This booklet incorporates ATS Pty Ltd Policies and Practices

Dated 12-5-2023

NDIS Provider Number 4050056296

Updates to Policy Book

Informed by internal quality review and client feedback, below are the updates since last year. 

1. Simplification where possible based on need for easy-read format.
2. Focusing the policy statements to more closely reflect our service and context.
3. During 2023, we let go of registration for Early Childhood Intervention but we retained the section on youth and early childhood policy as we continue to work with children under behaviour support and therapy registration.
4. Our Service Agreement Policy includes some new information on the PACE Portal System being trialled in Tasmania and the implications for participants moving into that system. The Service Agreement template we provide will hold the most up to date advice on this issue.
5. We have updated our policies around Risk, WHS, and related areas to reflect our service context in light of the NDIS increased focus on managing risks during and after the Covid-19 pandemic.
6. In light of a new NDIS Standard, we have updated and/or added an Emergency and Disaster Management Policy, and a Continuity of Services Policy.
7. Following late advice of the NDIS published 12/5/23 we added a Supported Decision Making Policy that reflects our standards and ongoing practices.

Introduction

1. We like our clients to be as informed as possible. 
2. This booklet informs you of your rights and responsibilities.
3. This booklet has been developed in discussion with clients, industry, professional associations, and NDIS Independent Auditors. 
4. In particular, we thank our clients for your review and help with making our service practical and useful for your needs.
5. Where possible, this booklet is presented in brief and simple language. 
6. Visit our website for any changes or updates to this information found under “Client Booklet Disclosure Terms and Conditions.”
7. This booklet is a requirement of the National Disability Insurance Scheme (NDIS). If you are a participant of the NDIS this booklet will help you understand your rights and responsibilities.
8. Thank you for choosing ATS, and for your support.

About Us

1. Ability Therapy Specialists Pty Ltd is primarily a counselling and psychotherapy agency. We work mainly with NDIS clients where the Scheme pays for our services. 
2. We are an online Telehealth service. We consult across Australia. 
3. We pride ourselves in helping rural and remote Australians but we also happily work with city-based clients who seek us out when they cannot find local help due to extended waiting lists or due to other access barriers. 
4. We are Counselling Psychotherapy Specialists in Person Centred and Solution Focused Therapies. 
5. We are NDIS Registered and NDIS Commission Certified Behaviour Specialists, and we are NDIS Registered Counsellors. 
6. We also work with Ericksonian Hypnotherapy, Neuro-Linguistic Psychotherapy; Creative Arts, Visual Arts, Ceramics and Clay Therapy; Sandtray and Symbol Work; Therapies Grounded in Culture, Spirituality and Mindfulness; and we work with Canine Animal Assisted Therapy.
7. This booklet provides more information on the types of services we offer and details on client’s rights and responsibilities. The booklet is designed to provide most of the practical information that you might need in order to function as a client of ATS.

ATS Code of Conduct 1. We uphold the following core values of respect for, Person Centred Supports Individual Values and Beliefs Privacy and Dignity Independence and Informed Choice Prevention of violence, Abuse, Neglect, Exploitation, and Discrimination Governance and Operational Management Risk Management Quality Management Information Management Feedback and Complaints Management Incident Management Human Resource Management Continuity of Support Access to Support Support Planning Service Agreements Responsive Support Provision Transitions to or from the Provider Safe Environment Respect for Money and Property 2. We operate alongside international, Australian national, and NSW state based frameworks for the care and protection of all clients particularly children, women, and vulnerable populations. 3. We uphold the ethical standards of the Australian Counselling Association (ACA) Code of Ethics and Practice 2013.  4. Our legislative frameworks uphold the Australian Children and Young Persons (Care and Protection) Act 1998 (the Act), The Privacy Act 1988,The Code of Conduct for Unregistered Health Practitioners,The NDIS Code of Conduct, The Objectives and Principles of the National Disability Insurance Scheme Act 2013, Relevant Australian anti-discrimination legislation, including, The United Nations Universal Declaration on Human Rights 1948. 5. Accordingly, we do not discriminate on the grounds of gender, marital status, pregnancy, age, ethnic or national origin, disability, sexual preference, religious or political belief.

The NDIS Code of Conduct The Code of Conduct requires workers and providers who deliver NDIS supports to: Act with respect for individual rights to freedom of expression, self-determination, and decision-making in accordance with relevant laws and conventions Respect the privacy of people with disability Provide supports and services in a safe and competent manner with care and skill Act with integrity, honesty, and transparency Promptly take steps to raise and act on concerns about matters that might have an impact on the quality and safety of supports provided to people with disability Take all reasonable steps to prevent and respond to all forms of violence, exploitation, neglect, and abuse of people with disability Take all reasonable steps to prevent and respond to sexual misconduct.

