The Six Reasonable and Necessary Criteria (Section 34, NDIS Act 2013)
Section 34 of the National Disability Insurance Scheme Act 2013 establishes the legal framework for what the NDIA will fund. A support must satisfy all six criteria to be included in a participant's plan. However — and this is the point most providers miss — the criteria don't just apply at the planning stage. They define the standard your organisation's documentation must meet on every shift, every session, every day.
The six criteria are:
- The support must be related to the participant's disability
- The support must represent value for money
- The support must be likely to be effective and beneficial to the participant
- The NDIA must take into account what is reasonable to expect families, carers, informal networks and the community to provide
- The support must be most appropriately funded or provided through the NDIS (not another system)
- The support must be consistent with the goals and aspirations in the participant's plan
Providers who understand these criteria and write notes that address them are in a fundamentally stronger compliance position than providers who write generic notes about what happened during a shift. Let's examine each criterion in detail.
Criterion 1: Related to the Participant's Disability
The first and most fundamental test is whether the support is needed because of the participant's disability. The NDIS does not fund general-purpose services that anyone might use — it funds supports that are specifically required because of the functional impacts of disability.
For providers, this means your documentation must connect the support to the participant's disability. A shift note that says "assisted John with showering" is incomplete. A compliant note says "assisted John with showering due to his limited upper body mobility and fine motor impairment caused by his cerebral palsy, consistent with his NDIS plan goal of maintaining personal hygiene independently where possible."
The disability connection should be established once in depth (in the participant's support plan) and then referenced concisely in each shift note. Auditors expect to see a thread from the participant's functional assessment, through the service agreement, to the daily shift notes.
Criterion 2: Value for Money
The value for money criterion requires that the cost of the support is commensurate with the benefit delivered. For registered providers, this is largely addressed by the NDIS Pricing Arrangements and Price Limits — if you are charging at or below the price limit and delivering the support as described, the value test is generally met.
However, value for money also requires that you are not delivering more support than the participant needs. Over-servicing — providing supports that exceed what is required to address the participant's needs — fails the value for money test even if you are within the price limits. This is a particular concern in SIL environments where staffing ratios may be set above participant needs for provider convenience rather than participant benefit.
Documentation for value for money
Your service agreement and support plan should document the rationale for the staffing ratio and support hours. If you provide two staff for one participant, your records need to justify why — for example, the participant's behaviour support plan requires two-person prompting for personal care, or the participant's manual handling needs require a two-person lift.
Criterion 3: Likely to Be Effective and Beneficial
The NDIS funds supports that are likely to produce measurable benefit for the participant. This means supports should be evidence-based (or at least rationally connected to a therapeutic or functional outcome) and should demonstrably help the participant achieve their goals or maintain their functional capacity.
For SIL and daily support providers, this criterion is met by documenting progress toward goals in shift notes. Notes that show the participant's skills are developing, their independence is increasing, or their safety is being maintained all satisfy criterion three. A flat, repetitive note that says the same thing every shift — with no indication of how the participant is progressing — raises questions about whether the support is achieving anything.
Criterion 4: Takes into Account Informal Supports
The NDIS does not fund supports that family members, carers, or the participant's community would ordinarily provide. This is the "informal support" or "natural support" test. The NDIA expects that where a participant has willing and capable family members who can reasonably provide certain supports, NDIS funding should not duplicate those supports.
For providers, this means you should be aware of the participant's informal support network and document situations where informal supports are absent or unavailable. If a participant's family is overseas, or is unable to provide care due to their own health issues, that is relevant context for your documentation. If a participant explicitly does not want family involvement in their support, that too should be documented as part of respecting Core Module Outcome 1.1 (Person-centred supports) and Outcome 1.4 (Independence and informed choice).
Criterion 5: Most Appropriately Funded by the NDIS
The NDIS is not a substitute for other funded systems. Health care is primarily the responsibility of Medicare and state health systems. Education is the responsibility of the education system. Employment support may be available through other government programs. The NDIS funds only those disability-specific supports that are not the responsibility of another system — or where the other system cannot adequately meet the participant's disability-related needs.
