Driving Instructors registering for NDIS will benefit with recent changes to the National Disability Insurance Scheme. The NDIS (Provider Registration and Practice Standards) Rules 2018 have been updated and changes came into effect from 1 January 2020. The process is now simpler and less costly.
This is a perfect opportunity to demystify the registration process and give our Specialised Driving Instructors information on how to register as an NDIS provider. These rule changes mean your business (even if a Pty Ltd Company) can now be registered under verification and not certification like before.
This fact sheet covers information on:
- What to consider before applying to register
- Time frames to plan for
- The steps to apply
- Documents needed to meet compliance
- Who can help?
- Ongoing registration renewal and auditing
- Other things to consider…
- Current trends
1.What to consider before applying to register
Before anything else, consider your financials. That’s the feedback we got from the Specialised Driving Instructor sector. What do we mean by this? You must analyse and work out the running costs for your business. What does the driving instructor hourly rate need to be to meet these overhead costs and make your business viable and profitable.
In the past Agency managed clients had a maximum fixed hourly rate, now, the rules have changed, and the latest 2019-2020 Price Guide does not have an hourly rate, instead a quote is required for approval. Note: It is important to always check back with NDIS to see what the latest conditions are, as they are always evolving and changing.
What volume of business will be generated by being an NDIS registered provider must also be worked out. Will it justify the added administration involved and the cost of maintaining compliance? Will this administration function need to be outsourced ? If it does, it will add to the running costs of doing business. Working out the volume of business generated can be dependent on the State you work in, the location and levels of competition in your area.
2.Time frames to plan for
There are a variety of time frames to consider when starting the process for NDIS registration. Once the online application process has commenced, you must update or submit the application within 60 days, or it will be deleted off the system. Use the reference number given whenever communicating with the Commission about your registration.
We found that it takes generally about 12 months to complete the process. Gathering and setting up all the documents and information needed to register with NDIS as a provider can take time. This is mostly due to the fact that you are still running a business alongside doing this added administration work.
3.The steps to apply
If you have decided it is still worth it – to register as an NDIS provider in all Australian states and territories except WA, you need to complete the online registration application. (WA is still being managed by the NDIA and not the NDIS Commission. WA will come across to the Commission in July 2020).
The registration group you will register is called Specialised Driver Training.
4.Documents needed to meet compliance
The self-assessment completed in the application process will have already indicated the areas that need supporting evidence. The documents required include:
- 100 points of ID – to set up a Provider Digital Access (PRODA) account. Note that you must create an individual account first and then link to the organisational PRODA account. For more information about how to create an account go to Department of Human Services – PRODA
- Right to work in Australia – This can be Citizenship Certificate, Birth Certificate, Visa Permit.
- Qualifications – Evidence of qualifications to be a Specialised Driving Instructor in Australia. Must be provided for each driving instructor in your organisation.
- CV/Resume – Your Curriculum Vitae/Resume providing evidence of your experience as a Specialised Driving Instructor. Must be provided for each driving instructor in your organisation.
- Worker Screening – Each person who will be in more than incidental contact with the NDIS participant must provide a Police Check report and a current Working With Children Check (WWCC) Number. This is a must for the driving instructors at the very least.
- Mandatory Training – Provide certificate of completion of the NDIS Worker Orientation Module training for each employee. You create an account first and then login to complete the training. All employees must complete this. It takes around 1.5-2 hours to complete. You can then download the Certificate as evidence of completion.
- Insurance – Certificate of Currency for Workers Compensation Insurance, Public Liability Insurance, Professional Indemnity Insurance, Car Insurances for all vehicles, Modification Insurance for all vehicles.
- Work Health and Safety (WHS) – WHS policies and procedures including evidence of incident management process. See the ‘who can help’ section below for information about these documents.
- Complaints Management Process – Provide a copy of your complaints process.
5.Who can help?
You may already be overwhelmed by what you need to provide by this stage. Don’t despair. There are organisations who can help with creating and developing some of these documents for you. They can produce your organisation’s policy and procedures documents which comply with the NDIS standards. Then it’s a matter of fine-tuning these to meet with your organisation’s specific operations and terminology.
They do come at a cost which can range in price from $500 – $1,500. However, they can take a lot of stress out of creating such documents if you don’t have them already. We have used Provider Plus to do these for us, however, there are numerous organisations with various price points who provide the same type of service. A google search for ‘policy and procedures that meet NDIS standards’ will show up a list of organisations for you.
