MANDY DONLEY: Hi. My name's Mandy Donley. And I'm the Victorian Senior Practitioner. I'm here today to introduce a suite of brand-new eLearning Modules. This series of eLearning Modules reflects my commitment to supporting the sector, in particular the role of the Authorised Program Officer, or APO, to reduce and eliminate the use of restrictive practice.
They are designed to be the starting point for you to understand the basics of the authorisation processes of restrictive practices in Victoria. The modules have been developed with a focus on supporting the sector to reduce and eliminate restrictive practice. They are underpinned by Kevin Ann Huckshorn's Six Core Strategies to reduce seclusion and restraint.
These are leadership towards organisational change; use of data to inform practice, workforce development; use of specific evidence-based reduction interventions; inclusion of the person and their family and peers; and reflective practice. These eLearning Modules were originally presented to the sector as webinars as part of our Strengthening the APO Role project. However, there were further requests for these webinars to be provided.
So these modules were developed to allow APOs, people with a disability, their families, service providers, and behaviour support practitioners to access on demand. The modules are part of a broader package of complementary supports made available by the Victorian Senior Practitioner, which includes the APO course and themed online workshops, as well as numerous written resources available on the Victorian Senior Practitioner website.
The eLearning Modules available to you include the following videos-- "What are restrictive practices?" "Authorisation process and key roles," "Legislative requirements for the authorisation of restrictive practices," and the "Restrictive Intervention Data System, or RIDS Training."
I trust this series of eLearning Modules will be a great resource for APOs moving forward. For any complex matters, please don't hesitate to contact our office. And once again, thank you for everything you do on a daily basis.
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What are restrictive practices?
This e-Learning module will equip staff working with people with a disability to recognise restrictive practices.
In this e-learning module, we'll explore what restrictive practices are and how to determine if something would be regarded as a restrictive practice or not. Restrictive practices are any intervention that are used to restrict the rights or freedom of movement of a person.
Under the Disability Act and NDIS rules, there are five restrictive practices that are subject to oversight by the Victorian senior practitioner and regulation by the NDIS Quality and Safeguards Commission. These are chemical restraint, mechanical restraint, seclusion, environmental restraint, and physical restraint.
CATHERINE RANSON: When can a restrictive practice be used? A restrictive practice should only ever be used as a last resort when all of the strategies have been implemented. The Disability Act sets out criteria that must be met for a proposed restrictive practice to be used.
A restrictive practice can only be used to prevent the person from causing physical harm to themselves or another person, or destroying property, where to do so could involve the risk of harm to themselves or another person. The use and form of restricted practice is included in the behaviour support plan and must be the least restrictive option as possible in the circumstances.
The restrictive practice cannot be applied for any longer than is necessary, and the use of restricted practice must be included in the person's behaviour support plan unless used as an emergency. For more information regarding the criteria for authorisation of restrictive practices, refer to the regulated restricted practice authorisation checklist on the VSP website.
The authorisation checklist outlines the criteria outlined in the Disability Act and provides some information on how this might look within a behaviour support plan, and what information would need to be provided to show that it meets the criteria.
TASHA HARAN: Chemical restraint is the use of medication or a chemical substance for the primary purpose of influencing a person's behaviour. It does not include the use of medication prescribed by a medical practitioner, the treatment of a diagnosed mental disorder, a physical illness, or a physical condition.
We often see psychotropic medications used as chemical restraint, but medications that are not psychotropic can still be considered a restrictive practice if they are used for behaviour control or if prescribed for reasons other than the treatment of a mental disorder, physical illness, or physical condition.
When you're looking at the purpose of a prescribed medication, some indicators for when it might be considered chemical restraint would be if it's prescribed for aggression, agitation, sedation, or behaviour management. However, this may not always be so obvious. So let's look into how to determine if medication would be regarded as treatment or chemical restraint.
CATHERINE RANSON: When determining whether a chemical restraint would be considered treatment or restraint, there are a few factors to consider. It will be considered treatment if the person has a formal, diagnosed condition that is current and the medication prescribed is clinically indicated for the treatment of that diagnosed condition, or the medication is enabling treatment of mental illness, physical illness or physical condition.
For example, if a person requires medication prior to attending a medical appointment, that would not be regarded as chemical restraint, as it is enabling treatment. To determine if a medication is clinically indicated to treat a particular condition, you can find this information on the consumer medicine information leaflet or on the Therapeutic Goods Administration website, which is a free resource.
TASHA HARAN: When does a medication become restraint? It would be regarded as chemical restraint if it's being used to change or modify someone's behaviour or is prescribed without a diagnosis of a physical disorder or mental health disorder for which the medication is indicated.
For example, if an anti-anxiety medication is prescribed to treat anxiety as a symptom, but there's no diagnosis of an anxiety disorder, it would be considered as chemical restraint.
CATHERINE RANSON: Similarly, if an antipsychotic is prescribed to treat anxiety without an underlying diagnosis that the antipsychotic is formally indicated to treat, it would be regarded as chemical restraint.
TASHA HARAN: It is the APO's responsibility to determine what is or is not chemical restraint. The prescriber is not required to determine the status of their prescription in terms of the Disability Act.
Rather, it's expected that the prescriber will explain the reason as to why the medication was prescribed and what it's being prescribed for. The APO can then use this information to make a determination as to whether it would be regarded as treatment or restraint under the Disability Act.
CATHERINE RANSON: Seclusion is the complete confinement of a person with a disability in a room or physical space at any hour of the day or night where voluntary exit is prevented or not facilitated. It's important to note that doors don't actually need to be locked for seclusion to occur.
If the person is told that they are not allowed to leave the room and it's implied that they won't be allowed to leave, then it would be regarded as seclusion. If the person is physically unable to open the door, it may also be considered seclusion.
A person may have access to a number of rooms in a facility and still be secluded. For example, if they live alone in a house and staff leave the house due to the person's behaviours of concern and the person is unable to leave the house or access the community or interact with staff or anybody else, then that would be regarded as seclusion despite the fact they have access to the whole house.
TASHA HARAN: Environmental restraint is any restraint that restricts a person's free access to all parts of their environment, including items and activities. Environmental restraint can be one of the trickiest restrictive practices to identify, as it covers a broad range of restrictions.
Some are obvious, such as a locked door or a locked cupboard to prevent a person's free access to an area or item. However, some may be less visible, such as when a person is being restricted from an activity or is being supervised for the purpose of preventing their access to areas of the community.
Devices used for the purpose of monitoring to prevent access or address a behaviour of concern are also considered environmental restraint. This includes CCTV, door sensors, and alarms. The NOUS Group environmental restraint resource provides a useful framework when considering what might be environmental restraint.
Five questions are posed about the restriction. What is the person prevented from accessing? Why are they prevented from accessing it? How is the restriction applied? What is the impact of the restriction on clients? When, and for how long, is the restriction applied?
By identifying what the restriction is-- for example, access to food-- rather than focusing on how it is restricted-- for example, a locked cupboard-- it allows the team to identify and implement strategies to reduce the actual restriction.
CATHERINE RANSON: Physical restraints refer to the use or action of physical force to prevent, restrict, or subdue movement of the person's body or part of their body for the primary purpose of influencing their behaviour.
It does not include the use of hands-on techniques in a reflexive way to guide or redirect a person away from potential injury consistent with what could reasonably be considered the person's exercise of care towards a person.
For example, preventing a person from running into oncoming traffic would not be regarded as physical restraint, but holding a person to stop them moving towards someone to take food would be. Physical restraint comes with a significant amount of risk and is rarely approved for use.
It can only be included in a BSP as PRN use. There are a number of physical restraints that are prohibited for use in Victoria. These include prone restraint, supine restraint, pindowns, basket holds, takedown techniques, and restraint that restricts or inhibits respiratory or digestive function, pushing the person's head towards their chest, or inflicting pain or pressure on joints or the person's chest.
The Victorian Senior Practitioner Physical Restraint Direction paper was released in 2011 and updated in 2022. It outlines standards that must be considered before physical restraint is used in relation to authorisation requirements.
TASHA HARAN: Mechanical restraint refers to the use of devices to prevent, restrict, or subdue a person's movement for the primary purpose of behavioural control. This does not include the use of devices for therapeutic or nonbehavioral purposes, or for enabling safe transportation of the person.
As with any other restraint, when considering if something would be mechanical restraint, we need to first determine its purpose for use. There are many devices or equipment that may be considered therapeutic or restrictive, depending on its purpose and how it's used.
Here are some examples of when a device that in other situations may be therapeutic may be restraint. Gloves when applied to prevent someone from biting their hands and breaking skin, a seat belt on a wheelchair that is in place to prevent a person from attempting to get out of their chair, helmets that prevent injury from self-injurious behaviours, such as head banging.
Often, people are unclear if a device may be considered mechanical restraint if it's used for safety. It's important to determine if the safety concern is due to a behaviour of concern that leads to risk of harm to self or others. If so, and the device is used to restrict movement, it would be regarded as mechanical restraint.
CATHERINE RANSON: A device would be considered therapeutic if it is used to assist a person with everyday activities, improve their functional independence, or to help their injuries heal. They must be prescribed by an appropriate professional after a thorough assessment and used for the specific and approved purposes for when the devices were designed.
