new workers regardless of their prior experience in the disability sector. Until the Director's sign-off is in place, the worker may only operate under direct supervision.

KS7 - Participant Onboarding

Key Stakeholders Training  |  Module 7 of 14  |  NDIS Practice Standards - Rights and Responsibilities

Every participant who chooses OCC is placing an enormous amount of trust in us. The participant onboarding process is where we either earn that trust or lose it. Getting it right means the participant understands their rights, feels heard, has a genuine support plan that reflects their goals, and knows exactly how to access help if something goes wrong.

The participant onboarding process is led by the Client Services Manager and requires Director sign-off on the service agreement before any services commence.

The Participant Onboarding Process

Step Activity Who Documentation
1 Initial enquiry received - captured in the enquiry register Client Services Manager Enquiry log
2 Eligibility confirmed - participant must be an NDIS participant with relevant funding in their plan Client Services Manager NDIS plan extract or myplace portal confirmation
3 Face-to-face or phone assessment to understand participant goals, preferences, support needs, and risk factors Client Services Manager Assessment form
4 Service agreement drafted, reviewed with participant and (if applicable) their nominated representative Client Services Manager OCC Service Agreement
5 Director reviews and signs off on service agreement before it is signed by participant Director Signed service agreement on file
6 Support plan developed with the participant, reflecting their NDIS goals and the support types funded Client Services Manager Participant support plan
7 Rostering - participant matched with suitable, screened, trained support worker Operations Manager Roster system
8 Participant rights and responsibilities explained, complaints process provided, emergency contacts confirmed Client Services Manager, support worker at first visit Participant handbook provided

Person-Centred Planning

OCC's support planning approach is built on the principle that the participant is the expert on their own life. The support plan is not a document we write about someone - it is a document we write with them. It must reflect their stated goals (using their own words where possible), their preferred routines and communication style, their risk factors and how to manage them, and their preferred support workers where this preference has been expressed.

Support plans are reviewed at least every 12 months, or whenever there is a significant change in the participant's circumstances, NDIS plan, or goals. The Client Services Manager is responsible for scheduling and leading plan reviews.

🔗 Authorised Source

Person-Centred Approaches to Support Planning

Source: ndiscommission.gov.au/providers/providing-services-and-supports/person-centred-approaches

The NDIS Commission expects providers to use a person-centred approach in all aspects of service delivery.

Participant Rights and Complaints

Every OCC participant is given a copy of the Participant Handbook at onboarding. The handbook contains their rights charter, our service delivery commitments, and information about how to make a complaint. Under our complaints management policy:

Step Timeframe Responsible
Acknowledge complaint receipt Within 2 business days Client Services Manager or Director
Investigate and resolve Within 28 days of receipt Client Services Manager, escalated to Director for significant complaints
Follow up with complainant Within 5 days of resolution Client Services Manager
Record in complaints register Immediately upon receipt Quality and Compliance Manager

Participants may also raise complaints directly with the NDIS Commission. We must never discourage a participant from doing so, and we must cooperate fully with any Commission-led investigation.

Participant Satisfaction Surveys

OCC conducts participant satisfaction surveys twice a year using the standard survey tool (CMP-PFS-001). Survey results are analysed by the Quality and Compliance Manager and reported to the Director. Any area where satisfaction scores fall below the target threshold triggers a quality improvement action in the CI Register. The survey is voluntary and anonymous - participants are encouraged but never pressured to participate.

Knowledge Check

What must happen before a service agreement is signed with a participant?

The Director must review and sign off on the service agreement before it is presented to the participant for signature. This ensures the agreement accurately reflects our registration conditions, complies with NDIS Price Guide requirements, and appropriately sets out both parties' rights and obligations. No services may commence before a signed agreement is in place.

How often are support plans reviewed?

At least every 12 months, and any time there is a significant change in the participant's NDIS plan, personal circumstances, goals, or risk profile. Reviews are led by the Client Services Manager and conducted with the participant (and their support person or representative if applicable).

KS8 - Incident Management & Risk

Key Stakeholders Training  |  Module 8 of 14  |  NDIS Incident Management Framework

Incident management is one of our most important compliance obligations and one of the clearest measures of our commitment to participant safety. An incident that is managed well - reported promptly, investigated thoroughly, and used to drive improvement - is evidence of a well-functioning provider. An incident that is hidden, minimised, or poorly managed is a serious compliance failure and a risk to participants.

OCC classifies incidents into three categories. The category determines the reporting pathway and timeframe.

Incident Categories

Category Definition Examples Reporting
Minor Low-level events with limited impact on participant wellbeing, no injury, no ongoing risk Participant refuses support, minor misunderstanding, late service delivery, small property damage Documented internally within 24 hours; reviewed monthly
Significant Events causing or likely to cause material impact on participant wellbeing, requiring management review and corrective action Medication error without serious harm, participant distress during support, worker conduct concern, unexplained injury of minor nature Incident form completed within 24 hours; Director review required; CI Register updated
Reportable Events that must be reported to the NDIS Commission under the NDIS (Incident Management and Reportable Incidents) Rules 2018 (Cth) Death of a participant, serious injury, sexual misconduct, physical or psychological abuse, neglect, unauthorised use of restrictive practices Report to NDIS Commission within 24 hours of becoming aware; full incident investigation; Director-led response

🔗 Authorised Source

NDIS Reportable Incidents

Source: ndiscommission.gov.au/providers/registered-providers/incident-management-and-reportable-incidents

Under the NDIS (Incident Management and Reportable Incidents) Rules 2018, registered providers must notify the Commission of reportable incidents.

