Welcome to Part 2 of my blog series of the highlights of the NDIS Scheme. If you haven’t already read it, here is the link to Part 1, which was on Stage 1 and 2 of the audit process: https://www.thequalitynerd.com/blog/highlights-of-the-ndis-scheme-stage-1-and-2
At the Stage 2 audit, the auditor will want to speak to your clients, and review client files. There is a methodology in the Scheme for how auditors must sample your clients – the methodology is multi-layered so that auditors can get the best coverage or sample of clients, but that means that it can be complex to understand.
The NDIS Quality and Safeguards Commission considers some Registration Groups to be low-risk, such as Household Tasks. They have listed these low-risk groups as Appendix D of the Scheme. These groups are excluded from client sampling.
For the other groups, the number of clients you have in each group will be added together, and the square root of this total number will be the number of clients that your auditor has to sample at your external audit.
For example, if you have 16 clients in total from the in-scope Registration Groups, the auditor will interview and review the files of four clients. At surveillance audits, it will be the square root of the total number, multiplied by 0.6.
The auditor will try and speak to clients best represent who you are delivering services to – they might choose clients that speak a different language, that have different communication needs, or that access more than one service at your organisation.
You, as the organisation, must ensure that you have notified your clients that the NDIS audit process is ‘opt-out’, meaning that clients must say that they don’t want to participate – otherwise the auditor will be able to access their file, and contact them for an interview. If possible, you can work with the auditor to arrange interview times with clients during the audit, but organisations are now allowed to pre-select clients for file review or interviews. The auditor needs to tell you which clients they would like to look at.
I hope that this has de-mystified the client sampling process for you. If you have any further questions, please don’t hesitate to contact me: email@example.com
Thanks for reading,
Whether you own or work in a business, compliance is key. Compliance is making sure that you meet all of the requirements relevant to your business - this could be legislation, regulations, best practice, or quality standards. Every business in Australia has compliance requirements, so knowing what they are, and having a system in place to manage these requirements, really puts you in front.
Many people think of quality management as a burden or an "extra", but compliance requirements aren't going away (especially in the human services sector). Remember what I said about embracing compliance? Setting up a quality management system is the easiest way to manage your compliance. Managing your quality management system - that is, actively working in and on it - will make compliance a breeze.
The best way to manage your QMS is to be proactive! Schedule time each week in your calendar for quality management tasks. Schedule different tasks for each week of the months. For example:
Week 1: Review policies and procedures
Week 2: Review complaints and incidents
Week 3: Review governance requirements
Week 4: Review improvement actions
Start with one hour a week - that is only 2.5% of your working week! That is surely worth the investment for the peace of mind that you are meeting your compliance requirements.
Speak to me about how to manage your QMS, and how to make compliance a breeze: firstname.lastname@example.org
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First of all, congratulations! You had the idea you wanted to become a provider of disability or aged care services. You worked hard to build up a company, get the right people involved, and work through the finances.
It’s a lot of work to become a registered or approved provider. Both the disability and aged care sectors are heavily regulated, and there are multiple compliance layers that new business owners need to work through. That’s why my number one tip to new providers is:
Compliance is interchangeable with quality management in this case. The policies and procedures you have to write, the supporting documents that need to be filled out, the communication you need to have in place with your staff and clients – all of this forms your quality management system, which helps you stay compliant.
The fact is, the disability and aged care sectors are not going to stop being heavily regulated any time soon – and given that we are in the human services sector, do we really want to reduce any of the checks and balances?
So now is the time to embrace quality management and compliance. Learn to love policies and procedures. Learn to love internal auditing, and engaging with stakeholders, and keeping your registers up to date. Learn to love continual improvement.
The result will be safer, better services, and happier staff and clients. For you, that means a more successful business.
And don’t forget, you don’t have to do this alone! Contact me for support – I can providing training for you and your staff on quality management and compliance: email@example.com
Thanks for reading,
If you had a bit of a holiday break over Christmas and New Year, welcome back to work - you're probably full steam ahead, because human services never really stops, so here are some quick tips to get your year started right, quality management-wise.
