Registration Groups for Support Coordination
Support coordination services fall under two separate registration groups in the NDIS provider registration framework. Understanding the difference between these groups is the starting point for any provider entering this market:
| Registration Group | Support Type | Target Participants | Audit Type |
|---|---|---|---|
| 0106 | Support Coordination | Participants who need help implementing their NDIS plan and connecting with supports | Verification |
| 0132 | Specialist Support Coordination | Participants with complex needs — multiple diagnoses, justice involvement, unstable housing, child protection involvement | Verification |
Support Coordination (0106) involves helping participants to understand and implement their NDIS plan, identify and connect with the services and supports they need, and build their capacity to manage their own supports over time. It is funded from the participant's Capacity Building budget under the "Support Coordination" support category.
Specialist Support Coordination (0132) is a more intensive support for participants with very complex needs that go beyond what standard support coordination can address. Specialist support coordinators typically hold relevant professional qualifications (social work, psychology, community services) and experience working with complex populations. It requires practitioners with specific skills and experience that go beyond the general competencies for support coordination.
Both registration groups require a Verification audit — the lower-level audit type. This reflects the fact that support coordination, while important, involves coordination and advocacy rather than direct physical care. The Verification audit focuses on document review: your policies, procedures, worker records, and a sample of participant files.
Verification Audit Requirements for Support Coordination Registration
The Verification audit for support coordination registration assesses compliance with the NDIS Practice Standards Core Module. The auditor will review a set of quality indicators relevant to your practice type. For support coordination providers, the indicators of greatest focus include:
- Person-centred practice: Evidence that support coordination services are directed by participants' goals and preferences, not driven by the coordinator's convenience or the provider's interests
- Conflict of interest management: This is the single most important indicator for support coordination providers. The auditor will look for a documented Conflict of Interest Policy, evidence of disclosures to participants, and documentation of how referral decisions are made
- Feedback and complaints: A functioning complaints process, accessible to participants
- Incident management: A documented process for identifying and responding to incidents, including incidents identified during support coordination activities (such as participant disclosures of harm)
- Worker screening: Evidence that all support coordinators have current NDIS Worker Screening Check clearances
- Governance: Evidence of sound organisational governance and financial management
For a small support coordination practice, the Verification audit is typically completed in half a day to a full day by a single auditor. The cost is generally between $800 and $2,500. Compared to the certification audits required for SIL or High Intensity providers, this is relatively manageable.
Policies Required for Support Coordination Providers
Every support coordination provider must have a set of documented policies and procedures that cover the core requirements of the NDIS Practice Standards. At minimum, these include:
- Conflict of Interest Policy (specific to support coordination)
- Complaints and Feedback Policy and form
- Incident Management Policy and incident reporting form
- Privacy and Confidentiality Policy
- Worker Screening Policy
- Code of Conduct
- Human Resources Policy (covering recruitment, induction, supervision)
- Risk Management Policy
- Governance Framework
- Quality Management and Continuous Improvement Policy
The policies must not be generic templates that could apply to any service type. They need to specifically address the support coordination context. The Conflict of Interest Policy in particular must be tailored to the specific conflicts that arise in support coordination — it cannot simply say "we manage conflicts of interest" without specifying how.
Support coordination providers who also deliver other NDIS supports (such as disability support workers, SIL services, or therapeutic supports) need policies that address the specific conflict of interest dynamics that arise from the dual role. A generic policy will not satisfy an auditor examining this area.
Conflict of Interest: The Central Compliance Issue for Support Coordination
Conflict of interest is the defining compliance issue for NDIS support coordination providers. The NDIS Commission has identified conflict of interest in support coordination as a systemic risk — the risk that participants do not receive genuinely independent support coordination because their coordinator is also their disability support provider (or is financially connected to one).
Under the NDIS Practice Standards, support coordination providers must demonstrate that they:
- Identify potential conflicts: Have a documented process for identifying when a real or potential conflict of interest exists, including conflicts arising from the organisation's own service delivery interests
- Disclose conflicts to participants: Proactively disclose identified conflicts to participants in writing, in plain language, at the time the conflict is identified — not just as a general statement at the start of the service agreement
- Document referral decisions: Record the basis for every referral recommendation made to a participant, including what other options were explored and why the recommended provider was selected
- Protect participant choice: Actively protect the participant's right to choose different providers, including providers who compete with the support coordination organisation's own services
- Review and update the policy: Regularly review the Conflict of Interest Policy and update it as the organisation's circumstances change
The NDIS Commission actively monitors conflict of interest in support coordination. Providers who both deliver support coordination and operate disability support services have been subject to compliance investigations where evidence shows that participants are consistently referred to the provider's own services without genuine exploration of alternatives. This has resulted in registration conditions, enforceable undertakings, and in serious cases, registration cancellation. Document your referral decisions — every time.
The practical implication is that support coordination organisations must have systems that create an evidence trail for every referral decision. This means case notes that document what providers were considered, what information was provided to the participant, and what the participant's own preference was. "Referred to [our own service]" is not sufficient documentation — the note must explain why, and what alternatives were offered.
Case Note Requirements for Support Coordinators
Case notes are the primary evidence base that demonstrates support coordinators are actively and appropriately serving participants. The NDIS Commission's compliance monitoring of support coordination consistently identifies inadequate case notes as a finding — and in some cases, missing case notes have led to findings of charging for services not delivered.
