Did you see the Massive NDIS High Intensity Practice Standard Skill Descriptor’s Update?

Updated high intensity practice standard skill descriptors launched December 2022

As promised in my December LinkedIn post, Jo Kernot and I have spent the Christmas break reviewing the updated high intensity skills descriptors and have had many robust conversations about how we have interpreted the new document and what it means for registered providers. We acknowledge that there are many un-registered providers who are providing, and are committed to, quality supports but the reality is that un-registered providers can choose to ignore these large skill updates while registered providers cannot.

We are in full support of rigorous standards involving high intensity daily personal support. The risks associated with these types of supports and the potential impacts for people needing those supports mean there is an absolute need to be skilled, competent and extra vigilant.

I also applaud the Commission for embedding a focus on participant engagement and control, however to say this new document does not represent significant change is an understatement.

Changes include:

• Each skill descriptor now includes a scope of where the skill descriptor is applied and a context of support

There is also an implied onus on the Service Provider to ensure “The support plan is up-to-date, readily available, clear and concise and clearly identifies and describes the support needs and preferences of the participant”. This is somewhat problematic as the Service Provider has no formal relationship in the purchasing relationship of the participant and their health practitioner. Who deems if a report is clear and concise? Who pays for changes to be made if it is not? Where is the associated guidance to Health Care practitioners for developing these documents in the context of NDIS support to facilitate a Support Worker to understand.

• Each skill descriptor includes specific training stating

“NDIS providers are responsible for ensuring workers have current skills and knowledge, and that the training of workers is documented and regularly audited. It is recommended that a worker’s competency to provide complex bowel care supports are reviewed annually to confirm the worker has the current skills and knowledge described in this skills descriptor. Where a worker has not delivered this support for a period of more than three months, or if a participant’s support needs have changed and/or they have an updated support plan in place, it is recommended the worker be reassessed before supporting the participant and undertake refresher training if required; this timeframe may vary depending on the nature of supports required and worker experience”.

Providers who have been historically delivering training will need to review the content to ensure all areas of skills and knowledge are appropriately covered. Providers also need to review who is delivering their training as it states “Training should be delivered by an appropriately qualified health practitioner or a person who meets the expectations of this skills descriptor”.

• Each skill descriptor includes the exact skills and knowledge required

We interpret this to mean that auditors will quiz your team to ensure they know the information. If they don’t know or can’t find the information quickly, you are at risk of non-conformance. Providing training is no longer enough to be compliant. How are you ensuring your staff actually know what you have trained them?

The following knowledge points of the included practice standard skill descriptors I think are of interest

Complex Bowel Care has 25 points of knowledge, including things like:

• Relationship between nutrition, hydration, dietary fibre, probiotics, and bowel motions and stoma management.
• Common causes of bowel care problems such as constipation and faecal incontinence.

Enteral Feeding Support has 29 points of knowledge, including things like:

• Risks of poor oral health and how these can affect people who rely on enteral feeding
• The impact of associated health conditions and complications that interact with enteral feeding, for example, reflux, constipation, breathing difficulties and dysphagia, diarrhoea, vomiting and bloating.
• Strategies to improve mealtime experience of participants reliant on tube feeding

Dysphagia Support has 23 points of knowledge. Staff must know things like:

• Roles and responsibilities of others involved in supporting the participant at mealtimes including carers, health practitioners and other workers.
• Basic understanding of dysphagia and related factors that can make eating difficult such as mouth and dental problems, reflux, breathing difficulties, poor appetite, food intolerance, tiredness, poor health, and some types of PRN medication.
• Understanding of the Australian Dietary Guidelines for Healthy Eating and applying these to menu planning.

Ventilator Support has 22 points of knowledge. Staff must know things like:

• Types of ventilators, the main components including batteries, and their function.
• Musculoskeletal problems associated with respiration and common conditions that can result in respiratory failure, including condition/s specific for the participant.

