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Compliance Checklist

TrustCare Support compliance checklist — NDIS Code of Conduct, HIDPA standards, worker screening and privacy obligations for an unregistered nursing provider in Perth, WA.

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Regulatory Compliance

Compliance Checklist

Last updated: March 2026 — based on NDIS Commission, OAIC, AHPRA, and WA Government sources

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TrustCare Support — Compliance Overview

This checklist summarises TrustCare's compliance status across all obligations applying to an unregistered NDIS provider operating as an AHPRA-registered RN clinical nursing subcontractor in Western Australia. Sources: ndiscommission.gov.au, oaic.gov.au, ahpra.gov.au.

✅ Compliant
⚠️ Compliant with monitoring required
ℹ️ Voluntary / best practice
— Not applicable
Mandatory — applies to all NDIS workers and providers

1. NDIS Code of Conduct

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The NDIS Code of Conduct applies in full to TrustCare and all TrustCare nurses regardless of unregistered provider status. Source: ndiscommission.gov.au/rules-and-standards/ndis-code-conduct

ObligationExact WordingStatus
1. Respect individual rightsAct with respect for individual rights to freedom of expression, self-determination and decision-making in accordance with applicable laws and conventions.✅
2. Respect privacyRespect the privacy of people with disability.✅
3. Safe and competent supportsProvide supports and services in a safe and competent manner, with care and skill.✅
4. Act with integrityAct with integrity, honesty and transparency.✅
5. Raise concerns promptlyPromptly take steps to raise and act on concerns about matters that may impact the quality and safety of supports and services provided to people with disability.✅
6. Prevent violence, abuse, neglect and exploitationTake all reasonable steps to prevent and respond to all forms of violence against, and exploitation, neglect and abuse of, people with disability.✅
7. Prevent sexual misconductTake all reasonable steps to prevent and respond to sexual misconduct.✅

Provider-level obligations also met: TrustCare has policies supporting all 7 obligations, trains nurses on Code requirements, and maintains a zero-tolerance culture for abuse, neglect, and exploitation. Code breaches are reportable to the NDIS Commission (1800 035 544).

Current obligations — unregistered NDIS providers

2. Unregistered Provider Obligations

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Source: ndiscommission.gov.au/providers/unregistered-providers

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NDIS Code of Conduct

Mandatory. TrustCare and all TrustCare nurses comply with all 7 obligations. The NDIS Commission can investigate and enforce against unregistered providers for Code breaches.

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NDIS Worker Screening

Voluntary for unregistered providers — but TrustCare commits to maintaining current NDIS Worker Screening Clearances for all nurses. When delivering under a registered provider's framework, the registered provider must verify clearances (see Worker Screening page).

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Complaint Handling

Required — no prescribed format but must be effective. TrustCare has a documented Complaints Policy: acknowledge within 2 business days, resolve within 14 business days, escalation to NDIS Commission and HaDSCO.

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Incident Management

Best practice expected. TrustCare maintains an internal incident register, notifies registered provider partners same business day, and cooperates with all Commission investigations. See Incident Management Statement.

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Privacy and Confidentiality

Mandatory under Code Obligation 2 and Privacy Act 1988 (Cth). TrustCare's Privacy Policy complies with the Australian Privacy Principles. Health information is sensitive information under the Act.

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NDIS Practice Standards Audit

Not required for unregistered providers. Applies to registered providers only. TrustCare's registered provider partners are audited — TrustCare supports those audits by providing documentation on request.

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2025–26 Regulatory Priority: Increased Oversight of Unregistered Providers

The NDIS Commission has named unregistered providers as a 2025–26 regulatory priority — specifically sole traders and nursing subcontractors. The Commission will "take decisive action" for serious Code breaches. TrustCare monitors these developments and maintains full Code compliance.

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From 1 July 2026: Mandatory Registration for SIL and Platform Providers

SIL providers and online platform providers must be NDIS registered from 1 July 2026. TrustCare does not provide SIL supports and is not a platform provider — this change does not currently require TrustCare to register. We continue to monitor mandatory registration reform.

Applies via registered provider's audit framework

3. NDIS Practice Standards — TrustCare as Subcontractor

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TrustCare is not directly audited against the NDIS Practice Standards. However, the registered provider's auditor assesses whether the principal has documented systems confirming TrustCare's compliance as a subcontractor. Source: ndiscommission.gov.au/rules-and-standards/ndis-practice-standards

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Core Module — Division 1: Rights and Responsibilities

Person-centred supports, dignity, privacy, independence, freedom from abuse. TrustCare nurses comply via Code of Conduct and NMBA professional standards.

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Core Module — Division 2: Human Resource Management (subcontractor oversight)

TrustCare provides registered providers with: evidence of AHPRA registration, NDIS Worker Screening Clearance, clinical qualifications, professional indemnity insurance, and incident/complaint handling documentation — all items assessed by the registered provider's auditor.

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Module 1 — High Intensity Daily Personal Activities (HIDPA)

TrustCare's RNs are the "relevant health practitioner" who develops support plans, trains support workers, and signs off competencies across all 9 HIDPA areas. This is TrustCare's core clinical governance function. See HIDPA section below.

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Module 4 — Specialist Support Coordination

Not applicable — TrustCare is a nursing subcontractor, not a Specialist Support Coordinator. This module applies to providers registered for Group 106 only.

