Key Takeaways
- The NDIS Practice Standards have three tiers: the Verification Module (for lower-risk supports), the Core Module (four sections, mandatory for all certification-pathway providers), and four Specialist Modules (for the highest-risk support types).
- Every certification-pathway provider must demonstrate compliance with all four sections of the Core Module, regardless of which other groups they hold. There is no partial Core Module assessment.
- Four registration groups trigger a Specialist Module in addition to the Core Module: group 0104 triggers Specialist Module 1, group 0110 triggers Specialist Module 2, group 0118 triggers Specialist Module 3, and group 0132 triggers Specialist Module 4.
- The Verification Module does not assess compliance with the Core Module or any Specialist Module. Verification providers are assessed only on qualifications, insurance, and operational policies.
- Auditors do not check that policies exist. They assess whether staff can describe those policies in their own words and whether participant records reflect them in practice.
- The Core Module's Governance and Operational Management section is the primary focus of mid-term audits, due approximately 18 months into each three-year registration cycle.
- From 1 July 2026, SIL providers (group 0115) must be registered and therefore compliant with the Core Module. Delivering SIL without registration is a criminal offence with a maximum penalty of 5 years imprisonment.
NDIS providers preparing for audit often focus on building policy libraries. That is necessary, but it is not what the Practice Standards are actually assessing. The Standards define outcomes: what must be true for participants as a result of how your organisation operates. Knowing which modules apply to your registration groups, and what each module requires in practice, is the foundation of any effective audit preparation.
This guide maps registration groups to their Practice Standards module obligations and explains what each module actually covers. For the mapping of all 36 registration groups to their audit pathways, the NDIS registration groups guide covers the full picture. For the certification audit timeline and non-conformity process, the NDIS audit pathways guide covers the full lifecycle.
The Three-Tier Practice Standards Structure
Which tier of Practice Standards applies to your organisation depends entirely on your registration groups.
Tier 1: The Verification Module. This applies to providers on the verification pathway, delivering lower-risk supports. The Verification Module is not a Practice Standards assessment. Auditors review evidence of professional qualifications and current registration for each worker, worker screening records, public liability and professional indemnity insurance certificates, and written policies for incident management, complaints handling, and risk management. There is no assessment against the Core Module or any Specialist Module. No site visit. No staff interviews.
Tier 2: The Core Module. This applies to every provider on the certification pathway, without exception. It has four sections: Rights and Responsibilities, Governance and Operational Management, the Provision of Supports, and the Support Provision Environment. If any one of your registration groups requires certification, you must demonstrate compliance with all four sections at your Stage 1 desktop review and your Stage 2 on-site assessment.
Tier 3: The Specialist Modules. These apply on top of the Core Module for four specific registration groups. A provider holding one of those groups must satisfy both the Core Module and the relevant Specialist Module. A provider holding multiple certification-level groups alongside one of the four specialist-module groups does not receive any exemption from Core Module requirements for their other supports.
The contamination rule applies throughout: one certification-level group moves your entire registration to the certification pathway, with full Core Module obligations.
The Verification Module: What Providers Must Demonstrate
Verification-pathway providers submit documentary evidence across five areas:
- Worker credentials: Professional registration certificates (AHPRA or equivalent) for each worker delivering supports. Qualifications must match the support type.
- Worker screening: NDIS Worker Screening clearances or exemptions for each worker, or documentation explaining why a role is not risk-assessed.
- Insurance: Current certificates of currency for professional indemnity and public liability insurance, at coverage levels commensurate with the scope and scale of the practice.
- Incident and complaints management: Written policies that describe how incidents and complaints are recorded, managed, and reported, including obligations to report NDIS reportable incidents to the Commission.
- Risk management: A risk management policy covering operational and work health and safety risks.
The auditor reviews this documentation off-site. No outcomes assessment. No participant conversations. The verification scope is bounded entirely by the module.
