Authorising process & decision making

Authorised Program Officers (APOs) require advanced knowledge, skills and capabilities to collaborate with Behaviour Support Practitioners and other providers involved in behaviour support plans.

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The authorising process involves online reporting systems:

all plans use the State-based portal, Restrictive Intervention Data System (RIDS), managed by the Department of Families, Fairness and Housing; and
NDIS-funded plans also use the NDIS-based provider portal.

The APO reviews and either authorises or refuses the proposed use of restrictive practices.

The Victorian Senior Practitioner also reviews any proposed use of seclusion, physical or mechanical restraint, and all restrictive practices proposed for people with psychosocial disability and must approve these before authorisation is complete and the plan can be implemented.

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Decision making as an APO requires collaborating with a multidisciplinary team. APOs rely on their ability to connect with others throughout the behaviour support process to produce strong outcomes that improve the life of the person with the proposed restrictive practice(s).

This also includes achieving good outcomes for the person’s team of providers, for example residential, community access and support coordinators.

Critical thinking & holistic support

APOs, like Behaviour Support Practitioners, should communicate and consult with the person with disability, their Circle of Support and paid support network to understand the person’s needs, goals, situation and how best to create a behaviour support plan that meets their needs.

This consultation and support does not stop when the plan is implemented, but should continue as regular contact outsider of the formal touchpoints of the authorisation process.

Authorising a plan requires critical thinking and holistic thinking about the person’s proposed restrictive practice(s).

In addition to whether the proposed use of restrictive practice meets the authorisation criteria under Section 136 of the Disability Act 2006, APOs should also consider whether the use:

improves the person’s quality of life,
helps the person progress toward achieving their life goals,
progresses the person’s behaviour support goals, and
fits within the person’s funding and available supports.

All APOs should be familiar with the Victorian Senior Practitioner’s:

regulated restrictive practices authorisation checklist (downloads Word doc) and
guidelines for authorising regulated restrictive practices in Victoria (downloads Word doc).

An APO must be alert to the approximate cost of various supports required to implement the proposed restrictive practice(s) safely, for example training for key people in the plan and number of staff available compared to those required.

It is particularly important that a person’s funding can support the plan, as any break in continuity of care will have significant impact on the person’s quality of life and the implementation of positive behaviour support.

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If funded by the NDIS, the APO may need to check in with the person’s NDIS contacts (eg: Support Coordinator) to assess the funding distribution and availability.

APOs will need to collaborate with other providers (including other providers’ APOs) to collaborate, confer and confirm that the proposed restrictive practice(s) can be implemented safely.

This includes supporting and attending training from the Behaviour Support Practitioner, promoting data collection, and being involved in monitoring and evaluating the behaviour support plan.

Which APO takes the lead?

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It is possible multiple providers will be involved in the restrictive practices authorised as part of a person’s behaviour support plan.

In cases such as these, each provider involved in implementing regulated restrictive practices must have an APO review and authorise any restrictive practice implemented by their employees.

APOs will need to consult and work together, with a primary provider being identified as the lead organisation for lodging the plan and engaging the independent person. The primary provider is usually the provider who has the most involvement with the plan (eg: the accommodation service, as opposed to respite or a day program).

Working across state borders

Sometimes APOs work with participants who are receiving services in two states (this is particularly relevant for APOs who work close to state borders).

Establishing which state has responsibility for authorising and monitoring safe, legal use of the restrictive practice is usually based on which state the restrictive practice is delivered in.

Using the Victorian and NSW states as an example (noting these apply also to cases of Victoria/South Australia):

the person lives in Victoria, however the services are provided to the person (and the restrictive practice is implemented) in NSW – the provider authorises and reports the use of restrictive practice in NSW.
the person lives in NSW, however the services are provided to the person (and the restrictive practice is implemented) in Victoria – the provider authorises and reports the use of restrictive practice in Victoria.
the person lives in Victoria, and services are provided (and restrictive practice(s) implemented) in both NSW and Victorian locations – the provider authorises and reports the use of restrictive practice in both states.

Some cases are less clear and can be confusing.

If APOs have any questions, contact the Victorian Senior Practitioner for further advice.

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Reporting

Regulated restrictive practices by disability service providers or NDIS providers must be included in a person’s behaviour support plan and authorised by the APO and Victorian Senior Practitioner (where required).

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Restrictive practice(s) approved for use under NDIS providers must also be registered with the NDIS Quality and Safeguards Commission.

Sometimes, priorities compete and timelines can be tight. The APO position requires navigating many people with diverse needs, views and expertise.