The Incident Reporting Process

Any staff member who witnesses or becomes aware of an incident must complete an Incident Report Form (INC-IRF-001) within 24 hours of the event. The completed form is submitted to the Operations Manager who classifies it, determines the appropriate response, and escalates to the Director for significant and reportable incidents. The Quality and Compliance Manager maintains the incident register and conducts monthly reviews of all entries.

A reportable incident

A support worker arrives at a participant's home and finds the participant has a bruise on their arm that was not present at the previous support session. The participant is unable to clearly explain how it happened. The support worker immediately contacts their supervisor, completes an incident report form, and does not leave the participant alone. The Operations Manager escalates to the Director immediately. The Director makes a preliminary report to the NDIS Commission within two hours and commences an internal investigation. The participant's GP is contacted that day. A full investigation report is submitted to the Commission within five business days.

Risk Management at OCC

OCC maintains a risk register that is reviewed quarterly by the Quality and Compliance Manager and presented to the Director. The risk register covers strategic, operational, participant safety, financial, and compliance risks. Each risk is rated by likelihood and consequence, assigned to a risk owner, and has documented mitigation strategies. High-rated risks require immediate escalation and a documented management plan.

Risk Rating Action Required
Low Monitor and review quarterly; no immediate action required
Moderate Implement mitigation strategies; review monthly; report to Director
High Immediate Director briefing; documented management plan; review weekly until rating is reduced
Critical Immediate Director and (if participant safety is involved) NDIS Commission notification; suspend related activities if necessary; daily review

Knowledge Check

What is the timeframe for reporting a reportable incident to the NDIS Commission?

Within 24 hours of the registered provider becoming aware of the incident. The Director or Quality and Compliance Manager submits the notification through the NDIS Commission online portal. A full incident investigation report must follow within five business days.

What are the six types of events that are 'reportable incidents' under the NDIS Rules?

Under the NDIS (Incident Management and Reportable Incidents) Rules 2018, the six categories are: (1) death of a participant connected to the delivery of supports; (2) serious injury requiring urgent medical treatment or hospitalisation; (3) abuse or neglect of a person with disability; (4) unlawful sexual or physical contact or assault of a participant; (5) sexual misconduct against or in the presence of a participant (including grooming); and (6) unauthorised use of a restrictive practice. Categories 1-5 must be reported within 24 hours; category 6 within 5 business days unless harm occurred (then 24 hours).

KS9 - Legislative Environment

Key Stakeholders Training  |  Module 9 of 14  |  NDIS Act 2013 & Related Legislation

OCC operates within a complex legislative environment. As a key stakeholder, you do not need to be a lawyer - but you do need to understand which laws apply to what we do, what they require of us, and where to look when you need to go deeper. This module is a reference guide to the key legislation governing OCC's operations.

Primary NDIS Legislation

Legislation What It Does Where to Find It
National Disability Insurance Scheme Act 2013 (Cth) The principal Act establishing the NDIS, the NDIA, and the NDIS Quality and Safeguards Commission. Defines participant eligibility, plan funding, and provider obligations. legislation.gov.au
NDIS (Provider Registration and Practice Standards) Rules 2018 (Cth) Sets out the NDIS Practice Standards (Core Module, HIDPA Module, and others) that registered providers must meet. legislation.gov.au
NDIS Code of Conduct Rules 2018 (Cth) Defines the seven conduct obligations binding on all NDIS workers and providers. legislation.gov.au / ndiscommission.gov.au
NDIS (Incident Management and Reportable Incidents) Rules 2018 (Cth) Defines reportable incident categories and notification obligations. legislation.gov.au
NDIS (Worker Screening) Act 2020 (Cth) Requires all workers in Risk Assessed Roles to hold a current NDIS Worker Screening Check. legislation.gov.au

Privacy and Information Handling

🔗 Authorised Source

Privacy Act 1988 (Cth) - Australian Privacy Principles

Source: oaic.gov.au/privacy/australian-privacy-principles

The 13 Australian Privacy Principles (APPs) govern how organisations collect, store, use, and disclose personal information. OCC is bound by the APPs as a provider handling sensitive health and disability information.

The Privacy Act 1988 (Cth) contains the 13 Australian Privacy Principles (APPs), which govern how we collect, hold, use, and disclose participant and staff personal information. Key obligations for OCC: we only collect personal information that is necessary for our purposes; we must tell participants what information we collect and how it is used; we must store information securely; and we must not disclose personal information about a participant without their consent, except in limited circumstances (such as risk to safety, or legal obligation to disclose).

Health information is classified as 'sensitive information' under the Privacy Act and attracts higher protections. All participant health information must be stored securely, accessible only to authorised staff, and never shared with third parties without explicit consent or legal requirement. File retention: participant files must be retained for a minimum of seven years, and indefinitely for Aboriginal and Torres Strait Islander participants.

Work Health and Safety

🔗 Authorised Source

Work Health and Safety Act 2011 (Cth) and state equivalents

Source: safeworkaustralia.gov.au

OCC has duties under WHS legislation as a person conducting a business or undertaking (PCBU). Victoria applies the Occupational Health and Safety Act 2004 (Vic).

As a PCBU (Person Conducting a Business or Undertaking), OCC must so far as is reasonably practicable ensure the health, safety, and welfare of all workers. This includes support workers delivering services in participants' homes - which are considered workplaces under WHS law. Key duties: identifying and managing hazards; providing information, training, and supervision; consulting with workers on WHS matters; and having a documented WHS management plan.

Employment Law

🔗 Authorised Source

Fair Work Act 2009 (Cth) - SCHADS Award (MA000100)

Source: fairwork.gov.au/employment-conditions/awards/awards-list

The Fair Work Act 2009 and the SCHADS Award govern employment conditions for OCC support workers.

