High Intensity Daily Personal Activities: evidence checklist for your NDIS audit

What counts as a High Intensity Daily Personal Activity?

High Intensity Daily Personal Activities (HIDPA) are personal care supports that carry a significantly elevated risk of harm if delivered by an unqualified or inadequately supervised worker. The NDIS Commission's Practice Standards identify these as a specialised support category under Module 2A of the NDIS Practice Standards, which applies to registered NDIS providers delivering supports to people with complex needs.

Examples of HIDPA tasks typically include:

• Complex bowel management (including manual evacuation)
• Urinary catheter management
• Enteral feeding (PEG or nasogastric)
• Tracheostomy management and suctioning
• Ventilator management
• Subcutaneous injections
• Wound management requiring clinical skill

Because these tasks intersect with health and nursing practice, providers must demonstrate that workers have the competencies, training, and oversight structures that an approved quality auditor expects to find during a certification or verification audit.

Why this matters for your 2026 audit

The strengthened NDIS Practice Standards framework — progressively implemented from late 2024 and continuing through 2026 — places greater emphasis on provider governance, worker screening, and evidence of ongoing competency maintenance. For SIL providers in particular, HIDPA sits at the intersection of Practice Standards Module 1 (Core) and Module 2A (Specialised Supports), meaning auditors assess both your general management systems and your specialised clinical governance arrangements.

Non-conformances in HIDPA evidence are among the more common findings raised in audit reports. Auditors have explicit guidance to check not just that a procedure exists on paper, but that it is implemented, understood by workers, and regularly reviewed. The consequences of a major non-conformance can include conditions on your registration, suspension, or cancellation.

The evidence checklist: what auditors check

Use this checklist as a self-assessment tool before your audit. Each item maps to a standard an approved quality auditor will verify.

1. Worker competency and qualification records

• Written evidence of each worker's training and competency assessment for every HIDPA task they perform (certificates, completed competency checklists, or sign-off by a registered health professional)
• Currency of training — competency verifications must be refreshed at intervals appropriate to the clinical risk of the task; document the date and assessor for each review
• For tasks that sit within a regulated health profession (e.g., complex wound management), evidence of delegation or supervised practice arrangements with the delegating registered health professional
• Records showing that workers performing HIDPA have passed NDIS Worker Screening checks
• Orientation records confirming HIDPA-specific induction before unsupervised practice

2. Individualised risk assessments

• A written, participant-specific risk assessment for each HIDPA task delivered to each individual
• The risk assessment must be authored or reviewed by an appropriately qualified health professional where clinically indicated
• Evidence that the participant (and/or their nominee) was involved in developing the risk assessment
• Review dates recorded; re-assessment triggered by any change in the participant's condition, support environment, or incident

3. Written support protocols and procedures

• A task-specific written protocol for each HIDPA performed — not a generic procedure, but one that names the participant, their health condition, the exact steps required, and any contraindications or warning signs
• Protocols signed off by the participant's treating health professional where delegation is required
• Version control on protocols with clear review dates
• Evidence that the worker has read and understood the protocol (signed acknowledgement)

4. Supervision and clinical oversight

• Documented supervision arrangements — who supervises, at what frequency, and in what format (direct observation, case review, clinical supervision)
• Records of supervision sessions completed, including any issues raised and actions taken
• Access arrangements to a qualified health professional for clinical advice — after-hours arrangements if the service operates outside business hours
• Escalation pathways documented and understood by all workers

5. Medication and treatment records

• Medication administration records (MARs) completed in real time for every dose administered, including the worker's name, time, and dose
• PRN (as-required) medication protocols with documented clinical rationale and review by the prescribing health professional
• Records of medication errors and near-misses, including incident reports lodged with the NDIS Commission where required under the incident management obligations
• Evidence of medication storage compliance

6. Incident reporting and management

• An incident management system that captures all HIDPA-related incidents, including near-misses
• Reportable incidents involving HIDPA notified to the NDIS Commission within the required timeframes (24 hours for immediate notification for serious incidents; five days for the written report)
• Evidence of post-incident review and corrective actions implemented
• Trend analysis showing the provider monitors HIDPA incidents for systemic issues

7. Participant consent and rights

• Documented, informed consent for each HIDPA task — consent obtained at enrolment and reviewed on any material change
• Evidence the participant understands the nature, risks, and alternatives to each task
• Records showing the participant's right to refuse or modify supports was communicated and respected
• Where a guardian or nominee provides consent, the legal basis and limits of that authority documented

8. Policy and quality management

• A HIDPA-specific policy that references the NDIS Practice Standards and the Commission's guidance on High Intensity Daily Personal Activities
• Evidence the policy was reviewed in the past twelve months or following a significant change
• Staff who can articulate the policy requirements during an auditor interview — this is a common non-conformance finding
• Continuous improvement records showing the organisation acts on HIDPA-related feedback, complaints, and incident data

Common non-conformances to address before audit day

A practical template: support protocol cover sheet

An approved quality auditor expects to see something like this at the front of each participant's HIDPA support protocol folder:

HIDPA Support Protocol — Cover Sheet

Participant name: [Full name]
Date of birth: [DOB]
Task: [e.g., PEG enteral feeding]
Risk rating: [High / Very High]
Authorising health professional: [Name, designation, AHPRA number]
Date authorised: [Date]
Review due: [Date — no more than 12 months]

Workers approved to perform this task:
1. [Name] — competency verified [date] by [assessor]
2. [Name] — competency verified [date] by [assessor]

Participant/nominee consent: [Name] — obtained [date] — form location: [file reference]

Escalation contact (business hours): [Name, role, phone]
Escalation contact (after hours): [Name, role, phone]

Store one cover sheet per task per participant and attach it to the full written procedure. Auditors frequently request to sight this during desktop document review.

Getting audit-ready

Working through this checklist pillar by pillar before your audit window opens will significantly reduce the risk of major non-conformances. If you are building or refreshing your HIDPA documentation suite from scratch, ndiscompliant.com.au provides a 74-document audit-ready SIL compliance kit that includes HIDPA-specific protocols, competency checklists, consent forms, and a self-audit mapping tool aligned to the NDIS Practice Standards — which can cut weeks off your preparation time.

Regardless of the tools you use, the most important discipline is this: every piece of evidence must be current, participant-specific, and show that your system is alive — not just documented. Auditors distinguish between a provider that has a policy and a provider that lives by it.