There are two key reporting processes involved in the restrictive practice authorisation process:

lodging the plan (only relevant for NDIS plans. This is the responsibility of the Behaviour Support Practitioner, via the NDIS-based provider portal), and
authorising restrictive practices (relevant for all plans. This is the responsibility of the APO, via the State-based portal).

Before authorising a plan, APOs must be satisfied the plan meets all requirements (see critical thinking and holistic support), including seeking the secondary approval of the Victorian Senior Practitioner for any proposed use of seclusion, physical or mechanical restraint, and all restrictive practices proposed for people with psychosocial disability.

Lodging the behaviour support plan

For NDIS-funded behaviour support plans, the Behaviour Support Practitioner enters the behaviour support plan in the NDIS-based provider portal.

NDIS-funded plans:

include interim behaviour support plans, which must be submitted in the NDIS-based portal within 1 month.
must have comprehensive behaviour support plans in place within 6 months of implementing interim plan.
plan reviews conducted within 12 months of implementing the comprehensive behaviour support plan, or earlier (if needed).

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Authorising restrictive practices

All restrictive practices authorised for use in Victoria must be done so via the State-based portal by the APO. This portal is called the Restrictive Intervention Data System (RIDS).

Learn more through the Victorian Senior Practitioner’s e-Learning module, which offers Restrictive Intervention Data System (RIDS) Training.

This portal allows behaviour support plans to be shared across providers and also supported by APOs, the Victorian Senior Practitioner and other professionals who can access the system.

It also enables the APO to authorise or refuse the proposed restrictive practice(s), refer the relevant proposed restrictive practice(s) on for review by the Victorian Senior Practitioner, and monitor the use of practices for people across the State.

Both NDIS-funded and non-NDIS-funded behaviour support that includes restrictive practices must be authorised by the APO in this system.

Assessing ‘suitable evidence’

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APOs need to have a strong understanding of what is considered 'suitable evidence' to support restrictive practice decisions.

This includes assessments and justification for the need for restrictive practice(s).

Conversations with the person with disability – and others – about their needs and behaviours of concern should be documented and kept on file.

Decisions, evidence to support them and consideration of alternative ways of supporting the person to alleviate their behaviour of concern should also be kept on file to demonstrate the efforts that have been made to avoid, reduce and/or eliminate restrictive practice(s) over time.

Reviewing plans

Once a person’s authorised restrictive practices are implemented as part of their behaviour support plan, the APO and Behaviour Support Practitioner should continue to collaborate informally to check on implementation, progress, successes and issues.

This also includes assessing the person’s needs, as well as that of the team implementing the plan, to see if any adjustments need to be made to the plan or additional training organised.

Questions for the APO and Behaviour Support Practitioner to consider include:

What has been effective/ineffective?
How can plan be strengthened/changed to improve the person-with-behaviour-support’s quality of life?
If a new plan is established, how have we ensured continuity?
How is this revised plan furthering the person’s behaviour support goals, NDIS goals & life goals? Include progress measures.

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Asking questions & getting help

Restrictive Intervention Data System (RIDS) questions

Email RIDS.Helpdesk@dffh.vic.gov.au with questions about using the State-based Restrictive Intervention Data System (RIDS) portal, including:

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setting up your provider (eg: service outlets, appointing APOs, etc.),
submitting behaviour support plans, or
reporting use of restrictive practices.

Restrictive practice questions

Email RIquestions@dffh.vic.gov.au with questions about restrictive practices, the authorisation process and provider obligations under the Disability Act 2006.

Compulsory treatment & supervised treatment orders

Email compulsorytreatment@dffh.vic.gov.au with questions about compulsory treatment and supervised treatment orders.

All other questions

Contact the Victorian Senior Practitioner at the Department of Families, Fairness and Housing on:

Phone: (03) 9096 8427

Email: Victorian Senior Practitioner (victorianseniorpractitioner@dffh.vic.gov.au)

Find out who to contact if you have concerns of neglect, harm or abuse.

Responding to questions

Requests from the Victorian Senior Practitioner

In cases where the Victorian Senior Practitioner requests information from disability service providers and NDIS registered providers, APOs may be responsible for managing these requests.

Under various sections of the Disability Act 2006, the Victorian Senior Practitioner can request information as part of:

a restrictive practices audit,
a desktop review of an APO’s authorisation of restrictive practices, and/or
any other power, duty or function of the Victorian Senior Practitioner under the Disability Act 2006.

Under Section 27(6) of the Disability Act 2006, providers are obligated to provide reasonable assistance and give full and true answers to the best of their knowledge.

The Victorian Senior Practitioner will provide as much detail as possible about what is expected of the provider.

If the request is unclear or you are unsure what is expected, contact the Victorian Senior Practitioner.