NDIS Practice Standard: High Intensity Daily Personal Activities explained (2026)

What is the High Intensity Daily Personal Activities Practice Standard?

The High Intensity Daily Personal Activities (HIDPA) module is a supplementary NDIS Practice Standard that applies to registered NDIS providers delivering personal care tasks requiring clinical skill or posing a heightened risk of harm to participants if performed incorrectly. It sits within the broader NDIS Practice Standards framework, which the NDIS Quality and Safeguards Commission administers under the National Disability Insurance Scheme Act 2013.

Unlike the Core Module — which covers general supports — the HIDPA module imposes additional, more demanding quality and safety obligations. Providers whose registration groups include high intensity personal activities cannot simply meet the Core Module requirements; they must demonstrate compliance with the HIDPA module at audit. Under the strengthened framework progressively taking effect through 2026, these obligations are being tightened further to address persistent gaps in complex-care competency across the sector.

Who Does This Apply To?

You are subject to the HIDPA Practice Standard if your organisation is registered — or seeking registration — under any NDIS registration group that includes high intensity personal activities. Common registration groups that trigger this module include:

• Daily activities (which can include complex personal care)
• Daily tasks and shared living (SIL)
• Assistance with daily life where high intensity tasks are explicitly within scope

SIL providers are particularly exposed because participants living in supported accommodation frequently require supports such as complex bowel management, PEG (percutaneous endoscopic gastrostomy) feeding, tracheostomy management, and ventilator support — all of which fall within the HIDPA scope.

Providers delivering solely low-risk personal care (for example, showering assistance or medication prompting) without any high intensity tasks do not need to meet this supplementary module. If you are unsure whether your registration scope includes HIDPA, check your certificate of registration or contact the NDIS Commission directly.

What High Intensity Tasks Are Covered?

The NDIS Commission has identified specific tasks as high intensity. These include, but may not be limited to:

• Complex bowel care (including digital bowel stimulation and manual evacuation)
• Urinary catheter management (including suprapubic catheters)
• Enteral feeding and management (PEG and nasogastric tubes)
• Subcutaneous and intramuscular injections
• Tracheostomy management
• Ventilator management
• Dysphagia support (management of swallowing difficulties, including modified texture diet preparation)
• Complex wound management
• Seizure management involving emergency medication administration

The Commission has published guidance noting that this list reflects tasks where an error or omission carries a realistic risk of serious injury or death. The strengthened 2026 Practice Standards reinforce that providers must have specific systems — not generic clinical policies — for each task type they are registered to deliver.

Core Requirements Under the HIDPA Module

There are four interlocking areas of obligation that auditors assess under the HIDPA Practice Standard.

1. Worker Competency and Currency

Workers performing high intensity personal activities must hold current, verified competency for each specific task. Competency must be:

1. Established through a recognised training pathway — typically a Registered Training Organisation (RTO) course or clinical trainer sign-off from a qualified health professional (for example, a registered nurse or physiotherapist).
2. Documented in the worker's file, including the date of assessment, the assessor's credentials, and the specific task(s) assessed.
3. Reviewed and refreshed at a frequency determined by the participant's support plan and clinical guidance — currency is not indefinite.

A common non-conformance at audit is treating a general disability support worker certificate as sufficient evidence of HIDPA competency. It is not. Competency must be task-specific and evidenced separately.

2. Individualised Support Plans and Health Action Plans

Each participant receiving high intensity support must have an individualised support plan that includes a health action plan (or equivalent) addressing the specific high intensity task. This plan must:

• Be developed in consultation with the participant and, where appropriate, their allied health professional, GP, or specialist
• Describe the procedure, equipment, and contingency steps in sufficient detail for a competent worker to follow without ambiguity
• Be reviewed whenever the participant's health status or clinical guidance changes, and at minimum annually
• Be physically accessible at the point of care — not locked away in a head-office system a support worker cannot access on a Sunday night

3. Clinical Governance and Oversight

Providers must have a clinical governance framework that covers high intensity supports. This does not mean every provider must employ a nurse, but it does mean:

• A named, appropriately credentialled person or contracted clinical advisor is responsible for oversight of high intensity tasks
• There are documented processes for escalating concerns about a participant's health status to a clinician
• Incidents involving high intensity tasks are reviewed with a clinical lens — not merely processed as administrative complaints
• Policy and procedure documents are reviewed by a qualified health professional, not solely by management