Person Centred Support Policy

1. The person is the centre of our work. 
2. Personhood reflects human rights and dignity, as well as the depth of identity, culture, family, and a sense of place and country.
3. Person Centred support has a long tradition in western psychotherapy and is built upon the work of Carl Rogers (1902-1987) who was a Psychotherapist. 
4. Rogerian theory and practice begins with the principle that all people are the experts in their own experience and they deserve respect, positive regard, empathy, and understanding. Our agency is founded on these principles and our founding members were trained in Rogerian Psychotherapy. 
5. The disability sector took up person centred values more broadly, and applied the tradition to practical support methods. As therapists and behaviour specialists, we apply these principles to each person’s needs and capacities. 
6. This policy provides information on what services we offer and the range of choices that our clients have in using our services. In each case, we work with you, the client, to understand your needs and hopes, goals and challenges, and to work out solutions and options that fit your life and circumstances.
7. We serve people with a wide range of specialist needs. For example, we design tailored personal solutions in concert with other therapists, allied health, nutritionist, and medical practitioners to help with,

Disability Services

1. Assessment and diagnosis of various conditions,
2. Major life transition support,
3. Mental Health concerns,
4. Intellectual disability, 
5. Autism, 
6. Down Syndrome,
7. Acquired brain injury, 
8. Aged Care, Dementia, Early Onset Dementia,
9. Physical disability including sensory disability, 
10. Learning disabilities, Communication Issues,

Complex Diagnosis Services

1. We have specialist experience with a wide range of rare genetic conditions and complex dual and multiple diagnoses with behavioural concerns. 
2. Many of our cases over the years have included Genetic Disorders with Intellectual Disability and/or Autism; Down Syndrome or other conditions.
3. Most cases include complex social and emotional issues, post traumatic stress, grief and loss, and dealing with personal limitations and outcomes from diagnosis.
4. Many cases we work with have diagnosed and/or observed Psycho-social and/or Mental Health conditions, and given our in-depth work with clients and our experience we provide insights to diagnosis and treatment planning to assist patient care.

Mental Health Services

1. Clinical Depression, Anxiety Disorder, Mood Disorders,
2. Schizophrenia, Schizoaffective Disorder, 
3. People on Treatment and Mental Health Orders,
4. Dual diagnosis of disability and mental health,
5. Trauma, Grief and Loss, Post Traumatic Stress, 
6. Anxiety Management and Recovery,

Capacity Building Services

1. Personal development, mindfulness, meditation, and self-care,
2. Daily life-skills, capacity building, relationship skills,
3. Social isolation, solitude, personal enjoyment, stress reduction,
4. Sexuality and/or Gender Identity, and Healing from Prejudice, 
5. Cultural Reclaiming and Integral Spirituality and Health,

Lifestyle Health Services

1. Lifestyle and holistic health reviews,
2. Weight loss and weight management, 
3. Intermittent fasting and behaviour support, 
4. Type 2 diabetes management and behaviour support,
5. Medications review in behavioural specialist assessment,
6. Implementation of nutritionist advice in behaviour support,
7. Motivational coaching and debriefing for healthy lifestyle goals.

Assessments and Reports Services

1. At the request of clients we often provide detailed assessments, reports, funding reviews, and correspondence to other allied health specialists, health and medical practitioners, and mental health specialists and psychiatrists. 
2. As we tend to work in-depth with our clients, we provide insights to diagnosis and treatment planning across a wide range of concerns and goals.
3. We provide a great deal of NDIS funding reviews in light of our whole-of-life clinical and lifestyle assessment process.
4. Funding reviews under NDIS also provide practical insights to personal needs, how to work with the individual, and ways forward in organizing disability and/or mental health and/or aged care services.
5. Our work helps to more clearly assess and then detail an individual’s functional behavioural capacity, that is, what a person is capable of doing and maintaining in daily life, and therefore what help they need to compensate for unmet needs.

Emphasis in Therapy

Within the services listed above our emphasis in therapy is on,

1. Person Centred and Rogerian Psychotherapy,
2. Strength Based, Empowerment, and Recovery,
3. Brief Solution Focused Therapy,
4. Modified and Holistic Cognitive Behaviour Therapy 
5. Ericksonian Hypnotherapy,
6. Neuro Linguistic Psychotherapy, 
7. Visual and Ceramic Art Therapy with all ages,
8. Sand Tray and Play Therapy with all ages,
9. Animal Assistance Therapy consultation and plan review,
10. Lifestyle Health which may include consulting around,
    • Reviewing healthy lifestyle issues,
    • Co-creating a healthy lifestyle plan that is practical and manageable, 
    • Including person centred principles in positive behaviour support to real life situations,
    • Applying and encouraging healthy practices per the person’s diet and Nutritionist’s recommendations,
    • Weight management and weight loss,
    • Behaviour specialist medications review – often discussing publicly available information on medications and their use and function while empowering awareness and informed Consent for the person in their relationship with medical practitioners that sometimes leads to GP or specialist medical review and medical practitioner changes and/or reduction in medications.

