Incident Management and Reportable Incidents

Purpose of Policy

The purpose of this policy is to ensure accurate and prompt reporting and response regarding incidents in the workplace, ensuring the safety, comfort, and welfare of both our clients and staff. 

Incident reporting helps to ensure that we are providing the best possible care for our clients, whilst providing a safe work environment for our staff.  As a registered NDIS provider, we also have an obligation to report certain incidents to the NDIS Commission. 

Commencement of Policy

This Policy will commence from Commencement Date. It replaces all other incident management policies of Lifeworks Occupational Therapy (whether written or not).

Application of the Policy

This Policy applies to all health service consumers of Lifeworks Occupational Therapy. Lifeworks Occupational Therapy may at its sole discretion, on a case by case basis, alter the manner in which the process outlined in this Policy is conducted to ensure it suits the particular incident.

What is an incident?

An incident may be any unplanned event or circumstances connected with providing services to a client, which have or have the potential to have (a “near miss”), caused harm to the client or others. 

Types of incidents that may occur during the provision of services to a client may include (but are not limited to): 

• Physical abuse or assault 

• Neglect 

• Sexual abuse or assault 

• Emotional or psychological abuse 

• Financial abuse 

• Physical violence or aggression 

• Verbal abuse or aggression 

• Drug use 

• Physical injury or harm 

• Restrictive practices not in accordance with a behaviour support plan

It is important to note that under the NDIS, there are certain incidents that are required to be reported to the NDIS Quality and Safeguards Commission. 

Responding to Incidents

You may become aware of an incident by witnessing signs of possible abuse, being told about the incident by a person with a disability, or directly witnessing the incident. 

When an incident occurs, immediate steps must be taken to ensure the safety and wellbeing of yourself, your client and any others around you. This may include: 

• Contacting emergency services (000):

• If a client requires immediate medical treatment

• If there has been an alleged or suspected criminal offence 

• There is ongoing danger 

• Notifying your Principal Occupational Therapist 

• Reporting the incident: 

• By following the process outlined below

• Reassuring and supporting your client by telling them what you are doing and what will happen next. 

• Protecting any evidence (eg: not disturbing evidence that may be required for an investigation)

• Reporting to police 

Resources to assist you with reporting an identifying and responding to incidents is available on the NDIS commission website: Resources to support incident reporting, management and prevention | NDIS Quality and Safeguards Commission. 

Please also refer to the separate policies “Emergency Procedures” and “Risk Management”.

If you are in doubt, contact your Principal Occupational Therapist or Clinical Supervisor to discuss. 

Process for Recording and Reporting Incidents

1. All incidents (including near misses) must be reported immediately to the Principal Occupational Therapist of the impacted team using the Online Incident Report & Investigation Form*: Online Incident Report & Investigation Form or the printable PDF Incident Report Form: PDF version of the Incident Report Form (printable document). 

2. The Principal Occupational Therapist can also be contacted directly via phone or google chat for support. 

3. In the event that the Principal Occupational Therapist is unavailable, another member of the management team is to be notified. 

4. There may be legal implications from the incident including the possibility that legal action will be taken by a regulatory body. Subject to the circumstances of the Incident, the Principal Occupational Therapist should consider whether there is a need to engage legal services.

*All members of the management team receive an email notification on the completion of the online Incident Reporting Form. 

What is a reportable incident under the NDIS?

An incident may be any unplanned event or circumstances connected with providing NDIS support or services to a person with a disability, which have or could have, caused harm to the person with a disability or others. 

For an incident to be reportable, a certain act or event needs to have happened (or alleged to have happened) in connection with the provision of support or services. 

Under the NDIS, there are six reportable incidents: 

1. The death of a person with a disability. 

2. Serious injury of a person with a disability. 

3. Abuse or neglect of a person with a disability. 

4. Unlawful sexual or physical contact with, or assault of, a person with a disability. 

5. Sexual misconduct, committed against, or in the presence of, a person with a disability, including grooming of the person with a disability for sexual activity. 

