Purpose
The purpose of this SOP is to provide a clear and structured approach for NDIS Support Coordinators to follow when they suspect fraudulent activities by participants. This SOP ensures that all actions taken are compliant with NDIS guidelines and the internal policies of their respective organisations.
Scope
This SOP applies to all NDIS Support Coordinators within any organisation, detailing their responsibilities and the procedures they must follow upon suspecting or reporting fraud.
Responsibilities After Reporting Fraud
1. Initial Reporting
1.1 Report to the NDIS Commission:
The first step for a support coordinator who suspects fraud is to report these suspicions to the NDIS Quality and Safeguards Commission. This report should be detailed and adhere to the guidelines provided by the NDIS. It is crucial to document the nature of the suspected fraud, the evidence gathered, and any relevant interactions with the participant.
1.2 Internal Reporting:
In addition to reporting to the NDIS Commission, support coordinators must follow their employer’s internal procedures for fraud reporting. This often involves notifying a designated person or department within the organisation and providing them with the same detailed information submitted to the NDIS Commission.
2. Further Reporting
2.1 Cooperate with Investigations:
Once the initial report is made, the support coordinator must fully cooperate with any investigations conducted by the NDIS Commission or other authorities. This cooperation may involve providing additional information, documentation, and participating in interviews. The support coordinator’s role is to facilitate the investigation by being transparent and responsive.
2.2 Follow-Up Reports:
If new information emerges that either supports or refutes the initial suspicion of fraud, it is the responsibility of the support coordinator to update both the NDIS Commission and their employer. Keeping all parties informed ensures that the investigation remains accurate and up-to-date.
3. Handling Invoices
3.1 Suspend Approval of Invoices:
A critical step in handling suspected fraud involves the suspension of invoice approvals related to the participant or the suspected fraudulent activity. However, this action should only be taken if instructed in writing by either the fraud team or the NDIS Commission. This precaution prevents any further potential misuse of funds while the investigation is ongoing.
3.2 Documenting Actions:
Support coordinators must meticulously document all actions taken, including the suspension of invoice approvals. Detailed records are essential for both the investigation and for internal audits. This documentation should be thorough, noting dates, actions taken, and communications related to the case.
4. Ongoing Monitoring
4.1 Monitor Participant’s Activities:
Even after reporting, it is crucial for support coordinators to continue monitoring the participant’s activities. Any additional suspicious behaviour should be promptly reported to the NDIS Commission. Continuous vigilance helps in identifying any further irregularities that might occur.
4.2 Review and Adjust Plans:
Support coordinators should review the participant’s NDIS plan and make necessary adjustments to mitigate the risk of further fraudulent activities. This may involve collaborating with other professionals to develop a more secure and foolproof plan for the participant. Adjustments should be documented and communicated to all relevant parties.
5. Communication
5.1 Inform Relevant Parties:
Maintaining clear and consistent communication is vital. Support coordinators should keep all relevant parties informed about the status of the investigation and any changes in procedures. This includes informing their employer, other support coordinators, and service providers involved with the participant.
5.2 Maintain Confidentiality:
Confidentiality is of utmost importance in fraud investigations. All information regarding the suspected fraud and the investigation must be kept confidential. Information should only be shared with those who need to know, ensuring that the investigation is not compromised.
Summary
To summarise, the responsibilities of NDIS Support Coordinators when handling suspected fraud include:
- Report: Report suspicions to the NDIS Commission and internally as required.
- Cooperate: Assist with investigations by providing necessary information and documentation.
- Suspend Approvals: Cease approving invoices related to the suspected fraud ONLY if instructed in writing by either the fraud team or the NDIS Commission.
- Monitor: Keep a close watch on the participant’s activities and update plans as necessary.
- Communicate: Inform relevant parties while maintaining confidentiality.
Review and Compliance
This SOP will be reviewed annually or as required to ensure compliance with NDIS guidelines and internal policies. Non-compliance with this SOP may result in disciplinary action. Regular reviews and updates help in keeping the SOP relevant and effective in addressing new challenges and ensuring the integrity of the NDIS system.
By following this SOP, NDIS Support Coordinators can effectively contribute to maintaining the integrity of the NDIS, ensuring that the support provided to participants is fair, transparent, and in line with legal and organisational standards.
