What is Specialist Behaviour Support (Registration Group 0110)?
Registration Group 0110 — Specialist Behaviour Support — covers the provision of specialist behaviour support services to NDIS participants. This includes developing, reviewing, and monitoring behaviour support plans, conducting functional behaviour assessments, and providing ongoing guidance to participants, families, and support workers on behaviour support strategies.
Under the NDIS Act 2013 and the NDIS (Restrictive Practices and Behaviour Support) Rules 2018, the NDIS Commission has a specific regulatory function in relation to behaviour support. This reflects the recognition that restrictive practices — when used within behaviour support — carry inherent risk to participant rights, dignity, and wellbeing. The regulatory framework exists to minimise that risk.
It is important to understand that Registration Group 0110 is specifically for organisations that deliver specialist behaviour support services — that is, organisations that employ or engage approved Behaviour Support Practitioners to develop and oversee behaviour support plans. It is a separate and distinct registration from that required by providers who merely implement the strategies contained in a participant's behaviour support plan during support delivery.
However, a provider who implements a behaviour support plan that contains regulated restrictive practices — even without being a specialist behaviour support provider — has its own set of registration and reporting obligations under the Behaviour Support module of the NDIS Practice Standards.
What is a Behaviour Support Practitioner?
A Behaviour Support Practitioner (BSP) is an individual who has been assessed by the NDIS Commission as meeting the requirements to develop behaviour support plans for NDIS participants. Being an approved BSP is a personal approval — it attaches to the individual, not their employer or organisation.
The NDIS Commission assesses BSP applicants against a capability framework that specifies the knowledge, skills, and experience required to practise as a BSP. There are two levels of BSP approval:
- Proficient BSP: Can develop behaviour support plans for participants with moderate complexity needs. This is the entry level of approval and covers the majority of community-based behaviour support work.
- Advanced BSP: Can develop behaviour support plans for participants with high complexity needs, including those with significant risk of harm to themselves or others, complex co-occurring conditions, or highly complex restrictive practice authorisation requirements.
The NDIS Commission's BSP capability framework draws on a combination of formal qualifications (typically in psychology, social work, occupational therapy, speech pathology, or related fields), professional experience, and demonstrated competency in Positive Behaviour Support approaches.
BSPs must be engaged by an organisation registered under Registration Group 0110. They cannot legally develop NDIS behaviour support plans unless they are employed by or contracted to a registered specialist behaviour support provider. A BSP operating independently, outside of a registered organisation, cannot legally provide NDIS specialist behaviour support services.
The Relationship Between BSPs and Implementing Providers
One of the most commonly misunderstood aspects of the NDIS behaviour support framework is the distinction between the BSP's role and the implementing provider's role. These are separate legal and regulatory relationships.
| Role | Who Performs It | Registration Required | Key Obligations |
|---|---|---|---|
| Develop and oversee behaviour support plan | Approved Behaviour Support Practitioner (BSP) | Registration Group 0110 (through employer) | Functional assessment, plan development, plan review, monitoring outcomes |
| Implement plan strategies during supports | Disability support workers employed by the implementing provider | Core Module + Behaviour Support module (if regulated restrictive practices used) | Follow plan strategies, document implementation, report incidents, submit Section 15(2) reports |
The implementing provider — the organisation whose workers deliver day-to-day supports to the participant — has regulatory obligations even if it is not a specialist behaviour support provider. If the participant's behaviour support plan contains any regulated restrictive practices, the implementing provider must:
- Be registered under the NDIS Practice Standards Behaviour Support module
- Have a current, documented behaviour support plan on file
- Maintain records of each instance of restrictive practice use
- Submit monthly Section 15(2) reports to the NDIS Commission
- Maintain a Restrictive Practices Register
- Ensure workers implementing the plan have been trained in the strategies
- Notify the BSP and the NDIS Commission of any incidents involving restrictive practices
NDIS Practice Standards Behaviour Support Module
The Behaviour Support Module in the NDIS Practice Standards sets out specific outcomes and quality indicators that providers registered under this module must meet. These are in addition to the Core Module requirements that all registered providers must satisfy.
Key Outcomes of the Behaviour Support Module
Outcome 1: Positive Behaviour Support — Participants receive behaviour support that is grounded in positive, person-centred approaches. Supports aim to address the underlying causes of behaviour, not just manage the behaviour's expression. This outcome requires providers to demonstrate that their workers understand and implement PBS principles consistently.
