NDIS Human Resources Policy: What Registered Providers Must Include

Why HR Policy is Central to NDIS Registration

The NDIS Quality and Safeguards Commission's registration framework is fundamentally about one thing: ensuring that the people who deliver supports to NDIS participants are safe, competent, and appropriately governed. The Human resources outcome (Outcome 2.6) of the Practice Standards Core Module is the primary mechanism through which auditors assess whether a provider has achieved this.

For a small SIL provider, the workforce is everything. Unlike large healthcare organisations with multiple layers of clinical oversight, a small provider often relies on individual support workers to make judgements and take actions that directly affect participant health and safety. The quality of those judgements depends on how well workers were recruited, screened, trained, supervised, and supported — and the HR policy is the document that governs all of these activities.

HR policy failures are also one of the most common pathways to serious participant harm. Providers that hired workers without completing worker screening checks, failed to identify qualifications that were fake, provided inadequate induction before workers commenced unsupervised shifts, or allowed serious misconduct to go unaddressed have all been subject to NDIS Commission enforcement action with devastating consequences.

Practice Standard Outcome 2.6: Human Resources

Outcome 2.6 is one of the broadest and most evidence-intensive outcomes in the Practice Standards. The quality indicators require registered providers to demonstrate that they:

• Recruit and employ workers who are suitable to work with people with disability, including completing all required pre-employment checks
• Provide workers with an appropriate induction before they commence unsupervised work
• Ensure workers maintain the qualifications, skills, and knowledge required for their role
• Provide regular supervision and performance management
• Have documented and fair disciplinary and termination processes
• Maintain a current register of all worker screening checks
• Ensure appropriate staffing levels for the supports delivered

The scope of Outcome 2.6 means that a single HR policy document is rarely sufficient on its own. Most providers need a suite of related documents — a separate recruitment policy, a supervision policy, a position description library — to fully evidence their compliance with this outcome. The Complete SIL Kit includes all of these documents, pre-drafted and ready to customise.

Recruitment and Pre-Employment Screening

The recruitment process is the first line of defence against unsuitable workers entering your organisation. Your HR policy must describe a structured recruitment process that includes:

• Position description review — every role has a current position description that specifies required qualifications, skills, experience, and personal attributes
• Advertising — how and where positions are advertised, and what information must be included (including notification that worker screening checks are required)
• Application assessment — how applications are shortlisted against selection criteria
• Interviews — structured interview questions that assess values, practice knowledge, and fit with your organisation's person-centred approach
• Reference checks — mandatory for all candidates, using structured questions that probe professional conduct and suitability to work with vulnerable people
• Qualification verification — original certificates must be sighted and copies retained on file
• Pre-employment checks — worker screening check, right to work in Australia verification, and any other mandatory checks

A common audit finding is that reference checks were either not completed or not documented. Your HR policy should make reference checks mandatory (not optional) for all workers, with a documented record of questions asked and responses received retained on the worker's personnel file.

NDIS Worker Screening Requirements

The NDIS Worker Screening Check is one of the most important pre-employment requirements for disability service providers. It is a mandatory check for all workers in risk-assessed roles — which includes virtually all direct support workers delivering NDIS services. Providers must not allow workers without a current clearance to commence or continue in a risk-assessed role.

The check is administered by the worker screening unit in each state and territory, not by the NDIS Commission directly. Workers apply for the check themselves, pay the applicable fee (which varies by jurisdiction and worker type), and provide the clearance ID to their employer. Employers must verify the clearance through the NDIS Commission's myplace portal or their state's equivalent system.

Your HR policy must address how screening checks are tracked — including expiry dates, what to do when a clearance is due for renewal, and your procedure if a worker's clearance status changes (for example, if an exclusion is imposed after employment commenced). The Worker Screening Register (maintained in your document system) must be kept current at all times.

Induction Requirements

Induction is the bridge between recruitment and unsupervised practice. A worker who commences an overnight shift in a SIL house without adequate induction is a risk to themselves and the participants in their care. Your HR policy must specify what induction must cover, in what timeframe, and what documentation must be completed before a worker commences unsupervised work.