1. Set your internal audit schedule - you might call this process or document reviews. However you do it, for your organisation, make sure you book it in now. Internally auditing or reviewing your organisation SHOULD NOT be ad hoc. Prioritise, based on risk, plan, and book in the relevant stakeholders.
2. Write or review your strategic or operational plans - or at least book in a review for later in the year. Now is a great time to revisit your business priorities. You can do this on a larger scale with your staff and clients, or it might just be a quick review to set some goals for the next few weeks.
3. Book in some time to get client feedback - again, this is about knowing where you are, and setting some goals for 2018. This process does not have to be formal (think paper or online surveys), although it can be. But if you're a small organisation, you might just call up your clients and ask them how last year went with regard to their services, and if they have any suggestions for this year. Record your findings in your Improvement Plan!
4. Schedule in staff training - training staff in human services should also not be ad hoc. You need to look at your client group and the type of services you provide, and tailor staff training accordingly. Schedule it in, book in external trainers if you need to, and evaluate the training afterwards. This is also a good time to chat to staff about their goals for this year, and review last year's performance and goal achievement. Or, book that chat in for later this year now.
I hope you have a great start to 2018. If you're a new organisation, you might be starting to think about your first external audit this year! I can help by checking number 1 from this list off for you, and conducting an audit on your business - see my Pricing page, or contact me.
Thanks for reading,
It's been a huge year for me at The Quality Nerd, as I followed my dreams and made the business my full-time job. I'm infinitely grateful for my clients that made the leap possible, and I'm very much looking forward to continuing to work with you in 2018.
For 2018, I hope for the following:
1. To support new businesses with their first external audits - if you registered as an NDIS or Home Care Provider in 2017, you will probably have your first audit in 2018. An audit can be scary if you haven't been through one before, but a great way to calm your nerves is to be prepared by having an internal audit. I have over 10 years experience in internal auditing, and I can help you with a desktop audit, or come to your site / office to thoroughly review your records.
2. Continue writing - I love to write, especially policies, procedures, tender applications, and self-assessments! I'm certainly not called a nerd for nothing. In 2018 I would like to support businesses by helping them write documents for their processes that are meaningful, useful, and compliant to requirements.
3. Travel with purpose - this links in with goal #2, in that I'd like to do more pro-bono work in 2018. That's right, if you're a small human services or animal welfare organisation, and you need some support with quality, processes, or management, I offer 1-2 days onsite of my time to help you with your business issues. All I ask is for permission to write a de-identified case study about you.
If you'd like to start 2018 with a business bang, please contact me any time: firstname.lastname@example.org
Thanks for reading,
Those of us working in the aged care sector in Australia have recently watched, in horror, as details have emerged from South Australia and Newcastle of shocking incidents and practices in aged care facilities. This has become public news, rightly so, and the government’s response to public outrage is, usually, to launch an inquiry. Which has, of course, happened.
However, the Aged Care Accreditation Standards, and the way in which those standards are assessed, has been under review for some time already. Actually, many years. There was one crack at it a few years ago, which stalled, but when the Quality Agency took over Home Care the move to make a single aged care quality standard was inevitable.
A few weeks ago, the Department of Health released its final consultation on the draft single set of standards and the assessment / review framework. But yet now the Quality Agency faces another inquiry. What no one has answered, yet, is how these two reviews will meet, if in fact they will at all.
But more importantly than that, have we really addressed the issue of aged care quality in Australia? Do we really know what we want to achieve? Do we understand how facilities work, how the staff in those facilities work, and how to balance safety and a person-centred approach?
The Aged Care Accreditation Standards came about because nursing homes were not accountable for providing quality, safe care – it led to poor outcomes for residents, and a workforce that couldn’t sustain itself. The Standards were all about safety, to start with. There were a few nice things in there about meeting the individual’s needs, but essentially, it was about protecting safety, rights, and overall wellbeing. I strongly believe it still achieves this, overall.