Tracheostomy Support has 20 points of knowledge. Staff must know things like:

• Common health conditions that require tracheostomy support, including condition/s relevant for the participant such as, spinal injury, paralysis, chronic pulmonary disease, neuromuscular diseases, neck or mouth difficulties and structural differences.
• Common types of tracheostomy and stoma care equipment and participant specific equipment documented in the support plan, components, and functions including speaking valves, tracheostomy cuffs, heat moisture exchange machines, humidifiers, nebuliser devices, suctioning equipment, and speaking valves.

Urinary Catheter Support (In-dwelling Urinary Catheter, In-out Catheter, Suprapubic Catheter) has 18 points of knowledge. Staff must know things like:

• Basic anatomy of the male and female urinary system.
• The risks and health problems associated with using catheters, including urinary tract infections and skin integrity issues.
• Catheter insertion techniques appropriate to males and females to minimise infection risk and participant discomfort.

Subcutaneous Injection has 32 points of knowledge. Staff must know things like:

• The impact of variables that affect take up of medication for example, injection site location, rotation and timing.
• Understanding the relationship between glucose levels, nutrition, physical activity, weight, stress, and diabetes.
• Risks associated with different methods of delivering diabetes medication.
• Understanding how to use sliding scale charts to calculate medication dose where required by the support plan.

 Complex Wound Care Support has 17 points of knowledge. Staff must know things like:

• Common strategies to prevent pressure areas and worsening wound status including frequent repositioning (which may include prompting for the participant), appropriate diet to support healing and use of assistive equipment such as lymphoedema machines or assistive circulatory devices.
• Basic understanding of the process and stages of wound healing to identify improving or deteriorating conditions.

Epilepsy and Seizure Support has 19 points of knowledge. Staff must know things like:

• Common risks associated with seizures.
• The impact of associated health conditions on epilepsy.
• Common medication used to manage seizures and related contraindications and side effects.
• Observation parameters to identify early indicators of seizure onset, monitor seizures and observe following a seizure.

Interestingly Tracheostomy Support and Epilepsy and Seizure Support are the only skill descriptors to include the need for “First aid techniques to check and clear airways, administer CPR and place a person in a recovery position.”

Supporting Potential’s Questions to the Commission

This is a really valuable document for supporting people with a disability receive the competent care and support they deserve, but I question the launch of the new robust standards. Given these supports have only recently been determined as suitable for Support Workers to deliver, I have some questions for the NDIS Quality and Safeguards Commission, which have been forwarded to the commission – we will keep you posted as to their response:

• How are service providers being supported to increase the skill levels of their staff?
• Noting that Disability Support workers do not require any formal training, if staff require such a level of medical knowledge, are people with disability better supported by trained medical professionals who meet APRHA standards?
• How have training providers been notified that there is a higher standard that needs to be demonstrated?
• How are organisations funded to conduct both routine and adhoc competency assessments and who is qualified to do this?
• Are there enough resources in the Australian health professional sector to conduct the volume of competency assessments required in the timeframe required?
• Have health/allied health professionals been provided with templates or guidelines to ensure plans meet the skills descriptors?
• How have NDIS Quality Auditors been trained to understand these standards and how they present in practice?

Supporting Potential’s Conclusions

By releasing this document (very quietly) in the week before Christmas when organisations are on shoestring staffing, and for registered providers who will likely need to overhaul their training content and competency assessments and then expecting compliance in five weeks is unfair in my opinion and setting up Service Providers to fail.

These skills descriptors are absolutely a step in the right direction for quality services and supports, and for registered (and unregistered providers) who also strive for best practice.  It is heartening to see the commission release more comprehensive guidance, however the negative is again the lack of sector engagement in the roll out, leaving registered providers to once again bear the resource cost and responsibility for communicating with participants and their support networks.  It does not go to building a trusting relationship of working together to ensure People with Disability are at the heart of optimal support.

It will be interesting to see if these requirements will be reflected in price reviews for high intensity supports from the NDIA in June. My concern is the way these standards have been implemented will result in providers saying the risk/reward equation is no longer viable for us to provide this type of support and people with disability, who essentially need these services to live a good life will be left without or pushed to un-registered providers who won’t adhere to the quality standards.

Contact – Supporting Potential