Examples of this may be adaptive devices or mechanical supports used to achieve proper body position, balance, or alignment to allow greater freedom of mobility that wouldn't be possible without the use of such devices, or mechanical supports or restraints for medical immobilisation-- for example, cast or splint to allow healing.
Ideally, any device that is prescribed for a therapeutic purpose will have guidelines provided by the prescribing professional about its purpose of use, how and when it's used, what training is required for the use, and date of review.
For more information about restricted practices, please refer to the Victorian Senior Practitioner's website. You can also contact the Victorian Senior Practitioner's office with any complex queries.
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Authorisation process and key roles
This eLearning module will provide an overview of the authorisation process for the use restrictive practices in Victoria and the key roles in this process.
This video focuses on the authorisation process of regulated restrictive practices in Victoria. We will cover the steps of authorisation for restrictive practices by NDIS-registered providers in Victoria, as well as introducing key roles in the authorisation of restrictive practices and their responsibilities.
CONNIE WU: The state of Victoria has adopted an administrative model regarding the use of regulated restrictive practices by disability services. Under this model, an Authorised Program Officer, or APO, must provide authorisation for the use of restrictive practices. The APO is a delegate appointed by the Victorian Senior Practitioner within a service provider who is responsible for the authorisation of restrictive practices implemented by that provider.
Some restrictive practices require additional approval by the Victorian Senior Practitioner following APO authorisation. We'll discuss this in more detail later on. Restrictive practices not authorised for use and implemented by NDIS-registered service provider must be reported as an unauthorised restrictive practice, also known as a URP to the NDIS Quality Safeguards Commission. Therefore, in situations where no behaviour support plan, or BSP, has been developed, or a BSP has been developed but is yet to be authorised by the APO, any restrictive practice implemented would be regarded as unauthorised and require reporting as a URP to the NDIS Commission.
CATHERINE RANSON: Before we step through each stage in the authorisation process, let's understand the important safeguarding responsibilities of the APO, the independent person, NDIS Quality Safeguards Commission, and the behaviour support practitioner.
An APO has a significant and responsible role in safeguarding the rights of people subject to regulated restrictive practices. The responsibilities of an APO are clearly outlined in the Disability Act. An APO is responsible for the authorisation of restrictive practices and should have a well-developed understanding of the legislative criteria that a behaviour support plan proposing the use of restrictive practices must meet.
Therefore, an APO is said to have an administrative role that includes deciding what may or may not be a restrictive practise under the guidance and direction of the Victorian Senior Practitioner and NDIS Quality and Safeguards Commission. Be involved in ongoing discussions with the team. Work collaboratively with key stakeholders, such as the behaviour support practitioner and independent person.
And reviewing and authorising the behaviour support plan, lodging it on RIDS, and seeking evidence of authorisation from the Victorian Senior Practitioner. Critical to the role of the APO is ensuring that the person subject to restrictive practices has a suitable independent person made available to them and who are responsible for explaining the proposed use of restrictive practices to the person.
In addition, it is the role of the APO who informs the behaviour support practitioner if any proposed restrictive practices are refused following review by the Victorian Senior Practitioner and to determine what amendments are required to the behaviour support plan to ensure it meets the legislative criteria.
CONNIE WU: The role of the independent person is another important safeguard for persons subject to regulated restrictive practices, and is unique to the Victorian authorisation process. The role of the independent person is described in the Disability Act, and it is the independent person's role to explain to the person, subject to restrictive practices, the restrictive practice outlined in the behaviour support plan, and that the person has the right to seek a review of the proposed restrictive practices.
The independent person must explain to the person what the restrictive practice is, why the restrictive practice is being proposed, when it's going to be used, and how it's going to be used. The role of the independent person is best suited to someone from the person's social network, someone who, as the name suggests, is independent from the provider that is implementing the restrictive practices and independent from the person that is developing the behaviour support plan.
Examples of suitable independent persons include a family member, a friend, a neighbour, a member of the local club, or anyone in the community that the person might know well. The independent person should have an understanding of the person's communication abilities, know what a behaviour of concern is, understand behaviour support plans and what constitutes a regulated restrictive practice. An independent person is needed when a new behaviour support plan is developed and a restrictive practice is proposed or if a behaviour support plan is reviewed, potentially before that 12-month period, and a new restrictive practice is proposed.
CATHERINE RANSON: An NDIS behaviour support practitioner's role is to complete a behavioural assessment, develop a behaviour support plan, and implement strategies to increase a person's quality of life and support skill building. The behaviour support practitioner should consult with the participant on their supports to ensure their quality of life is the main focus, and therefore reduce the need for restrictive practices. The NDIS Commission expects that a behaviour support practitioner observes the participant with behaviours of concern in all environments, as well as consult and gather information about all aspects of the person's life.
Once the behaviour support plan is developed, it is their responsibility to work with the provider to implement the strategies included. It is critical that the APO and behaviour support practitioner should work collaboratively. This collaboration is crucial to develop a behaviour support plan that is accurate and able to be implemented. NDIS-registered behaviour support practitioners are subject to a set of requirements that are outlined in the NDIS restrictive practices behaviour support rules.
CONNIE WU: The role of the NDIS Quality and Safeguards Commission is to improve the quality of support services provided by registered providers. In terms of behaviour support planning, the NDIS Commission promotes a positive behaviour support approach, focusing on increasing the quality of life for people, and therefore reducing restrictive practices.
The NDIS provides clinical leadership in behaviour support and regulates both practitioners and registered implementing providers to ensure their compliance with regulations. All behaviour support plans written by NDIS-registered behaviour support practitioners must be lodged with the NDIS Commission, regardless of whether they are implemented by a disability service provider or not. The NDIS Commission does not have a direct role in authorisation of restrictive practices but will review plans lodged on PRODA to ensure that they are compliant in their state authorisation process.
CATHERINE RANSON: The role of the Victorian Senior Practitioner is outlined in the Disability Act. The responsibilities of the Victorian Senior Practitioner include ensuring that the rights of people subject to restrictive practices and compulsory treatment are protected and supporting disability service providers to reduce restrictive practices throughout the authorisation process. Once the APO has authorised restrictive practices, the Victorian Senior Practitioner will provide evidence of authorisation for the use of restrictive practices.
Some restrictive practices, such as mechanical restraint, seclusion, and physical restraint, require additional approval from the Victorian Senior Practitioner. This provides an extra safeguarding method. The Victorian Senior Practitioner also monitors the authorisation and proposed use of restrictive practices.
This monitoring process informs data-driven education initiatives, audits, and research. Additionally, the Victorian Senior Practitioner is responsible for supporting implementing providers in recognising and reducing restrictive practices. This support can take the form of working closely with specific providers or providing broader education initiatives.
CONNIE WU: Now that we have discussed the role of key stakeholders, we will discuss how they need to work together in safeguarding people subject to restrictive practices through the authorisation process.
Step one, a service provider must become NDIS registered and completed Module 2A before they can implement restrictive practices. Module 2A assesses an NDIS registered service provider's understanding of restrictive practices and the associated risks as well as the appropriate skills to safely apply regulated restrictive practices. This registration process might take some time, so it's important to plan ahead of time.
Registered service providers should contact the NDIS Commission with any questions relating to registration against Module 2A. An NDIS registered service provider must also register with RIDS, the Restrictive Intervention Data System. This involves registering on both eBusiness and RIDS. They must then appoint an Authorised Program Officer and submit an application to the Victorian Senior Practitioner.
This application must include the qualifications and professional background of the Authorised Program Officer. The Victorian Senior Practitioner will review the credentials of the nominated APO before deciding whether the appointed APO has the relevant skills needed to act in this important role.
CATHERINE RANSON: Step two, development of a behaviour support plan. The implementing provider will need to engage with an NDIS registered behaviour support practitioner. This may be organised via a support coordinator, or maybe family. However, it is vital that the implementing provider engage and work collaboratively with the behaviour support practitioner to develop a behaviour support plan.
This should include discussions relating to the person's goals, skills and abilities, selection of proactive strategies, understanding the behaviours of concern used by the person, and ensuring any restrictive practices being implemented are the least restrictive as possible to prevent harm to the person or others. A behaviour support plan is a live and dynamic document that should be reviewed at regular intervals, or at least every 12 months, or when an NDIS participant's circumstances change.
Examples to change in circumstances include changes to the person's living environment, service provider, proposal to increase restricted practices, or when a new behaviour of concern emerges. The behaviour support plan must be developed in accordance with the NDIS rules and the legislative criteria outlined in the Disability Act 2006.
CONNIE WU: Step three, the Authorised Program Officer reviews the developed behaviour support plan against legislative criteria outlined in the Disability Act 2006. If the APO is not satisfied that the behaviour support plan meets the legislative criteria for authorisation, they should provide feedback to the behaviour support practitioner. Once the Authorised Program Officer is satisfied that the developed behaviour support plan meets the authorisation criteria, the APO must then make an independent person available.
It is the role of the independent person to explain the restrictive practices described in the behaviour support plan and to inform the person subject to the proposed restrictive practices that they have a right to seek a review. The Authorised Program Officer and behaviour support practitioner should work collaboratively in developing accessible information and make this available to the person. This could be in the form of an easy-read behaviour support plan or social story and should be tailored to the person's communication needs.
