Incident Management Procedures
1. Introduction
An incident is defined as an act, omission, event or circumstance that could have, or did, lead to unintended and/or unnecessary harm; that could adversely impact the well-being and safety of our clients and employees. NeuroRehab Allied Health Network aims to provide effective management of incidents in accordance with our obligations under the NDIS Act 2013, its associated rules and practice standards.
2. Purpose
These procedures provide employees with an effective, standardised system of reporting and managing incidents. It also tells management about problems so that work practices can be reviewed to reduce the likelihood of the incident happening again.
This procedure will:
Provide means of quickly identifying unmet needs for extra support or training
Provide a picture of developing patterns of incidents, which may necessitate a change in work practices in order to better safeguard our clients and employees
Provide a record of the incident in case later reference is needed.
3. Responsibilities
All employees are responsible for implementing this procedure. The Director and Organisational Integrity Officer are responsible for monitoring and responding to incidents, the team leaders and staff are responsible for ensuring that incident reports are completed and sent to the Director and Compliance office for logging in the incident register. The Management is responsible for reviewing incidents to identify patterns or issues that may require a review of policies and/or change in work processes and practices.
4. Procedure
When an accident occurs employees must:
Ensure the immediate safety of clients and other employees and render First Aid if required;
Call 000 – if required (Police, Fire, Ambulance) – refer to Adverse Incident Policy;
Immediately notify families, carers and guardians of a Severe or Major incident and if a client is injured;
If the incident is a Severe or Major incident, notify the Team Leader, Director and Organisational Integrity Officer by phone or email as soon as is practicable, no later than two (2) hours following the incident occurring;
If the incident is a Moderate or Minor incident notify the Team Leader, Director and Organisational Integrity Officer by phone or email within 24 hours of the incident occurring;
Complete a NeuroRehab Allied Health Network Incident and Hazard Report within 12 hours of the incident occurring and submit it to the Director, Head of Clinical Services and Organisational Integrity Officer via email: steve@nrah.com.au and integrity@nrah.com.au
If required, the incident will be reported externally.
5. Incident Categories
Minor Incident
Minor injury to a client or their carer – First Aid not required;
Minor injury to an employee – First Aid not required;
Verbal abuse;
Minor property damage.
Moderate Incident
Injuries to employees requiring First Aid;
Injuries to clients or carers requiring First Aid;
Significant property damage.
Severe or Major Incident
Severe injury to employees requiring medical treatment or hospitalisation;
Severe injury to clients and/or carers requiring medical treatment or hospitalisation;
Any incident involving the Police, Fire or Ambulance service;
Death of a client or person with a disability;
The abuse or neglect of a person with a disability; unlawful sexual or physical contact with or assault of a person with a disability, sexual misconduct committed against, or in the presence of, a person with a disability, including grooming of the person for sexual activity;
Events which may be of significant interest to the media.
6. Investigation and assessment of incidents
Following the incident, an assessment will be completed with regard to the following issues:
whether the incident could have been prevented;
how well the incident was managed and resolved;
what, if any, remedial action needs to be undertaken to prevent further similar incidents from occurring, or to minimise their impact; and
whether other persons or bodies need to be notified of the incident.
The outcome of the assessment will determine what further action should be taken, which could include:
providing ongoing support to impacted people with disability and/or ensuring the ongoing wellbeing and safety of impacted people with disability;
identifying and implementing practice improvement measures;
notifying the NDIS Commissioner and/or other bodies or agencies, if appropriate;
undertaking further investigation;
identifying and taking corrective action to prevent a reoccurrence of incidents; or
deciding no further action is necessary.
The outcome of the assessment will be recorded on NeuroRehab Allied Health Network’s Incident Register.
7. Process for initiating and conducting investigations
In some circumstances it may be necessary to conduct a more formal investigation to establish the cause of a particular incident, its effect and any operational issues that may have contributed to the incident occurring.
Process for conducting internal and external investigations:
All incidents will undergo internal investigation by the Director or delegated employee.
The approach, process undertaken, findings and recommendations of the internal investigation will be documented in a way that is proportionate to the severity of the incident.
If police are involved, an internal investigation should not commence until the police have completed their inquiries.
Severe, Major and any incidents involving assault, sexual assault and/or hospitalisation of a client will require an external investigation to be conducted by an appropriately qualified investigator. Refer to the NDIS Commission’s NDIS Procedural Fairness Guidelines during the course of conducting any investigation into an incident.
8. Support to clients
If a client is injured whilst receiving services from us, employees must ensure they receive medical attention appropriate to the severity of the injury.
In the event of a serious incident e.g. assault, team members should offer counselling to affected clients.
A NeuroRehab Allied Health Network delegate will invite the client to be involved in the management of the resolution of the incident and this will be recorded.
9. Notifying the NDIS Quality and Safeguard Commission
9.1 Incident notification to the NDIS Commission
Registered providers must report to the NDIS Commission serious incidents (including allegations) arising in the context of NDIS supports or services, including:
the death of an NDIS participant;
serious injury of an NDIS participant;
abuse or neglect of an NDIS participant;
unlawful sexual or physical contact with, or assault of, an NDIS participant;
sexual misconduct committed against, or in the presence of, an NDIS participant, including grooming of the NDIS participant for sexual activity;
the unauthorised use of a restrictive practice in relation to an NDIS participant.
9.2 Timeframes and reports
Most reportable incidents must be notified to the NDIS Commission within 24 hours of a provider’s key personnel being made aware of it, with a more detailed report about the incident and actions taken in response to it to be provided within five (5) business days.
The unauthorised use of restrictive practice must be notified to the NDIS Commission within five (5) business days of a provider’s key personnel being made aware of it. If there is harm to a participant, it must be reported within 24 hours.
A final report may also be required within 60 business days of submitting the five-day report. The NDIS Commission will advise providers whether a final report is required.
In all cases, the following must be assessed:
the impact on the NDIS participant;
whether the incident could have been prevented;
how the incident was managed;
what, if any, changes are required to prevent further similar events occurring.
10. Minimum record keeping requirements
Under the NDIS Incident Management requirements, for each incident, registered NDIS providers must record, at a minimum, the following details:
a description of the incident, including the impact on, or harm caused to, any person with disability;
whether the incident is a reportable incident;
if known, the time, date and place at which the incident occurred or if not known, the time, date and place at which the incident was first identified;
the names and contact details of the persons involved in the incident and any witnesses to it;
the actions taken in response to the incident, including action taken to support or assist a person with disability impacted by an incident;
if an investigation is undertaken by the provider in relation to the incident – the details and outcomes of the investigation; and
the name, position and contact details of the person making the record of the incident.
All records must be kept for seven (7) years from the day the record is made.
11. Availability of records
NeuroRehab Allied Health Network commits to making our records available to auditors as part of our Quality Assurance process and contribute to NDIS Commission investigations relating to incidents.
12. Further information
For further information on this procedure or to request a full copy of our Incident Management System Policy, email Steve Woollard, Director at mail@nrah.com.au