NDIS Incident Management Policy for Safety and Compliance

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Introduction

Bloom Healthcare desires to be known for providing quality service delivery and is sought out as a ‘participant provider of choice’. This includes having a clear process for the management and reporting requirements for incidents or alleged incidents that involve or impact participants during service delivery.

Bloom Healthcare management and employees are committed to:

• Ensuring the rights of people with disability are upheld and supported.
• Provide a high standard of duty of care and ensure the safety and well-being of each participant using our services, our employees, and members of our community.
• Fostering a culture of continuous improvement with a proactive approach to preventing incidents
• Promptly and appropriately responding to the incident in an equitable, objective, and fair manner
• Recording all incidents, reporting (if required) and investigating (if required)
• Ensuring the principles of procedural fairness are maintained by providing those affected an opportunity to give their side of the story and to comment on any adverse views
• Maintaining an incident management system to aid in recording, managing, and resolving incidents
• Ensuring the incident management policy and process is provided to participants and stakeholders via email or hard copy during onboarding and at any time by request.

This Incident Response and Management Policy outlines the processes and procedures to be followed in the event of an incident to ensure that any incidents are identified, assessed, contained, and resolved promptly and effectively.

Scope

This policy defines incidents including serious incidents and incidents which are reportable to a number of professional and governing bodies:

1. NDIS Quality and Safeguards Commission
2. Australian Health Practitioner Regulation Agency (AHPRA)
3. Office of the Australian Information Commissioner (OAIC)

An incident is broadly defined as:

• Acts, omissions, events, or circumstances that occur in connection with providing NDIS supports or services to a person with a disability and have, or could have, caused harm to the person with a disability.
• Acts by a person with a disability that occur in connection with providing NDIS supports or services to the person with a disability and which have caused serious harm, or a risk of serious harm, to another person.

Specific types of reportable incidents include:

• The death of a person with a disability.
• Serious injury of a person with a disability.
• Abuse or neglect of a person with a disability.
• Unlawful sexual or physical contact with, or assault of, a person with a disability (excluding, in the case of unlawful physical assault, contact with, and impact on, the person that is negligible).
• Sexual misconduct committed against, or in the presence of, a person with a disability, including grooming of the person for sexual activity.
• The use of a restrictive practice in relation to a person with a disability, other than where the use is in accordance with an authorisation (however described) of a State or Territory in relation to the person or a behaviour support plan for the person.
• Data breach or breach of personal information
• Injury or death of a worker while on duty 
• Any incident involving crimes such as assault, theft and fraud

This policy applies to all employees, and contractors at Bloom Healthcare.

Purpose

The purpose of this policy is to:

Ensure timely and effective responses are taken to address immediate participant safety and well-being.

Be accountable to participants for actions taken immediately and planned in response to their experience of a critical incident.

Ensure due diligence and responsibilities to participants are met.

Support the provision of high-quality services to participants through the full and frank reporting of adverse events.

Assure and enhance the quality of service and supports to clients through monitoring and acting on individual incidents as well as trends identified through the analysis of incident reports.

Support organisational consistency.

Ensure that identified deficits in service and support are addressed.

Roles and Responsibilities

All Employees and Contractors: Every employee and contractor of Bloom Healthcare is responsible for reporting all incidents to their manager, who will assess the situation to determine whether it is reportable. They should also identify potential witnesses and report the incident to their manager. They are responsible for providing support to participants in the event of an incident and ensuring that immediate needs are met, such as providing first aid medical attention and separating the alleged worker involved.

Managers: Managers are responsible for investigating all incidents and determining whether they are reportable. They will also be responsible for ensuring that the Incident Response Form is completed within 24 hours of the incident occurring.

NDIS Quality and Safeguards Commission: The NDIS Quality and Safeguards Commission is responsible for receiving reports of serious incidents and ensuring that appropriate action is taken.

Australian Health Practitioner Regulation Agency (AHPRA): AHPRA is responsible for the registration and accreditation of health practitioners in Australia. They need to be notified of incidents involving health professionals, such as abuse or negligence.

Office of the Australian Information Commissioner (OAIC): The OAIC is responsible for receiving reports of data breaches and ensuring that appropriate action is taken.