It is crucial that the person is actively involved in the process. Once the behaviour support plan is finalised, the behaviour support practitioner lodges the plan onto the NDIS Commission portal, known as PRODA. At this point, the APO should be aware of the contents of the plan, as collaboration should have occurred throughout the development of the plan.
The APO then creates a submission in RIDS, lodges a copy of the behaviour support plan, and shares the behaviour support plan with any secondary implementing providers -- that is, other registered service providers implementing any of the restrictive practices identified in the behaviour support plan. The APOs of all implementing providers must identify and authorise the restrictive practices they will be implementing in RIDS.
CATHERINE RANSON: Step four, the Victorian Senior Practitioner will provide evidence of authorisation of restrictive practices or provide additional approval if required. The Victorian Senior Practitioner acknowledges the Authorised Program Officer's authorisation for the proposed use of chemical and environmental restraint by providing a letter of authorisation to be lodged with the NDIS Commission.
If the behaviour support plan contains mechanical restraint, seclusion, or physical restraint, the Victorian Senior Practitioner will also review them against the legislative criteria and provide additional approval. There may be other restricted practices that require additional approval, as per directions by the Victorian Senior Practitioner. Once evidence of authorisation is provided by the Victorian Senior Practitioner, the behaviour support practitioner and the implementing service provider will receive a copy of this letter, which needs to be uploaded to PRODA alongside the behaviour support plan.
CONNIE WU: Step five, administrative review. The independent person or the person subject to restrictive practices can seek a review of the APO's decision to authorise the restrictive practices proposed in the behaviour support plan. The circumstances under which a review can be requested include when the behaviour support plan does not meet the legislative criteria outlined in the Disability Act and if the person does not understand the proposed restrictive practices described in their behaviour support plan.
Once the independent person or participant has informed the APO of their decision, the APO must review their decision to authorise the proposed restrictive practices or notify the Office of the Public Advocate of the person's request for review of the proposed restrictive practices. The independent person must also notify the Victorian Senior Practitioner if these requirements are not met. The Office of the Public Advocate may contact the Victorian Senior Practitioner or lodge an application with the Victorian Civil and Administrative Tribunal, or VCAT.
CATHERINE RANSON: Step six, reporting to the NDIS Commission. Once evidence of authorisation is received from the Victorian Senior Practitioner, this letter is attached to the behaviour support plan on PRODA, which allows the plan to be activated. The implementing provider may then commence reporting against restricted practices on a monthly basis. The use of any unauthorised restricted practices are considered a reportable incident and must be reported to the NDIS Commission within five days.
CONNIE WU: The flowchart here outlines the process step by step. As you can see, each key role is involved throughout the process. We can also see here that the behaviour support planning process doesn't finish with the authorisation of restrictive practices, but rather continues through the lifetime of the plan.
The practitioner and service provider need to work together to implement strategies included in the behaviour support plan, which will then be reviewed again during the next update within 12 months. For more information about restrictive practices, please refer to the Victorian Senior Practitioner website. You can also contact the Victorian Senior Practitioner's office with any complex queries.
Legislative requirements for authorisation of restrictive practices
This eLearning module will provide an overview of the authorisation requirements for the use restrictive practices in Victoria (Disability Act 2006) and how behaviour support plans can satisfy the authorisation requirements.
TASHA HARAN: This e-learning module will be focused on the legislative requirements for the authorisation of restrictive practices. You'll learn about the legislative context regarding the authorisation of restrictive practices in Victoria, how to apply the authorisation criteria outlined in the Disability Act to behaviour support plans, and how to provide feedback on whether the authorisation criteria have been met in behaviour support plans through the development of positive behaviour support strategies.
Why do we use the authorisation process? It's important to acknowledge that restrictive practices infringe on human rights. The intent of the Disability Act legislation is not to enable the use of restrictive practices. Instead it's to provide a formal framework for the reduction and elimination of restrictive practices.
We know restrictive practices are not therapeutic. They don't address the underlying factors that cause behaviours of concern. Therefore, we don't want them being used as a long-term response. The use of restrictive practices reduces freedom of movement and decreases quality of life. And the reduction in restrictive practices through the implementation of positive behaviour support allows for improved quality of life. The authorisation process allows us to determine if a restrictive practice is only used when absolutely needed and is reduced and ceased as soon as possible.
ADAM FINKELSTEIN: Let's have a look at the difference between authorisation and approval. The Authorised Program Officer or APO of the implementing service provider is responsible for the authorisation of all restrictive practices used by their service. They must determine if the proposed use of a restrictive practice meets the legislative requirements of the Disability Act.
If the behaviour support plan or BSP proposes the use of chemical restraint or environmental restraint only, the Victorian Senior Practitioner will provide written evidence of the APO's authorisation, which is then lodged with the BSP with the NDIS Commission. The approval process is quite similar in the sense that it has the same first step, where the APO authorises the restrictive practices if it meets the requirements of the Disability Act.
However, if the BSP contains physical restraint, mechanical restraint, or seclusion or any restrictive practice proposed to be used with someone with a psychosocial disability, then it requires additional approval by the Victorian Senior Practitioner. The Victorian Senior Practitioner uses the same authorisation criteria from the Disability Act to assess the proposed restrictive practice as the APO did during authorisation.
We'll look at this criteria later in this module. If both the APO and the Victorian Senior Practitioner determine that the proposed restrictive practice meets the legislative criteria, evidence of approval will be provided to be lodged with the NDIS Commission. If you're in the space of using restrictive practices and behaviour support plans in Victoria, it's critical that you familiarise yourself with this part of the Disability Act regarding the use of restrictive practices.
This part includes information about the APO restrictive practices, the powers of the public advocate, the independent person role, and much more. This part provides the necessary requirements before restrictive practices can be authorised for use by disability service providers or registered NDIS providers in Victoria. We'll go through each of these criteria individually.
But as an overview, a restrictive practice can only be used if: it's necessary to prevent harm, it's the least restrictive option, it's included in the behaviour support plan, it's in accordance with the NDIS behaviour support plan, it's used for no longer than necessary, it's in accordance with the NDIS rules, and all the requirements around seclusion are met. There are also some directions and prohibitions that have been disseminated by the Victorian Senior Practitioner. So all of these will be needed to be met as well.
TASHA HARAN: Before we go into further detail about the criteria, I want to bring your attention to this document, the Regulated Restrictive Practices Authorisation Checklist. This document clearly outlines each of the authorisation criteria items and how it can be met within a BSP. So let's jump into the authorisation criteria.
I will refer to all of the criteria as how it's articulated in the Disability Act, which starts with the Authorised Program Officer may authorise the use of a regulated restrictive practice on a person in respect of whom this Part applies if the Authorised Program Officer is satisfied that. So the APO must decide if the criteria is met in full for each restrictive practice, not the BSP as a whole but each restrictive practice that is proposed within that BSP.
The first authorisation criteria item is that the regulated restrictive practice is necessary to prevent the person from causing physical harm to themselves or to another person. So in a nutshell, a restrictive practice can only be used to prevent harm to themselves or others.
Now, this might seem obvious. However, this is often something that isn't clearly evidenced within BSPs. An example of this is where the behaviour of concern identified is physical aggression, but there's a locked door proposed for use with no explanation as to why that door is locked. So the proposed use of the environmental restraint in this example would not meet this first authorisation item because there's no demonstration as to how it's in place to prevent physical harm to the person or others.
Another example of when this authorisation item may not be met is when there's a behaviour of concern listed in the BSP that doesn't actually cause harm to the person or others but rather something that is just challenging for service providers or socially inappropriate. For example, a person regularly pulling out all of their clothes out of their cupboard, this behaviour doesn't actually cause physical harm to themselves or others. So locking the cupboard to manage this behaviour would not meet the authorisation criteria.
ADAM FINKELSTEIN: The next item in the authorisation criteria is the Authorised Program Officer may authorise the use of the regulated restricted practice on a person if they are satisfied that the use and form of the proposed restrictive practice is the least restrictive option for the person as is possible in the circumstances. Restrictive practices are not therapeutic, and they don't address the function of the behaviour used by the person to meet their needs.
Restrictive practices can only be used as an option of last resort to allow for positive behaviour support strategies to be implemented. To meet this authorisation item, appropriate non-restrictive strategies must be identified for use before a restrictive practice is proposed. And the restrictive practice should only be used for as little time as possible.
Response strategies should be listed from least restrictive to most restrictive. This clarifies what response strategies are to be applied first to address the behaviour of concern before using a restrictive practice as an option of last resort. This authorisation item also applies to routine restrictive practices. Consideration must be given to whether the routine use of that restrictive practice is the least restrictive option.
For example, if a door is locked 24/7, why is that? Is this actually the least restrictive option? Are there points during the day where a staff member is available to engage with the person, and the door doesn't need to be locked during that time? This information should be clearly demonstrated in the BSP.
