The System Audit Before the Real Audit: NDIS Registration Through a Functional Cognition Lens

If you're a clinic owner sitting on the fence about NDIS registration, this episode is going to reframe the whole thing for you. Getting registered isn't a compliance exercise — it's a systems assessment. And as OTs, systems assessment is literally what we do.

Imogen is currently going through the registration process herself and shares what she didn't see coming: why having great policies isn't enough, why the audit is really asking whether your clinic can function without you holding it all together, and how getting on top of your cognitive load and getting NDIS compliant are — almost exactly — the same project.

Including real examples from her own audit prep: Splose, Canyou, and the systems that actually made the difference.

Sign up to my newsletter.

Follow me on Instagram.
Connect on LinkedIn.

Transcript

SPEAKER_00 0:00

Welcome to Cognitive Capacity Chat. This is the podcast for the therapist ready to think beyond the therapy room. I talk about our cognition as our foundation, not just for our clients, but for ourselves. Because the way we think, organise, and live directly shapes our clinical work, our capacity, and longevity in this profession. I'm Imogen, an OT, here to bring you practical conversations that fit into real life. This podcast is for the therapist who wants more depth, more clarity, and more life. Welcome. Hello, welcome back to the cognitive capacity chat. This week I wanted to talk about something that's really live in the industry right now and very this week I have been going through it, and that is NDIS registration. Specifically, what it actually takes to get there. And I suppose what I wish I knew before I started. If you're a clinic owner or a sole trader working with NDIS participants and you're currently sitting on the fence whether to get registered or not, this episode is for you because I know there's a lot of noise at the moment. There's a lot of up in the air, differential pricing, changes to early intervention space, and whether registration is going to become mandatory. And I feel that most people should be await and see rather than trying to get registered and having that additional cost. But I decided to go ahead with getting NDIS registered because I felt like my company was already operating at the clinical integrity it was required to meet compliance. Unfortunately, we've passed our initial audit. So hopefully I continue with that good news story, but I will keep you posted if anything has come through. But I suppose what I wanted to show and highlight is that it's not just compliance, it's actually everything I teach around systems and cognitive load. And I wanted to be really transparent about my registration process because I am a really organized person. I have systems, I have processes across my clinical practice, I have onboarding workflows for my staff, policies, standard operating procedures. All of the infrastructure is there. And so I thought that getting registered is really the next logical step. And it just makes sense. I suppose I just didn't fully anticipate the amount of proof that you needed to provide that you were actually doing what your policies were saying that you were doing. It's not enough to just have a policy document. The audio auditor actually wants to see the policy is being followed and implemented across your team, across yourself. And I suppose that's something that I do when I needed to gather that information for her, but I didn't realize that I needed to do that at the start. At the start, I had just all the policies in my OneDrive file for her. And she's like, cool, that's great. But how are you actually implementing them? And that's when it clicked for me that it's not just the policies or the paperwork. It's actually about understanding the implementation, which is exactly what I teach from a functional cognition lens. Because your clinic systems, they actually need to function. They don't just need to be pieces of paper. They actually need to be how you operate and how you implement your clinical integrity. And so I want you to think about it like this. When we assess a client, we're not just asking, can this person do a task? We're asking, is the environment set up to support them, to do it reliably over time, across different conditions, across different scenarios? We know that this client has reduced processing speed or potentially executive functioning difficulties. So, how do we implement things that they can do or scaffold it so that when things fall apart, we're we're able to pick them back up, or we're able to get supports in, or we're able to use a compensatory strategy. And how you operate your organization, whether it's a clinic, a sole trader, you're a leader in the team, you need to be able to have an environment that supports your policy, supports your clinical integrity, your professional indemnity, everything that you are doing needs to be implemented. And you also need to be non-reliant. So if you were to step away, that your clinic can still operate, that you still have processes in place, that even if you weren't there, your clinic would be able to operate without you. Obviously, if you're from the only one providing services, that's a bit different. What I mean is if you are able to step away from your desk and go to hospital for six weeks, I hope you don't have to go to hospitals for six weeks. But if you do that, your lovely virtual assistant that you have working for you, or your husband who has no idea what they're doing but needs to be able to hold the clinic in place, can literally just look at your compensatory strategy, such as your planner, and be like, this is exactly the workflow that I need to do. Maybe it's your occupational therapy friend. Sorry, I'm just thinking aloud. So, what I want to do is give you two examples of my own registration process because that might assist you with understanding what I mean. So the first one is risk management. One of the practice standard areas is around managing risk and specifically being able to demonstrate the safety of staff and participants when we consider the home visit risk