Most allied health sole traders and small practices registering only for Therapeutic Supports (group 0128) sit in this tier. This includes occupational therapists, physiotherapists, speech pathologists, psychologists, and podiatrists. Standard support coordinators registered only for group 0106 also sit here.
The Core Module: Four Sections, All Mandatory
Rights and Responsibilities
This section covers person-centred supports, individual values and beliefs, privacy and dignity, independence and informed choice, and preventing violence, abuse, neglect, exploitation, and discrimination. Auditors assess whether participants are supported to make genuine decisions about their services, and whether rights are practically communicated rather than just listed in a policy.
Evidence auditors look for includes signed service agreements reflecting participant goals and choices, documented support plans, staff training records covering participant rights and VANED, and participant feedback mechanisms that give people a real channel to raise concerns.
Governance and Operational Management
This is the section that mid-term audits focus on. It covers governance and management structures, the quality management system, risk management, human resource management, information management (including privacy), and emergency and disaster management planning.
For providers with a board or governing body, auditors assess how the board oversees quality and risk, what reporting it receives, and whether it acts on findings. For smaller providers, governance expectations scale to size, but structured processes are still required.
Specific evidence areas include: board or management meeting minutes where quality and risk items appear; a quality management system with documented continuous improvement activities; a current risk register; HR policies covering recruitment, induction, supervision, and performance management; a privacy and information management framework; and an emergency management plan with evidence of testing.
The Provision of Supports
This section covers how supports are planned, delivered, reviewed, and transitioned. It includes assessment and support planning, delivery of supports, and transitions between services.
Auditors examine participant files directly at Stage 2. They look for support plans that reflect current participant goals, signed and current service agreements, evidence that supports are regularly reviewed, and processes for managing transitions without creating gaps for participants.
The most common finding in this section is support plans that have not been updated to reflect changes in a participant's circumstances or goals.
The Support Provision Environment
This section applies to providers whose participants receive supports in a physical setting. It covers safe and suitable environments, medication administration, mealtime management, waste management, and management of participants' money and property.
For SIL providers (group 0115), this section carries particular weight. Auditors inspect accommodation, assess how participant money is managed, and verify that any restrictive practices are authorised and documented. Providers who do not operate physical service environments have a narrower scope within this section.
The Four Specialist Modules
Specialist Module 1: High Intensity Daily Personal Activities (Group 0104)
Group 0104 covers supports that involve clinical tasks beyond standard personal care: complex bowel care, enteral feeding and tube management, urinary catheter support, subcutaneous injections, tracheostomy care, ventilator management, complex wound care, epilepsy and seizure response, and dysphagia support.
The critical Specialist Module 1 requirement is that each support type you deliver must have its own specific policy and procedure, not a generic clinical care policy. Each procedure must address the clinical task itself, the skills descriptor workers must meet, how competency is assessed, and how assessments are documented and updated. At Stage 2, auditors ask frontline workers to describe how they handle specific tasks and compare those answers to the written procedure.
Clinical oversight is also required: either an appropriately qualified clinical supervisor within the organisation or a clear documented process for obtaining clinical supervision for complex cases.
Specialist Module 2: Specialist Behaviour Support (Group 0110)
Group 0110 covers specialist behaviour support, including functional behaviour assessments and the development of behaviour support plans. Providers must confirm that their behaviour support practitioners have been assessed by the NDIS Commission as suitable to deliver behaviour support. This is a separate suitability assessment from qualifications alone.
The module requires a behaviour support plan for each relevant participant, developed in accordance with the NDIS (Restrictive Practices and Behaviour Support) Rules 2018. Practitioners must maintain ongoing professional development in evidence-based positive behaviour support, and clinical supervision arrangements must be documented. Providers who use any restrictive practices also have overlapping obligations under the NDIS restrictive practices framework, including monthly reporting to the Commission and authorisation under state or territory legislation.
Specialist Module 3: Early Childhood Supports (Group 0118)
Group 0118 covers early intervention supports for children under 9. The defining feature of this module is the family-centred practice requirement. Supports must be structured around the whole family, not just the child, with goals and plans reflecting the family's priorities alongside the child's developmental needs.
