CT1 - NDIS Framework & OCC Overview
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 core team member, 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.
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 core team member, 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
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.
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.'
CT2 - NDIS Code of Conduct
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).
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. |
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 core team member, 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 core team members must participate fully and provide honest, transparent responses to auditors.
Knowledge Check
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.
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).
CT3 - Practice Standards & Audit
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.
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
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.
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.
CT4 - Participant Rights & Engagement
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 core team member, 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.
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 |
Knowledge Check
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.
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.
CT5 - Risk & Incident Management
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 core team member, 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.
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 core team members are expected to participate honestly and constructively in the external audit process.
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
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.
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.
CT6 - HR, SCHADS & Employment Law
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.
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 |
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 core team member, you must understand the key provisions of this award to ensure OCC meets its legal obligations as an employer.
| 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
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.
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.
CT7 - Financial Management & NDIS Pricing
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.
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
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.
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).
CT8 - WHS & Safe Work Practices
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 |
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 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
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.
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).
CT9 - Privacy, Consent & Information Governance
OCC operates within a complex legislative environment. As a core team member, 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
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
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
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
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.
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.
CT10 - Quality & Continuous Improvement
The NDIS Code of Conduct is one of the primary regulatory instruments that governs how everyone at OCC must behave. As a core team member, 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.
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.
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 core team members, 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
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.
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.