Compliant support coordination case notes must:
- Be dated and attributed to the specific coordinator who made them
- Document the specific action taken (phone call, meeting, research, referral) and its outcome
- Link the activity to the participant's goals and plan objectives
- Record decisions made and the participant's input into those decisions
- Document any referrals made, the basis for them, and what alternatives were explored
- Note any concerns identified about the participant's safety or wellbeing
- Be contemporaneous — written at or immediately after the interaction, not reconstructed later
A case note that says "Called participant. Discussed plan. Sorted service agreement" will not survive audit scrutiny. A compliant note documents what was discussed, what decisions were made, what actions were taken, and what the next steps are. The free Notes Rewriter tool can help support coordinators transform brief activity notes into detailed, compliant case note records.
Support coordinators should maintain records for every billable activity. The NDIS Commission and the NDIA have the power to request records to verify that services were actually delivered as claimed. Where records cannot demonstrate service delivery, the Commission may require repayment of NDIS funds claimed.
Setting Up a Compliant Support Coordination Practice
For providers establishing a new support coordination service, the following steps provide a practical pathway to registration:
- Develop your policy and procedure suite: Start with the Conflict of Interest Policy as your centrepiece. Build the full set of Core Module policies around it. Ensure every policy is contextualised to support coordination rather than being a generic disability support document.
- Set up your case management systems: Whether you use a dedicated software platform (Careview, ShiftCare, or another CRM) or a structured file-based system, your records management must be designed to capture the case note detail that auditors require. Test your recording system before you start delivering services.
- Complete worker screening: All support coordinators must have a current NDIS Worker Screening Check clearance before delivering services. Allow 4–6 weeks for the check to be processed.
- Develop your service agreement template: Your service agreement for participants must address support coordination specifically — including the conflict of interest disclosure, the scope of service, fees, and the participant's rights.
- Apply for registration: Submit your application through the NDIS Commission's provider portal, nominating Registration Group 0106 (and 0132 if relevant). The application includes your organisational details, key personnel information, and a self-assessment against the NDIS Practice Standards quality indicators.
- Engage an approved quality auditor: Following your self-assessment, the NDIS Commission will direct you to engage an NDIS-approved quality auditor to conduct the Verification audit. The auditor assesses your documentation and makes a recommendation to the Commission about your registration.
- Receive your registration decision: If the auditor recommends approval, the Commission will make a registration decision. Registration is typically granted for three years, after which a renewal audit is required.
Key Personnel Requirements for Support Coordination Organisations
All registered NDIS providers must nominate key personnel as part of the registration process. Key personnel are the people who have decision-making authority over the delivery of NDIS supports — typically directors, owners, managers, and anyone with significant operational control.
For support coordination providers, key personnel requirements include:
- All key personnel must have NDIS Worker Screening Check clearances (or equivalent state checks for transitional purposes)
- The organisation must notify the NDIS Commission of any changes to key personnel
- Key personnel must not be persons who have had their NDIS registration cancelled or suspended in the past
- The organisation must assess the suitability of all key personnel as part of its governance processes
The NDIS Commission's Key Personnel Suitability Assessment is conducted as part of the initial registration process and at each renewal. Providers should document this assessment in their governance records.
Common Compliance Failures Specific to Support Coordinators
The NDIS Commission's compliance monitoring activity has consistently identified the following as the most common compliance failures in support coordination:
1. Inadequate Conflict of Interest Documentation
Providers have a Conflict of Interest Policy but no evidence that it has ever been applied in practice. No disclosure records, no documentation of referral decision-making, no evidence that participants were offered choice.
2. Missing or Inadequate Case Notes
Case notes are sparse, vague, or absent for significant periods of service delivery. The NDIS Commission treats this as evidence of either inadequate service delivery or a risk of fraudulent claiming.
3. Incorrect Claiming
Support coordination providers claiming for activities that are not support coordination (claiming for direct support delivery under coordination codes, or for administrative activities at professional rates).
4. Inadequate Supervision and Support for Coordinators
Particularly in smaller organisations, support coordinators work in isolation without documented supervision or professional support. The NDIS Practice Standards require that workers have access to appropriate supervision — for support coordinators dealing with complex participant situations, this is a genuine quality and wellbeing issue.
5. Not Informing Participants of Their Rights
Participants are not informed of their right to change their support coordination provider, to seek a second opinion, or to raise concerns about the service. The participant's rights statement in the service agreement is present but not explained or discussed at service commencement.
The NDIS Commission's Focus on Support Coordination Quality
The NDIS Commission has made support coordination quality a specific strategic compliance focus. This reflects the systemic importance of good support coordination to participant outcomes and the NDIS's overall effectiveness. Providers should be aware that:
- The Commission conducts both proactive compliance monitoring and reactive investigations in the support coordination space
- Complaints from participants and families about support coordination quality are taken seriously and investigated
- The Commission has published detailed guidance on conflict of interest in support coordination that providers are expected to have read and implemented
- NDIS auditors assessing support coordination registrations are briefed to scrutinise conflict of interest evidence carefully
Need NDIS-Compliant Progress Notes?
The free Notes Rewriter helps support coordinators and support workers turn brief activity summaries into detailed, structured progress notes that meet NDIS documentation standards.
Try the Notes Rewriter — FreeImportant: 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.