Specific obligations include documented tracking of each child's developmental outcomes across functional domains, evidence of collaboration with other services involved in the child's support network, and specialist early childhood expertise within the workforce. At Stage 2, auditors speak with families as well as staff. Family experience of the service carries significant weight in the assessment.
Specialist Module 4: Specialist Support Coordination (Group 0132)
Group 0132 covers specialist support coordination for participants with complex needs. The module focuses on practitioner competency, documentation standards, and conflict of interest management.
Providers must demonstrate that their specialist support coordinators have expertise commensurate with the complexity of the participants they support, beyond what standard coordination requires. Documentation standards are more prescriptive than for group 0106: coordinators must record contacts, actions, referrals, and participant progress against NDIS goals in sufficient detail to demonstrate genuine coordination activity. Conflict of interest policies must be documented and applied in practice.
Standard support coordinators registered only under group 0106 sit on the verification pathway and are not assessed against this module. Adding group 0132 to a verification-only registration triggers full certification.
Registration Group to Module: Quick Reference
| Registration Group | Pathway | Module Required | |---|---|---| | 0128 (Therapeutic Supports) | Verification | Verification Module only | | 0106 (Standard Support Coordination) | Verification | Verification Module only | | 0120 (Household Tasks) | Verification | Verification Module only | | 0107 (Daily Personal Activities) | Certification | Core Module | | 0115 (SIL) | Certification | Core Module | | 0116 (Innovative Community Participation) | Certification | Core Module | | 0117 (Development of Daily Life and Life Skills) | Certification | Core Module | | 0104 (High Intensity Daily Personal Activities) | Certification | Core Module + Specialist Module 1 | | 0110 (Specialist Behaviour Support) | Certification | Core Module + Specialist Module 2 | | 0118 (Early Childhood Supports) | Certification | Core Module + Specialist Module 3 | | 0132 (Specialist Support Coordination) | Certification | Core Module + Specialist Module 4 |
What Auditors Are Actually Looking For
The Practice Standards define outcomes. Auditors are trained to assess whether your organisation achieves those outcomes in practice, not just whether documentation exists. Common findings that could be avoided include:
- Workers who cannot describe a policy they are required to follow, even when that policy is written and accessible
- Support plans in the system that have not been reviewed in more than 12 months
- Incident reporting procedures that staff cannot explain or apply consistently
- Specialist Module 1 procedures that address the support type generically rather than the specific clinical task the organisation is registered to deliver
- Governance meeting minutes that record attendance and agenda items but do not show quality or risk items being actively considered
For a detailed breakdown of what auditors look for at each stage of the certification process, the NDIS audit preparation checklist covers the full set of evidence categories.
How ClinicComply Helps
ClinicComply maps all four Core Module sections and all four Specialist Modules to a live evidence checklist, reflecting the specific registration groups your organisation holds. Upload your policies and procedures against each criterion, assign preparation tasks to team members with deadlines, and see which areas are evidenced and which have gaps before Stage 1 begins.
The platform tracks the Governance and Operational Management section separately as the primary mid-term audit focus, and sends automated reminders as your 18-month mid-term due date approaches. For Specialist Module providers, the NDIS policy templates library includes procedure frameworks for each high-intensity support type under Module 1, the behaviour support documentation structure required by Module 2, and the family-centred practice records framework for Module 3.
Use the NDIS Compliance Quiz to assess your current gap against the modules that apply to your registration groups. Start a free 30-day trial at cliniccomply.com.au/signup and have your Practice Standards evidence organised before your auditor's Stage 1 documentation request arrives.
Frequently Asked Questions
What are the NDIS Practice Standards modules?
