24 Hours. 5 Days. 7 Years: NDIS Compliance, Simplified
Small NDIS providers thrive on trust—and that trust now hinges on fast, precise incident reporting and rock-solid records. Here’s how one team translated the NDIS Commission’s Oct 2024 detailed guidance into a practical, scalable system that works for busy, remote-first operations.
1) Introduction: The Update That Resets the Clock
In October 2024, the NDIS Commission sharpened expectations: notify within 24 hours for death, serious injury, abuse/neglect, unlawful sexual or physical contact, and sexual misconduct. For unauthorised restrictive practices, notify within 5 business days—or within 24 hours if harm occurs. For a small provider juggling rosters and remote teams, this wasn’t just policy—it was a race against time.
What changed—and why it matters
- Clearer incident definitions and reporting timeframes.
- Stronger emphasis on accurate categorisation and evidence.
- Record-keeping that must stand up for at least 7 years.
Bottom line
Compliance isn’t paperwork—it’s protection for participants, staff, and your business.
2) Challenge: “What Exactly Is Reportable?”
The team’s first hurdle was confusion over categories. Registered NDIS providers must notify the NDIS Commission of all reportable incidents related to the delivery of NDIS supports or services. But frontline notes didn’t always match the guidance.
Symptoms we saw
- “Serious injury” logged as a “minor incident.”
- “Unlawful physical contact” phrased as a “client altercation.”
- Restrictive practice use noted without checking authorisation status.
The audit move
We cross-walked case-note phrases to the Commission’s incident categories so the same event couldn’t be called five different things. Usually only one registered provider reports a participant’s death—so we added a coordination step to avoid duplicate notifications.
3) Challenge: Restrictive Practices—Where Good Intentions Go Wrong
Misclassifying restrictive practices is a common non-compliance trigger. The rule: unauthorised use is reportable within 5 business days, or within 24 hours if it results in harm.
Practical examples
- Environmental restraint (locking a kitchen) used without current authorisation → report within 5 business days.
- Chemical restraint administered outside the behaviour support plan and the person is harmed → notify within 24 hours.
- Emergency use that isn’t in a plan → document, debrief, and assess authorisation pathway, then notify per rules.
Action signal
If it’s not in the plan or lacks active authorisation, treat it as unauthorised and trigger the reporting workflow.
4) Challenge: Beating the 24-Hour and 5-Day Timers
Remote workers, casual shifts, and weekend rosters made timing risky.
System fix
- Automated alerts: When an incident type is selected, the system starts a countdown (24-hour or 5-day) and pings owners on email, SMS, and Teams/Slack.
- Escalation rules: At T+12 hours (for 24-hour incidents) or T+3 days (for 5-day incidents), managers are auto-alerted.
- Templates: Pre-filled Commission forms reduce time-to-submit and cut errors.
Quote from the floor
“The clock starts the moment we know. Capture facts, classify fast, submit on time.”
5) Challenge: “Document Your Business or Get Out”
The founder put it bluntly: if it isn’t documented, it isn’t real.
Single source of truth
- Incident SOP library: Version-controlled workflows for every incident type.
- Role clarity: RACI mapped so remote workers know exactly who does what by when.
- Evidence standards: Photos, timelines, witness notes, and consent logs—collected the same way, every time.
Remote teams, consistent outcomes
Mobile-first checklists and short, gamified micro-lessons let casual staff follow instructions on shift. The mantra lived on the dashboard:
“Document your business or get out.”
6) Solution: The 10-Day Compliance Makeover
We ran a tight sprint to embed the Oct 2024 guidance.
- Internal audit (Week 1): Reconcile incident categories with the detailed guidance; sample 30 past incidents to find misclassifications.
- Timer automation: Build 24-hour/5-day alerts with escalation to managers and the quality lead.
- Form hardening: Mandatory fields for category, authorisation status, and harm; auto-attach evidence.
- Training refresh: 20-minute modules on reportable incidents, with quick-reference cards for shifts.
- 7-year retention: Lock retention policies and backups; tag records for the Provider Payment Assurance Program.
Outcome by Day 10
No missed notification windows in live tests; staff could classify correctly in under 60 seconds.
7) Results: Fewer Fires, Better Sleep
Two weeks after go-live, a real incident put the system to the test: an alleged unlawful physical contact. The support worker followed the checklist, the 24-hour clock started, and the manager was alerted instantly.
What improved
- Speed: Average time-to-notify dropped to 3.5 hours.
- Accuracy: Misclassification rate fell from 18% to 2%.
- Assurance: Records are organised, searchable, and retention-locked for 7 years—ready for Commission inquiries or payment assurance reviews.
Compliance posture
We operate under the NDIS Commission and NDIA frameworks and relevant Australian laws. The system doesn’t just meet rules—it proves we follow them.
8) Outro: Make Compliance Boring—and Automatic
Compliance should be predictable. Build the single source of truth, automate the clocks, and train for consistency. Do the internal audit this month, not next quarter—future you (and your participants) will thank you.
Your next 5 moves
- Map your incident categories to the Oct 2024 detailed guidance.
- Switch on automated 24-hour and 5-day alerts with escalations.
- Embed evidence standards and mandatory fields in your forms.
- Lock a 7-year retention policy with backups and access controls.
- Run a mock notification and debrief to close gaps within a week.
Related Links:
- NDIS Commission: Reportable incidents and incident management
- Detailed Guidance on Reportable Incidents (Oct 2024)
- NDIS Provider Compliance



