NDIS High Intensity Daily Activities Module: Registration Requirements and Practice Standards (2026)

What is the High Intensity Daily Activities Registration Group?

Registration Group 0104 — Assistance with Daily Life: High Intensity — is a support category under the NDIS (Provider Registration and Practice Standards) Rules 2018 that covers a defined set of complex health-related supports. These are supports that carry elevated clinical risk and require workers with specialist qualifications, supervised practice, and documented competencies to deliver safely.

The High Intensity Daily Activities module is one of the supplementary modules in the NDIS Practice Standards framework. It sits on top of the Core Module, meaning any provider seeking this registration must fully satisfy both the Core Module requirements and the additional requirements in the High Intensity module. There is no shortcut to this — auditors assess both modules during a certification audit.

Under the National Disability Insurance Scheme Act 2013 (NDIS Act) and the rules made under it, the NDIS Quality and Safeguards Commission (the NDIS Commission) has statutory responsibility to ensure that registered providers meet minimum quality and safety requirements. For providers delivering supports to participants with complex health care needs, the High Intensity module provides the specific framework for how that safety is maintained.

It is important to understand that Registration Group 0104 itself covers all Assistance with Daily Life supports — including everyday personal care. The High Intensity module is triggered when the specific clinical support types listed below are included in the supports you deliver. If you only provide basic personal care such as showering, dressing, and meal preparation, you do not require the High Intensity module. The module is specifically required when workers perform invasive or clinically complex procedures.

Which Supports Fall Under High Intensity?

The NDIS Practice Standards High Intensity Daily Activities Module identifies seven specific support types that trigger the additional requirements. Each of these involves a level of clinical complexity that ordinary disability support workers — without specific health training — are not equipped to manage safely.

If your organisation provides any of these supports — even to just one participant — you must hold the High Intensity Daily Activities module registration. This applies regardless of whether the support is delivered in a SIL setting, as in-home support, or in a day programme context.

Why High Intensity Requires Certification (Not Verification)

Not all NDIS providers undergo the same type of audit. The NDIS Commission requires either a Verification audit or a Certification audit depending on the support types a provider is registered for. High Intensity Daily Activities always requires a Certification audit — the higher-level of the two.

The fundamental difference is this:

• Verification audits are conducted primarily through document review. The auditor assesses whether the provider's policies, procedures, and worker records meet the required standards. These are appropriate for lower-risk supports such as support coordination or therapeutic supports.
• Certification audits involve a much deeper assessment: document review, interviews with participants and families, interviews with workers, direct observation of practice, and on-site visits. They are conducted by NDIS-approved quality auditors and are significantly more rigorous.

The NDIS (Provider Registration and Practice Standards) Rules 2018 specify that Registration Group 0104 (High Intensity Daily Activities) requires a Certification audit because the risk to participants — if supports are delivered unsafely — is potentially life-threatening. Ventilator mismanagement can cause respiratory failure. Incorrect tracheostomy care can lead to tube dislodgement and airway compromise. The audit process reflects that level of risk.

For providers already registered under Registration Group 0104 for basic daily activities, adding the High Intensity module will require a variation audit of Certification type. The auditor will assess your High Intensity-specific policies, worker competency records, clinical governance structures, and participant Health Care Plans as a minimum.

Additional Qualifications Required for Workers

The NDIS Practice Standards High Intensity module requires that workers delivering high intensity supports have demonstrated competencies that are specific to the type of support they provide. The module does not prescribe a single qualification pathway — instead, it requires providers to demonstrate that workers are competent through a combination of:

1. Relevant formal health qualifications (where applicable)
2. Competency-based training specific to the support type
3. Supervised practice assessed by a qualified health professional
4. Documented competency sign-off
5. Ongoing review and refresher training

Registered Nurses and Allied Health Oversight

For the most complex support types — particularly tracheostomy management, ventilator management, and complex bowel care — the NDIS Commission's guidance strongly indicates that a Registered Nurse (RN) must be involved in training workers, conducting competency assessments, and providing clinical oversight. This does not necessarily mean an RN must be present during every support delivery, but the organisation's clinical governance model must include RN oversight of worker practice.