TASHA HARAN: The third item of authorisation criteria is the Authorised Program Officer may authorise the use of a regulated restrictive practice on a person if they are satisfied that the use and form of the proposed restrictive practice is included in the person's behaviour support plan. This means that information about what the restrictive practice entails must be detailed in the BSP. Again, this might seem obvious but we often see BSPs where the restrictive practices are only included in the restrictive practice schedule without good detail about what the proposed restrictive practices actually are and how they are to be used.
So similar to the previous authorisation item, this doesn't just apply to restrictive practices. It also applies to routine practices. The BSP should clearly outline when the proposed restrictive practice is to be used, why it is used, under what conditions it is used, and when it can be removed, ceased, or is not needed.
In terms of PRN restrictive practices, a clear PRN protocol should be developed for each restrictive practice and made available in the appendix section of the BSP. These protocols should be simple, clear, and easy to follow giving those implementing the restrictive practice a step-by-step guide about what needs to occur before, during, and after using a restrictive practice.
These protocols should be simple, clear, and easy to follow giving those implementing the restrictive practice a step-by-step guide about what needs to occur before, during, and after a restrictive practice is applied. We highly recommend referring to the NDIS Quality and Safeguards Commission Regulated Restrictive Rractices Guide which provides an example of a PRN protocol template for each restrictive practice type.
ADAM FINKELSTEIN: The next authorisation item is at the Authorised Program Officer may authorise the use of a regulated restrictive practice on a person if the Authorised Program Officer is satisfied that the use and form of the proposed restrictive practice is in accordance with the person's behaviour support plan. Essentially, this means that the proposed restrictive practice needs to be included in the BSP, and all relevant details should be specified in the plan.
The proposed restrictive practice must be consistent with information included in the BSP. For example, the restrictive practice can only be used if it relates to an assessed behaviour of concern identified in the BSP. Any proposed restrictive practice must be consistent across the BSP and RIDS submission. The restrictive practice information included in a RIDS submission is what is being put forward for authorisation. So this information needs to accurately match the BSP.
TASHA HARAN: The next authorisation item is at the Authorised Program Officer may authorise the use of a regulated restrictive practice on a person if the Authorised Program Officer is satisfied that the use and form of the proposed restrictive practice is not applied for longer than necessary. As we mentioned earlier, a restrictive practice should be the least restrictive option and only used as a last resort. This item emphasises that a restrictive practice must only be used for the shortest necessary amount of time.
The BSP must include details explaining why the proposed restrictive practice is used for the specified time and why this duration is the least amount of time required to prevent harm. For example, if a routine restrictive practice is proposed to be implemented 24/7, the BSP needs to justify why that is the case, and considerations should be made as to whether the restrictive practice could be used for a shorter period of time.
Similarly, for PRN restrictive practices like seclusion or mechanical restraint, the BSP must specify at what point their use can be discontinued. It's important to evaluate whether a proposed routine restrictive practices can be implemented as PRN, such as using a helmet only when the person shows signs of escalation rather than wearing it all day.
Including these details in the BSP is crucial, as is often assumed information that the author or familiar staff may know. But clarity is required within the plan to ensure that the restrictive practice can be reduced over time.
ADAM FINKELSTEIN: Next in the authorisation criteria, is the Authorised Program Officer may authorise the use of a regulated restrictive practice if the Authorised Program Officer is satisfied that the person's NDIS BSP is in accordance with the requirements of the NDIS Restrictive Practice and Behaviour Support Rules if the person is an NDIS participant or a Disability Supports for Older Australians (DSOA) client. The NDIS rules encompass various responsibilities for behaviour support practitioners and implementing providers.
Both behaviour support practitioners and service providers should familiarise themselves with these rules, as they play a significant role in the Victorian authorisation requirements and implementation of a BSP. Here are some key points to keep in mind. A comprehensive BSP must include a fade out plan for all restrictive practices.
This fade out plan should include strategies to reduce the need for the restrictive practice, such as skill-building strategies or identifying replacement behaviours. It should also have clear timelines for gradually reducing the use of the restrictive practice.
Fade out plans should include any required involvement from health professionals, such as medical practitioners or allied health clinicians. NDIS requirements for timelines around the development of interim and comprehensive plans must be met. An interim BSP can only be authorised for up to six months, at which point a comprehensive plan must be developed. The correct NDIS template must be used depending on whether the behaviour support plan is an interim or a comprehensive plan.
The NDIS rules also outline the definitions of restrictive practices. In Victoria, the Disability Act definitions of restrictive practices align with the NDIS rules. So when referring to restrictive practices in a BSP, these will need to be consistent with the NDIS rules definitions.
TASHA HARAN: If seclusion is proposed for use, the Disability Act outlines certain provisions that must be met. The person must be supplied with appropriate bedding and clothing, have access to adequate heating or cooling, be provided with food and drink as appropriate, and have adequate toilet arrangements. It's also recommended to use seclusion for the shortest duration possible and maintain frequent observations at least every 15 minutes with detailed monitoring plans, especially when PRN medication is being administered.
It should be clearly stated in the BSP how the person in seclusion can access or request these items. The authorisation criteria in the Disability Act also requires Authorised Program Officers to comply with the independent person requirements. The APO must ensure that an independent person is available to explain the proposed use of restrictive practice to the participant.
ADAM FINKELSTEIN: The role of the independent person is explained in our video about the authorisation process and roles. There are other legislative requirements regarding authorisation that are mandated by the Disability Act. The authorisation of restricted practices applies to people who receive disability services, are NDIS participants, or are Disability Supports for Older Australians (DSOA) clients.
Only providers registered with the NDIS or a state-funded disability service providers need to be listed in the restricted practices schedule in a BSP if they will be implementing a restricted practice. Other individuals or entities implementing restrictive practices, such as families, hospitals, or schools who are not funded for disability support by the NDIS or the department can be listed in the body of the BSP or under a different heading outside the restrictive practices schedule.
The proposed use of restrictive practices must comply with any other requirements set forth by the Victorian Senior Practitioner, which have been disseminated as directions that can be found on the Victorian Senior Practitioner website. There are existing directions stating that the APO and the author of the BSP cannot be the same person, that the behaviour support plans must be written using either the NDIS Commission or Victorian Senior Practitioner templates without modification and that there are prohibited forms of physical restraint that must not be used in Victoria.
Other considerations when authorising restrictive practices include: BSPs must be current and recently signed off by the behaviour support practitioner, information in the BSP must be legible. For example, screenshots of medication treatment sheets should not be copied into the restrictive practice schedule. Please ensure that the document is finalised with no track changes or comments.
TASHA HARAN: Adam and I are now going to examine an example of a behaviour support plan and apply the authorisation criteria to it.
ADAM FINKELSTEIN: Thanks, Tasha. Let's go through what we consider to be a gold standard BSP. This mock BSP has been deliberately designed to be simple and not overly complex. Whether it's a relatively straightforward or a more complex scenario, you can always rely on the authorisation criteria and principles we've covered in this video.
I also want to clarify that the Victorian Senior Practitioner's office does not recommend the use of restrictive practices. The BSP were presenting here, which includes restrictive practices, is solely for the purpose of applying the Disability Act authorisation criteria within a BSP. We're not endorsing the use of this specific BSP.
For this example, I'm going to play a behaviour support practitioner who has developed a BSP for an NDIS participant named Anya. Tasha will act as the APO who is considering the authorisation criteria. As you can see here, the behaviour support practitioner is clearly listed on the BSP, which is crucial. We have identified that the APO and the practitioner are two different individuals, which aligns with the direction provided by the Victorian Senior Practitioner.
In these first few pages, it's important to have the details of the key contacts, such as Anya, family members, other professionals and anyone crucial to the development or implementation of the BSP. The NDIS service provider has been clearly identified as the implementing provider with the service location at 123 Redsway, Melbourne.
This information should match what is stated in the RIDS submission. Additionally, the authorised reporting officer as mentioned in the NDIS Commission template may be a different person from the APO. It's also important to note that providers who are not implementing restrictive practices should be listed as key contacts rather than implementing providers in the BSP.
In this example, we have a day program manager listed as a key contact, which is fantastic because we want everyone who is playing an important role in Anya's life to participate in the development of the BSP. Only registered NDIS providers or disability service providers implementing restrictive practices should be listed as implementing providers in the BSP. This applies to families as well.
So let's move on to the next section, which is the behaviours of concern table. Here we have identified a behaviour of concern, which is the compulsive eating of food. There are details about this behaviour of concern, including the harm caused by the behaviour, high risk settings, triggers, low risk settings, and the function of the behaviour. Additionally, replacement behaviours that meet the function of the behaviour and behavioural goals have been specified.
TASHA HARAN: When examining this section as an APO, I'm checking that any proposed restrictive practices in the BSP are clearly linked to this behaviour of concern. For example, if seclusion is mentioned as a potential restrictive practice later in the BSP, I'd want to consider whether it's actually necessary to prevent harm in this case.
ADAM FINKELSTEIN: In the next section we can see I've added a collection of preventative strategies to proactively manage this behaviour and improve Anya's quality of life. When preparing the BSP, I've made sure to consider various aspects about Anya and her behaviour, including regarding Anya's goals, environment, skills, and support needs, as well as risks.
A useful BSP is an easily accessible and concise document for the supports in Anya's life. I don't need to include extensive paragraphs or complex analyses of factors influencing behaviour here. I included all additional information in the functional behaviour assessment report or a separate document.