Outcome 2: Restrictive Practice Minimisation — The provider has systematic processes to reduce and where possible eliminate the use of regulated restrictive practices. This includes evidence of transition plans developed collaboratively with the participant's BSP, tracking of restrictive practice usage trends, and regular review of whether authorisation conditions are being met.
Outcome 3: Rights Protection — The provider can demonstrate that participants' rights are protected throughout the delivery of behaviour support. Participants are informed about restrictive practices, their consent is considered, and there are clear processes for participants and families to raise concerns about restrictive practice use.
Positive Behaviour Support: The NDIS Framework
Positive Behaviour Support (PBS) is the evidence-based framework mandated by the NDIS Commission for all behaviour support work. PBS is not a technique or a set of strategies — it is a person-centred, values-driven approach that seeks to understand why a participant behaves in a particular way, and to address the root causes through environmental changes, skill building, and systemic support.
The key principles of PBS that are relevant to NDIS compliance include:
- Functional assessment: Understanding the purpose or function of a behaviour (communication, escape from demands, sensory stimulation, social interaction) before developing strategies to address it
- Proactive strategies: Changes to the environment, routine, and support approach that reduce the triggers for the behaviour — not just reactive responses after the behaviour occurs
- Skill development: Teaching the participant alternative ways to meet the needs that the behaviour currently meets
- Reduction and elimination of restrictive practices: PBS explicitly aims to minimise and ultimately eliminate the use of restrictive practices, not to use them as a permanent management tool
- Participation and consent: The participant and their support network are meaningfully involved in understanding the behaviour support plan and the strategies within it
Behaviour support plans that do not reflect PBS principles — that focus purely on consequence-based approaches or that use restrictive practices without a documented reduction plan — will not meet NDIS Commission standards and will be identified as deficient during audit.
What Counts as a Restrictive Practice?
Under the NDIS Act 2013 and the NDIS (Restrictive Practices and Behaviour Support) Rules 2018, a regulated restrictive practice is any practice or intervention that restricts the rights or freedom of movement of an NDIS participant. The NDIS Commission recognises five categories of regulated restrictive practice:
- Seclusion: Confining a participant to a space from which they cannot leave of their own free will
- Chemical restraint: Using medications to control or manage behaviour (as opposed to treating a diagnosed medical condition). This includes as-needed (PRN) medications used for behaviour management
- Mechanical restraint: Using a device to restrict a participant's movement (such as lap belts used for behaviour management rather than postural support)
- Physical restraint: Using physical force to restrict a participant's freedom of movement
- Environmental restraint: Restricting a participant's access to parts of their environment (such as locked cupboards, locked doors, restricted access to certain items) as a behaviour management strategy
It is important to note that these practices are only "regulated" when they are used for the purpose of managing behaviour. A medication prescribed by a psychiatrist to treat a diagnosed mental health condition is not a regulated restrictive practice. A bed rail used for postural support is not a regulated restrictive practice. However, the context and intent of the intervention determines whether it is regulated — and providers must be able to clearly articulate that distinction for every intervention in their participants' plans.
Unauthorised restrictive practices are a serious breach. Using a regulated restrictive practice that has not been authorised through the relevant state or territory process is an unauthorised restrictive practice. Providers must report unauthorised restrictive practices to the NDIS Commission as a reportable incident within 5 business days. Multiple findings of unauthorised restrictive practices can result in registration suspension or cancellation.
Authorisation Requirements: State-by-State Differences
One of the most complex aspects of the restrictive practices framework is that authorisation processes are state and territory-based. Each jurisdiction has its own legislative framework for authorising restrictive practices, and providers operating across multiple states must navigate different requirements in each.
| State/Territory | Authorisation Framework | Key Body |
|---|---|---|
| Victoria | Disability Act 2006, Senior Practitioner oversight | Senior Practitioner (DFFH) |
| New South Wales | National Disability Insurance Scheme (NSW Authorisation) Rules | NDIS Commission (interim arrangement) |
| Queensland | Disability Services Act 2006, restrictive practice authorisation | Senior Practitioner (QLD) |
| South Australia | Disability Inclusion Act 2011 | Office of the Public Advocate |
| Western Australia | Interim NDIS Commission authorisation arrangements | NDIS Commission |
| Tasmania / ACT / NT | Interim NDIS Commission authorisation arrangements | NDIS Commission |
Until full national consistency is achieved, providers must understand and comply with the authorisation framework in each state or territory where they operate. Failure to obtain the correct authorisation for a restrictive practice before implementing it constitutes an unauthorised restrictive practice regardless of whether the BSP has recommended the practice and regardless of whether the participant's family has consented.