OCC's employment obligations are governed by the Fair Work Act 2009 (Cth) and the SCHADS Award (MA000100). The National Employment Standards (NES) set minimum entitlements - including annual leave (four weeks), personal/carer's leave (10 days), and parental leave - that apply to all employees regardless of award. The SCHADS Award sets minimum pay rates, allowances, and conditions specific to the disability and community services sector.

Knowledge Check

Which Act requires OCC to hold an NDIS Worker Screening Check for all risk assessed role workers?

The National Disability Insurance Scheme (Worker Screening) Act 2020 (Cth). This Act establishes the national worker screening framework and makes it unlawful for a registered NDIS provider to engage a person in a Risk Assessed Role if they do not hold a clearance or have not been approved to work pending clearance.

How long must OCC retain participant files?

A minimum of seven years. For Aboriginal and Torres Strait Islander participants, files must be retained indefinitely. These requirements apply from the date of the last service delivery entry. Files must be stored securely and accessible only to authorised personnel, in line with the Privacy Act 1988 and the Australian Privacy Principles.

KS10 - NDIS Code of Conduct

Key Stakeholders Training  |  Module 10 of 14  |  NDIS Code of Conduct - Provider Obligations

The NDIS Code of Conduct is one of the primary regulatory instruments that governs how everyone at OCC must behave. As a key stakeholder, you are bound by the Code of Conduct Rules 2018 in everything you do. You are also responsible for ensuring your team understands it, and for responding correctly when a conduct issue arises.

🔗 Authorised Source

NDIS Code of Conduct Rules 2018 (Cth) - Guidance for Providers (April 2024)

Source: ndiscommission.gov.au/rules-and-standards/ndis-code-conduct

These rules are legally binding on all registered NDIS providers and their workers. The April 2024 guidance documents provide current explanations of each obligation.

The Seven Conduct Obligations

Obligation The Legal Requirement Your Leadership Responsibility
1. Respect individual rights Act with respect for individual rights to freedom of expression, self-determination, and decision-making in accordance with applicable laws and conventions. Model a culture where participant choices are respected. Ensure staff never override participant decisions without lawful authority. Support staff to understand that respecting autonomy is not permissive - it is legally required.
2. Respect privacy Respect the privacy of people with disability. Ensure all participant information is held, used, and disclosed in line with the Privacy Act 1988. Audit access to participant files. Investigate any privacy breach immediately.
3. Safe and competent delivery Provide supports and services in a safe and competent manner with care and skill. Ensure workers are rostered only for supports they are trained and qualified to deliver. Maintain mandatory training registers. Never pressure staff to exceed their competence.
4. Integrity, honesty, transparency Act with integrity, honesty, and transparency. Ensure all service agreements, invoices, and communications with participants are accurate and clear. Address dishonesty in the team immediately.
5. Raise and act on concerns Promptly take steps to raise and act on concerns about matters that might have an impact on the quality and safety of supports provided to people with disability. Create a culture where staff feel safe to raise concerns without fear. Never punish a worker for a good-faith report. Respond to every concern promptly and on the record.
6. Prevent violence, exploitation, neglect and abuse Take all reasonable steps to prevent and respond to all forms of violence against, exploitation, neglect, and abuse of people with disability. Ensure all staff are trained in recognising and responding to abuse and neglect. Follow up every concern with documented action. Cooperate fully with Commission investigations.
7. Prevent sexual misconduct Take all reasonable steps to prevent and respond to sexual misconduct. Report immediately to the Director. Mandatory Commission notification within 24 hours. Zero-tolerance policy - no exceptions, regardless of the circumstances.

Worker Conduct Management

When a conduct concern is raised about a staff member, OCC must respond consistently and fairly. The process: receive the report and document it; determine whether to stand the worker down from participant-facing duties pending investigation (for serious allegations, this is the default); conduct a fair, documented investigation; make a finding; implement an appropriate outcome (counselling through to termination); and notify the NDIS Commission if the conduct constitutes a reportable incident or the worker poses an unacceptable risk.

⚠ Mandatory Commission notification

If an OCC worker is dismissed - or resigns - in circumstances where OCC reasonably believes the worker posed an unacceptable risk to participants, OCC must notify the NDIS Commission. This obligation exists even after employment has ended. Failure to notify is a serious compliance breach.

Building a Safe Conduct Culture

Regulatory compliance alone does not create a safe culture. As key stakeholders, you actively build a culture where staff feel safe to raise concerns without fear of retaliation; participant feedback is taken seriously; conduct expectations are communicated clearly from day one; and you model OCC's values - particularly Accountability and Responsibility - in how you manage your teams.

Knowledge Check

Which Code of Conduct obligation requires a 24-hour notification to the NDIS Commission?

Obligation 7 - take all reasonable steps to prevent and respond to sexual misconduct. Any sexual misconduct involving a participant must be reported to the Director and notified to the NDIS Commission within 24 hours of the registered provider becoming aware. This is also a reportable incident under the NDIS (Incident Management and Reportable Incidents) Rules 2018.

What are the seven conduct obligations in correct order?

1. Respect individual rights; 2. Respect privacy; 3. Safe and competent delivery; 4. Integrity, honesty, transparency; 5. Raise and act on concerns about quality and safety; 6. Prevent violence, exploitation, neglect and abuse; 7. Prevent and respond to sexual misconduct. These are the seven obligations under the National Disability Insurance Scheme (Code of Conduct) Rules 2018.

KS11 - Understanding the Support Worker Role

Key Stakeholders Training  |  Module 11 of 14  |  NDIS Practice Standard 1.1 - Human Resources

As a key stakeholder, you will not be delivering direct supports yourself - but every decision you make affects the people who do. Understanding what a support worker actually does, the pressures they face, and what good practice looks like is essential for building a functional, quality organisation.