Supported Decision Making Policy

1. The NDIS states that, ‘Supported decision making is the process of providing support to people to make decisions to remain in control of their lives. Supported decision making involves building the skills and knowledge of people with disability, their friends, families, carers, peers and professionals. Everyone uses supported decision making, as everyone needs support with decisions at different points in time. How much and what kind of support a person needs to make decisions can change from time to time.’
2. The NDIS policy is guided by 4 main principles that ATS Pty Ltd agrees ought to be used to guide how we can better support people with disability to make decisions,
   1. All adults have an equal right to make decisions that affect their lives and to have those decisions respected.
   2. There must be access to support for people who need help communicating and participating in decisions.
   3. Decisions are directed by a person’s own will, preferences and rights.
   4. Include appropriate and effective safeguards against violence, abuse, neglect or exploitation.
3. ATS staff seek to uphold supported decision making and independence wherever this is possible and pertaining to the client’s capacities, needs, and vulnerabilities. In principle, we support the NDIS proposed five principles to,
   1. Increase opportunities for participants to make decisions.
   2. Support participants to develop skills and knowledge.
   3. Build skills and knowledge of decision supporters.
   4. Build skills and knowledge of NDIA staff and Partners in the Community.
   5. Strengthen the supported decision making approach in the appointment, operation and review of nominees.
4. ATS staff have a very focused clinical and therapeutic role with our participants, so the application of these principles in practice relate largely to our service context.
5. In our unique service context, we provide senior clinical advice, direct therapy, and clinical reports, and in some cases we are requested to provide varying aspects of the roles of mentoring, guiding, counselling, skill building, capacity building and/or training. 
6. In all of these aspects, we endeavour to uphold the UN Convention on the Rights of Persons with Disabilities which in our view highlights the balance between human rights alongside civic and relational responsibilities. This model accounts for providing support that is equitable which is based upon an adequate understanding of both the strengths and capacities as well as the needs and vulnerabilities of each individual.
7. Following the UN Convention, and Australian Standards, ATS hold that the principles of Dignity of Risk and Duty of Care must be correctly addressed and balanced. This is to ensure participant’s safety and health, as well as their lifestyle satisfaction and liberties, are all taken into account and managed in the most effective and least restrictive way in each case and situation.
8. In light of the above, ATS staff provide our reports and therapeutic support as these are based on evidenced based clinical practice and outcomes. 

Behaviour Support and Restrictive Practices Policy

Person Centred Ecology

1. ATS is a person centred and strength-based provider where our therapists are highly trained and well regarded in supporting people in proactive and personalised ways. Our work centers on the person while being family oriented and ecological – that is we seek to make our assessments and suggestions for support and change both practical and manageable in the actual environment of the person day to day. In this way, we work closely to co-design solutions and we seek active participation in the process of creating goals that are measurable and achievable.
2. ATS also seeks to support people’s real life values, beliefs, and attitudes by helping individuals and families by respecting their situation and culture and weaving this into the support approach and method. Where people feel heard and respected and when they are affirmed in their primary beliefs and values, they tend to meet the challenges of the situation with more of a sense of personal responsibility and empowerment. ATS staff are trained to provide this higher level of clinical and counselling communication support that underpins our approach to behavioural assessment and treatment planning.
3. ATS recognises, upholds and promotes the rights of people with disability and their right to personal freedom and dignity and is committed to positive behaviour support. Our Positive Behaviour Support Policy meets the National Standards for Disability Services (specifically standard 1: Rights); and the National Disability Insurance Scheme Quality and Safeguarding Framework Quality and Practice Standards. This policy complies with state and territory based legislation and the NDIS Restrictive Practices and Behaviour Support Rules 2018.
4. ATS works under evidenced-based practice standards and our work is inclusive, proactive, solution focused, holistic, and ecological.
5. ATS works within existing ecologies of service support, so that all plans are written to fit the participant’s life and the contexts of their support relationships. These take into account the person’s NDIS Plan, Support Planning, and other relevant information.