For enteral feeding (PEG and NG feeds), the relevant health professionals involved in worker training and competency assessment may include RNs and dietitians, depending on the complexity of the feeding regime. For subcutaneous injections (particularly insulin administration), competency assessment by an RN or diabetes educator is standard.

Certificate III and IV in Individual Support

Workers holding a Certificate III or IV in Individual Support (Disability) have foundational training, but this qualification alone is not sufficient to deliver High Intensity supports. These workers will require additional, specific competency-based training for each high intensity support type they deliver, assessed and signed off by a health professional.

In practice, many providers engage a Clinical Nurse Consultant or Registered Nurse on a sessional basis specifically to train workers, conduct competency assessments, and develop or review the organisation's clinical procedure guidelines for each High Intensity support type.

NDIS Practice Standards High Intensity Daily Activities Module Requirements

The NDIS Practice Standards document describes the High Intensity Daily Activities Module under a set of outcomes and quality indicators. The key outcomes specific to this module require providers to demonstrate the following:

Outcome 1: Comprehensive Health Supports

Participants receive supports that are consistent with their health care needs as identified in their individual Health Care Plans. This requires:

• A documented Health Care Plan for each participant receiving high intensity supports
• The Health Care Plan is developed in collaboration with the participant's treating health professionals
• Workers know and follow the specific procedures outlined in the Health Care Plan
• The plan is reviewed regularly and updated when the participant's health status changes

Outcome 2: Worker Competency and Training

Workers delivering high intensity supports have the skills, knowledge, and competencies required to safely deliver those supports. This requires:

• Documented competency assessments for every worker, for every high intensity support type they deliver
• Competency assessed by an appropriately qualified health professional
• A Training Register that tracks completion dates and scheduled review dates
• A process for retraining and reassessment when competency lapses or incidents occur

Outcome 3: Clinical Governance

The organisation has a clinical governance framework that ensures the safety of high intensity supports. This requires:

• Clearly documented clinical procedure guidelines for each high intensity support type
• A process for involving qualified health professionals in clinical decision-making
• An incident reporting and review process specific to high intensity support events
• Regular review of clinical guidelines by qualified health professionals

Key Quality Indicators

The NDIS Practice Standards include quality indicators for the High Intensity module that auditors use as assessment benchmarks. These are not optional — they represent the minimum evidence required to pass your audit. Key indicators include:

• Each participant's Health Care Plan is documented, current, and specific to the supports being delivered
• Workers can articulate the procedure they follow for each high intensity support and why
• Competency records exist for every worker delivering high intensity supports
• The organisation has written clinical procedure guidelines for each support type
• Clinical procedure guidelines have been reviewed by a qualified health professional in the last 12 months
• Incidents involving high intensity supports are recorded and reviewed with clinical input
• Workers know how to escalate concerns or emergencies related to high intensity supports
• Participants and/or their families have been involved in developing the Health Care Plan

Documentation Requirements

Documentation is the backbone of a High Intensity audit. The auditor will conduct file reviews for a sample of participants and workers, and will expect to find a comprehensive and consistent evidence base. The following documentation is required:

Participant-Level Documentation

• Health Care Plan: A document developed with the participant's treating health professionals that describes the support to be provided, the procedure to be followed, emergency protocols, and review arrangements. This must be participant-specific — a generic template with names inserted is not adequate.
• Risk Assessment: A risk assessment specific to the high intensity supports being delivered, identifying risk factors and mitigation strategies relevant to the participant's circumstances.
• Progress Notes: Shift notes documenting the delivery of high intensity supports must be detailed, objective, and complete. Notes should document what was done, how the participant responded, any deviations from the Health Care Plan, and any concerns or observations. The free Notes Rewriter tool can help workers transform brief shift notes into NDIS-compliant progress notes.
• Incident Reports: Any adverse event or near miss related to a high intensity support must be reported, documented, and reviewed. Certain incidents (such as respiratory events during ventilator management) may be notifiable to the NDIS Commission under the reportable incidents framework.