What a Support Worker Does Day-to-Day

Support workers at OCC provide assistance with daily living, community access, and personal care under NDIS funding. A typical shift might involve helping a participant get ready in the morning, preparing meals, supporting them to attend community activities, assisting with medication administration, documenting the session in progress notes, and reporting any concerns to the supervisor.

Support workers often work alone in a participant's home or in the community. They make real-time judgements about safety, communication, and care quality without management present. The quality of their practice depends heavily on three things: how well they were inducted, how well they are supervised, and how supported they feel by the organisation.

Key NDIS Support Categories OCC Workers Deliver

  • Assistance with Daily Life - personal care, domestic support, in-home assistance
  • Assistance with Social and Community Participation - social activities, outings, recreation
  • Assistance with Travel and Transport - supporting participants to travel independently
  • High Intensity Daily Personal Activities (HIDPA) - clinical and complex care requiring specialist training
  • Short Term Accommodation (STA) - respite and overnight support

What Good Practice Looks Like

A high-performing support worker communicates clearly and respectfully with the participant, follows the support plan without overriding participant choices, documents accurately and on time, raises concerns promptly, maintains professional boundaries, and treats the participant's home with the same respect the participant would expect. Good practice is visible in the documentation, in participant feedback, and in the absence of escalated concerns.

Common Pressures Workers Face

Support workers in the disability sector face real pressures: unpredictable hours under the SCHADS Award, emotionally demanding work, physical risks from manual handling and infection exposure, the challenge of professional boundaries, and the isolation of lone working. Organisations that ignore these pressures experience high turnover, poor engagement, and eventually, poor participant outcomes.

As a key stakeholder, your role is to build systems that address these pressures: structured supervision, clear rostering, prompt access to PPE, a culture where concerns are heard, and fair pay and conditions. These are directly linked to your obligations under NDIS Practice Standard 1.1 (Human Resources).

The Link Between Worker Experience and Participant Safety

Research in the disability sector consistently shows a direct correlation between worker wellbeing and participant safety. Workers who feel unsupported, undertrained, or undervalued are more likely to be absent, more likely to make errors, and less likely to report concerns. The NDIS Quality and Safeguards Commission has identified workforce management as a core contributor to serious safeguarding failures. Building a workplace where support workers feel respected, adequately trained, and genuinely supported is a core practice standard obligation and a direct safeguard for participants.

👥 Leadership Reflection

Think about the last operational or rostering decision you made. How did you consider its impact on the workers delivering supports? What would a support worker need from you this week to deliver safe, high-quality support? Building the habit of asking this question is at the heart of effective leadership in the NDIS context.

Knowledge Check

Why is the quality of staff induction directly linked to participant safety?

Support workers often work alone without direct supervision. Their ability to make safe decisions in the moment depends entirely on the quality of training and induction they received before they started. A poorly inducted worker may not know how to recognise an unsafe situation, how to report a concern, or how to correctly follow a participant's support plan - creating direct risk to participants and a compliance exposure for OCC under Practice Standard 1.1.

Name two pressures support workers commonly face and explain why they matter to leadership.

Unpredictable hours (SCHADS Award complexity) and the emotional and physical demands of direct care work. These matter to leadership because unaddressed workplace pressures lead to higher turnover, lower engagement, and increased risk of errors or incidents. Leaders who build systems to mitigate these pressures - structured supervision, fair rostering, access to support - see better retention, better practice quality, and better participant outcomes.

KS12 - Leadership, Culture and Team Building

Key Stakeholders Training  |  Module 12 of 14  |  NDIS Practice Standards - Human Resources & Governance

Leadership in an NDIS registered provider organisation is about creating the conditions in which high-quality, safe support can be delivered consistently. This module covers the leadership behaviours, cultural foundations, and team-building practices that distinguish effective NDIS organisations.

The Leader as Culture Setter

Culture in a disability support organisation is not what is written in the staff handbook - it is what happens when no one is watching. As a key stakeholder at OCC, you set the culture through your behaviour: how you respond when something goes wrong, whether you genuinely listen to a worker raising a concern, whether you model the values you expect of others, and whether you treat participants with the same respect you expect from workers. The NDIS Commission's quality framework recognises that a provider's internal culture is one of the strongest predictors of participant safety.

Psychological Safety

Psychological safety - the belief that you can speak up, raise concerns, or admit a mistake without fear of punishment - is the most critical ingredient of a high-performing care team. Research consistently shows that teams with high psychological safety report more errors, not because they make more, but because they report them. Early error reporting prevents escalation to serious incidents. As a key stakeholder, you build psychological safety by responding to concerns with curiosity rather than blame, making it safe to say "I don't know", following up on every concern with documented action, and never punishing a worker for a good-faith report.

Leadership Behaviours That Build a Quality Culture

  • Conduct regular, structured supervision - not just when problems arise
  • Be visible and accessible to workers - present and supportive, not just oversight-focused
  • Acknowledge and celebrate good practice specifically and genuinely
  • Respond to errors with a root-cause lens, not a blame lens
  • Involve workers in decisions that affect how they do their job
  • Model the Code of Conduct in every interaction

Delegation and Accountability

Effective leadership requires clear delegation - being explicit about who is responsible for what, to what standard, and by when. The Delegation of Authority Register documents OCC's formal delegation structure. In practice, this means trusting people to deliver within agreed parameters and holding people to account fairly when things fall short. The trap many small NDIS providers fall into is either over-centralising decision-making (the director approves everything, creating bottlenecks) or under-delegating accountability (everyone is responsible, so no one is). OCC's growth depends on building a team where responsibility is genuinely shared.

