Preamble
BigDog Support Services Pty Ltd (BigDog) ensures that each participant is protected through an incident management system which ensures that incidents are acknowledged, responded to, well-managed and learned from.
BigDog provides service responses that meet the needs of individuals whose lives are impacted upon by disability. From time-to-time critical incidents occur involving participants within a service structure, it is important that BigDog workers are conversant with their responsibilities when and if a participant critical incident should arise.
BigDog is committed to be an employer of choice, and to providing a safe and healthy workplace free from abuse, harassment or bullying. It is crucial that all critical incidents are reported in order to undertake the appropriate assessments and to ensure a safe work environment.
As these situations are all unique and the dynamics surrounding them are often vastly different, BigDog workers must be extremely mindful of their responsibilities in a range of areas prior to proceeding.
2.6.1 Incident Management System
BigDog maintains an incident management system through which complies with the requirements under the National Disability Insurance Scheme (Incident Management and Reportable Incidents) Rules 2018.
CareMaster
CareMaster’s robust incident tool lets BigDog coordinators quickly manage and view incident reports through the desktop/cloud app. Incidents can be categorised according to severity, record staff, participants and witnesses involved, as well as record actions taken. CareMaster can also log property and vehicle related incidents, such as car crashes and property damage.
2.6.2 Incident Management Information
BigDog ensures each participant is provided with information on incident management, including how incidents involving the participant have been managed.
All information is to be secured and presented to the Directors as soon as possible. It is to be kept in the strictest confidence and secured through administrator only access of the CareMaster software.
All involved parties will be requested to complete written reports of the critical incident. Reports should contain the facts as observed firsthand by the individual who is doing the reporting. The reporting should only contain straight forward description of the event or incident in chronological order. Emotive or subjective language should be avoided and instead the report should accurately describe what was observed.
All actions by BigDog are to be recorded and all workers will avail themselves to any external investigation honestly and openly. Workers should not enter into speculative or uncollaborated information but should simply record and pass on to the Directors
Note: It is important not to contaminate information by adding to it with personal opinion or innuendo, leave the investigation up to those in positions to do this appropriately.
For participants who use augmented or alternative communication methods, they will be assisted to give a report utilising their communication methods. External advocacy or support will be supplied if required.
The company solicitor and insurance broker are to be contacted by the Directors or the Operations Manager in all instances that may result in legal proceedings and/or insurance claims.
2.6.3 Continuous Improvement of Incident Management
BigDog demonstrates a continuous improvement in incident management by regular reviews of incident management policies and procedures, review of the causes, handling and outcomes of incidents, seeking of participant and worker views, and incorporation of feedback.
There is a separate policy for Continuous Improvement
2.6.4 Informing Workers of Incident Management Systems
BigDog ensures all workers are aware of, trained in, and comply with the required procedures in relation to incident management through CareMaster and NGO Training.
Reportable Incidents
NDIS (Incident Management and Reportable Incidents) Rules 2018
The incidents that must be recorded and managed are:
Acts, omissions, events or circumstances that occur in connection with providing NDIS supports or services to a person with disability and have, or could have, caused harm to the person with disability
Acts by a person with disability that occur in connection with providing NDIS supports or services to the person with disability and which have caused serious harm, or a risk of serious harm, to another person
Reportable incidents that are alleged to have occurred in connection with providing NDIS supports or services to a person with disability.
BigDog is responsible for, identifying, managing and resolving incidents. CareMaster incident management system includes procedures for identifying, assessing, recording, managing, resolving and reporting incidents. BigDog must ensure that we respond appropriately and take steps to prevent such incidents from happening again.
BigDog is required to keep the records on our incident management system (including records about reportable incidents) for a period of 7 years.
The above list is not exclusive and may be added to if determined by the level of an incident.
NDIS Quality and Safeguards Commission
The NDIS Commission is an independent government body that works to improve the quality and safety of NDIS services and supports, investigates and resolves problems, and strengthens the skills and knowledge of providers and participants.