Organisational-Level Documentation

• Clinical Procedure Guidelines: Written procedures for each high intensity support type your organisation delivers. These must be evidence-based, current, and reviewed by a qualified health professional.
• Competency Records: A register or individual records documenting each worker's competency assessments, who conducted the assessment, the date, and the scheduled review date.
• Training Register: A matrix tracking which workers have completed which training, when, and when refresher training is due.
• Clinical Governance Policy: A policy describing how the organisation provides clinical oversight of high intensity supports, including the role of qualified health professionals in training, assessment, and review.

Transitioning from Informal to Formal High Intensity Supports

Many providers in the disability sector — particularly those who operate residential or group home services — have workers who have been delivering high intensity supports informally for years. The participant has always needed their catheter emptied, or has always had a PEG tube, and the workers have always managed it. But the organisation has never formalised the registration, the documentation, or the competency framework.

The transition to formal High Intensity registration requires a systematic approach:

1. Audit your current practice: Identify every participant who receives any of the seven high intensity support types. Map which workers deliver these supports and document what those supports involve.
2. Engage a clinical expert: Engage a Registered Nurse or other appropriately qualified health professional to review your current practice, develop clinical procedure guidelines, and conduct initial competency assessments of your workers.
3. Develop Health Care Plans: Work with each participant's treating health professionals to develop or formalise the Health Care Plans that describe the high intensity supports to be delivered and the procedures to be followed.
4. Complete competency assessments: Have every worker delivering high intensity supports assessed for competency by the clinical expert. Document the outcomes and schedule refresher assessments.
5. Update your policies and procedures: Review and update your Clinical Governance Policy, Incident Management Policy, and other relevant policies to specifically address high intensity supports.
6. Apply for registration variation: Submit your application to the NDIS Commission to vary your registration to include the High Intensity module. This triggers the variation audit process.
7. Prepare for the audit: Organise your documentation, brief your workers on what to expect, and ensure participant files are complete and current.

This process takes time — typically three to six months from start to audit. Do not underestimate the time required to develop clinical procedure guidelines, complete competency assessments, and build the evidence base the auditor will want to see.

Common Audit Findings for High Intensity Providers

Based on patterns observed across NDIS certification audits, certain deficiencies are commonly identified in High Intensity Daily Activities assessments. Being aware of these common findings allows you to address them proactively before your audit:

Finding 1: Inadequate Competency Evidence

The most common finding. Providers present online training completion certificates as evidence of worker competency. Auditors require evidence of assessed, observed practice — not just course completion. Ensure every competency record includes who assessed the worker, what they were assessed on, the date, and the assessor's signature.

Finding 2: Generic or Outdated Health Care Plans

Health Care Plans that are clearly template-based, lack specific procedural detail, or have not been reviewed in over 12 months consistently attract findings. Each plan must be participant-specific, reflect the current support needs, and show evidence of involvement from the participant's treating health professionals.

Finding 3: No Clinical Procedure Guidelines

Many providers lack written procedure guidelines for the high intensity supports they deliver. Workers may follow established practice, but without documented procedures that have been reviewed by a qualified health professional, the provider cannot demonstrate a safe and systematic approach to clinical governance.

Finding 4: Incident Reporting Gaps

High intensity support incidents are frequently underreported. Adverse events such as a participant refusing their feed, a catheter leak, or a wound that has deteriorated are not always being captured in incident reports. All adverse events and near misses involving high intensity supports must be documented and reviewed.

Finding 5: Insufficient Clinical Oversight Structure

Providers cannot demonstrate how qualified health professionals are involved in ongoing clinical governance. There is no evidence of regular review of clinical procedures, no documented process for escalating clinical concerns, and no clear line of clinical accountability within the organisation.

Providers who are preparing for SIL registration and who also deliver high intensity supports should ensure their Core Module documentation is fully in order before adding the High Intensity layer on top. The SIL Rescue Kit provides the complete set of Core Module policies, forms, and registers needed to satisfy the foundational requirements of a certification audit. Once your core documentation is in order, you can systematically build the High Intensity-specific documentation on top.