This example is simplified. So information from other professionals involved, such as allied health clinicians or medical practitioners would normally be included.
TASHA HARAN: As the APO reviewing this BSP from an authorisation perspective, I can see that a restrictive practice would only be used as a least restrictive option to manage the risk of harm given the focus on implementing non-restrictive proactive strategies as regular practice. For instance, it was mentioned earlier in the BSP that a high-risk time for the behaviour of concern is when Anya hasn't had a full or nutritious meal.
Under the health section, there are details about ensuring Anya has had three nutritious meals following a dieticians plan, which is attached in the appendix, and having food available at all times. These proactive strategies demonstrate that if restrictive practices are used, they're intended to be the least restrictive option.
It's also important to acknowledge any side effects of medication that Anya is taking that may influence her appetite. It's beneficial to consider alternative approaches rather than immediately resorting to restrictive practice. Because as mentioned earlier, restrictive practices don't address the underlying function of the behaviour of concern.
ADAM FINKELSTEIN: I've included the routine restrictive practice in this section. I made sure that clear time limits and specific conditions are indicated for its use. The restrictive practice is only implemented overnight when staff support is unavailable, but there's safe food available for Anya to access if she's hungry overnight.
TASHA HARAN: The authorisation item for using the restrictive practice for the least amount of time necessary and as the least restrictive option are clearly addressed in the BSP here. Considering that the behaviour of concern is only related to taking food out of the fridge and eating unsafe items and it occurs only when staff support is unavailable, the decision to lock only the fridge overnight aligns with the least restrictive approach. However, we're still reviewing the BSP, and the goal is to ensure that the practice is not applied for longer than necessary.
ADAM FINKELSTEIN: That's right. If I was suggesting keeping the fridge locked at all times, even when staff support is available or when Anya has just eaten a meal, I'd expect that the APO would suggest that this was not the least restrictive option and would not provide authorisation for this use of restrictive practices. The relationship between the APO and the practitioner is critical. There needs to be ongoing conversations as to whether or not a proposed restrictive practice meets the Disability Act authorisation criteria.
Having clear response strategies is a vital part of the BSP, particularly, when demonstrating if a restrictive practice is required or the least restrictive option to prevent harm. The response strategies outlined here are very basic, and we would expect a more detailed plan with clear escalation cycles or similar approaches.
As you can see here, staff are able to identify when the behaviour is beginning to escalate and address it safely without the need for a restrictive practice. Now we've come to the restrictive practices schedule, which should outline any restrictive practices implemented by an NDIS provider or disability service provider requiring authorisation.
TASHA HARAN: As an APO, it's my responsibility to make sure that the details in the restrictive practice schedule match with the RIDS submission.
ADAM FINKELSTEIN: As we've discussed how a restrictive practice should only be a short-term response to allow for positive behaviour support strategies to be implemented, having a comprehensive fade out plan for each restrictive practice is important. It's also required as a part of the authorisation criteria. This fade out plan outlines who is involved and what actions they will take throughout the process. I've also included a clear timeline for this.
TASHA HARAN: A fade out plan should go beyond a simple statement that the behaviour of concern will be reduced so then the restrictive practices will be reduced. It should provide detailed steps and demonstrate how the reduction will be achieved. Critical thinking should be applied to explore how these restrictive practices can be gradually eliminated over time, which may involve difficult conversations about the funding model and potential adjustments needed at a system level if individual skill-building techniques are insufficient on their own.
This is where I as the APO within the service provider and Adam as a behaviour support practitioner would need to work together. So does the BSP meet the authorisation criteria? As an APO, I need to consider whether the restrictive practice is necessary to prevent harm.
In this case, there's a clear behaviour of concern, and the restrictive practice is directly linked to that behaviour. It's used as a least restrictive option, as we discussed earlier. The kitchen fridge is the only thing that's locked, and it only lasts for the period when Ana cannot be supported overnight.
All the necessary details regarding the use and form of the restrictive practice are included in the BSP and the restrictive practice schedule. The use of the restrictive practice is not used for longer than necessary. The NDIS rules have been met with a comprehensive plan being developed within six months, and a robust fade out plan has been included. As the APO, I would authorise this plan, which is a start of a 12-month journey with the practitioner to implement the recommendations to reduce and eliminate the use of the restrictive practices.
ADAM FINKELSTEIN: Developing a BSP and applying the authorisation criteria requires careful consideration. Person-centred planning ensures that the participant's voice remains central in all behaviours support activities and that their goals and aspirations are achieved. The authorisation of restrictive practices interlinks with the key principles of positive behaviour support, increasing quality of life by promoting capable environments and enabling people to meet their needs safely without using restraint.
End of transcript.
Restrictive Intervention Data System (RIDS) Training
This eLearning module will give the user a better understanding of the processes and requirements of completing a Behaviour Support Plan (BSP) for authorisation in the Restrictive Intervention Data System (RIDS).
In this Victorian Senior Practitioner e-learning module, I'll be taking you through the fundamentals of the Restrictive Intervention Data System, or as we know it, RIDS. Hopefully it will give you a better understanding of your requirements when using the system.
What is RIDS? RIDS is a database that is used to record restrictive practise data for the state of Victoria which provides the function of submitting Behaviour Support Plans for people with disability that are subjected to restraint or seclusion that require authorization by the Victorian Senior Practitioner as per the revised Disability Act of 2006. It also has the capability to record restrictive practises administered to people with disability subjected to restraint or seclusion for state funded clients, which has captured data on restrictive practises since 2007.
It has enabled the Victorian Senior Practitioner to analyse the data and, through research, has been able to make evidence-based change to promote the reduction in the use of restrictive practises for people with a disability in Victoria.
Why should you learn about RIDS? The benefit of understanding what your requirements are in RIDS will reduce the administrative errors, which can hold up the processing of your Behaviour Support Plans. These errors can lead to the Behaviour Support Plans being refused and delayed, thereby increasing your requirements to record Unauthorised Restrictive Practises, or URPs, to the NDIS Commission. In addition to this, while the data is collected in RIDS, it has the capability to inform and support clients via various reporting available on the system.
I'm Anthony La Sala, the systems manager for the Victorian Senior Practitioners Restrictive Intervention Data System. We will, over the course of this module, help you get a better understanding in getting access to RIDS as a new provider, how to register as an APO, create a person, add an NDIS BSP for approval, how to add a Secondary Implementing Provider, what to do if the BSP refused, how to add a state-funded plan, how to access reports from RIDS.
The module is segmented into different sections to allow existing users to skip to areas of learning they require and/or reinforce certain aspects of RIDS they've forgotten about. We hope the following Victorian Senior Practitioners e-learning module will help you understand your requirements of the Restrictive Intervention Data System.
New Organisation and APO Approval. To get access into the RIDS system, you need to be NDIS registered. You will need to have access into the eBusiness Portal. That portal looks after many applications, RIDS being one of them. And once you're in the system, you can go in and register your APO.
So the process is pretty convoluted, you may think, as you can see on this particular flowchart. And it can be a bit confusing. So what I'll do is I'll take you through each individual step. But the first step is, are you registered in the NDIS? If you're not, you need to be registered and come back.
Once you are registered in the NDIS, you need to have access to eBusiness. If you haven't got access into eBusiness, you need to register in eBusiness, and then come back. Once you've done that, you can then access the RIDS system and request access as an APO.
The NDIS process, unfortunately, I can't help you on that. But you need to go to this website to register your Organisation in the NDIS with the NDIS Quality and Safeguards Commission. You will require eBusiness access to get access to the RIDS system. You need to call the 1300-799-470 number. On the first set of prompts, select 1 to get eBusiness Support. On the second set of prompts, select number 4 to speak to the eBusiness Administrator.
They'll send you through some information for you to fill out in regards to eBusiness. There is an agreement to be completed. Complete the eBusiness Agreement. Send it back to the eBusiness Administrator. And they can confirm and create the actual system. Once you're registered, you'll be able to access the RIDS system.
The RIDS registration process involves you going into the RIDS system after you've got access into eBusiness. The application will be showing on the portal. Once you've clicked on that, you can click on the Register Provider option.
When you click on the Register Provider option, you can actually register the provider details. Once you've done that, you can register at least one outlet. And then, once you've confirmed all the provider details, you will get approval from the Victorian Senior Practitioner.
Once you have access to the RIDS system, you will need to have a provider authority. The provider authority is a person that actually approves the APOs in the RIDS system. So they should be a CEO, director, or a general manager. And once that request has been made, it will come through the Victorian Senior Practitioner's Office for approval.
If you are not one of the three, which is a CEO, director, or general manager, you can delegate that role. And you'll need to send an email to the RIDS Helpdesk. Those details will come through at the end of this module.
So the APO Approval. So this can be a bit convoluted also. There's a lot of steps that need to go through. So you can see confusion on the page again. Let's go through the process to apply to be in APO.
So the applicant submits the request via the RIDS system. It goes to the Provider Authority. And if you're already an APO at that Organisation, you'll be approved. Otherwise, it still needs to go through the Provider Authority, and they will assess if you need to be approved.