6. Use of a restrictive practice in relation to a person with a disability where the use is not in accordance with an authorisation (however described) of a state or territory in relation to the person, or it is is used according to that authorisation but not in accordance with a behaviour support plan for the person with a disability.

Who is responsible for notifying the NDIS about reportable incidents?

The Principal Occupational Therapist for the impacted team is responsible for reporting incidents to the Commission once the staff member has reported an incident. In the absence of the Principal Occupational Therapist from the impacted team, another member of the management team is to be notified and is responsible for reporting incidents to the commissioner after receiving the incident report.

On review of the incident form, the Principal Occupational Therapist is responsible for identifying if the incident is a reportable incident, and notifying the NDIS Commission using the NDIS Commission Portal (you will need to use your PRODA account to do this). 

Additional resources to assist with reporting an incident to the NDIS Commission can be obtained from their website here: Resources to support incident reporting, management and prevention | NDIS Quality and Safeguards Commission. 

Timeframes for notifying the NDIS about reportable incidents

Assessment and Investigation of Incidents

The Principal Occupational Therapist for the team is responsible for ensuring that each incident is thoroughly investigated, root causes identified, and appropriate corrective actions taken.

This includes: 

• Why the incident occurred

• Whether the incident could have been prevented

• How well the incident was managed and resolved

• What, if any, regulatory action needs to be undertaken to prevent further similar incidents from occurring, or to minimise their impact

• Whether other persons or bodies need to be notified of the incident

If these factors cannot be established on assessment, further investigation may be required, either internally or through an external provider. Examples where an investigation may need to occur are as follows: 

• The cause of the incident is unknown 

• The nature and impact of the incident was significant 

• The incident involves an allegation against a worker 

The purpose of an investigation is to establish the causes of a particular incident, its effect on the impacted person, and any operational issues that may have contributed to the incident occurring.

The following steps are required in the investigation process: 

1. Nominate the appropriate person(s) to undertake the investigation.

2. Plan the investigation which might include arranging to visit the relevant site, coordinating interviews, reviewing documents and records and setting timeframes for completion.

3. Examine the relevant area where the incident or near-miss occurred.

4. Interview people directly involved and any witnesses to get a variety of points of view on what happened.

5. Examine any relevant documents and records which might include risk or job safety assessments, maintenance records, inspection of checklists, hours of work records etc.

6. Analyse the information and determine what happened and why it happened; where it may have been prevented or lessened in severity; whether there is ongoing risk;  

7. Write up the investigation findings and keep a record of this report. This should also include actions to be taken, which may include: 

• No further action 

• Corrective actions to avoid the incident occurring in the future (e.g. training and education, developing a policy and procedure, modifying the environment, disciplinary actions) 

• Restorative actions to repair the relationship with the client (e.g. providing ongoing support, making an apology) 

Record Keeping

All incident records will be stored in the Central Incidents Register, which can only be accessed by authorised staff. Documentation of any assessments or investigations should also be recorded here.

The details of the incident are also to be documented in the clients file, along with all correspondence relating to the incident. 

Relevant Resources

Ref: Incident Management Systems: Detailed Reference for Registered NDIS Providers, June 2019, NDIS Quality and Safeguards Commission: 

Other Associated documents

• National Disability Insurance Scheme (Incident Management and Reportable Incidents) Rules 2018

• The Occupational Safety and Health Act 1984

A copy of this policy and procedure is available for clients and participants to view on our website www.lifeworksot.com.au. Email or paper versions of this procedure can be made available to participants on request. 

The End

If you are reading this, well done!  You got to the end of this Incident Management Policy kudos to you.

Updates to our Privacy Policy

Please make sure to check in on our Incident Management Policy periodically, as we may update this Incident Management Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.  We will always ensure that the current date of the Incident Management Policy also known as the “Effective Date” is prominently displayed at the very top of this Incident Management Policy so you know it’s the latest version.