The following is targeted at new providers but a reminder for established organisations also.
One common feedback that auditors give prospective providers is to put their company name/logo on their documented policies and procedures. This is taken literally most of the time and the provider then scrambles to do so with the 50-100 documents they may have on hand. The myth here is that this is a regulatory requirement. It is not. Let me explain.
Myth Busting
The very act of putting branding on a document implies ownership, but the real point being raised by auditors is responsibility and accountability. The typical reason why an auditor has raised this is that they sense that the provider has not actually ‘owned’ nor live by the policies and procedures presented to them.
NDIS Practice Standards
Below is the actual phrase that is repeated in the NDIS practice standards at least 9 times:
“Appropriate policies and procedures are in place.“
In Action
The key part of this phrase is ‘in place’. It may not be explained in the detail of the regulation, but even a layman would not suggest that just having a document would be sufficient. Logo or not.
Another way to look at policies and procedures are that they are the ‘rules’ of how your organisation will run. So how can an organisation demonstrate this will be the case? Here are some examples:
- Register of when the policies and procedures were approved by management and when they will be reviewed again.
- Register of all staff reading and understanding the content.
- Policies and procedures are easily accessed by staff. Not just in a physical binder in a draw somewhere.
- Additional activity that the organisation does to remind and instil the practices e.g. periodic team meetings to discuss topics.
- Posters around the work environment to remind staff of their responsibilities.
This is also hinted at by these phrases in the NDIS practice standards:
“All workers are aware of, trained in, and comply with the required procedures”
“Regular review of XXXX policies and procedures”
Do the homework
Remember, auditors will meet and assess many provider organisations in their travels. It becomes very easy to pick up if a provider is managing compliance with the focus that is required or one that is treating it like a ‘tick the box’ exercise. Do the homework and make sure they are really in place.