NDIS High Intensity Support Skills Descriptors — February 2025

4. High Intensity Daily Personal Activities (HIDPA) — 9 Support Areas

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TrustCare's RNs are the clinical lead for all 9 HIDPA areas. For each area: the RN develops and oversees the participant support plan, trains support workers, and signs off competency. Source: NDIS HIDPA Skills Descriptors (February 2025)

1. Complex Bowel CareRN Plan + Competency Sign-off
RN develops/oversees bowel care plan; trains and signs off support workers. Worker delivers routine care independently once trained. Competency: anatomy, participant's bowel routine, suppository/enema use, autonomic dysreflexia recognition, infection control, emergency response.
2. Enteral Feeding (PEG & PEJ)RN Plan + Competency Sign-off
RN oversees feeding plan (multi-disciplinary with dietitian/speech therapist). Signs off worker competency. Worker delivers routine feeds per protocol. Competency: feed rates/volumes, stoma hygiene, blockage identification, aspiration prevention, emergency management.
3. Severe Dysphagia ManagementSpeech Pathologist primary; RN clinical oversight
Plan developed by Speech Pathologist; RN provides overall clinical oversight and supports worker training. Competency: IDDSI texture levels, swallowing difficulty recognition, choking emergency response, aspiration sign recognition.
4. Tracheostomy ManagementStrongest RN oversight — life risk
RN develops care plan; signs off all worker competencies. Clinical review required regularly. Competency: stoma site cleaning, routine suctioning, inner cannula care, tube displacement/obstruction recognition, infection monitoring, emergency airway management and contacting emergency services.
5. Urinary Catheter ManagementRN Plan + Oversight; RN present for insertion
RN oversees catheter plan. Routine bag change/emptying may be delegated to trained workers. Catheter insertion and suprapubic care require qualified clinician presence. Competency: hygienic bag management, catheter site care, UTI/blockage sign recognition, escalation procedures.
6. Ventilator / Respiratory SupportLife-support — RN accessible at all times
RN + respiratory specialist develop care plan; RN competency sign-off mandatory. Routine monitoring by trained worker; RN must be accessible in emergency. Competency: ventilator operation and circuit assembly, mask fitting, respiratory monitoring, alarm recognition, manual bagging emergency response.
7. Subcutaneous InjectionsRN Plan; RN for variable-dose decisions
RN oversees clinical support plan. Fixed pre-dosed injections may be delegated to trained workers. Variable doses (e.g. insulin dose decisions) require RN clinical oversight. Competency: injection technique, pre-dosed administration, BGL monitoring, adverse reaction recognition, safe sharps disposal.
8. Complex Wound CareRN develops wound plan; may delegate dressings
RN or wound care specialist develops wound management plan. Routine dressing changes per documented protocol may be delegated to trained workers. Competency: wound types and healing stages, dressing selection, aseptic technique, infection recognition, escalation triggers.
9. Epilepsy & Seizure SupportRN/Neurologist plan; RN trains workers
Epilepsy management plan developed by neurologist, GP, or RN. Worker training by qualified health practitioner. Competency: seizure type/trigger/pattern recognition, seizure first aid, emergency medication administration (buccal midazolam/rectal diazepam), post-ictal monitoring, documentation.
10. Diabetes ManagementRN Plan + Oversight; RN for insulin dose decisions
RN develops diabetes management plan in collaboration with GP/endocrinologist. RN provides clinical oversight and training. Insulin dose decisions require RN/clinical oversight. Competency: blood glucose monitoring, hypoglycaemia/hyperglycaemia recognition and response, insulin administration per protocol, dietary awareness, emergency glucose administration.

Key principle: It is NOT a requirement that HIDPA supports be delivered by a nurse. However, a qualified health practitioner (TrustCare's RN) must: develop and review the support plan, train support workers, and sign off competencies. The registered provider must have documented evidence of this clinical oversight for each HIDPA area. Source: NDIS HIDPA Skills Descriptors, September 2024.

Voluntary for unregistered providers — TrustCare voluntarily complies

5. Worker Screening

ℹ️
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All TrustCare nurses hold current NDIS Worker Screening Clearances

WA screener: Department of Communities | 📞 1800 225 558 | 5-year validity, nationally recognised | $145 fee

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AHPRA registration does NOT substitute for NDIS Worker Screening in WA

TrustCare maintains both: AHPRA registration (professional obligation) + NDIS Screening Clearance (NDIS obligation). Confirmed by NDIS Commission.

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Evidence provided to registered provider partners on request

Clearance evidence provided before first service delivery and available at any time. Registered provider may also verify via NDIS Worker Screening Database.

Full details: Worker Screening Compliance Statement →

Privacy Act 1988 (Cth) — Australian Privacy Principles — OAIC audited March 2026

6. Privacy Compliance

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TrustCare's Privacy Policy was audited against the OAIC Guide to Developing an APP Privacy Policy in March 2026. The policy has been updated to address all identified gaps.

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Privacy Act 1988 (Cth) and all 13 APPs — compliant

Health service provider exemption from small business turnover threshold confirmed. Policy covers all 13 APPs.

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Health information as sensitive information — addressed

Policy explicitly addresses APP 3 sensitive information requirements, consent-based collection, and heightened protection standards.

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Authorised representative access — addressed

Policy includes provisions for guardians, plan managers, and authorised representatives acting on behalf of participants.

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Data retention period — 7 years for health records (adults)

Consistent with AHPRA nursing standards and WA health legislation retention requirements.

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Access and correction — 30-day response timeframe stated (APP 12.3)
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Notifiable Data Breaches Scheme — policy includes NDB procedure

NDB scheme applies to all health service providers under Part IIIC of the Privacy Act.

View full policy: Privacy Policy →

Health Practitioner Regulation National Law Act 2009

7. AHPRA / NMBA Professional Standards

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Current AHPRA registration maintained

Publicly verifiable at ahpra.gov.au

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NMBA Registered Nurse Standards for Practice (2016) — all care delivered within scope
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NMBA Code of Conduct for Nurses (2018)
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Continuing Professional Development (CPD) — maintained per AHPRA requirements
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Professional indemnity insurance — maintained per AHPRA requirements
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