Managing Performance and Conduct

Performance management done well gives people clear feedback, support to improve, and a fair process when things are not working. OCC's performance framework (HR-EPA-001, available via the Staff Supervision tool) provides the structure. Your role as a leader is to use it consistently, fairly, and with genuine intent to support worker development wherever possible. Performance management done poorly damages trust, increases legal risk, and drives away good workers.

Building a Team Through the Growth Stage

OCC is at a growth stage where the founding team is transitioning from doing everything themselves to building systems and people who can deliver consistently. This transition - from founder-led to system-led - requires deliberately bringing people into decision-making, building capability rather than just capacity, and accepting that others will approach tasks differently. Documenting how OCC does things (the systems, workflows, and standards) is not bureaucracy - it is the foundation of scalable, consistent quality.

👥 Leadership Reflection

A support worker tells you they felt pressured to deliver a support they were not trained for because the rostered worker called in sick. How do you respond? What systems does this expose as needing improvement? What does your response communicate to the rest of the team about the culture at OCC?

Situational Leadership - Adapting Your Style

There is no single leadership style that works in all situations. Effective leaders at OCC adapt their approach based on the person and the context. A new support worker who has never worked in disability before needs a directive style: clear instructions, close supervision, regular check-ins, and specific feedback. An experienced coordinator who has been with OCC for two years needs a different approach: collaborative problem-solving, autonomy over their schedule, and coaching rather than instruction. Using the wrong style - over-supervising someone competent, or under-supporting someone new - is one of the most common causes of worker disengagement and error.

Four Leadership Styles - When to Use Each

  • Directing (high task, low relationship): For new workers or new tasks. Provide specific instruction, close supervision, and check understanding explicitly.
  • Coaching (high task, high relationship): For developing workers. Explain the why, not just the what. Involve them in finding solutions. Build confidence.
  • Supporting (low task, high relationship): For capable workers who need encouragement. Share decision-making. Ask, don't tell. Recognise their contributions.
  • Delegating (low task, low relationship): For experienced, motivated performers. Set the outcome, agree on check-in points, then step back. Trust and verify.

Leading Through Change

OCC is growing and changing - adopting new systems like ShiftCare and SharePoint, expanding its participant base, adding new service types, and building its team. Change is unsettling for many workers, particularly those who work in isolation and may feel disconnected from management decisions. Effective change leadership at OCC means: communicating changes early and clearly, explaining the reason for change (not just what is changing), acknowledging that change creates uncertainty, giving workers a voice in how changes are implemented, and following through on commitments made during change processes.

Scenario - Introducing ShiftCare

OCC is transitioning support workers from paper-based progress notes to ShiftCare's digital rostering and notes system. Some workers are uncomfortable with technology. Effective change leadership here means: announcing the change at a team meeting with a clear timeline, offering training sessions with hands-on practice, having a go-to person for questions, not penalising early mistakes, and gathering feedback after the first month to identify what is not working and adjusting accordingly.

Difficult Conversations Framework

One of the most avoided responsibilities in leadership is the difficult conversation - addressing underperformance, raising a behaviour concern, or managing conflict between team members. Avoiding these conversations does not make the problem go away; it signals to the team that problems are tolerated, and it is ultimately unfair to the person who needed the feedback. A simple framework for difficult conversations at OCC:

Step What to Do Example
1. Prepare Know the specific behaviour or performance issue. Have dates, examples, documentation. Be clear about what outcome you are looking for. "I want to speak with [worker] about three shifts this month where progress notes were not submitted."
2. Create safety Choose a private time and place. Start by stating your intent: "I want to talk about something because I want to support you to succeed." Not in front of colleagues. Not at the end of a long shift. Not by text message.
3. State facts, not judgements Describe what happened specifically. Avoid labels like "unprofessional" or "lazy." Say what you observed. "I noticed that progress notes for [participant] on 3, 8 and 14 March were not submitted."
4. Listen Ask what was happening for them. There may be a legitimate reason, a skill gap, or a personal circumstance you are unaware of. "Can you help me understand what happened on those shifts?"
5. Agree on action Agree on what will change, by when, and what support you will provide. Document it. "From Monday, notes will be submitted within 24 hours of each shift. I'll check in with you weekly for the next month."
6. Follow up Do what you said you would. If the issue recurs, escalate through the formal performance management process (see OCC_Staff_Supervision.html). One week later: check whether notes are being submitted. Acknowledge improvement if it occurs.

Self-Leadership - Sustaining Yourself as a Leader

Leadership in a growing NDIS organisation is demanding. You carry responsibility for participant safety, worker welfare, compliance obligations, financial performance, and organisational culture simultaneously. Burnout is a real risk for key personnel in small disability providers - and a burnt-out leader cannot effectively support their team. Self-leadership means: knowing your own limits and communicating them, building routines that protect your energy (exercise, sleep, boundaries on after-hours contact), asking for help before you are overwhelmed, and modelling the wellbeing practices you expect of your team. The NDIS Code of Conduct applies to you as much as to your support workers.

Knowledge Check

What is psychological safety and why does it matter in a disability support context?

Psychological safety is the belief that you can speak up, raise concerns, or admit a mistake without fear of punishment or retaliation. In a disability support context, it matters because early concern-raising prevents minor issues from escalating into serious incidents. Workers who feel safe to report problems - including their own errors - create a much safer environment for participants than workers who conceal mistakes out of fear.

What is the risk of over-centralising decision-making in a small NDIS provider?