4. Incident Management and Continuous Improvement

The NDIS Commission requires providers to have a functioning incident management system. For HIDPA, this means high intensity-related incidents — including near-misses — must be recorded, classified, and reviewed with enough rigour to identify systemic issues. Providers must also be able to demonstrate that lessons learned are fed back into training, procedure updates, and support plan revisions. Under the strengthened 2026 framework, the Commission has signalled closer scrutiny of whether providers' continuous improvement processes are genuine or merely procedural box-ticking.

Consequences of Non-Compliance

Non-conformance against the HIDPA Practice Standard carries real consequences. At audit, findings can result in:

• Conditions on registration — limiting the scope of supports you can deliver until issues are remediated
• Banning orders and suspension — in cases of serious or repeated non-conformance
• Deregistration — removing your ability to deliver NDIS-funded supports entirely
• Compliance notices and enforceable undertakings — legally binding remediation obligations

Beyond regulatory action, the practical consequences of a HIDPA failure during service delivery can be catastrophic for participants. The Commission's compliance framework exists precisely because inadequate complex-care practices have caused serious harm.

Preparing for a 2026 HIDPA Audit: A Practical Step List

1. Map your HIDPA tasks. List every high intensity task type currently delivered across all participants. Do not rely on what is written in registration paperwork — verify against actual support plans.
2. Audit worker competency records. For each task type, confirm every worker who performs it has current, task-specific competency documentation on file.
3. Review each participant's health action plan. Check that plans are current, signed off by an appropriate clinician, and accessible at the point of care.
4. Identify your clinical governance lead. Document who holds clinical oversight responsibility and what their credentials are.
5. Run a mock incident review. Take a recent HIDPA-related incident and trace it through your system — was it classified correctly? Was a clinician involved in the review? Was a corrective action logged and followed up?
6. Check policy currency. Confirm that your HIDPA procedure documents reflect current clinical guidance (for example, updated continence or dysphagia guidelines) and have been reviewed by a qualified health professional within the past year.
7. Document your continuous improvement loop. Be ready to show an auditor a concrete example where a HIDPA finding or near-miss led to a documented change in practice.

Policy Excerpt Template

Policy: High Intensity Daily Personal Activities — Complex Bowel Care
Version: [X.X] | Review date: [DD/MM/YYYY] | Approved by: [Clinical Lead, credentials]

Purpose: To ensure all workers delivering complex bowel care to NDIS participants do so
competently, safely, and in accordance with each participant's individualised health
action plan.

Scope: All support workers, team leaders, and rostered staff delivering complex bowel
care at [Organisation Name].

Competency requirement: Workers must hold current task-specific competency assessed
by a Registered Nurse or accredited RTO trainer prior to independent practice.
Competency is reviewed [annually / as directed by clinical lead / on change in
participant condition].

Procedure: Refer to each participant's Health Action Plan (HAP) for participant-
specific instructions. The HAP is accessible via [system/location]. Do not proceed
if the HAP is unavailable or out of date — escalate to [clinical lead contact].

Escalation: If the participant shows signs of pain, bleeding, or obstruction, stop
the procedure, contact the on-call nurse/clinical lead immediately, and document
in [incident system].

Providers building or auditing their HIDPA documentation suite may find it useful to work from a structured compliance kit. The 74-document SIL audit-ready compliance kit at ndiscompliant.com.au includes HIDPA policy templates, health action plan formats, competency assessment checklists, and clinical governance frameworks aligned to the 2026 Practice Standards — a practical starting point for providers who need to move quickly.

The 2026 Strengthened Framework: What Has Changed

The NDIS Commission's strengthened Practice Standards, phased in through 2026, place greater emphasis on demonstrable outcomes rather than policy existence alone. Auditors are increasingly expected to look for evidence that a provider's systems actually work — for example, by reviewing real incident records, interviewing workers, and spot-checking individual participant files — rather than simply verifying that a policy binder exists. For HIDPA providers, this means a well-formatted but unenforced policy is unlikely to satisfy a diligent auditor. The bar for evidence of genuine clinical governance has risen.