Behaviour Support Assessment and Planning

6. Behaviour support is about creating individualised strategies for people with disability that are responsive to the person’s needs, in a way that reduces the occurrence and impact of behaviours of concern and minimises the use of restrictive practices. This approach includes undertaking a functional behavioural assessment, then developing an NDIS behaviour support plan containing evidence-based, proactive strategies that meet the specific needs of the participant.
7. ATS complies with the NDIS Commission requirement that a registered provider of specialist behaviour support services must use a behaviour support practitioner whom the NDIS Quality and Safeguards Commissioner considers suitable to undertake behaviour support assessments and develop behaviour support plans that may contain the use of restrictive practices. To be considered suitable, ATS is committed to providing details of our behaviour support practitioners to the NDIS Commission.
8. ATS works within the NDIS Commission Behaviour Support Capability Framework that focuses on the knowledge and skills that underpin contemporary evidence-based practice and standards. ATS therapists will supply their details to the NDIS Commision for review and certification of their status to work in the field of specialist behaviour support.
9. A behaviour support plan is a person centred and proactive supportive document developed with and for a person with disability by an NDIS behaviour support practitioner. It is developed in consultation with the participant, their family, carers, guardian, and other relevant people, as well as the service providers who will be implementing the plan. A behaviour support plan specifies a range of evidence-based and person-centred positive strategies that focus on the individual needs of the participant building on strengths while addressing concerns. This includes positive behaviour support to build on the person’s strengths, increase their opportunities to participate in community activities, and increase their life skills. It also includes any regulated restrictive practices that may be required.

Restrictive Practices

10. ATS takes a well balanced view of unregulated and regulated restrictive practices that seeks to balance the factors of dignity of risk and duty of care. 
11. Restrictive Practices are any intervention and/or practice used to restrict the rights or freedom of movement of people with disability, with the primary purpose of protecting the person or others from harm. From this broad perspective there are unregulated and regulated restrictive practices.
12. Regulated Restrictive Practices have been identified by the NDIS Commission. Regulated Restrictive Practices include
    1. Environmental Restraint, 
    2. Physical Restraint, 
    3. Mechanical Restraint, 
    4. Chemical Restraint (Regular and/or PRN), and 
    5. Seclusion. 
13. Under NDIS policy Regulated Restrictive Practices require clinical assessment and annual review. They must undergo an external approval review process. And they must submit to monitoring under policy and practice among NDIS implementing providers. 
14. Unregulated practices are other kinds of restrictive measures that may be prescribed by medical or allied health specialists or that have been practiced within a family or support setting in the past where there is perception that the practice helped or assisted an individual in their day to day life. 
15. In many respects, ATS encourages the review of unregulated restrictive practices from a holistic ecological and person centered behavioural support perspective because this review can clarify the utility or risks around each practice in light of evidenced based clinical outcomes. Unregulated restrictive practices include a wide range of factors and circumstances, and each needs to be understood in the person’s context and in relationship to the ecological factors identified across the domains of daily living, health, medication, physical issues, relationship patterns, sensory systems, emotional responses, cognitive and psychological, cultural and spiritual values and beliefs. Clinical review assists to understand the person in relationship to their unique capacities, skills, and needs.
16. As a clinical behavior specialist service, ATS does not implement restrictive practices whether they are regulated or unregulated. Our role is to provide clinical assessment and treatment planning associated with these practices. ATS staff are required to assess and develop treatment planning around regulated restrictive practices.
17. ATS seeks participant consent to work with support networks toward increasing their knowledge and strategies needed to support the person. Risks, alternatives, and ongoing evaluation are warranted in many cases to reduce and eliminate the use of restrictive measures. Clinical support is provided under participant’s NDIS Plans where funding allows. ATS works collaboratively with participants and stakeholders and seeks to support their implementation of behaviour support plans and with participant’s consent. ATS includes in our BSPs only restrictive practices specified by the Rules 2018 of the NDIS. ATS manages restrictive practices under the conditions described in the Rules 2018. ATS makes every effort to include and encourage strategies that may lead to the reduction and elimination of restrictive practices.
18. ATS behaviour support staff undertake professional development to maintain and enhance understandings of restrictive practices, as well as to gain greater knowledge and expertise in their reduction and elimination. Staff actively engaged in concerted effort to gather and maintain an up to date professional portfolio of evidence for review and professional development purposes and in order to comply with the Commission Quality and Safeguarding Framework review of practitioners.

