SIL pricing and funding: documentation an auditor expects

Why pricing and funding documentation is a primary audit focus

Supported Independent Living (SIL) is one of the highest-cost, highest-complexity supports in the NDIS. Because a single SIL arrangement can draw on hundreds of thousands of dollars per participant per year, approved quality auditors place significant scrutiny on whether providers can demonstrate that every dollar claimed is properly authorised, accurately documented, and traceable to the participant's funded plan.

Under the NDIS Practice Standards and Quality Indicators, registered providers must maintain records that allow an auditor to verify compliance at the individual participant level — not just at an organisational policy level. The strengthened framework introduced ahead of mandatory registration in 2026 reinforces this expectation, with tighter requirements around transparency, participant rights, and financial accountability.

The non-conformances most likely to generate findings at audit are not dramatic fraud scenarios — they are paperwork gaps: missing or unsigned service agreements, rosters that do not reconcile with invoices, and support plans that describe a level of support that differs from what is actually being funded and delivered.

The exact documents an auditor will request

When an approved quality auditor arrives at your organisation for a SIL-related audit, expect them to request some or all of the following document categories. Having these ready in an organised format signals maturity and reduces audit time.

1. NDIS plan excerpts and budget confirmation

• A copy of the relevant section of each participant's current NDIS plan confirming SIL is an approved, funded support.
• Written confirmation (from the participant's planner or Local Area Coordinator) of the approved SIL hours or budget envelope where applicable.
• Evidence that the provider has confirmed the participant's plan is active and the support category (Assistance with Daily Life) has sufficient remaining funds before services are delivered.

2. Service agreements

• A signed service agreement for each participant that clearly states the supports to be provided, their frequency, and the price per unit of support referencing the current NDIS Pricing Arrangements and Price Limits.
• Evidence that the agreement was provided in an accessible format, that the participant (and/or their representative) had the opportunity to ask questions, and that consent was freely given.
• Any variations to the service agreement must themselves be documented and signed.

3. Rostering and timesheets

This is the area where audit findings are most common. Auditors will cross-reference rostered hours against:

• Actual hours worked (verified through timesheets, electronic scheduling systems, or sign-in/sign-out logs).
• Hours claimed in payment requests submitted to the NDIA.
• The agreed support schedule in the service agreement.

Where rosters are managed electronically, auditors may request system exports. Where timesheets are paper-based, they must be legible, dated, and counter-signed. Any unexplained discrepancies between rostered hours and claimed hours are treated as a potential non-conformance against the requirement to charge only for supports actually delivered.

4. Support plans linked to funded outcomes

• An individualised support plan (sometimes called a support schedule or behaviour support plan addendum) describing the daily and weekly supports each participant receives and their connection to the participant's NDIS goals.
• Evidence of regular review — auditors will check that support plans are not static documents dated years in the past.
• Where a participant's needs have changed, documentation showing that the service agreement and claimed support levels were updated accordingly.

5. Compliance with NDIS Pricing Arrangements and Price Limits

The NDIA publishes its Pricing Arrangements and Price Limits annually. Auditors do not set prices — but they do verify that the prices charged in service agreements and invoices do not exceed the applicable price limits for each support item, and that the correct support catalogue line items are being used. Common errors include:

• Using a weekday support item code for weekend or public holiday shifts (or vice versa), resulting in either over- or under-charging.
• Claiming provider travel at a rate not supported by the current pricing guidance.
• Billing for supports that fall outside the scope of what is listed in the participant's approved plan.

6. Incident and restrictive practices records connected to billing

Where a participant has an approved Behaviour Support Plan that includes the use of regulated restrictive practices, auditors will check that the support hours claimed include the supervision required under the plan — and that any incident reports filed are consistent with the staffing levels that appear on rosters for the same shifts. Inconsistencies between incident reports and roster data are a significant red flag.

How auditors sample and test your records

Approved quality auditors do not audit every participant. They apply a risk-based sampling approach, typically selecting a cross-section of participants that may include newly onboarded individuals, those with complex support needs, and those whose charges are at or near the applicable price limits. For each sampled participant, the auditor traces a complete thread:

1. NDIS plan confirmation → service agreement → support plan → roster → timesheet → payment request.
2. They verify that the support item codes used in payment requests match the nature of the support described in the service agreement.
3. They check that the dates and hours on timesheets align with what was claimed and that no claims were submitted before the relevant shift was completed.
4. They look for evidence that the participant has received a statement of supports — a record of what has been delivered and charged on their behalf — at the agreed frequency.
5. They confirm that the provider has a clear complaints and feedback process that participants are aware of, which is relevant to pricing disputes.

Common non-conformances and how to prevent them

Preparing your document management system

The NDIS Practice Standards require that records be stored securely, accessible to authorised staff, and retrievable promptly during an audit. In practical terms, this means:

• Each participant should have a single, clearly named electronic or physical file containing all the documents listed above.
• Documents must be legible and, where they contain handwritten entries, those entries must be dated and attributed to the person who made them.
• Your records retention policy should align with NDIS Commission guidance — at minimum, retain records for five years after the support was delivered, or longer if state or territory law requires it.
• Access controls must ensure that participant records are not accessible to staff who have no care relationship with that participant.

The strengthened 2026 framework — what changes for SIL providers

The strengthened NDIS Practice Standards, which take full effect with the 2026 mandatory registration renewal cycle, place greater emphasis on demonstrating outcomes rather than simply producing paperwork. For SIL pricing documentation, this means auditors will be looking not just for signed service agreements but for evidence that those agreements have been genuinely negotiated with the participant, that any changes to funded supports were communicated in plain language, and that participants have exercised meaningful choice over the support arrangements they are being charged for.

Providers who currently maintain robust paper trails but have limited evidence of participant engagement in pricing decisions should begin addressing this gap now, well before their next scheduled audit.

Pulling it together before your next audit

A structured pre-audit review should cover every participant file against the checklist above. Many SIL providers find it helpful to use a standardised compliance kit that maps each required document to the relevant Practice Standard indicator, reducing the risk of gaps. The 74-document audit-ready SIL compliance kit available at ndiscompliant.com.au is one option worth considering if you are building or overhauling your documentation framework ahead of a scheduled audit.

Whatever approach you take, the key principle is the same: the documentation trail must allow an external reviewer — who has no prior knowledge of your organisation — to follow every funded support from authorisation through to delivery and payment without needing to ask a single clarifying question.