The Complete SIL Kit's Staff Induction Checklist (Doc 32) provides a 26-item checklist covering all required induction topics. At minimum, induction must cover:

• NDIS Worker Orientation Module (completed before commencing work)
• Organisation's key policies and code of conduct
• NDIS Code of Conduct obligations
• Mandatory reporting — what to report, to whom, and when
• Participant rights and person-centred practice principles
• WHS induction — hazards in SIL settings, lone worker procedure, emergency procedures
• Infection control and hand hygiene
• Manual handling — theory and (where possible) practical demonstration
• Medication management procedures (where applicable)
• Participant-specific support requirements — supported by shadowing an experienced worker
• Emergency procedures for each allocated house (including individual evacuation plans)
• Incident reporting procedure

Mandatory Training Requirements

Training requirements for NDIS support workers extend well beyond induction. Your HR policy must specify the ongoing training obligations for all workers, including the training required at induction, annual refreshers, and role-specific training for workers with particular responsibilities.

All training must be recorded in the Training Register (Doc 45 in the Complete SIL Kit), with the training date, topic, delivery method, provider, and worker signature. Training records must be made available to auditors on request.

Supervision and Performance Management

Your HR policy must address the supervision and performance management obligations for all workers. This includes the frequency of formal supervision sessions, the documentation requirements, and the process for managing workers whose performance is below expectations. These obligations are covered in more detail in the companion NDIS Supervision Policy guide.

Performance management is a distinct but related process to supervision. When a worker's performance falls below acceptable standards, there must be a documented, fair process for identifying the concern, communicating expectations, providing support and an opportunity to improve, and — where improvement does not occur — progressing to formal disciplinary action. Your HR policy must describe this process and ensure it complies with applicable employment law (including the Fair Work Act 2009 for most employees).

Annual performance reviews are best practice and are increasingly expected by auditors. Doc 34 (Performance Review Template) in the Complete SIL Kit provides a structured template for conducting and documenting annual reviews.

Staffing Ratios in SIL

The NDIS does not publish fixed staffing ratios for SIL settings — staffing levels are determined by the NDIS planner based on each participant's assessed needs and documented in the participant's NDIS plan and SIL funding decision. However, your HR policy must address how you manage staffing to meet those planned levels, and how you respond when staffing falls below required ratios.

Common staffing scenarios that your policy should address include:

• Minimum staffing for overnight shifts (many SIL houses have a single overnight worker)
• Staffing escalation for participants with complex support needs or behaviours of concern
• Sick leave and unplanned absence management — how do you fill a shift at short notice?
• Escalation procedures when you cannot fill a required shift
• Use of agency or labour hire workers — and the verification requirements for worker screening and qualifications

A failure to staff SIL houses to planned ratios can constitute a breach of the participant's service agreement and may need to be reported as an incident if the shortfall affects participant safety.

Position Descriptions

Every role in your organisation must have a current, documented position description. Auditors will request position descriptions as evidence that roles are clearly defined and that workers understand their responsibilities. A position description must include:

• Job title and reporting line
• Employment type (full-time, part-time, casual)
• Primary purpose of the role
• Key duties and responsibilities
• Required qualifications and certifications
• Required skills, experience, and attributes
• NDIS Practice Standards the role is responsible for
• Pre-employment screening requirements (worker screening check, police check if applicable, right to work verification)

Doc 61 in the Complete SIL Kit provides a complete position description for a SIL Support Worker that can be adapted for your organisation and specific support environment.

Disciplinary and Exit Procedures

Your HR policy must describe a fair, documented process for managing disciplinary matters and worker separations. This includes the steps for managing misconduct allegations (which may require immediate suspension pending investigation), the process for conducting a disciplinary investigation, the possible outcomes (counselling, formal warning, termination), and the process for managing a worker's exit from the organisation.

When a worker is terminated for reasons related to participant safety — including abuse or neglect — there may be an obligation to notify the NDIS Commission and the relevant worker screening unit. Your HR policy must specify who is responsible for making these notifications and the timeframes that apply. Failure to make required notifications can itself constitute a compliance breach.

Exit procedures should also include the return of keys, security codes, and any organisational equipment, de-activation of system access, and a process for collecting feedback from departing workers that may identify organisational issues requiring attention.