Section 15(2) Restrictive Practice Reports
Section 15(2) of the NDIS (Restrictive Practices and Behaviour Support) Rules 2018 requires registered providers to submit monthly reports to the NDIS Commission for each participant where a regulated restrictive practice was used during that month.
These reports are commonly called Section 15(2) reports or restrictive practice reports. They must be submitted through the NDIS Commission's provider portal. Key details about these reports:
- Who submits them: The implementing provider (the organisation whose workers delivered the supports). Not the BSP, not the participant's family — the registered provider.
- When they are due: Monthly, for each month in which a regulated restrictive practice was used. Reports are typically due within a month following the reporting period.
- What they must contain: The participant's NDIS number, the type of regulated restrictive practice used, and the number of times it was used during the reporting period.
- What triggers the requirement: Any use of any of the five regulated restrictive practice types during the reporting month, whether or not the use was planned or unplanned.
Missing or late Section 15(2) reports are consistently identified as a compliance failure during audits. Providers must have a system in place for tracking restrictive practice usage month-by-month and ensuring reports are submitted on time. A Restrictive Practices Register — recording each instance of restrictive practice use, the date, the worker, and the circumstances — is the practical tool that enables accurate monthly reporting.
Documentation Requirements
Providers registered under the Behaviour Support module must maintain the following documentation as a minimum:
- Current behaviour support plan for each participant with a behaviour support need
- Evidence that the plan was developed or reviewed by an approved BSP
- Restrictive Practices Register recording each instance of regulated restrictive practice use
- Monthly Section 15(2) reports submitted to the NDIS Commission
- Evidence of state/territory authorisation for each regulated restrictive practice in use
- Worker training records showing workers have been trained in the behaviour support plan strategies
- Strategy implementation records (shift notes documenting how PBS strategies were applied)
- Incident reports for any incidents involving behaviour or restrictive practices
- Evidence of regular plan review (at least annually)
Progress notes for participants with behaviour support needs are particularly important and are commonly identified as deficient during audits. Notes must document the PBS strategies that were applied, how the participant responded, any environmental triggers that were observed, and any incidents or near-misses. The free Notes Rewriter tool can help support workers transform brief shift notes into structured, NDIS-compliant progress notes that capture this level of detail.
Common Compliance Failures in Behaviour Support
The NDIS Commission's compliance monitoring activity consistently identifies the following as the most common behaviour support compliance failures:
1. Behaviour Support Plans Not Current
Plans that are more than 12 months old without a documented review are a standard finding. Providers must actively track plan review dates and ensure the BSP is engaged to review plans before they lapse.
2. Missing or Late Section 15(2) Reports
Many providers do not have a reliable system for tracking restrictive practice usage and submitting monthly reports. This is often the result of workers not documenting when regulated restrictive practices are used, making it impossible to accurately complete the monthly reports.
3. Workers Not Trained in Plan Strategies
Workers are implementing supports for participants with behaviour support plans but have not been trained in the specific strategies in the plan. They may be unaware that a behaviour support plan exists, or aware of its existence but not its content.
4. Unauthorised Restrictive Practices
Providers are using regulated restrictive practices that have either never been authorised, or where the authorisation has lapsed. This is particularly common with environmental restraints, where locking arrangements or access restrictions have been in place for years but have never been formally authorised.
5. Inadequate Documentation of Restrictive Practice Use
Shift notes do not record when restrictive practices were used, making it impossible for the provider to demonstrate compliance with authorisation conditions or to accurately complete Section 15(2) reports.
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View the SIL Rescue Kit — $297Important: This article provides general guidance about NDIS compliance requirements. It is not legal or professional advice. Requirements may change as the NDIS Commission updates its policies and Practice Standards. Always verify current requirements with the NDIS Quality and Safeguards Commission or a registered NDIS consultant before making compliance decisions.