NDIS Policies and Procedures Manual – Core Module
Document Number: CM-POL-043
Document Control
This table shows a record of significant changes to the document.
| Legal Name: | Holistic Healthcare Management Services |
| ABN: | 20695058096 |
| ACN: | 695058096 |
| Primary address/head office: | 15 Agasse Way, Tapping WA 6065 |
| Document Name: | Sub-Contractor Management Policy |
| Document Number: | CM-POL-043 |
| Approved by: | Director |
| Date Approved: | February 2026 |
| Version No: | 1.0 |
| Comments: | Initial Release of the Policies and Procedures Manual |
| Next Review Date: | Feb 2026 |
1. Introduction and Purpose
The purpose of this policy is to establish a comprehensive framework for the selection, engagement, management, monitoring and review of sub-contractors engaged by Holistic Healthcare Management Services. This policy ensures that all supports and services delivered through sub-contracting arrangements comply with the NDIS Practice Standards and Quality Indicators (All Modules), the NDIS Code of Conduct and all applicable Commonwealth and WA legislation. Holistic Healthcare Management Services acknowledges that it retains full responsibility and accountability for the quality and safety of supports delivered under its NDIS registration, including services delivered by sub-contractors. This policy supports participant safety, dignity and human rights, quality service delivery, effective governance and risk management, continuous improvement, and regulatory compliance and audit readiness.
2. Scope
This policy applies to all individuals, sole traders, partnerships or organisations engaged as sub-contractors by Holistic Healthcare Management Services, all NDIS supports and services delivered under Holistic Healthcare Management Services’s registration, and all management personnel responsible for approving and monitoring sub-contracting arrangements.
3. Legislative and Regulatory Framework
This policy aligns with and is informed by the National Disability Insurance Scheme Act 2013, NDIS Practice Standards and Quality Indicators (All Modules), NDIS Code of Conduct, NDIS (Incident Management and Reportable Incidents) Rules 2018, NDIS (Complaints Management and Resolution) Rules 2018, NDIS Worker Screening requirements, Privacy Act 1988 (Cth), and Fair Work Act 2009 (Cth).
4. Definitions
| Term | Description |
|---|---|
| Sub-Contractor | An individual or organisation engaged by Holistic Healthcare Management Services under a formal written agreement to deliver NDIS supports or services on its behalf. |
| Delegated Supports | Supports delivered by a sub-contractor under the registration and regulatory responsibility of Holistic Healthcare Management Services. |
| Due Diligence | A structured assessment process undertaken to verify a sub-contractor’s compliance, capability, insurance, qualifications and suitability prior to engagement. |
| Reportable Incident | An incident that meets the definition under the NDIS (Incident Management and Reportable Incidents) Rules 2018 and must be notified to the NDIS Commission. |
5. Outcomes and Quality Indicators Alignment
In accordance with the NDIS Practice Standards (Governance and Operational Management, Provision of Supports, and Risk Management), Holistic Healthcare Management Services ensures that:
- Participants receive safe and competent supports regardless of service delivery model.
- Sub-contractors are subject to equivalent screening, qualification and supervision requirements as employees.
- Risks associated with outsourcing are identified, assessed and managed.
- Incident and complaints systems apply equally to sub-contractors.
- Participants are informed where services are delivered by sub-contractors.
- Records are maintained to demonstrate oversight and compliance.
6. Guiding Principles
- 6.1 Participant-Centred Approach: All decisions relating to sub-contracting prioritise participant safety, choice and control.
- 6.2 Accountability and Governance: Holistic Healthcare Management Services retains full governance oversight of sub-contracted services.
- 6.3 Transparency and Informed Consent: Participants will be informed if services are delivered by a sub-contractor and consent will be documented.
- 6.4 Risk-Based Approach: Engagement and monitoring intensity will reflect the complexity and risk level of the supports provided.
- 6.5 Continuous Improvement: Feedback, audits and incident data will inform ongoing improvement of sub-contractor arrangements.