If the Victorian Senior Practitioner doesn't approve it, you'll get an email to that, stating you're being refused. Otherwise, you'll get an email saying you're being approved. So if the applicant has already had access to the Organisation as an APO, the request will go to the Provider Authority.
The Provider Authority will either reject it or approve it. If they refuse it, they'll get an email, and it will be a direct approval. And then the APO will have access to that Organisation. There's no requirement to go to the Victorian Senior Practitioner.
Getting Started-- Person Profile. So when you come into the RIDS system, this is the landing page. There are information references on the screen, on the landing page. There is also important information on the left-hand side of the screen, which you can actually download as documents and whatnot in there.
But you will need to actually have a person to put a BSP against. So the first place of call is the Person Profile, but I'll just explain these other areas. We've got the Main Features area, we've got the Reporting area, and we've got Support Functions. So in Reporting, there are reports in the system. And in the Support Functions is where you need to request additional access.
So in the Person Profile screen is where you actually create a new person. You will see that there's the provider, your provider, and service outlets. If you have access to one or more access, they'll list the two. But if there's only the one access, there will only be one outlet showing, and you won't have a dropdown.
So if we go to the top outlet, it will show you all the actual people at those outlets. And you can see there's Person A and there's Person C. So they reside at those two different outlets. So if we go to the other outlet, it is only the one. So you see Person B sitting in there.
But if you wanted to create a new person in the system, then you click on New Person. And you select where you want that person to be at, which particular outlet. And Continue. So you'll need information here. So the CRIS reference number and the NDA number are not mandatory, but the first name and the last name, the gender, date of birth are.
So you put their first name in, their gender, their date of birth, and you go Next. What the system does now, it goes through and it searches for a duplicate person. If that person already resides in the system, it will come up with a warning.
And it may be that person has a common name, like Peter Smith. But you can check that by having a look at their date of birth. And their dates of birth here are different. So if it's not a duplicate, you can continue, or you can edit the duplicate.
But at this point in time, I would go back and search for the person in the system so you can share them. It's important that you do do that. Otherwise, you can create a duplicate. If you do create a duplicate, it will come through to the system administrator and myself, and we'll review it. And we will delete that record and notify you of that. So be sure that you do do that and make sure that you haven't got the wrong information being put into the system.
So let's go back and try to find Person D in the system. It actually asks you for one of these things or two of these things. But like I said, the CRIS number is not required, but you can actually have the first name and last name. So if we put in Persona D in the system, and we search for them, you can see Person D is actually sitting at Provider B. We're at Provider A.
And when I click on Person D, it gives me this information. I can request access to them or request a transfer. Because the BSPs are shared, and they're actually added by the APO when they're loaded, you'll get access to them via that method.
So if you are the provider, that is, the lead provider, you request transfer, you put the actual outlet that you want to transfer them to, you say Yes to that. And what will happen is an email will go to the APO of the other Organisation, they'll approve that transfer, and you'll become the lead on that Organisation.
So that's how you actually transfer a person from one Organisation to another Organisation. So let's go back and create a new person. So if we click on New Person again, and we'll put in a new person, Continue. And once again, we'll put some information that's required.
Most of the fields are mandatory, as I said, but the CRIS and the NDA numbers are not required. So we'll put a person in. And any fields that are a date or a time, you can put the number in, and it will change to the date field.
And it asks you for more information around the client. So what's the country of birth? That defaults to Australia, but that can be changed to all the countries around the world. The Indigenous status-- there was four selections there. If they are culturally and linguistically diverse, we can click that.
Now, this treatment plan requirement is not required for most NDIS participants. If you have one of those, I will refer you to another e-learning module, but not this particular one. So click on No for this particular instance.
So what's the disability? So there's a range of six or seven there at the moment. So we'll put in intellectual disability. And you do require to put in a secondary disability group. So it can be none. And you click on the Save option. And that's how you create a person in the system.
Fairly straightforward. And you can see that they're in the system now. But if you wanted to edit that information, you can click on that Edit option, and you may require to edit that person's information in regards to-- they may no longer reside at that service, or they are no longer receiving restrictive Practises.
So you can deactivate that person by clicking on the Deactivate option down the bottom, and it will actually ask you why it's being deactivated. You can see Deceased or [INAUDIBLE] for one of the reasons. So that's what's on the system at the moment for the deactivation. But on this occasion, we won't do that. We'll just go back and continue on. And go back again. And that's how you create a person in the system.
Adding a BSP for Authorization. When a Behaviour Support Plan you're sending to the office to be authorised, it can take different paths. It can be refused, it can go via Secondary Implementing Provider, and it can also be authorised. So it can be a little bit confusing.
So what I'll do, I'll take you through the individual steps of the flowchart. So when a plan goes to get authorised, it can be shared with other implementing providers. If it's not shared, an email will go to the Victorian Senior Practitioner for approval.
They will review it. And if it's approved, an email will go to the Behaviour Support Practitioner and the APO with a letter of authorization. So a BSP refusal, the plan is sent in by the APO. It goes to the Victorian Senior Practitioner if it's not shared by another independent provider.
They will review it. If it's been refused, an email will go to the APO and the Behavioural Support Practitioner. The APO can discuss with the Behaviour Support Practitioner plan, and it will have to be resubmitted.
If the Behaviour Support Plan is a secondary approval, once again, it doesn't need to go to another APO for another provider. The other provider will get an email saying, please approve. They will review it. They'll tick off any restrictive Practises that are required from their service outlets.
If they approve it, it'll go to the Victorian Senior Practitioner. Once again, it will be reviewed. If it's approved, an email will go out to all the APOs Behaviour Support Practitioner with the letter of approval.
The same thing happens in the case of a rejection. It goes the other way. If there is a requirement for a secondary provider to approve the plan and they refuse it, the plan will go to the secondary provider for approval. They may not be required to be on the plan. They can actually refuse it, and they can refuse it.
When they do refuse it, they'll actually send an email back to the actual practitioner, and they'll have to discuss it and resubmit that plan. So they are the different paths you can take when a BSP has been authorised and/or refused.
Lodgement of NDIS BSP. OK. So now we've created the person in the system, the next logical step will be to add a Behaviour Support Plan. You can see here there's a Behaviour Support Summary there on the bottom, and there's also status history. And it tells you who created the person in the original aspect or if they've come from another Organisation.
But in the Behaviour Support Plan Summary, it tells you Current, Authorised, and Archived. The system archives Behaviour Support Plans after two years, or 48 months. So that can be found in that section. And obviously, there's nothing in there.
There are no current plans in this particular person's file because we haven't created one, and he's a new person in the system. So we'll add a BSP. The next option we have here is, is it an NDIS client or participant, or is it a state-funded? So it's an NDIS, which most people will be accessing the system for.
Between the two plans here, we've got comprehensive and interim plans. A comprehensive plan is created for 12 months. An interim plan is created for six months. And it's to cover the Behaviour Support Practitioner while they get to know the client, and then they can write a comprehensive plan.
So the requirements for both of these plans are the same, except one can only go for six months, the interim plan, and the other one goes for 12 months, which is the comprehensive plan. So click on that. And then OK. And it'll give you a template to complete.
So it's fairly straightforward. A lot of the fields are dropdowns, and there's not a lot of requirements for typing, except for this page, where you need to put information in. So the start date can only be a start date from today. So you can't backdate plans, and plans obviously can't go greater than a year.
So we'll go from-- we'll start a plan that we've received that's going to start on the 1st of August. And we'll create a plan that goes for 12 months. So we'll go to the 12 months option. So I've got a 12 month plan.
It does ask you, was the person with disability or guardian consulted in the planning of the plan? That's part of the legislation that's required. It will ask for the Independent Person. An Independent Person is someone that is independent of the Organisation.
These will be gone into in more depth in the other modules presented by the Victorian Senior Practitioner, so we'll just put one in for now. We do need their contact number because we do contact the actual Independent Person to see if they were actually involved in the planning of the plan.
OK. So we'll need the actual Behaviour Support Practitioner's name. So this goes on the letter to the Behaviour Support Practitioner when the actual plan is either refused or approved. And the only way we can get it to them, basically, is via the email.
So we do need the correct email. If you don't have the correct email, they will not receive the letter of authorization or refusal. So it's important you get this right. We have had calls in regards to this not people receiving letters of acceptance or refusal. So make sure you do get this right in the system.
So click on the Next option. And it asks for some more information. So all this information is contained on the Behaviour Support Plan that will need to be attached in the system. So what is the Behaviour of concern? You can see there's six options there. There's a harm to self, harm to others, and combination of harm to self with destroying property and others.
So we select one of those six options. And we need to add the restrictive Practises that are contained on the plan. So click on Add Restrictive Practises. So there are a couple of types. There's PRN, or as-required medications, or restrictive Practises, and there's routine. The routine, obviously, are the medications or Practises that are given on a daily basis.
So we'll put an example of all of these in, just to show you how it works. So the chemical restraint, that actually asks you for a routine chemical. We say Add. So we have a dropdown list here, which we need to fill out. So we put in the spelling. So we'll put in Valium. And a list will appear down below.
You are required to select off the list because the system doesn't trust your spelling. We'll give you a bit of information around the groups and the generic names of the actual medication in this instance. You put in the dosage, the measure, frequency, how frequent is it given, and how it is given, the route.