6. Ongoing registration renewal and auditing
Once you are registered, you will need to renew your registration before the expiration date. To apply to renew your registration (usually within 6 months from your current expiration date), you will need to complete the online application process via the NDIS Commission portal. The Renewal Quick Reference Guide is a useful resource to help you. You can also ask the NDIS Commission for guidance to complete your renewal.
Initial Scope of Audit
Once the renewal application has been submitted with relevant documents attached, you will receive an ‘initial scope of audit’ document by email from the NDIS Commission, summarising the registration requirements that apply to your organisation.
Engage an Auditor
It is your responsibility as the applicant to engage an approved quality auditor to complete the audit. You can request a quote from more than one auditor to make your decision. They will use the ‘initial scope of audit’ document you received to quote for their services. Generally speaking, a verification audit costs around $700 – $1,200. Definitely worth shopping around!
For Specialised Driving Instructors, you will need to undergo a verification audit within the time frame specified on your Certificate of Registration. The time frame given considers your organisation type, size, scope and complexity of the services and supports you provide.
A verification audit involves a desktop audit. This means you will supply a list of documents to the auditor for verification (usually via email). They will be available to ask questions and help you define what is required and how you can best meet compliance. The auditor will submit the outcome of the audit to the NDIS Commission through an online portal.
NDIS Commission Assessment
The NDIS Commission assesses your application and makes a decision. This can take up to 12 months but for less complex businesses such as Specialised Driver Training, this can be much shorter. If you have applied for renewal of registration prior to the date of expiry, your registration will automatically be extended until the Commissioner makes a decision on your application for renewal.
When you receive the outcome, this is what will happen:
For successful applicants: you will receive a certificate of registration outlining the services you are registered to provide, the period of registration, and any conditions you must follow to keep your registration.
For unsuccessful applicants: you may contact the NDIS Commission and request a review within three months of the decision. If your application is still unsuccessful following the review, you may seek a further review by the Administrative Appeals Tribunal.
Once your renewal has been completed, and successful, you will be re-verified by an auditor every three years. This will be a business cost to factor into your business overheads every three years. Obviously over time, the costs to pass an audit will reduce. For example you will not need to create new policies and procedures every time etc.
7. Other things to consider…
To work with NDIS you don’t have to be a registered provider. You can still provide specialised driving lessons to NDIS participants who are self-managed or plan managed. As long as you have an ABN, technically that’s all you need for these participants. However, the funds still need to be approved into the plan by the Agency and this is where you may come up against some competition from providers who are registered. NDIS registered providers may also be preferred by driver trained OTs and general OTs. This ensures that they work with organisations who meet the NDIS standards.
Making the sale
When quoting for driving lessons it can take months (on average at least 4 months) before the funds are approved and the sale can be made. This is something to factor into business operations. In some occasions the funds get approved but then they end up being used for other competing priorities and these funds get allocated to be spent on other services. You may have to wait for a review of the participant’s plan to get the funds made available again.
There are a few ways that payment can be made. NDIA managed participants, a service booking is created by NDIA and allocated to your business portal. These funds can be claimed directly in the portal once the lessons are completed. Plan managed participants, the driving instructor sends their invoice to the Plan Manager for payment. Self-managed participants invoices can be sent directly to the participant for payment. For driving assessments – these are paid by the OT directly to the driving instructor. (They factor this cost into their OT costs of assessing the participant).
8. Current trends
Where traditionally the specialised driving instructor mostly had clients with physical disabilities, the NDIS has facilitated the expansion of the disability sector to a broader range of clients with disability. It is a new frontier for the industry, these days 80%-90% of clients needing specialised driving lessons are clients on the Autism spectrum or with mild intellectual and/or learning disabilities. In the past these people didn’t even get a choice and the cost was often too high to consider.
The general assumption of ‘10 lessons will cover the learning required’ does not work for these clients. Often you may need 30 or 50 lessons to get the learnings and sometimes they may never manage to get to the point of passing a driving test successfully. For this reason, being a specialised driving instructor can be very rewarding, but it comes with extra work and responsibility.
It is different to the traditional way, there are more factors involved and more variables to consider. At times you don’t get the feedback you normally would from your client. Patience is key and having a very good relationship with their parents/guardians ensures communication flows and the client’s preferences and needs are met and understood.
It takes specialised skills to teach this new type of client and we need more specialised driving instructors out there who will make it their passion to teach for independence.