The draft single standards want to go in a completely different direction, and focus more on person-centred care. PCC is a model that is very popular in Australia, because it has worked so well overseas. I feel, though, that no one has asked – are our facilities the same as they are overseas? Is our workforce the same?
I would love to say that Australia provides person-centred care. But we don’t. Not yet. We provide very good care; we have wonderful staff, and we have commitment at all levels, from what I’ve seen, to give residents the best quality of life that we can.
But – we are over-regulated, we are not funded adequately (I’ll concede that the government is reviewing the funding model also), and our workplaces are just not yet set up for true person-centred care.
The trouble with aged care quality in Australia is that the support system it needs isn’t there yet. We need to address that first. I believe that quality will remain the same – despite a new model, standards, or inquiries – until we can address the support system first.
If you follow my Twitter (which I hope you do!), you’ll have seen my tweets yesterday from the conference. In summary, it’s a very, very long day, but the speakers were great and it was very interesting to hear about how aged care works in different countries.
But I’m a Quality Nerd! I’m here to listen, learn, and talk about quality management. Which was exactly the one thing missing from yesterday. Many of the speakers talked about quality – quality of life, quality of services. But no one talked about quality standards. This really surprised me. Towards the end of the day I had the opportunity to ask a question of Sean Rooney, CEO of Leading Age Services Australia (LASA), who was on a panel discussing the future of assisted living and skilled nursing care for Asia Pacific.
Two other members of the same panel spoke about aged care that very heavily aligns to my own values about human services – that is, that above all else, quality of life is what matters; and that our work must come from a place of love. So my question was: have the Australian aged care quality standards failed; have they stifled innovation; and have they stifled love?
Sean Rooney, as I expected, talked about where the standards came from – to implement safe practices – which lead to a bit of a discussion on risk and the dignity of risk. And I believe that has been the big achievement of the Australian framework – I believe that at the time they were implemented, and even today, they do promote safety and better services for aged care clients.
But that leads to the question – why hasn’t Asia (and other parts of the world) got standards? Have they just skipped past safety? How safe are their services in that case, and who decides that? Asia, it seems to me, has moved past standards to where Australia is only just now coming into – quality of life, and true person-centred care.
I could write another whole (several) blog posts about whether or not I think quality of life outcomes and person-centred care will work under the current funding model in Australia (short answer: no). But for now, I’d like to ponder the question – who is asking about safety and risk in aged care services in Asia, and who is deciding what that looks like?
I’d love to hear from you, especially if you are in aged care services in Asia.
Thanks for reading,
I have been a huge fan of Christopher Paris’s work essentially since I first started in Quality Management way back when. His Eyesore 9001: A Smartass’s Guide to ISO 9001:2000 (now in 2008 version) basically saved my bacon when I was a Quality newbie. It was useful and applicable, and it told me that I wasn’t going crazy and that no matter how ISO tried to dress up 9001 as a standard for both ‘products and services’, it really, really wasn’t written for services at all (or by anyone who understood service organisations?), especially human services.
For ISO’s 2015 version of 9001, Paris hasn’t released an Eyesore – instead he went down the rabbit-hole and has written and published an entire book. This book is the most comprehensive drill-down of the ISO 9001 that you will ever read. How Paris made it out of his analysis alive and sane could be considered a miracle (or did he? Someone let me know), as he has really left out no detail – it’s pretty much a word-by-word breakdown of what is, in my opinion, the worst written anything of everything.
I have, since the beginning of my Quality career, been a huge critic of the use of ISO 9001 in human service organisations. I absolutely believe that organisations should have management systems in place, and should be concerned about the quality of their services and how they achieve quality for their clients. But it scares me that governments have written into service agreements that human service organisations must be certified to ISO 9001, and that some organisations are voluntarily opting-in (because they think it helps prove that they’re doing the right thing) when the standard just isn’t written in our language and is still very much “we make products” focused.
(Also, governments, there are so many human services quality standards you can now pick from that you could ask organisations and services to demonstrate compliance to (without needing them to be certified if the standard is from another state). Why waste time with ISO 9001?)