Providers need to be cautious about delivering supports that overlap with health or education funding. Nursing care, for example, might be appropriate under NDIS in some circumstances (where the participant's nursing needs are disability-related and not adequately addressed by the health system) but not in others. When in doubt, document the rationale for why NDIS is the appropriate funder.
Medication administration is frequently misclassified. Routine medication administration by support workers must be specifically funded in the participant's plan and must comply with NDIS high-intensity support requirements. Providers delivering medication support without appropriate registration, training, and documentation risk serious compliance findings. See the medication management policy guide for detail.
Criterion 6: Consistent with the Participant's Goals
This is the criterion with the most direct impact on how you write shift notes. Every support delivered under NDIS should be consistent with — and ideally, actively progress — the participant's NDIS plan goals. Goals are documented in the participant's plan as statements about what the participant wants to achieve or maintain.
Providers who don't reference goals in their shift notes are creating a documented gap between what the participant's plan says should happen and what your records show is happening. This is the single most common audit finding for SIL providers.
How Progress Notes Must Link to NDIS Plan Goals
Goal-linking in shift notes does not have to be complex. A brief, explicit reference is sufficient. When onboarding a new participant, your intake process should document the participant's key NDIS goals. Your shift note template should prompt support workers to reference at least one goal per entry.
Consider this before-and-after example:
| Non-compliant note | Goal-linked compliant note |
|---|---|
| "Assisted Sarah with meal preparation. She was happy. No incidents." | "Assisted Sarah to prepare a two-course dinner, with verbal prompting at each step. Sarah independently measured the pasta portions and set the table without prompting — progress toward her goal of building meal preparation skills for greater independence. No incidents. She expressed satisfaction with the meal." |
| "Took Michael to the shops. He bought some food." | "Supported Michael to travel to Woolworths by public bus (first time unassisted boarding — required one verbal prompt for Opal card). Michael completed grocery shopping using his list with minimal support. This supports his goal of independent community access. Return trip completed independently. No incidents." |
The free NDIS Notes Rewriter tool helps support workers transform basic notes into goal-linked, compliant documentation in seconds. It identifies missing elements — including absent goal references — and produces notes that satisfy auditor expectations.
Common Audit Findings: Notes That Fail the Test
NDIS auditors reviewing provider documentation regularly find the same patterns. Understanding these common failures helps you proactively prevent them in your organisation:
- Generic, repetitive notes: The same note template repeated every shift with only the date changed. No indication of participant progress, engagement, or goal work.
- No disability connection: Notes that describe what happened but never explain why the participant needed support. "Assisted with showering" with no reference to the functional limitation.
- No goal reference: Notes that document activities but never connect them to the participant's NDIS plan goals.
- Missing incident documentation: Situations that should have triggered an incident report (even minor) that appear in shift notes only as a passing comment.
- Time discrepancies: Notes that claim a certain number of support hours but contain internal evidence that contradicts this (e.g., activities described suggest a shorter actual engagement).
- Subjective language: Notes using terms like "had a good day," "seemed happy," or "was difficult." Auditors look for objective, behavioural descriptions.
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Try the Notes Rewriter — FreeDocumentation Tips for Each Criterion
| Criterion | What to document | Where in your records |
|---|---|---|
| Related to disability | The functional limitation that requires the support | Support plan, service agreement, shift notes |
| Value for money | Rationale for staffing levels and hours; link to assessed needs | Support plan, SIL assessment (if applicable) |
| Effective and beneficial | Participant's progress toward goals; skill development observed | Shift notes, progress reports, goal tracking |
| Informal supports considered | Availability/absence of family/carer support; participant preferences | Support plan, intake assessment |
| Appropriately NDIS-funded | Why this support is not covered by another system | Support plan, specialist reports if relevant |
| Consistent with goals | At least one goal reference per shift note | Every shift note and session record |
For more detail on how to write NDIS-compliant progress notes, see our comprehensive guide on how to write NDIS progress notes.
Important: 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.