As a registered NDIS provider, BigDog must notify the NDIS Commission of all reportable incidents (including alleged reportable incidents) that occur (or are alleged to have occurred) in connection with the provision of NDIS supports or services we deliver, even where we have recorded and responded within CareMaster incident management system. It is a condition of our registration that we comply with the NDIS Quality and Safeguards Rules about notifying them of reportable incidents.
The NDIS Commission may take action in response to a reportable incident, where required. This may include requiring BigDog to undertake specified remedial action, carry out an internal investigation about the incident, refer the incident to another body, or engage an independent expert to investigate and report on the incident.
Upon review of specified actions undertaken by BigDog a determination may be made to refer a matter on to another function within the NDIS Commission.
For an incident to be reportable, a certain act or event needs to have happened (or be alleged to have happened) in connection with the provision of supports or services.
Subsection 73Z (4) of the NDIS Act states that reportable incident means:
the death of a person with disability (24 hrs)
serious injury of a person with disability (24 hrs)
abuse or neglect of a person with disability (24 hrs)
unlawful sexual or physical contact with, or assault of, a person with disability (24 hrs)
sexual misconduct, committed against, or in the presence of, a person with disability, including grooming of the person with disability for sexual activity (24 hrs)
use of a restrictive practice in relation to a person with disability where the use is not in accordance with an authorisation (however described) of a state or territory in relation to the person, or if it is used according to that authorisation but not in accordance with a behaviour support plan for the person with disability. (5 business days)
Child Safety
The Child Protection Act 1999 defines critical incidents as responding to and reporting events which negatively impact, or have the potential to negatively impact, on the safety, well-being, and best interests of a child in care and is covered in-depth in a separate policy. There will be occasions where a child under Child Safety will also be a NDIS participant. Incidents are divided into Critical Incidents, Major Incidents and Incidents of significant concern which includes circumstances in which BigDog is concerned that a child in care has suffered, is suffering or is at an unacceptable risk of suffering, significant harm caused by physical or sexual abuse.
Workplace Health and Safety Queensland (WHSQ)
By law, certain incidents are notifiable to WHSQ. An incident is notifiable if it arises out of the conduct of a business or undertaking and results in the death, serious injury or serious illness of a person, or involves a dangerous incident.
Violence toward workers, volunteers, work experience students, contractors or individuals by a participant
Violence toward another person by workers, volunteers, work experience students, contractors or individuals
Serious injury, incident or accident to an worker, volunteer, work experience student, contractor or visitor including the amputation of any part of the body, a serious head, eye, skin, lacerations or a spinal injury.
Death of a worker, volunteer, work experience student, contractor or visitor
Sexual abuse or harassment (actual or alleged) toward workers, volunteers, work experience students, contractors or visitors
Abuse of a worker, volunteer, work experience student, contractor or visitor or allegation or suspicion of abuse
Dangerous events
Queensland Police Service (QPS)
If police are not required to attend immediately, complete an online form or contact Policelink on 131 444.
Adult sexual assault
Domestic violence
Home break-in
Missing person
Property damage and graffiti
Suspicious activity
Violence that cannot be contained by BigDog staff
Vehicle accident or incident
Vehicle break-in or theft
Procedures
Support Staff
What to do in an emergency:
1. If safe to do so the participant must be protected immediately by removal from the situation
2. Dial 000 and ask for Ambulance, Fire or Police and describe the nature of the incident and the assistance required
a. If overhead power lines have fallen notify the relevant electricity entity or Police.
3. Administer first aid if required.
a. Do not touch anyone who is receiving an electric shock. Turn off power or free the person with a non-metallic item.
b. Nothing should be touched or moved unless it is to administer first aid, or there is further risk of property damage.
c. Nothing further should be touched upon the determination that the Participant is deceased.