Paris’s book is amazing, right from his documentation of the history of how the standard comes about (which should be appalling to all of us quality professionals), to his breakdown of the clauses, to how we can apply it in our organisations – but (and this is not Paris’s deficiency, but rather my conclusion), his book only further convinces me of the unsuitability of ISO 9001 for our industry. That being said, if you do work in human services and you do need help figuring out ISO 9001, this is the best book you could buy to help you.
PS – this blog post is not sponsored, and I don’t know Christopher Paris and I’ve never done any work with Oxebridge. I just really respect what he is trying to do and I have genuinely found his work to be very helpful to me as I’ve tried to navigate the ISO 9001.
One of the biggest fears about having an external audit is that you'll get a nonconformity (or non-compliance, or not met). To avoid this, people put a huge amount of effort into preparing for their audit. As I've said previously, being prepared is not a bad thing; but, especially if your organisation is just starting their quality management journey, you may still get a nonconformity. So what happens next?
First of all, your external auditor should say that they will provide you with written details of the nonconformity. This information should be specific - while it won't tell you how to address the issue, it should provide you with enough information so that you clearly know what to do. If you feel that the auditor hasn't given you the information in a clear and specific way, tell them! The auditor won't mind (we prefer to know that you understand the issue and want to resolve it).
Once you have that written information, you should ensure that you cross-reference it with the indicator / standard that it is against - this should give you enough information to confidently address the nonconformity. Now is the time to start documenting this resolution phase:
1. State what you will do to address the issue, for example, that x procedure will be updated to include y and z.
2. State what you will do once that change has been made, for example, that the procedure will be
distributed and explained to all staff at the next staff meeting.
3. Include a follow up action and a timeframe - this provides assurance that you will know that the change has been embedded. Document this when completed with a description of what happened (please note, stating something like 'achieved' is really not good enough. You don't have to be a writer to be able to describe what happened when you did something, you just have to put the effort in).
All of this information will need to be provided to the external auditor at some point (different quality frameworks have different requirements, and it also may depend on how serious the nonconformity is), so it is important that you document thoroughly.
important thing, though, is to not feel too disappointed or discouraged from a
nonconformity - it is a part of quality and of the continual improvement
process. See it as an opportunity to improve and keep moving forward.
Now that you know when to call a finding a non-conformity, the next step is making sure that the non-conformity (or issue or observation) has been closed out. This will usually fall to the internal auditor to do, as being someone who can provide an independent assessment of the effectiveness of the action taken.
I believe best practice is not just to note if an action has been taken, but to also assess if that action has been effective, thus minimising the risk of future non-conformances. This might involve some time spent on a follow-up audit or desktop review. To me it's time well spent - I would rather continue to follow up an issue than write about the same issue occurring in report after report.
The first step in the process is to give people a clear idea of what the issue is and why it's an issue. A statement like the following makes things really clear: "The service is not currently reviewing client support plans within the timeframes set out in the Client Review procedure, i.e. every six months, as monitoring of review timeframes has not taken place regularly."
At this stage you might like to give a direction for action - at the very least, you should give a timeframe for completion, such as: "The service should ensure that all clients that are overdue for review have one completed in the next four weeks."
You could extend this to ensure minimisation of ongoing non-conformity: "The service should ensure that the client review report is monitored weekly and reminders set in relevant staff calendars to ensure that reviews are conducted on time."
You then need to let the service know how their non-conformity will be closed out: "Manager to provide the client review report to the internal auditor by (date)."
Now the most important part is actually following up - mark it in your calendar and keep your word. Sticking to your own rules is a fundamental part of being an internal auditor.
If someone has not been able to close out a non-conformity, set a new follow up time and keep going back until the issue is resolved; also ensure that you follow your escalation processes, particularly if you feel the issue is high risk.
Thanks for reading,
Do you have a topic suggestion? Something really bugging you about Quality? Send me an email! Your details will remain private, but I'll send you an email back