When you click OK, you can see it appears there on our list. And we can add another one if there is another routine medication. So once again, we start typing in the actual medication. And you can see the spelling references come up. We click on the actual medication. So [INAUDIBLE].
Once again, it's the same thing. What's the dosage? And you can see we've added another medication. So see, as you put them in, it actually adds them to the grid above. And if we're happy with that, we can save them, or we can go remove them or edit them-- right, sorry. To the right of them.
OK. So now, we can add the other types of restrictive Practises. We can add the PRN for a chemical restraint. So I'll just put in Valium. Once again, selecting off the list. And it actually asks you-- instead of the frequency, it actually asks you, how many times a day is it going to be given at the very most?
And we save that restrictive practise. And once again, you can see it added to the top there, and it's added to the list of medications for chemical restraint. So I'll go through now and put in some other restrictive Practises. They're slightly different, but they work pretty much the same way with different requirements.
So for mechanical restraints, it's the same thing. It's a routine. We're going to click on Add. It gives us a range or different types we can select. We can select bedrails, wheelchairs. So we say, we're going to disable the wheelchair, for instance, and we're going to disable it at lunch time. So we'll put in 12:10, and we'll finish at 1 o'clock. This is a 13-hour-- 24-hour clock, should I say. Click OK.
And you can see, it's added there. We can add other mechanical routine restraints if you wanted to. And we just click on Save Restrictive Practise, and it's added the wheelchairs there. So we'll continue on and put a couple more different types of restrictive Practises.
So I'll put in PRN, or as-required seclusion. Seclusion asks you for some information. So there's free text. So how are you secluding this person? So we're going to lock them in their room. And the period we're going to be doing that for.
So this is all part of the plan that's been created by the Behaviour Support Practitioner. So it should be straight out of their plans. So we can add another restrictive Practise. And this time, we're going to be putting in an environmental restraint. So we'll put in a routine for environmental.
So Add Routine. So we'll just scroll down the page and show you the screen. So we've got, what is the person prevented from accessing? So there's a range of tick boxes, and you can put in multiple. And it's the same, what is the restricted-- or how is the restriction applied?
So we do have a bit of issues in regards to people putting in this particular restraint because they may have multiple environmental restraints. And they will put in, oh, he has food and drink, and he has a locked cupboard or fridge. But he also has an external area, and he has supervision for the same period.
But that gets a bit confusing when you put and you look at the actual restrictive Practise because they're all bunched together and hard to read. So I'll just show you what the outcome will happen in that instance.
And is restricted Practise required as part of the court or tribunal order? You say, no. You say, OK. And you can see it's all lumped in. Locked cupboard, fridge, pantry supervision. It's not very clear in regards to what we should be trying to work out what this person has if they're individual types of environmental restraints.
So I'm going to remove that and show you how you should be doing it. So once again, I'm going to add another one and show you how it's done. There's no additional work, it's just in and out a couple times. So food and drink. Refrigerator.
We're going to put it in there from 10:00 to 12:00. So we're going to add that. So you can see it's showing me what I've put in there. Locked cupboard and locked fridge/pantry. So add another one. So instead of bunching them all together, we can put it in like this.
OK. And you can see it's easier to read. It's not all bunched together. So that would be the better way and the recommended way of putting in environmental restraints, if there's more than one, for that particular person. You can see how it's logged in here also. It says, food and drink for that period, then external area for that.
If it was all together, it would be all bunched up, and you wouldn't know what was what. So that was the best way to do it. And the last one I'll put in is physical restraint, and that can only be put in as a PRN. So if I click on the Routine option, you'll see that I can't click Physical Restraint.
But as a PRN, I'm able to engage that particular restrictive Practise. And I can actually put in the different types or the type of restraint that's being applied in a particular instance. So physical hands. And we don't encourage use of physical restraint, but that's the option that's been submitted by the practitioner.
We save the restrictive Practise. And you can see that I've got a grid here. And it's showing me what I'm going to send off for approval to the Senior Practitioner. So my next option is to click on the Continue Authorization Process.
So at this point in time, it actually asks me, are there any other providers? Now, going back to the slide that was demonstrated earlier-- not the slide, the actual flow chart showing if other implementing providers are engaged, this is how you actually do the sharing of a plan if there is another. If there isn't, you click on No, and you submit it for approval.
But in this instance, I'll show you how to share another provider. So click on the Yes option. So it gives us a alphabet, basically. So where is this other outlet that needs to be joined? This person needs to have a joined plan. So click on X. And we're going to say, we're going to join that Provider B.
And what's the address of Provider B? Turtle Way. So those two have been selected. So what happens here, we click on Add the Implementing Provider. So it actually says, you're going to be joining and sharing the information. You click on Yes. And this is a confirmation.
You can just click off that confirmation. And you can see down the bottom here-- so you can see here from the grid down below, we've got X Learning Provider B. Turtle Way. So we've not completed the actual sharing of this BSP yet. We need to click on the Select option and apply the selection.
And you'll see down here a tick will appear under the Sharing option. That is confirmation that it's been shared. So we've done that. And you can see at the top here, if I scroll up to the top of the page, you'll see also it's sitting under the Shared By under the Behaviour Concern area.
So in the actual grid of all the actual restrictive Practises, which is just here, you can see that there's all the restraints. And it says it's being used by Provider A. So these are all the ones that we're committed to. They're all being linked. So they're all being shared by this particular provider.
So we're happy to go here. But what we need to do is now add an attachment. So we click on Add Attachment. So we need to attach a document because you can't submit a plan without attaching a document. So we'll just go to put in a description of it.
So when you get the green button there, you can actually save. You can also remove it if you've clicked on the wrong one, obviously. So click on the Save option. And that'll append that to the plan. So we've now got a plan that's been attached to the plan. So we're right to go.
So now we've got the options down the bottom here. You can add another Behaviour support-- Behaviour concern, should I say, or another attachment. At this point in time, we can just send it off to be Authorised. So click on Save and Authorise.
So it does double-check to makes sure that you have actually added any additional implementing providers. Your plan will be refused if you haven't put the implementing provider and the attachment text. BSP has got an implementing provider on it.
So once again, just scroll up the page there. You'll see, at the very top, Shared By. So you've been successful in sharing that plan. So it's OK to say Yes and move forward. So what will happen now, that plan will go off to the secondary provider to be approved, and they can cherry pick the actual restrictive Practises that are in the system for them. So you can see now-- let's come back out-- you've been successful. We've got a Shared By on the BSP there, and it's now pending.
Secondary Provider Approval. So let's go back and do that. So we'll come back in. We're going to Provider B. We'll come back in as the APO. So an email will say, go to your To-Do Items. I'm going to my To-Do Items.
And in there, you can see Person H sitting in there. And it's waiting for approval. Click on the Select option. That will bring up the plan. So you need to select, as a secondary provider, minimum of one restrictive Practise. So if you're not doing any of these sort of things and you're only administering the Valium in the middle of the day, click on the Valium, and you link that.
You need to click on the Link option. Even though the tick's sitting in there, you need to click on the Link option. You'll see now that Turtle Way Is now sitting under that particular Practise. So you're now ready to go. You click on Authorise.
And that email will now go to the Victorian Senior Practitioner. It will say, there's a BSP that needs to be approved. And that will be in there for them to approve. And that's how that works.
Victorian Senior Practitioner Approval. So when a BSP has been Authorised by the APO, an email will go to the BSPQuestions inbox, and it will go to the To-Do Items list for the Victorian Senior Practitioner to review and Authorise or refuse. So basically, I'll just show you what is on that process or in that process.
So we have the Approval and Authorization option. So if it has a mechanical seclusion or physical restraint, they will go through the checklist, and they do go through the checklist with the other medications and the environmental type restraints. But they need to ensure that the checklist has been fulfilled.
So in this scenario, if they click on a No option, they will put through a comment. And if you do have a no, the actual BSP will be refused. So when the BSP has been refused, it will actually send through an email to the APO and also the Behaviour Support Practitioner. And in that email, there will be an attached letter.
The letter will state in the checklist in regards to what has actually happened in that space and what you need to address to resubmit a plan. With the authorization, it will just be an authorization letter, and that will be attached to the actual BSP. If it has been refused, there will be a commentary also in regards to why it has been refused, and that will be actually contained in the actual BSP email refusal.
So we'll reject this one. What will happen is an email will go through for refusal, and the refusal reasons will need to be addressed before you can resubmit. So how do you deal with a refusal? I'll take you through in the next section.
What to do if a BSP is refused. When you receive the email of refusal, you need to define the person that has been refused. So go to the Person Profile and find the person in the system that has been refused. On this occasion, it was Person H.
When you select that one, you can see there there's one that's been rejected. Click on the View option. It brings up the plan. And what you need to do is Create and Copy. This will create a copy of the plan. It will ask the question to confirm that you want to create a new version of the plan. Click OK.
It'll bring through all the records that are required, but you will need to put the dates of the Behaviour Support Plan back in. You will also need to re-establish the actual restrictive Practises that were on the plan. So you need to select on the actual restrictive Practises.
