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Conflict of Interest Policy and Procedure

NDIS Policies and Procedures Manual – Core Module

Document Number: CM-POL-028

Document Control

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Legal Name: Holistic Healthcare Management Services
ABN: 20695058096
ACN: 695058096
Primary address/head office: 15 Agasse Way, Tapping WA 6065
Document Name: NDIS Policies and Procedures Manual – Core Module
Document Number: CM-POL-028
Approved by: Director
Date Approved: February 2026
Version No: 1.0
Comments: Initial Release of the Policies and Procedures Manual
Next Review Date: May 2026

Introduction and Purpose

This policy demonstrates Holistic Healthcare Management Services’s commitment to maintaining transparency, promoting participant choice and control, and ensuring impartiality in the provision of supports. By effectively identifying, managing, and communicating potential or actual conflicts of interest, Holistic Healthcare Management Services ensures participants receive unbiased advice and can make informed decisions about their supports without undue influence. The policy aligns with the principles of the NDIS to safeguard participant rights and promote trust in service delivery.

Scope

This policy applies to all staff, contractors, and stakeholders involved in delivering supports, including specialised support coordination. It covers practices for identifying and disclosing conflicts of interest, supporting participant understanding of options, ensuring impartiality in referrals, and maintaining transparent documentation.

Definitions

Term Description
Conflict of Interest (COI) A situation in which a provider or staff member’s personal, professional, or financial interests could compromise or appear to compromise their ability to act impartially in a participant’s best interests.
Specialised Support Coordination A higher level of support coordination provided to participants with complex needs or high-risk situations, focused on reducing risk and ensuring effective implementation of support plans.
Impartial Advice Unbiased information or recommendations that enable participants to make independent and informed decisions about their supports.
Referrals Recommendations or connections made between a participant and a provider to access specific supports or services.

Outcomes and Indicators

Outcome Indicator
Each participant receives transparent, factual advice about their support options which promotes choice and control.
  • Conflict of interest policies are provided or explained to each participant using the language, mode of communication and terms that the participant is most likely to understand.
  • Each participant is supported to understand the distinction between the provision of specialised support coordination and other reasonable and necessary supports funded under a participant’s plan using the language, mode of communication and terms that the participant is most likely to understand.
  • If the provider has an interest in any support option available to the participant, the participant is aware of this interest. The participant understands that any choice they made about providers of other supports will not impact on the provision of the specialised support coordination.
  • Referrals to and from other providers are documented for each participant.

Guiding Principles

  • Transparency: All potential or actual conflicts of interest are disclosed to participants, ensuring they are fully informed when making decisions about their supports.
  • Participant Choice and Control: Participants are empowered to make independent decisions about their supports without influence or coercion from the provider.
  • Accessibility: Conflict of interest policies and related information are communicated to participants in a language, mode of communication, and terms they can understand.
  • Documentation: All referrals, disclosures, and participant acknowledgments of conflicts of interest are documented to maintain accountability and compliance.
  • Trust and Accountability: The organisation upholds a commitment to ethical practices, ensuring that participants receive unbiased support and advice.

Policy

Managing conflict of interest appropriately is paramount for Holistic Healthcare Management Services.

Communication of Conflict of Interest Policies

Holistic Healthcare Management Services ensures participants understand the organisation’s conflict of interest policies and their implications through accessible plain language communication, interactive discussions, and documented participant acknowledgments (Indicator 1).

Supporting Participant Understanding of Supports

Participants are supported to distinguish between specialised support coordination and other funded supports using educational discussions, visual tools, and clarification opportunities (Indicator 2).

Disclosure of Provider Interests

Holistic Healthcare Management Services ensures participants are aware of any provider interests in available support options via proactive disclosures, explicit reassurance of independence, and maintained acknowledgment records (Indicator 3).

Documentation of Referrals

All referrals to and from providers are documented to ensure transparency and accountability, maintaining secure referral records, comprehensive audit trails, and participant access (Indicator 4).

Procedure

Staff are strictly prohibited from accepting money, gifts, services, or any benefits that could compromise their integrity or influence their decisions in a way that is not in the best interests of NDIS participants. All staff must remain impartial and free from any financial or personal interests that could directly or indirectly impact a participant’s choice of provider or the provision of supports. Any form of commission, incentive, or preferential treatment, whether given, received, or solicited – is not tolerated under any circumstances. Holistic Healthcare Management Services upholds the highest ethical standards, ensuring that all decisions are made solely to support the needs, rights, and choices of participants and their families.

Communicating Conflict of Interest Policies

During initial engagement, staff explain conflict of interest policies using accessible materials, encourage interactive questions and scenarios, and document participant confirmation or signed acknowledgments.

Supporting Participant Understanding of Supports

Staff provide clear explanations comparing specialised support coordination versus other supports, offer follow-up sessions, and utilise feedback mechanisms to evaluate participant understanding.

Managing and Disclosing Provider Interests

Staff proactively disclose any relationships or interests before participant decisions, secure signed records of participant awareness, and undergo regular supervisor monitoring.

Documenting Referrals

Staff use standardised templates to document participant consent and referral reasons, store documentation securely, and conduct regular audits to verify impartiality and appropriateness.

Roles and Responsibilities

Ref No Roles Responsibilities
1 Governing Body
  • Ensure the organisation has robust conflict of interest policies and procedures in place.
  • Conduct regular reviews of policy compliance and effectiveness.
2 Clinical Supervisors and Managers
  • Provide training to staff on conflict of interest management and disclosure practices.
  • Oversee the documentation and monitoring of referrals and disclosures.
3 Behaviour Support Practitioners
  • Communicate conflict of interest policies to participants in an accessible manner.
  • Disclose any provider interests transparently and maintain impartiality in all recommendations.
  • Document all referrals and disclosures accurately.
4 Workers
  • Daily Implementation: Apply inclusion strategies during everyday interactions and routines, ensuring the child actively participates in family and community life.
  • Feedback Provision: Share observations and insights from daily interactions to inform plan adjustments and improvements.
  • Training Participation: Attend all required training sessions to maintain a strong understanding of inclusion principles and practical application.
5 Participants
  • Engage in discussions to understand conflict of interest policies and their implications.
  • Provide feedback on the impartiality and transparency of support coordination services.

Record Keeping

  • Conflict of Interest Policy Acknowledgments: Records of participant acknowledgment of the policy.
  • Disclosure Records: Detailed documentation of disclosed provider interests.
  • Referral Logs: Comprehensive records of referrals made to or from other providers, including consent documentation.
  • Training Logs: Records of staff training on conflict of interest management and ethical practices.

Related Documents

  • Conflict of Interest Report Form
  • Conflict of Interest Register
  • Risk Management Policy and Procedure
  • Risk Register
  • Code of Conduct
  • Governing Body Meeting Agenda & Minute
  • Senior Management Meeting Agenda & Minute
  • Team Meeting Agenda & Minute

References

  • National Disability Insurance Scheme (NDIS) Act 2013
  • NDIS Code of Conduct
  • Australian Privacy Principles (APPs)
  • NDIS Practice Standards and Quality Indicators
  • NDIS Price Guide and Support Catalogue

Policy Review

This policy will be reviewed annually to ensure alignment with legislative updates, best practices, and stakeholder feedback. Revisions will be communicated promptly to staff, families, and other relevant stakeholders to maintain transparency and shared accountability.