Restrictive Practices Regulation

19. NDIS Commission standards for the regulation of restrictive practices apply to NDIS registered providers. While the standards ought to be instructive and helpful, the regulation framework does not apply to the private family context. ATS is committed to education and capacity building among all of our participants regardless of their choice of providers and whether they rely on informal family and community support or formal NDIS paid support.
20. There are two levels of external regulation that ATS must support under the NDIS Commission national standards that are laid out in the NDIS Behaviour Support Quality and Safeguarding Rules 2018. The first level is state-based external review. This varies from state to state. Some states elect to use a Restrictive Practices Authorisation Panel, other states provide an Office of Senior Practitioners to provide oversight. The second level is national and consists of the submission of the functional behavioural assessment report and behaviour support plan and supporting documentation to the NDIS Commission via their online portal.
21. ATS provides with consent the functional assessment report and behaviour support plan and supporting documentation containing regulated restrictive practice to the state-based authority. In most cases the NDIS registered implementation provider(s), who may be an accommodation provider or a provider of daily activities and community participation, etc., are required to activate a Review within their state system. As the state level review process is independent from the context of developing the behaviour support plan, ATS behaviour specialist staff are not typically directly involved. The state review provides a form of Authorisation of the Restrictive Practices in the Behaviour Plan or they make a determination and/or will provide advice and recommendations to the relevant parties.
22. At or around the same time, ATS provides with consent the functional assessment report and behaviour support plan and supporting documentation containing regulated restrictive practice to the NDIS Commissioner as prescribed in the National Disability Insurance Scheme (Restrictive Practices and Behaviour Support) Rules 2018. In practice this is contingent on NDIA funding and other factors that are outside of our control, and which are documented in each case.
23. Once the state-based Authorisation provides approval for the regulated restrictive practice(s), if necessary ATS adds relevant information to the NDIS Commission portal and changes the submission from draft to active. This allows the provider(s) to lodge data to the portal regarding the use of the regulated restrictive practice(s).
24. Subject to referral, funding, and consent, ATS is committed to annual review of restrictive practices particularly where these are regulated practices. Regular review provides clinical oversight and leadership in regards to assisting families and providers to maintain their quality assurance and to adjust plans and implementation methods based on assessments and recommendations.

Functional Behaviour Assessment

25. Before completing a Behaviour Support Plan, ATS is normally required to complete a Functional Behaviour Assessment Report. 
26. This report provides a clinical assessment of capacities, strengths, and needs in light of NDIS models of support. The report provides a range of recommendations and funding review suggestions to assist Support Coordinators and NDIS Planners. Where the service continues we provide an Interim Behaviour Support Plan, and then a Comprehensive Behaviour Support Plan where the case includes regulated restrictive practices.
27. In many cases where we support people with relationships and capacity building, mental health support or other more common disability support needs, we may write a less formal personal support plan that is adapted to their circumstances and that does not have the formality necessary where restrictive practices are present. The main point is that ATS is committed to helping people where they are at with the needs they have in their day to day lives. Therapeutic skill and capacity building works alongside behaviour support services to engage the participant and their family, carers, or staff towards implementing person centred practical solutions and to work to accomplish life goals and aspirations.
28. Functional behavioural assessment seeks to identify unmet needs, the functions of behaviours of concern, and that enables identification of strategies to address behaviour support. The functional behaviour assessment report works toward documenting all relevant data and forms a basis for the behaviour support plan. The plan includes behaviour assessments, clinical reports or diagnostic information, case histories, and input from relevant stakeholders.
29. ATS works with consent to ensure our assessments and treatment planning are developed in consultation with the participant in a person centered method that where possible includes parents, families, carers, guardians and/or providers who will be implementing the suggestions, strategies, and plans to encourage maximum utility, practicality, and the genuine endorsement of the stakeholders.