The NDIS Practice Standards have three tiers. The Verification Module applies to lower-risk support providers and focuses on qualifications, insurance, and operational policies, without assessing Practice Standards compliance. The Core Module applies to all certification-pathway providers and has four mandatory sections: Rights and Responsibilities, Governance and Operational Management, the Provision of Supports, and the Support Provision Environment. The four Specialist Modules apply on top of the Core Module for specific high-risk groups: Module 1 for group 0104, Module 2 for group 0110, Module 3 for group 0118, and Module 4 for group 0132.
Which NDIS registration groups require a Specialist Module?
Four registration groups require a Specialist Module in addition to the Core Module: group 0104 (High Intensity Daily Personal Activities) requires Specialist Module 1, group 0110 (Specialist Behaviour Support) requires Specialist Module 2, group 0118 (Early Intervention Supports for Early Childhood) requires Specialist Module 3, and group 0132 (Specialist Support Coordination) requires Specialist Module 4. All other certification-pathway groups require only the Core Module. Verification-pathway groups require neither the Core Module nor any Specialist Module.
Does a therapeutic supports provider (group 0128) need to comply with the NDIS Practice Standards?
No. Group 0128 (Therapeutic Supports) sits on the verification pathway. Allied health providers registering only for group 0128, including occupational therapists, physiotherapists, speech pathologists, and psychologists, are assessed under the Verification Module. They are not assessed against the Core Module or any Specialist Module. If a therapeutic supports provider adds a certification-level group such as group 0107 (Daily Personal Activities), the entire registration moves to the certification pathway and Core Module compliance becomes mandatory across all supports delivered.
What does the Core Module's Governance and Operational Management section require?
The Governance and Operational Management section requires documented governance structures with evidence that quality and risk are actively overseen, a quality management system with continuous improvement activities, a current risk register, HR policies covering recruitment, induction, supervision, and performance management, a privacy and information management framework, and an emergency management plan with evidence of testing. This section is the primary focus of mid-term audits at approximately 18 months into each three-year registration cycle. Auditors look for evidence that governance is happening operationally, not just that policies describing it have been written.
What does Specialist Module 1 require for high-intensity daily personal activities?
Specialist Module 1 requires a specific written policy and procedure for each high-intensity support type the provider delivers. The support types covered include complex bowel care, enteral feeding and tube management, urinary catheter support, subcutaneous injections, tracheostomy care, ventilator management, complex wound care, epilepsy and seizure response, and dysphagia support. Each procedure must address the clinical task itself, the skills descriptor workers must meet, how worker competency is assessed, and how assessments are recorded. Generic clinical care policies do not satisfy these requirements. Clinical oversight arrangements, in the form of qualified supervision, are also required.
Do unregistered support coordinators need to comply with the NDIS Practice Standards?
No. Unregistered providers are not subject to the NDIS Practice Standards. They are subject to the NDIS Code of Conduct, worker screening obligations where applicable, and incident reporting requirements, but Practice Standards compliance is a condition of registration only. The NDIS unregistered provider obligations guide covers in full what unregistered providers must and must not do.
What is the difference between Specialist Module 2 and restrictive practices compliance?
Specialist Module 2 (Specialist Behaviour Support) sets the Practice Standards for providers registered under group 0110. It covers practitioner suitability assessment by the Commission, behaviour support plan requirements, professional development, and clinical supervision. Restrictive practices compliance is a separate but overlapping obligation governed by the NDIS (Restrictive Practices and Behaviour Support) Rules 2018. It requires authorisation under state or territory legislation before any restricted practice is used, monthly reporting to the Commission, and specific documentation for each practice in use. Registered behaviour support providers must satisfy both sets of requirements simultaneously.
What happens if my audit finds non-compliance with the Practice Standards?
Non-compliance results in non-conformity findings. Minor non-conformities must be closed within 12 months of issue. If not closed within that period, they escalate automatically to major non-conformities. Major non-conformities require a corrective action plan submitted to the audit team leader within 7 calendar days of written notification, and a follow-up audit within 3 months. Unresolved major non-conformities result in automatic suspension of certification. The NDIS audit pathways guide covers the full non-conformity resolution process and timeframes in detail.