assessment. We have the policy and we have a form, but what I also had was a system that was showing we actually completed it. So I was doing tags in SPLUS to easily identify if it had been completed. This way, when the auditing comes up, I'm able to visibly show that I don't have just a random home visit risk assessment in my case notes. I actually it's actually trackable and it's not just sitting in anyone's memory to recall. We then have a process if risks are identified. We have that risk matrix in place so that when a high-risk situation comes up, staff aren't having to figure out what to do in the moment. This scaffold is already there. They're able to identify the risk and follow the matrix and put any safeguards in place, and then obviously bring it to me and make sure that I'm across what is happening in this risky situation. We should all be doing that anyway, but this is an NDIS compliance requirement, but we're just making it formal. Additionally, I was able to teach staff when I was onboarding that you need to complete that for NDI for your staff for your own safety. And so as a clinic, I should be providing them with that information regardless. The second example is professional standards. I think this is one that we, even as sole traders, should really be across and keeping track of everyone's APRA, police certificates, professional indemnity insurance, hand hygiene modules, the NDIS certificate certifications. All of these kinds of things is really easy to let slip, particularly if you're really busy, particularly if you're tracking it manually on Excel spreadsheet. That can be really tricky to keep on top of and remember to check that annually. What I use is an app called Can You, so C-A-N-Y-O-U. And it's free for small businesses, which is a great benefit. Basically, what you just upload all your certificates and you can put different expiry dates on it, get automatic notifications through email when it's due for renewal. And this just means that whenever anyone comes to me, because what happens when we become NDIS registered, you can get audited at any time. So, what happens if I get audited? I know my documentations are on top of them because I'm actually able to see that my staff can upload their certificates every time it expires. It doesn't just rely on me having memory, it doesn't just rely on me getting an email from an auditor saying, hey, we're going to do an audit in a week, and me worried that I'm going to need to get all my documents in line. It means that the systems are there to carry that uh compliance. Again, we should already or always be doing this, but it carries that compliance and it allows me to be operating at that high integrity standard at all times. But honestly, I implemented that because I was like, this is too much work on my cognition to hold all of these HR documents, to remember when people needed new things, to just get that email, get that document, and now it's just hand it over to the staff. The shortcut is there, it's easy, it's applied to my staff, relatively straightforward. I suppose what I didn't recognize, which I now do, and now I'm trying to hand over this wisdom, is getting NDIS compliant is effectively just getting on top of your cognitive load and managing your workflow effectively. Because what the practice standards are asking you to demonstrate is documented systems, consistent processes, evidence that things are happening the way they should. Then that's exactly what a well-managed cognitive load is in practice. So if you have a system for every process, if information is in the environment and not in your head, if your team can follow a procedure without needing to ask you every question, you are pretty much there. You're pretty much operating at an NDIS compliance standard. Which means that if you are sitting on the fence right now about registration, the most useful thing you can do is not wait on building those systems. Start building those systems now. Not because registration is looming and it may well be, but it also may well not be, but because systems are going to make you a better operator and less overloaded clinic owner and enable you to be a more present clinician and more present person in your life outside of work. And the registration outcome is almost just a byproduct of that. And I know this can be a really stressful situation, and I know right now we are all way over capacity just associated with the NDIS changes that may or may not be coming. This fear of unknown is really tricky. But to have more capacity in your life, you can actually engage in my five-day cognitive capacity. Reset is a private podcast. You get a podcast episode that's five to ten minutes, and then you get a workbook to go through to actually enable you to have more capacity, to actually be feel like you can tackle these sorts of things, these big scary things. Just by doing 20 minutes a day by reducing your cognitive load for five days can help you feel less overloaded by the likes of these NDIS changes. Because I know tackling something like NDIS registration feels impossible when you're already stretched. So I truly feel like you should jump in and do that if you're feeling like I don't even know where to start. You can find it just on my website, Imogen Ot.com.au. Otherwise, feel free to send me a DM. I'm more than willing to send you the link. And if you do feel like great, that's amazing, Imogen. It sounds like your systems and processes are really cool. But where do I even start? This is actually what I do. I love to do, I love to critically analyze people's systems, I love to make sure you're operating in a space that actually really supports your capacity and how you work. I could recommend all the different technology, but what I truly believe is everyone just operates slightly differently, and we need to recommend a product that is best for you and a system that and process that is best for you. And one to one mentoring is something I offer and I would love to spot you through as well. I hope this has helped you feel less intimidated by getting NDIS registered if that's something that you want to do. I will see you in the next episode. Thanks so much for listening.