Procedure

Bloom Healthcare undertakes a 2 step process whereby the staff member will complete an electronic link regarding the incident, the manager will then complete a correction action plan. All information is stored within Bloom Healthcare’s appropriate data base

Allegations of abuse against Bloom Healthcare workers

The Director or their delegate will:

• Take all allegations of abuse seriously and clarify what is being alleged with the person who is making the allegation.
• In the case of an allegation of sexual misconduct, the Director or their delegate will immediately notify the police.
• Assess whether or not the child or young person is ‘at risk of significant harm’, and if so, make a report to the Child Protection Helpline.
• Determine whether or not the allegation is a reportable allegation, a reportable conviction, or reportable conduct.
• Report reportable allegations and reportable convictions to the Ombudsman within 30 days of receipt.
• Consider whether or not the police need to be informed of the allegation and, if so, make a report.
• Ensure confidentiality is maintained at all times and that systems are in place to deal with any breaches of confidentiality.
• Undertake a risk management approach after an allegation to ensure the protection and safety of children, staff members, contractors and volunteers. Based on this risk assessment, decisions will be made in order to manage the risks that have been identified.
• Develop an investigational plan for the matter. Obtain relevant information from a range of sources. This may include a statement from the person against whom the allegation had been made and any other relevant documentation.
• If the allegation is being investigated by the State or Territory authority or the Police, Bloom Healthcare will be guided by their advice as to whether they should independently investigate the allegation.
• If the investigation is carried out by Bloom Healthcare, the information that has been gathered will be assessed, and a finding made as to whether the allegation is false, vexatious, misconceived, not reportable conduct, not sustained or sustained. The reasons for the finding will be clearly recorded to ensure that the decision-making has been transparent.
• Advised the staff member/contractor/volunteer or student of the outcome of the investigation in writing. Advice will be provided about the investigation finding and any follow-up that may be required. Advice will also be provided about any rights of appeal, and the person will be advised that the Ombudsman has been notified, and the Commission of Children and Young Persons has also been notified of any relevant employment proceeding.
• All State and Territory relevant authorities will also be informed of the outcome of the investigation.
• Consider if the incident or allegation is reportable as per the Incident Management policy and procedure and is reportable to the NDIS Commission.
• Treat the staff member/contractor/volunteer or student with fairness at all times and uphold their employee rights at all times.
• Depending on the nature of the allegation, arrange to inform the person immediately.
• Arrange for the person against whom the allegation has been made to have a support person attend the meeting. This support person must not participate in the discussions throughout the meeting.
• Make accurate documentation of all conversations, and ensure that all records are being kept confidentially.
• Offer counselling or support to the person subject to the allegation.
• Depending on the nature of the allegation made, the person subject to the allegation may be suspended pending further investigation.
• After all investigations are completed, provide the staff member/contractor/ volunteer/student with verbal and written notification of the outcome of the investigation.

Training and supervision

• Training and supervision are important to ensure that everyone in our organisation
• Understands that child safety is everyone’s responsibility.

Bloom Healthcare’s culture aims for all staff and volunteers (in addition to parents/carers and children) to feel confident and comfortable in discussing any allegations of child abuse or child safety concerns.

The Management Team train staff and volunteers to identify, assess, and minimise risks of child abuse and to detect potential signs of child abuse.

Staff and volunteers are equipped with the knowledge, skills and awareness to keep children and young people safe through ongoing education and training.

New employees and volunteers will be supervised regularly to ensure they understand Bloom Healthcare’s commitment to child safety and that everyone has a role to play in protecting children from abuse, as well as checking that their behaviour towards children is safe and appropriate.

Any inappropriate behaviour must be reported to the Director or their delegate.

Staff found to be non-compliant with this policy are subject to appropriate disciplinary action by Bloom Healthcare, including, but not limited to, one or more of the following:

• Counselling;
• Further training and development;
• Demotion;
• Suspension;
• Warning;
• Referral to appropriate legal and regulatory bodies as appropriate;
• Termination of employment (with or without notice or any payment); or
• Termination of engagement (in the case of contractors)

Confidentiality

Bloom Healthcare will handle any allegation of any abuse and in particular child abuse in a confidential manner (refer to Privacy and Information Management Policy).

Record Keeping

Full, timely and accurate participant notes must be kept about cases of suspected, observed or alleged harm, risk of harm, abuse or neglect of participants.

Any incident or complaint-related documentation generated as a result of this policy must be kept in accordance with the Incident Management Policy and Procedure, Feedback and Complaints Management Policy and Procedureand Risk Management Policy and Procedure.

Policy Review

The policy will be reviewed after any reportable incident to ensure that it is up-to-date with current best practices in preventing and responding to child abuse incidents and allegations or as a result of legislative or regulatory change or improvement.

Training

All new employees and contractors will receive training on this policy during their induction. Bloom Healthcare will provide regular training to ensure that all employees and contractors are aware of this policy and understand their responsibilities.

Monitoring and Evaluation

Bloom Healthcare will monitor and evaluate the effectiveness of this policy on an ongoing basis, using feedback from employees, clients, and customers, as well as data detailed on the Incident Register.

The Director/s and management team will be responsible for ensuring that the policy is implemented effectively, and that progress is tracked and reported to relevant stakeholders.

Employees and contractors are encouraged to provide feedback and suggestions for improving the policy and related procedures.