7. Policy
7.1 Approval and Justification
Sub-contractors will only be engaged where there is a documented operational or specialist need, the arrangement does not compromise participant safety or quality, risks have been assessed and deemed manageable, approval is granted by the Director, and a documented business justification is retained.
7.2 Due Diligence Requirements
Prior to engagement, Holistic Healthcare Management Services will verify ABN and business registration status, relevant qualifications and professional registrations, NDIS Worker Screening clearance, National Police Check, Working with Children Check, Professional Indemnity and Public Liability insurance, experience delivering similar supports, compliance history, and capacity to comply with restrictive practice requirements. No sub-contractor may commence services until due diligence is completed and approved.
7.3 Written Agreement Requirements
A formal written Sub-Contractor Agreement must be executed prior to service delivery, covering scope of services, NDIS Practice Standards and Code of Conduct compliance, incident management, complaints handling, safeguarding and child safety, privacy, data protection, insurance, conflict of interest management, audit rights, termination clauses, and indemnity provisions.
7.4 Incident and Complaints Management
Sub-contractors must immediately notify Holistic Healthcare Management Services of any incident, report reportable incidents within required legislative timeframes, cooperate with investigations, and participate in corrective action processes. All complaints involving sub-contractors will be managed under Holistic Healthcare Management Services’s Complaints Management Policy.
7.5 Safeguarding and Risk Management
Where supports involve high intensity daily personal activities, behaviour support and restrictive practices, community access supports, or clinical/nursing supports, enhanced monitoring and documented risk assessments will be undertaken, and sub-contractors must comply with all safeguarding requirements and behaviour support plan obligations.
7.6 Monitoring and Oversight
Holistic Healthcare Management Services will implement ongoing monitoring which may include scheduled performance reviews, participant feedback surveys, file audits, observation of service delivery, and review of incident and complaint trends, with monitoring outcomes documented.
7.7 Non-Compliance and Corrective Action
Where non-compliance is identified, a corrective action plan will be issued with documented rectification timeframes, increased monitoring may be implemented, serious breaches may result in suspension or termination, and reportable incidents will be notified to the NDIS Commission.
8. Procedure
- 8.1 Identification of Need: Management documents the need for subcontracting and conducts a preliminary risk assessment.
- 8.2 Completion of Due Diligence Checklist: All required documentation is collected and verified.
- 8.3 Risk Assessment: A documented risk assessment is completed considering participant vulnerability, support complexity, environmental risks, and workforce capability.
- 8.4 Agreement Execution: Agreement is drafted, reviewed, signed and stored securely.
- 8.5 Induction and Orientation: Sub-contractors complete induction covering NDIS Code of Conduct, Incident Management, Complaints Management, Privacy, Safeguarding, WHS, and Emergency procedures, with completion documented.
- 8.6 Ongoing Monitoring: Monitoring activities are scheduled and documented.
- 8.7 Review and Renewal: Sub-contractor agreements are reviewed annually or earlier if risks change.
9. Roles and Responsibilities
| Roles | Responsibilities |
|---|---|
| Director | Approves engagement and termination, ensures governance oversight, and reviews high-risk subcontracting arrangements. |
| Management | Conducts due diligence, monitors compliance, manages incidents and complaints, and maintains records. |
| Sub-Contractors | Deliver supports in accordance with agreement, maintain compliance documentation, report incidents and risks, and uphold participant rights and safety. |
10. Record Keeping
Records maintained include the Sub-Contractor Register, Due Diligence Checklist, Risk Assessment documentation, Signed Agreements, Insurance certificates, Screening verification, Monitoring reports, and Incident and complaint records. Records are stored securely and retained in accordance with legislative requirements.
11. Related Documents
- Governance and Risk Management Policy
- Incident Management Policy
- Complaints Management Policy
- Risk Management Policy
- Human Resource Management Policy (CM-POL-012)
- Code of Conduct
12. Policy Review
This policy will be reviewed annually or earlier if legislative or regulatory changes occur, an audit identifies gaps, a serious incident occurs, or organisational structure changes. All revisions will be approved by the Director and documented in the version history.