Review and Recommendations

30. Where funding and the request for our service continues, ATS provides ongoing clinical support and consultation to ensure that participants are well looked after and that their parents, guardians, carers, staff, and/or providers as well as other therapists and medical staff have the assistance they need to achieve positive behaviour support implementation outcomes.
31. Where the NDIS Plan funding allows, Behaviour Support Plans are regularly monitored and reviewed by ATS staff each six or twelve months, and as participant’s circumstances change. The timeline of review is in part decided by the NDIS standards where restrictive practices are involved and cannot extend beyond twelve months. Where there are no restrictive practices and the plan is less formal, there is more flexibility and the timeline may be suggested by the clinician.
32. Review windows usually align with funding reviews, to allow the behaviour specialist to suggest broad based goals to assist the NDIS Planner and Support Coordinator to focus funding where it is needed to build the person’s capacities and goals. 
33. While outside of our control, we seek to understand how the implementation of behaviour support practices is progressing and we often encourage the collection of data, and provide surveys or other measures to help form a picture of how implementation is going. From these insights we can provide advice and recommendations.
34. Internally, ATS staff have long association with quality evaluation tools in the clinical behaviour support and disability sector and have adapted standardised measures to self-evaluate and provide collegial feedback and clinical supervision on behaviour support plans and functional assessments and/or other clinical reports. 
35. ATS is committed to participating in NDIS Quality and Safeguarding Commission Behaviour Support Practitioner Review and Registration Certification, which is a quite in-depth and comprehensive self-evaluation and peer-evaluation that documents the work and capacities of the practitioner.
36. ATS encourages and often nurtures and supports the monitoring and review of implementation work undertaken by providers and families. ATS seeks where possible to provide respectful and encouraging clinical oversight of the effectiveness of implementing strategies through various measures including data collection, verbal interviews, observations, analysis of incident reports and other means as relevant to each case. 
37. Quality feedback to ATS clinicians has in the past resulted in updates to plans and additional strategies designed where participants require specific interventions that go beyond the scope of the behaviour plan. ATS revises and modifies behaviour plans according to new evidence as this comes to light, editing and developing the plan accordingly. 
38. ATS investigates and pursues any and all opportunities to reduce the use of restrictive practices and/or implementing less restrictive options. Often our role is to provide another point of view and to raise questions that encourage shifts in perspective. These strategies result in the creation of new ways to support people in a positive and person centred approach that quite often reduces or eliminates restrictive approaches to support.
39. Within client’s consent, ATS is committed to informing the Commissioner and working with the Commissioner to address obstacles and barriers that appear where provider’s implementation falls short of disability sector standards for any reason, and where the supports and services are not being implemented in accordance with the behaviour support plan.
40. Under participant’s consent, ATS will notify the Commissioner of changes in each participant’s behaviour support plan in the manner and time frame prescribed in the NDIS Rules 2018.
41. In some cases our staff may become aware or be requested to help a participant, family, or provider to address an emergency use or unauthorised use of a restrictive practice. In these circumstances, ATS is committed to offering support, advice, and capacity building to the provider/s implementing each participant’s behaviour support plan during the process of responding to a reportable incident involving the use of restrictive practices.
42. ATS provides under participant consent and where funding allows review services around incidents with participants, family, or support providers implementing behaviour support plans.

Governance and Operations Policy

1. Ability Therapy Specialists Pty Ltd is a private company limited by shares.
2. ATS comprises a Director Dr Joseph R Bowers, and Secretary Dr Dwayne A. Kennedy.
3. Dr Bowers and Dr Kennedy maintain the company and provide senior specialist services.
4. Due to NDIS complexities, we have decided not to expand the company by taking on more employees or contractors, i.e. by brokering other therapists.
5. Maintaining a small and beautiful operation allows us to maximise effectiveness by limiting our intake of referrals, providing high quality services that are focused on our relatively small client cohort, and keeping our relationship with clients more direct and person centred.
6. Working within the limits of our capacity to take on clients, we provide in-depth quality assurance and oversight.
7. This policy provides information on our organisational structure as well as case based steps and procedures.

Organisational Structure

1. All roles are maintained within a streamlined model of operations.
2. The Director and Secretary maintain the company business while utilizing external outsourcing for key functions.
3. Each role includes clinical roles, which is quite common among clinical agencies.
4. The Director and Secretary are Senior Specialist Counselling Psychotherapists.
5. To keep operations running smoothly and to make our work with our clients more direct and efficient, we do not employ secretaries or administrative assistants.
6. The following organisational chart shows the relationship between areas and functions. At the top and centre is the Person who is the Client and Participant. 

The Person Who is the Client and Participant

Director

Secretary

Accountant (Outsourced)	Clinical Supervisor(Outsourced)	Collaboration with External (NDIS) Providers
Administration Functions
Client Management System Designed for NDIS Providers	Organisational Management and Data Security System	Mobile ProviderInternet Provider Operational Administrative Applications

Position 1 Role Definition	Position 2 Role Definition
Director and Clinical SpecialistOperations ManagementBookkeepingBehaviour SupportCounselling	Secretary and Clinical SpecialistWHS & Risk OfficerOffice & Site ManagementBehaviour SupportCounselling

Case Based Steps and Procedures

The following sections address the following steps in the referral and service process. This information is helpful for both clients and for therapists to understand the progression of steps through the process.

1. Referral 

2. Intake/Admin and information gathering 

3. Assessment of appropriateness for service 

4. Clinical Assessment 

5. Client notes 

6. Documentation 

7. Billed and unbilled hours 

8. Closure and discharge summary

Referral

1. Clients can be referred from anywhere. Most are self-referred. Referrals can come from NDIS Support Coordinators, Providers, other allied health practitioners, GPs, Psychiatrists, NDIS Registered Aged Care Facilities, or other organisations.
2. Referrals often come via the internet. Internet referrals come via Google and from our website. People use our website form to send an email inquiry. This helps to ensure compliance with having read our Client Booklet – Disclosure, Terms, Conditions.