4. BigDog Administration or “On Call” must be called and notified fully of the incident verbally in the first instance
5. Follow all reasonable instructions from the coordinator
6. Any witnesses to the incident should be noted for later reference
7. The staff member must then record an Incident Report including as much relevant information as possible on CareMaster
Management
Administration, On Call and Coordinators will:
1. Document all information and take appropriate steps to secure the safety all persons involved in the interim
2. Immediately contact a director and advise of the incident and seek further instructions
3. Provide Support Staff with instructions
4. A director will complete the notification to the NDIS Commission or give appropriate direction to the coordinator.
5. A director will notify other appropriate people depending upon circumstance. Incident notification should occur as soon as possible after the above mandatory responsibilities are attended to
6. Notifications are brief until official investigations and reports are complete
7. No information should be given to an external authority until legal representation is gained.
It is important that the on-call coordinator record all pertinent information. Sequence the information and the time of all notifications with phone numbers, the person contacted and the time of the contacts as well as the corresponding instructions from a director
Directors’ Responsibilities
A Director will:
1. Report the incident immediately through the NDIS Commission website within 24 hours
2. Instigate an investigation through the appropriate means determined by the type of incident and the complexity of the situation.
3. Investigations are to remain as pure in process as possible with the emphasis upon ensuring Natural Justice to all parties.
4. Advise the appropriate NDIS Commission officer of any internal investigations’ findings and act upon any reasonable request of that officer in relation to future risk prevention.
5. Debrief workers and professional counselling offered if required or requested by the affected staff member(s).
6. Assist any individual to gain access where appropriate to external advocacy, legal representation or counselling.
7. Assist the alleged perpetrator if a participant, to gain access where appropriate to external advocacy, legal representation or counselling.
8. Review the incident at a management meeting with a view to secure future situation preventing possible reoccurrence.
In addition to incident reporting requirements under the NDIS Commission, in Queensland, a death in care under the Coroner’s Act 2003 (QLD) must be reported immediately to the Coroner or Police.
Summary
As outlined in the NDIS (Incident Management and Reportable Incidents) Rules 2018, incidents that must be recorded and managed include incidents where harm, or potential harm, is caused to or by a person with disability while they are receiving NDIS supports or services.
Disciplinary Action
BigDog recognises that the most serious incidents occur as a result of an accumulation of several factors and events all conspiring together. Workers should be encouraged to report incidents without fear of disciplinary action in a culture of learning, not of blame.
Fear of disciplinary action may deter workers from reporting a critical incident. The view of BigDog is that disciplinary action should not form part of the response to an incident except in cases where one or both of the following apply:
Where the actions causing the incident/arising from the incident were far removed from acceptable practice.
Where there is failure to report an incident in which the worker was either involved or about which they were aware.
Failure to report an incident or event is seen as a very serious matter and will result in performance management.
Positive Behaviour Support
Positive behaviour support is an approach that is responsive to a participant’s needs. It requires a thorough understanding of a person and their behaviour in order to determine the best ways to support them.
Using positive behaviour support ensures the focus is always on the individual and is responsive to their needs.
If a restrictive practice is being used to support an adult with an intellectual disability who exhibits challenging behaviour, a positive behaviour support plan is required.
Supporting Documents Policies
ABC Form
CareMaster Incident Report
Client Risk Assessment
Incident Report
Information
ABC Reporting Reference Material
Human Services Quality Framework October 2021 Version 8
Incident Flowchart
Indicators of Abuse Assault Neglect
NDIS Code of Conduct
NDIS (Incident Management and Reportable Incidents) Rules 2018
NDIS Practice Standards November 2021 Version 4
NGO Training
ABC Reporting
Child Safety Critical Incidents
Child Safety Major Incidents
Comprehensive Health Assessments
Keeping safe at work
Transitions of Care
Legislation
Child Protection Reform and other Legislation Act 2022 (QLD)
Disability Services Act 2006 (QLD)
Disability Services and Inclusion Act 2023 (Cwth)
National Disability Insurance Scheme Act 2013 (Cwth)
NDIS (Provider Registration and Practice Standards) Amendment Rules 2021
Privacy Act 1988 (Cwth)
Safe Work Australia Act 2008 (Cwth)
Work Health and Safety Act 2011 (Cwth)
NDIS Practice Standards and Quality Indicators
BigDog Support Services Pty Ltd (BigDog) is a registered NDIS provider and is required to apply the scheme’s practice standard and quality indicators.