Over-centralisation creates bottlenecks, slows response times, and prevents the organisation from scaling effectively. It also means that if key decision-makers are unavailable, the organisation cannot function. The NDIS Commission expects registered providers to have clear governance structures with appropriate delegation - a model where one person controls all decisions is both operationally fragile and a governance concern.

KS13 - Business Growth, NDIS Market and Organisational Sustainability

Key Stakeholders Training  |  Module 13 of 14  |  Business Strategy & NDIS Sustainability

OCC exists to deliver high-quality disability supports - and to do that sustainably, it must function as a viable, well-governed business. This module covers the NDIS market context, growth strategy considerations, the link between quality and sustainability, and the business and growth mindset that key stakeholders need.

Understanding the NDIS as a Market

The NDIS is a demand-driven, consumer-directed market. Participants choose their providers. Funding follows the participant. This means OCC's success depends directly on the quality of experience participants have, their willingness to continue with OCC, and their willingness to recommend OCC to others. Unlike government block-funded systems, there is no guaranteed revenue - it is earned shift by shift, participant by participant.

The Victorian NDIS market is competitive. There are thousands of registered providers ranging from large national organisations to sole traders. OCC's advantage is its ability to provide genuinely personalised, culturally responsive, high-quality supports - something large organisations consistently struggle to deliver. This is the foundation of a sustainable growth strategy: know your advantage and protect it.

NDIS Pricing and Revenue

OCC's revenue is governed by the NDIS Pricing Arrangements and Price Limits (PAPL), updated annually by the NDIA. The PAPL sets maximum prices for each support type. Understanding the pricing structure, the difference between standard and higher-intensity support rates, travel and cancellation provisions, and the distinction between NDIS-funded and non-NDIS revenue is essential for financial sustainability. The Financial Management module (KS7) covers the mechanics in detail.

Growth Mindset in an NDIS Context

  • Quality before quantity - one excellent participant experience generates referrals; one serious complaint can define your reputation in a local market
  • Systems before scale - build the capacity to deliver consistently before expanding participant numbers
  • Workforce first - every participant you add requires a worker who is trained, supervised, and supported; plan workforce ahead of participant growth
  • Compliance as a competitive advantage - providers with strong compliance records attract participants, attract quality staff, and survive audits; providers who cut corners do not
  • Data-informed decisions - use the KPI tracker, incident register, complaint register, and participant feedback to inform strategic decisions, not just gut instinct
  • Learning culture - treat every complaint, incident, and audit finding as a learning opportunity, not just a compliance obligation

Organisational Sustainability

Sustainability for an NDIS provider means more than financial viability. It means maintaining registration in good standing, retaining capable workers, maintaining participant trust, managing organisational risk, and building the internal capability to deliver consistently over time. The Business Continuity Plan (01_Governance/Strategic_Planning) addresses service disruption. The Compliance Strategy maps how OCC maintains regulatory standing through planned, systematic activity rather than reactive responses.

Community Reputation and Referral Networks

OCC's reputation - among participants, families, support coordinators, Local Area Coordinators (LACs), Allied Health professionals, hospitals, and community organisations - is one of its most valuable assets. Reputation is built slowly and damaged quickly. Referral networks are the primary source of new participants for most NDIS providers. Building genuine relationships based on trust and quality outcomes is more effective and more sustainable than any marketing activity. Every interaction a staff member has with anyone connected to the disability sector is an opportunity to demonstrate OCC's values.

Strategic Planning

OCC's Business Plan (01_Governance/Strategic_Planning/Business_Plan.docx) is the governing document for OCC's direction and priorities. As a key stakeholder, you have a responsibility to contribute to, understand, and advocate for this plan. Strategic planning in an NDIS context means setting realistic growth targets aligned with workforce capacity, identifying which support types to grow or add, planning for changes in NDIS policy and pricing, and building the financial reserves that allow OCC to weather uncertainty and invest in quality.

👥 Strategic Reflection

OCC is approached by a support coordinator with five new participants who need complex clinical supports starting in three weeks. The revenue would be significant. What questions do you ask before saying yes? What systems need to be in place before you can deliver safely? How does your answer connect to OCC's values of quality, accountability, and participant safety?

Entrepreneurial Mindset in Disability Services

Running an NDIS provider organisation is, at its core, an entrepreneurial act. You are building something that did not exist before - a service, a team, a reputation - in a competitive, regulated market, under uncertainty. The skills that make a good entrepreneur are the same skills that make a good NDIS provider leader: curiosity, initiative, persistence, comfort with uncertainty, and the ability to see problems as opportunities.

Founder Thinking - What It Looks Like at OCC

  • Ownership mentality: Treat every participant outcome, every support plan, every staff hire as something you personally care about - not as someone else's problem.
  • Take initiative beyond your role: If you see something that could be better, raise it, fix it, or escalate it - do not wait for someone else to notice.
  • See problems as design opportunities: When a participant repeatedly cancels, that is not just an administrative problem - it is a signal that something in the service experience is not working. Investigate and redesign.
  • Move fast on small things, deliberately on big things: Reply to participant families the same day. Think carefully before changing service models or taking on new support types.

Innovation in Disability Services

Innovation in disability services does not mean inventing new technology. It means finding better ways to meet participant needs, deliver supports more efficiently, and create a working environment that attracts and retains great support workers. The lean approach applies directly: identify an unmet participant need, design a small-scale response, test it with one or two participants, learn from what happens, and scale what works. Examples of OCC-relevant innovation: a structured handover process between support workers that reduces information loss; a participant feedback call 30 days after commencement that identifies dissatisfaction early; a worker recognition programme that costs nothing but dramatically improves retention.