Intake and Service Provision

Intake procedures include,

1. First conversations, receiving early non-contracted information about the client and case. These discussions inform our capacity and caseload and whether we are the right service provider for the client.
2. First sharing of information about who we are, and what we do. We share our Information Pack that consists of,
   1. Consent Form, 
   2. If applicable, the NDIA Consent Form,
   3. Client Booklet – Disclosure, Terms, Conditions, 
   4. A book on Telehealth,
   5. And may include a brochure.
3. When clients return a completed Consent Form, we may provide a Service Agreement in Draft.
4. Upon receipt of a signed Service Agreement, we open a client file within our data management system and NDIS client management system.
5. At this time, we book first meetings with the participants and begin a case review.
6. Normally, we review case files that comprise past reports, assessments, diagnosis, and treatment plans. 
7. We interview the participant and/or relevant carers, staff, managers, and/or meet with Support Coordinators or other practitioners.
8. From these informative sources we co-create with the client a person centred treatment plan.
9. In many cases, our treatment plan or behaviour support plan is co-designed with participants and stakeholders and is implemented by the family and/or stakeholders. In other cases, we work as therapists directly with the client for periods of time as funding warrants.

Clinical Assessment

1. Assessment begins with the Client sharing Consent information, past reports and documents, and continues with discussion, input and meetings. 
2. Assessment helps to determine capacities, needs, and treatment options. From these insights we provide reports and recommendations for support.
3. Assessment provides a kind of map of the relationships between contributing factors that make up a client’s current situation, and assessment can suggest the way forward. But the way forward will not always lead to logical treatment options because these always rely on client decisions, freedom of choice and control over options, as well as the contexts that may include limitations, opportunities, beliefs, and values.
4. The therapist will communicate the assessment and treatment options with the client and/or their carer, family, or staff. This will be in a way and language the client and others can understand.
5. In many cases assessments take on the form of verbal feedback and suggestions, in-depth discussion and troubleshooting, and may be reflected in internal client notes, and are further documented in formal clinical letters, functional behaviour assessment reports, and/or a behaviour support plan. 
6. Various approaches to documenting assessments facilitate the content areas. These are tailored by the therapist to the needs of the person and their context and circumstances. 
7. Clinical assessment helps to develop support models for clients, which helps to understand how to position other support systems like NDIS funding, mental health funding, etc., in the life of the person.
8. Many of our reports provide funding assessment reviews in light of our clinical assessments around functional capacities and needs, particularly under the NDIS Act 2013 reasonable and necessary criteria.

Client Notes

1. Every clinician is required to keep client notes in every case. 
2. Without exception, keeping client notes applies to every case. 
3. Notes are taken when we enter a service hour booking within our client management system. Notes are attached to the service hour(s) entered. These notes are kept brief and contain statements of what was accomplished during the service hour(s).
4. Notes are entered at other times when we do not have funded compensation so no formal booking is entered as these hours do not attach payment. These notes apply the service time and date with a notation of the amount of time offered.

Client Documentation

1. Client documentation is legally required in the ATS quality framework and under the NDIS Act 2013 and other relevant statutes.
2. A range of documentation is required by ATS clinicians that enable our service, provide histories of our case work, and that capture data for various purposes. 
3. Client documentation is kept in secure password protected cloud third party services.

Case Closure

1. Case closure normally happens for a range of reasons, these may include,
   1. Issues are resolved or addressed as much as possible,
   2. Funding is used and not continued,
   3. Reports are completed,
   4. The natural life cycle of therapy has ended,
   5. The therapist or the client decide to end the service, or to refer to other providers,
   6. The NDIS Plan renewal date passed, or the NDIA updated the plan, or changed the plan details, thus ending our capacity to continue working.
2. Closure is communicated to the Client and stakeholders via phone or email notification.
3. Where applicable, referral to other providers is suggested.
4. A Client Evaluation Form is usually shared with the Client and/or stakeholders with requests for quality feedback for our services.

Legal Jurisdiction Policy

Under the fullest extent made possible by the law and in respect of the legal jurisdiction of New South Wales Australia and any other laws deemed relevant by this jurisdiction that,

1. The Client’s decision to access our website and to use the services offered by the Provider conveys a clear and reasonable level of informed Consent. 
2. The Client agrees that informed Consent implies a high degree of indemnity assurance to the Provider as to the Client actively taking personal and/or corporate responsibility as the case may be in reading understanding and providing informed Consent in light of and congruent to these Client Booklet – Disclosure Terms and Conditions.
3. The Client agrees to provide a reasonable level of Consent in writing and verbally or by virtue of the act of access that applies to the whole of their interaction with this website and the services offered by the Provider. 
4. The Client agrees that consent is ongoing, and consent can be freely withdrawn at any time. 
5. The Client agrees that having read, understood, and made an informed decision on the use of our website and the services offered by the Provider the Client will decide if the Client wishes to access, engage, and/or pay for our services.
6. The Client agrees that in relation to any and all legal issues arising the Client and the Provider are governed by the legal jurisdiction of the State of New South Wales Australia and that all legal matters arising will be referred to this jurisdiction.