The standards have been developed to create an important benchmark to assess provider performance and ensure that high quality and safe supports and services are provided to NDIS participants.
The four core modules are:
1.0 Rights and Responsibilities;
2.0 Governance and Operational Management;
3.0 The Provision of Supports; and
4.0 The Support Provision Environment.
The supplementary modules cover:
5.0 Specialist Support
5.1 High intensity daily personal activities.
5.3 Implementing behaviour support plans.
2.6 Incident Management
Each participant is safeguarded by the provider’s incident management system, ensuring that incidents are acknowledged, respond to, well-managed and learned from.
2.6.1 An incident management system is maintained that is relevant and proportionate to the scope and complexity of supports delivered and the size and scale of the organisation. The system complies with the requirements under the National Disability Insurance Scheme (Incident Management and Reportable Incidents) Rules 2018.
2.6.2 Each participant is provided with information on incident management, including how incidents involving the participant have been managed.
2.6.3 Demonstrated continuous improvement in incident management by regular review of incident management policies and procedures, review of the causes, handling and outcomes of incidents, seeking of participant and worker views, and incorporation of feedback throughout the provider’s organisation.
2.6.4 All workers are aware of, trained in, and comply with the required procedures in relation to incident management.
Human Services Quality Framework
The Human Services Quality Standards set a benchmark for the quality of service provision. Each Standard is supported by a set of performance indicators which outline what an organisation is required to demonstrate to meet that standard.
1 Governance and Management
Sound governance and management systems that maximise outcomes for stakeholders.
1.4 BigDog management systems are clearly defined, documented and monitored and (where appropriate) communicated including finance, assets and risk.
1.5 Mechanisms for continuous improvement are demonstrated in BigDog management and service delivery processes.
4 Safety, Wellbeing and Rights
The safety, wellbeing and human and legal rights of people using services are protected and promoted
4.2 BigDog proactively prevents, identifies and responds to risks to the safety and wellbeing of people using services.
4.3 BigDog has processes for reporting and responding to potential or actual harm, abuse and/or neglect that may occur for people using services.
Delegation of Authority
Version Details
This policy will be reviewed every twelve (12) months unless circumstances deem it necessary to review earlier. The review process will involve an analysis of the usefulness of the policy and to note any changes which are required to improve the policy. If minor changes are made in wording or to clarify the intent, the version number will indicate this by adding a ‘point’ i.e. Version 1.0 indicates the original version and 1.1 with the first round of minor changes made. A significant change or intent of the policy will be indicated by a whole new number i.e. Version 2.0.
The following rules also apply in interpreting this policy:
• Headings are for convenience only and do not affect interpretation.
• A singular word includes the plural and vice versa.
• A word that suggests one gender includes the other genders.
July 2012 1.3 Changed several words “serious” to “critical” that had been missed in the original change of policy
Changed “where substantiated sexual abuse” to “where suspected sexual abuse”
October 2012
October 2013
by Community Committee 15th October 2012
Standards replace Service Standard Indicators Training sub-heading added to Supporting Documents February
July 2016
Expanded on the term ‘staff’ to include ‘employees, volunteers, work experience students, contractors’
Expanded on definition section
Changed ‘Participant Incident Report’ to ‘Critical Incident Report’
Changes to the procedure – administration section.
Added information on how to report under ‘Information’ Added to contact insurance broker if necessary
August 2017
Added reference to Department of Communities, Child Safety and Disability Services Corporate and Executive Policy, Critical Incident Policy January
Date V Details
January 2021
January 2022
January 2023
January 2024
Front cover updated to Standards colour identification
Supporting Policies updated
5.1 Updated Responsible Officers details
Changed ‘the director’ to ‘the directors’ Introduction of BigDog Training Portal and modules
5.2 Updated officers, training modules and Practice Alerts
NDIS Practice Standards November 2021 Version 4
6.0 Included Human Services Quality Standards and Child Protection Act and the term “Participant” is returned to “Client” to allow for policies to cover NDIS and Child Safety.
6.1 Disability Services Act 1986 replaced with Disability Services and Inclusion Act 2023 and policy review process included.