Commercial Awareness - Understanding the Numbers

Key stakeholders at OCC do not need to be accountants, but they must be commercially aware. Commercial awareness means understanding how OCC generates revenue, what it costs to deliver a shift, and what the margin between those two figures means for the organisation's sustainability.

Concept What It Means OCC Application
Revenue per participant The total NDIS funding OCC invoices for a participant's supports in a given period Higher-intensity supports (HIDPA) generate more revenue per hour than standard assistance with daily life
Cost of delivery The total cost to deliver one hour of support: worker wages, superannuation, worker's comp, training, supervision, overheads Under SCHADS Award casual rates plus weekend penalties, the cost per hour can approach the NDIS price limit - leaving little margin
Gross margin Revenue minus direct delivery costs, as a percentage of revenue A healthy NDIS provider typically targets 20-35% gross margin before overheads
Cancellation rate The proportion of scheduled shifts that are cancelled by participants without OCC providing an alternative High cancellation rates directly reduce revenue. The NDIS Price Guide allows providers to charge a cancellation fee under specific conditions.
Roster utilisation The proportion of rostered worker hours that are actually billed to participants Idle time - workers rostered but without participants - is a direct cost with no revenue offset

Reading a Profit and Loss statement at a high level means understanding: revenue (total NDIS invoices), cost of goods sold (worker wages and direct costs), gross profit (revenue minus direct costs), operating expenses (office, insurance, compliance, management), and net profit (what is left). If OCC's net profit is consistently negative, the organisation is unsustainable - no matter how well it performs clinically.

Risk Appetite vs Risk Management - The Balance

Compliance culture in disability services can create excessive risk aversion - a reluctance to try anything new for fear of breaching a standard. Entrepreneurial leaders balance compliance (managing known risks) with calculated risk-taking (pursuing growth and improvement). The question is not "could this go wrong?" but "if it goes wrong, how serious is the consequence, and can we manage it?" For decisions with catastrophic potential consequences - participant safety, financial insolvency, registration loss - be highly risk-averse. For decisions about marketing, new service types, technology adoption, or team structure - accept that imperfect action beats paralysis, and build in review points.

Building Your Personal Brand as a Leader

In a relationship-based sector like disability services, personal reputation matters as much as organisational reputation. The key stakeholders at OCC are, in effect, the face of the organisation in the local community. Building a personal brand as an NDIS leader means: being visible at industry events (local disability expos, NDIS Commission information sessions, support coordination forums), building genuine relationships with allied health professionals, plan managers, and support coordinators who could refer participants to OCC, sharing knowledge generously (LinkedIn posts, community group contributions), and consistently demonstrating that you prioritise participant outcomes above commercial interests. The most powerful referral source in disability services is a satisfied participant, followed closely by a respected professional who trusts your organisation.

Knowledge Check

Why is growing participant numbers without growing operational capacity a quality risk rather than a growth strategy?

Each participant requires a trained, supervised, and supported worker. Growing participant numbers faster than your ability to recruit, induct, and supervise workers causes support quality to deteriorate - existing workers become overloaded, supervision gaps emerge, documentation quality drops, and incident risk increases. The NDIS Commission expects providers to take on only the participants they can deliver to safely and competently. Taking on more than you can manage is both a quality risk and a registration risk.

Name two ways that strong compliance performance creates a competitive advantage in the NDIS market.

First, a strong compliance record builds trust with participants, families, and referrers - people choose providers they trust to be safe and accountable. Second, strong compliance attracts quality workers - capable, qualified people want to work for organisations that are well-run, compliant, and treat staff and participants fairly. A provider known for poor practice or Commission investigations struggles to attract both participants and staff.

KS14 - Australian Legal Framework for NDIS Providers

Key Stakeholders Training  |  Module 14 of 14  |  Corporations Act 2001, ACL, Fair Work Act & State Legislation

As a key stakeholder, director, or senior leader at OCC, you operate within a layered legal framework. This module provides a plain-English overview of the key Australian laws that govern OCC as a company and as an employer. It is not legal advice - for specific situations, always consult a qualified solicitor.

Important: This Is Not Legal Advice

This module is designed to raise your awareness of relevant legislation. The law is complex and fact-specific. When you face a real situation involving legal risk, seek professional legal advice from a qualified Australian solicitor.

Corporations Act 2001 (Cth) - Your Duties as a Director or Officer

OCC is registered as a Pty Ltd company. All directors and officers of OCC are subject to the duties set out in the Corporations Act 2001 (Cth), administered by the Australian Securities and Investments Commission (ASIC). There are four core duties:

Duty Section What It Means in Practice
Care and diligence s 180 Make decisions with the care and diligence a reasonable person would exercise. Read board papers, ask questions, attend meetings, understand the financials.
Good faith s 181 Act in the best interests of the company and for a proper purpose. Do not use your position to benefit yourself at the expense of OCC or its participants.
Proper use of position s 182 Do not use your position to gain an advantage for yourself or another person, or to cause detriment to the company.
Proper use of information s 183 Do not use company information obtained through your role to gain personal advantage or harm the company.

The business judgment rule (s 180(2)) provides a defence: if you made a decision in good faith, for a proper purpose, without a personal interest, having informed yourself reasonably, and rationally believing the decision was in the company's best interests - you will not be in breach of your duty of care, even if the decision turns out to be wrong.

What This Means for OCC Day-to-Day

  • Attend every board or management meeting - or send apologies and review minutes
  • Read financial reports before signing off on them
  • Declare any conflict of interest at every meeting - even if you think it is minor
  • Do not make payments, contracts, or decisions that personally benefit you without full board knowledge and approval
  • Ensure OCC has adequate insurance, including Directors and Officers (D&O) liability cover

Insolvent Trading - A Critical Risk

Under s 588G of the Corporations Act, a director has a duty to prevent a company from incurring debts when the company is insolvent (or will become insolvent as a result of the debt). If OCC cannot pay its debts as they fall due, directors must take immediate steps: seek legal advice, consider voluntary administration, and stop incurring new liabilities. Personal liability for company debts can result from a breach of this duty. This is one of the most serious risks for directors of growing small businesses.

