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Questions asked at our Positive Behaviour Support (PBS) Webinar

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Everyday Independence

The team at Everyday Independence have answered the following questions asked during the webinar we delivered: Positive Behaviour Supports & the NDIS:

1. Can I stop a participant from trying to commit suicide for the first time and then report this immediately?

We must act with a duty of care to keep the people we support safely. Please seek support from your management and they can guide you to their policies and/or appropriate training.


2. Would using harnesses in wheelchairs & whilst transporting a client living with HD be seen as therapeutic rather than a restrictive practice?

This will be guided by the occupational therapist/assistive technology specialist involved or behaviour support practitioner. Remember that a device can be both therapeutic and restrictive. If the person is showing some elements of challenging behaviors when in the wheelchair, then it would have a restrictive element, and we as their supports need to find out the function of that behaviour. For example, they may need thoracic support in the form of a harness to enable functional posture (I.e. supporting a person’s trunk so they can use their upper limbs more effectively to eat independently ) but they are also using challenging behaviours in the wheelchair. If we do not understand the function of the behaviour, then we are also not addressing what the person is trying to communicate to us when in the wheelchair (maybe the wheelchair seating system is uncomfortable?).

A restrictive practice is only restrictive when it is used to manage or change behaviour and on most occurrences, we need to understand the whole situation to determine whether something is restrictive or not.


3a. Can Independent Support workers work with restrictive practices if they are not registered with the commission?

3b. As a registered provider supporting a client who has a Positive Behaviour Support Plan (PBSP) with no restrictive practices vs a PBSP with restrictive practices. Does the provider need to be registered under any certain groups or areas to support the client?

NDIS Quality and Safeguards Commission provides the following information when addressing these questions:

What is an implementing provider?

An implementing provider is any NDIS service provider that uses a regulated restrictive practice in the course of delivering NDIS support to a participant. For example, support workers restricting a participant’s free access to the community due to behaviours of concern are implementing a regulated restrictive practice.

Implementing providers are required to:

  • Be registered with the NDIS Commission for the type of support they are providing. They do not need to be registered specifically for behaviour support registration group 110
  • Submit monthly reports to the NDIS Commission on the use of restrictive practices
  • Ensure staff are appropriately trained to implement positive behaviour strategies or use restrictive practices
  • Notify the NDIS Commission in the event of any unplanned or unapproved use of a restrictive practice through the reportable incident process
  • Help your staff, NDIS participants, their families, and other decision-makers to understand the NDIS Commission’s behaviour support function

So in short, the answer is, you are required to be registered with the NDIS Commission if you are implementing restrictive practices.

If there are no restrictive practices, then you are not deemed an “implementing provider” and therefore do not need to be registered to deliver that support to that participant.


4. Can an independent support worker (not registered) support a client on a Positive Behaviour Support Plan (PBSP)?

This depends on whether the PBSP has a regulated restrictive practice or not. Remember some PBSP have no restrictive practices. The regulations do not sit with Positive Behaviour Support as a model or the reports but the restrictive practices.


5. Are Support Coordinators responsible for reporting incidents to the commission if there are no registered providers involved?

The behavior support practitioner is required to upload the unauthorized Behavior Support Plan onto PRODA and close the account, advising the NDIS commission that an unregistered NDIS provider is implementing restrictive practices within self or plan managed funding.

In most occasions, we, the Behaviour Support Practitioner will notify the providers, participants, family they are doing this.

The Behaviour Support Practitioner will continue to implement the plan which includes the supports of completing important documentation and incident reporting if they occur. (Unregistered providers still have obligations as stated on the NDIS Commission Website.
See Unregistered NDIS providers | NDIS Quality and Safeguards Commission

The NDIS commission may then work with the participant and the unregistered provider to make appropriate arrangements.

Details on how to complete an incident report can be found here


6. Please provide some resources or person contact in case we can sort any doubts related to the PBS?

My first recommendation is to contact the Behaviour Support Practitioner, so you can discuss the doubts or findings. If you are still not satisfied, then refer to the signed service agreement on how you can escalate your concerns.


7. Are there any reporting requirements for family members or self-employed support workers who are implementing a restrictive practice?

Family members do not complete monthly reporting to the Commission. The Behavior Support Plan is uploaded onto PRODA to advise there is an RP in place but is being implemented by the family. The Plan is then closed on PRODA so monthly reports do not need to occur. The RP’s will continue to be monitored and discussed between family and Behaviour Support Practitioners to determine whether the strategies are successful in achieving quality of life outcomes and RP fade out plan.

Self Employed Support Workers- please refer to Question 3.


8. Will prompting client to take medication (PRN), when the doctor has signed to say able to self medicate, be termed as Chemical restraint?

Firstly, the prescribing doctor needs to advise us the purpose of the medication- is it for physical reasons or a diagnosis- if it’s either of these, this is not restrictive. If it has been prescribed for behaviour management; then this is restrictive. Prompting someone to take a chemical restraint or any restraint to stop or influence a behaviour, would be deemed as being restrictive.


9. Typically, how many sessions and time is required to complete a Behaviour Support Plan (BSP)? Can BSPs be completed only by interviewing family, services, AH etc? Are PBS Prac typically required to make observations and meet with individuals?

It can fluctuate but approximately 20 hours, and it depends upon the situation.

PBS is a person-centered approach and we value the time with participants to get to know them, their goals, and how we can support them to reach their full potential. However, remember, it is not just about the Behavior Support plan - the outcomes happen mostly in the implementation phase so more hours are required to implement the strategies with the participant and their team of supports.

We do recognise that on some occasions spending time with the participant is not accessible and this needs to be planned well to ensure that the participant and the practitioner are and feel safe.

However, we are also seeing the value of TelePBS to address some of these scenarios and slowly introduce ourselves into some of our participants' lives. 
See more on TelePBS from the NDIS Quality and Safeguards Commission 

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