Make sure that you click Link so they are now linked to your outlet. And you'll see them appear here under Used By. And if the plan was shared, which it was on the last occasion, we need to re-establish that link also. And you can see at the top here, under Shared By, that hasn't been shared with the other provider.
Apply the selections. Once again, there is that sharing tick box that will appear. And you'll see at the top the actual e-learning Provider B has been shared. So at this point here, we need to put the BSP on again. And the reason why we're putting that on again is it may have changed through the directions from the office.
So you need to put that back on again. We'll put the corrected Behaviour Support Plan on. And once you've done that, you'll see that all the information is on there. So you can now, once again, Save and Authorise and get that approved by the Victorian Senior Practitioner.
Once again, it confirms, or wants you to confirm, that you have added the other provider. And we can see that it actually has been. So we can now continue. Click on the Yes option.
And once again, the process of emails going out to the Victorian Senior Practitioner will go on. You'll see that it's pending. And it's ready to go and be approved by the VSP or the Victorian Senior Practitioner.
Pending Status on a BSP. So what to do when your scenario is as pending. You'll see there's a Pending status against the actual plan. So we've actually put this plan through and we're wondering, why is there a holdup?
So if we go back into the plan and look at the plan and click on the Edit option, or View if it's in a View status, it'll open the plan up. Down the bottom of the plan, you'll see an option that says Authorizations. When you click on the Authorization option, you will see that it gives you the status of where the plan is at.
So you can see here that Joe Bloggs, which is the APO of the secondary provider, still needs to approve this plan. So that's where the holdup is. It does datestamp when the plan was submitted and when it's been Authorised.
So you've got a record of when it was submitted to the office, and you can see where the holdup is. So that's all good. So we'll just go back, and we'll now wait for the approving of the plan from the Victorian Senior Practitioner.
State Funded Plans. As a provider, you may need to submit a State Funded Plan for approval. Now, a State Funded Plan is normally a plan that is for a person that hasn't got NDIS funding or is not an NDIS participant. So the way you put that in, it's very similar to the NDIS, but there's more details required.
So you click on Add a BSP, click on the State Funded Plan, and OK. And it brings up a different template. And the details in the plan are required to submit the plan for approval. All the fields here are mandatory. So there's quite a few in here, and I'll just take you through them.
So we need to have a date. Obviously, the date criteria is the same with other plans. It has to go for up to a year. It can't go greater than a year. And it can't be a date prior to the day of submission. So we'll just put a date in.
It does require the independent person, the same with the other one. It does require a plan to have an independent person. The contact number. Once again, was the guardian consulted or the person with disability. And it's just a reminder here, has a Functional Behavioural Assessment been carried out?
And it takes you into the realms of more information in regards to the template requirements. So it does require as mandatory history, health, and communication. So I'll just put in some information in those fields. But the other fields are not required and they're not-- well, they are required, but they're not mandatory.
So we have History, Health Communication, Likes and Dislikes, Sensory, Life, Dreams, and Aspirations, and Other. There's always an Other option throughout the plan. And it's important to note that if you have got a lot of information, like a Sensory Assessment, you don't need to cut swabs of information into these boxes.
You can actually add them as an attachment. And in this box, you can say, please refer to the attached Sensory Assessment. So I'll go into the next option. So what it does there, it actually saves what's being put in that section. You do require, once again, what the Behaviour is. So there's the six options-- harm to self, harm to others, and a combination of that with destroying property.
A description of the Behaviour, which is not required in the actual NDIS because it's contained in the attached plan. But then, again, it actually asks for more information here. So all this information is normally on an attached NDIS plan. But given that it's a State Funded Plan, you may require to put this in.
So you'll have a dropdown for each tab. So you can have the communication requirement, and you need to put a descriptor in here. And all these tabs work the same way, but you can actually add additional triggers or additional functions by clicking on the Add Trigger option.
And you put in the activity. And once again, that's the requirement for each one. So when you click on the next tab, you'll see that it's the same sort of setup. There is a dropdown, a requirement for the description of what you selected, and you can add additional.
There is a plus sign against each box so you can only see three lines. But if you click the plus sign and you're typing away and you want to see more information, that plus sign will allow you to see 15 lines of information, and a scroll bar will appear if that's required.
So as you are clicking on each one of these boxes-- or, sorry, tabs-- they actually save into the system what you've actually put through. So you don't lose your information. So I'll quickly complete these because these are all the same in the way they function. But they are all required as a mandatory field as part of the submission of a State Funded Plan.
So we get to the Restrictive Practise tab, and you will see a very similar screen if you've been through the start of this e-learning module. So there is a requirement to have an emergency or routine. So once again, you can see the boxes that are available for routine.
And I'll just quickly put in a routine medication. And you'll see, it's exactly the same as is a requirement to complete all these fields. So once again, it works exactly the same as an NDIS plan. So you need to select off the actual box and the information around what's required for that particular medication.
There is a subtle difference. It does require you to put in a prescriber who prescribed the medication and their name. Once you've put that in, there is a further requirement in regards to, how does the use of this restrictive Practise reduce the risk of harm to the person and/or others? So once again, there is a requirement for information there.
So these are all mandatory fields. So if you do try to save or push this one through, it'll come up with a yellow box, and it'll tell you you need to fill out the required fields. So I'm clicking on the OK. So I've saved that requested Practise, and it's now going to be sitting under that tab, as you can see here.
And it's now all in the actual plan. So at this point in time, we need to move to the next part, which is actually add people involved. When you're adding the people involved, there is a select provider or enter external person. So when you click on Select Provider or Staff, it actually looks at actually who's in the actual system.
You can put down the role and where they sit. Click OK. It'll add it to the list. If it's an external person-- so if it's Dr. Harry Who on this occasion-- I need to find the role. So he's a doctor and medical professional. And you can see, they're adding the actual information.
There is a requirement also for team coordination and review. These formulate a good quality plan to have all this information in. And you can click on the Save and complete the BSP. And you can see I've got most of my fields in. You can add an attachment, but the attachment requirement is not mandatory, where it is in the NDIS.
And at this point, you can save it and come back to it and complete it. And you can then save and submit it When you click on Save and Submit It, it should go through and be ready for approval. And once again, it's pending, waiting approval from the VSP. So that's how you put in a State Funded Plan.
Reporting available on RIDS. So if you wish to get some reporting out of the RIDS system, there is the Reporting function on the front landing page, under the Reporting tab. Click on the Reporting tab. You'll see End of Month Reporting, Standard Reports, and Custom Reports. So under Standard Reports, you'll see Reports.
When you click on the Reports option, you will see a suite of reports that have been developed. These are reports that are-- we like to call them Canned Reports because the reports are generated by the system and then easily accessed. These reports are updated overnight. So you can run these reports.
But anything put in on the day will not be in the reports. You'll have to wait for the following day to see those reports. There's quite an interesting suite of reports in here, so I encourage you to go and have a look at these reports. And one particular one I encourage to go to is eBSP Summary and Details Report.
So we'll go to the eBSP Summary and Details Report because it's an interesting report, and it does give you an idea of what sort of BSPs are due over the period of 12 months. So we'll just put in-- you can select for different service outlets. I'm going to select all the outlets, and this is going to give me a view of all the actual BSPs in the actual system.
So click on the View Reports, and it brings up a graph. And in that graph, it'll actually have all the BSPs that are due over the year. And you can see there's quite a few in here because this is the actual system administrator's view. But there's stuff in here where you can actually see the current plans that have been Authorised.
There's no current plans. So you can actually go down to an outlet level. So if you wanted to look at one outlet, you can actually see what plans are due and when they are due. There's quite a few there in this scenario. So if you click on the actual-- or hover over one of the actual columns, you'll see the hand come up.
And when the hand comes up, you can click on that, and that'll drill down, and it will show you whatever the number is of actual plans that are awaiting approval. And it's the same here. If you've got a whole year of plans, you can click up here, under the underlined number there. If you click on that, it'll bring up all the plans that are available for you.
So I do encourage you to have a look at the reports. And this report is quite good if you're trying to manage what sort of plans are coming through, how to chase up Behaviour Support Practitioners for plans because they can take a little while to get plans together. So it's a good little plan to have.
The system does send out alerts to APOs in regards to Behavioural Support Plans and when they're due. It looks forward 120 days, and an email does go out to the APOs and says, well, over the next 120 days, these people at these outlets are required BSPs.
So it'll help you get in line in regards to getting people organised, Behaviour Support Practitioners organised, and it'll also help you in regards to not having to report URPs, or Unauthorised Restrictive Practises, to the Commission because you haven't got a plan in place. Once again, have a look at the actual reporting that's available, and hopefully they can help you out in looking after the client.
Resources. As mentioned throughout the module, the RIDS Data Team can be contacted via the RIDS Helpdesk email if you have any technical questions about the RIDS and its use. If you have a restrictive Practise questions, please email the RIQuestions email.
If you have questions regarding the Behaviour Support Plans, please email the BSPQuestions email. For all other correspondence or questions to the Victorian Senior Practitioner, you can email the VictorianSeniorPractitioner email.
I also encourage you to visit the Victorian Senior Practitioner website, where you can find information around the Victorian Senior Practitioner annual reports, publications, and other research. Thank you for joining this Victorian Senior Practitioner e-learning module. I hope it was helpful to you.
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