Australian Consumer Law (Competition and Consumer Act 2010)

The Australian Consumer Law (ACL) applies to OCC's service delivery. Key provisions relevant to NDIS providers include:

ACL Provision What It Means for OCC
Misleading or deceptive conduct (s 18) Do not make false or misleading statements about OCC's services, qualifications, registration, or capacity - in any form, including marketing materials and verbal representations.
Consumer guarantees Services must be rendered with due care and skill, be fit for the purpose the participant communicated, and be delivered within a reasonable time. These guarantees cannot be excluded by contract.
Unconscionable conduct (s 21) OCC must not take advantage of a participant's vulnerability, disability, or lack of bargaining power. This is particularly relevant given OCC's participant cohort.

Fair Work Act 2009 - Employer Obligations at a Glance

OCC is an employer under the Fair Work Act 2009. Module KS6 covers HR and the SCHADS Award in detail; the legal framework that underpins it is the Fair Work Act. Key obligations include:

Core Fair Work Act Obligations

  • Provide all employees with a Fair Work Information Statement and a Casual Employment Information Statement (for casuals) at the start of employment
  • Pay employees at least their applicable Modern Award minimum (SCHADS Award for OCC's workforce)
  • Not take adverse action against an employee for exercising a workplace right (e.g. raising a concern, taking leave, making a complaint)
  • Meet National Employment Standards (NES) - including leave entitlements, notice periods, and flexible work provisions
  • Consult employees before making major workplace changes that are likely to have a significant effect on them
  • Maintain accurate time and wage records for 7 years

Cross-Reference: Legislation Covered in Other KS Modules

Several key laws are covered in dedicated modules. This table summarises the full legislative environment OCC operates within:

Legislation Relevance to OCC Covered In
National Disability Insurance Scheme Act 2013 (Cth) Registration, practice standards, participant rights, NDIS Commission powers KS1, KS2
NDIS (Quality Indicators) Guidelines 2018 Quality and audit framework KS3, KS5
NDIS Worker Screening Act 2020 (Cth) Mandatory worker screening for risk-assessed roles KS6
Privacy Act 1988 (Cth) & Australian Privacy Principles Collection, use, disclosure and storage of personal information KS9
Work Health and Safety Act 2011 (Cth) / WHS Act 2021 (Vic) Duty of care to workers and others in the workplace KS8
Disability Discrimination Act 1992 (Cth) Non-discrimination in service delivery and employment Across all modules
Victorian Disability Act 2006 State-level disability services standards; Victorian context for NDIS delivery This module
Equal Opportunity Act 2010 (Vic) Non-discrimination in employment; reasonable adjustments for workers with disability This module
Children, Youth and Families Act 2005 (Vic) Mandatory reporting obligations when supporting participants under 18 This module

Victorian Disability Act 2006 and Equal Opportunity Act 2010

The Victorian Disability Act 2006 sets out principles for disability services in Victoria including the rights of people with a disability to access services without discrimination, to receive services that meet their individual needs, and to participate in decisions about their own lives. While the NDIS national framework largely supersedes the state framework for registered providers, the Victorian Act remains relevant for state-funded supports and the broader service delivery culture.

The Equal Opportunity Act 2010 (Vic) prohibits discrimination in employment on the basis of disability, among other attributes. For OCC this means: you cannot discriminate against a job applicant or worker because of a disability; you must make reasonable adjustments to accommodate a worker with a disability; and you must not subject any worker to harassment or victimisation.

Scenario - Director Conflict of Interest

A director of OCC is also a director of a cleaning company. The director suggests at a management meeting that OCC contract that cleaning company to provide environmental cleaning services at a participant's home. Under the Corporations Act, this director must immediately declare their conflict of interest, must not be present for the discussion or vote on the proposal, and the remaining directors must consider whether the arrangement is genuinely in OCC's best interests. Failure to declare and manage this conflict is a breach of director duties.

Knowledge Check

Under the Corporations Act 2001, what are the four main duties of a director? Give a brief description of each.
1. Care and diligence (s 180): Exercise the care and diligence a reasonable person would in the same role. Stay informed, attend meetings, understand the business.

2. Good faith (s 181): Act in the best interests of the company and for a proper purpose - not for personal gain.

3. Proper use of position (s 182): Do not exploit your role to gain a personal advantage or harm the company.

4. Proper use of information (s 183): Do not misuse confidential company information for personal benefit.
What is the insolvent trading duty, and what should a director do if they believe OCC may be unable to pay its debts?
Under s 588G of the Corporations Act, directors must not allow a company to incur new debts if the company is insolvent or will become insolvent as a result. If a director believes OCC may be unable to pay its debts as they fall due, they should immediately: stop incurring new liabilities, seek urgent legal and financial advice, consider voluntary administration as a mechanism to protect creditors, and document all decisions made. Personal liability can attach to directors who breach this duty.
Name two obligations OCC has under the Australian Consumer Law in relation to how it delivers services to participants.
Any two of: (1) Services must be rendered with due care and skill. (2) Services must be fit for the purpose communicated by the participant. (3) OCC must not engage in misleading or deceptive conduct about its services. (4) OCC must not engage in unconscionable conduct - taking advantage of a participant's vulnerability or disability.

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Key Stakeholders Training Pathway  |  14 modules  |  Open Care Connect

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