Definitions

Agency: An agency is a legal entity such as a corporate client, medical doctor or clinic, psychologist(s), non-government organisation, or government department.

Client: A person(s) or entity who enters into communication with the Provider via any means or media and/or via a contractual arrangement for services. The NDIS prefers the term Participant. Participant and Client hereby mean the same thing.

Third Party Provider: Another professional, such as a doctor, community health nurse, occupational therapist, speech pathologist, minister, or any other support system that the client specifies.

Third Party Payment: Where an insurance provider or other payment is arranged by or part of the service to the client.

Participant, Client or Entity: A participant, client, or entity is an individual person or a legal entity that communicates with the Provider by any means or media and/or uses the services of the Provider.

Provider: The Provider refers to Ability Therapy Specialists Pty Ltd as the corporate body and provider of services that are used by the participant, client, or entity. Individual therapist practitioners may from time to time be employed or contracted by Ability Therapy Specialists Pty Ltd and/or be in association with the Provider for professional, collegial, and/or administrative purposes.

NDIS: The National Disability Insurance Scheme as managed by the National Disability Insurance Agency (NDIA). The Agency is tasked with everyday administration of the Scheme. The NDIS Commission is a separate body tasked with quality supervision of the disability sector nationally including in the areas of specialist behaviour support. 

Service Agreement: In the first instance, the Global Service Agreement is this Client Booklet – Disclosure Terms and Conditions. Under normal circumstances the Provider may offer a Service Agreement that is relevant to the service requested by the Client. In the context of the NDIS Service Agreement refers to a formal contract for services between a participant of the NDIS and Ability Therapy Specialists Pty Ltd as a Registered NDIS Provider.

Informed Consent Policy

1. Consent is your agreement to receive our service.
2. Consent is ongoing as you agree to the service on a day to day basis.
3. Consent can be withdrawn at any time.
4. These Disclosure, Terms, and Conditions apply to our service.
5. We view Consent as an ongoing process of learning and respect.
6. To agree to our service means deciding how you want to engage with what we have to offer.
7. What we offer is determined by policies and standards, and we will explain these to you from time to time.
8. As such, Consent offers you choices about accepting or declining our services and how these are delivered to you.
9. ATS Pty Ltd uses one Consent Form for all clients, many of whom are NDIS participants, but some of whom are private clients.
10. The Consent Form must be completed and signed by the client or their legally appointed delegate or parent or guardian for service to be assessed and begun.
11. The Consent Form holds key information about health and lifestyle issues, diagnoses, and what other health, allied health, and/or disability practitioners the client is seeing. 
12. The information you provide on the Consent Form can save you funding and time during therapy, and we will ask you or your delegate authority whether and how we need to report or correspond with the people you list on your form to assist your needs.

Consent and NDIS Policy

1. Due to NDIS legislative policies and quality standards NDIS participants who want to access our service must Consent to the terms and conditions of service laid out in this booklet.
2. Consent for NDIS services with our agency means that you will supply us with a copy of your NDIS Plan to assist our understanding of your support profile and how our service fits within your Plan.
3. Consent for NDIS services with our agency means that we need your Consent to contact on your behalf the NDIS and other NDIS providers who are helping you or supplying services. 
4. Our Consent Form and Your Consent to receive our service is built around this understanding of working within the Scheme’s standards and rules. Without these basic provisions we cannot provide a service.
5. It is your right to refuse Consent and to withdraw Consent at any time.
6. It is our right to refuse service as a Counselling Psychotherapy agency under the Australian Counselling Association Code of Conduct and as a Registered Provider under the NDIS Code of Conduct and the NDIS Commission Standards and Rules. 
7. ATS Pty Ltd may refuse service and/or refer clients to other providers if and when we feel that Consent does not match our need to meet obligations and responsibilities.
8. The NDIS Act 2013 and subsequent developments and amendments have a range of standards for the provision of services. 
9. For example, when you need a Behaviour Support Plan we need to assess whether this needs to be lodged with the NDIS Commission and your relevant State level Agency. To receive behaviour support at this specialist level requires Consent Agreement to these standards and procedures. 
10. While on one hand, we can write behaviour plans and may rarely have clients refuse Consent to lodge the information with the state and federal bodies; you must understand that we may be legally obligated to report restrictive practices to the NDIS Commission whether Consent is provided or not.

Mandatory Reporting Policy

1. When Consenting to our service you need to understand that we are Mandatory Reporters.
2. Mandatory reporting means that when there is reasonable doubt associated with risk to health and safety, particularly with under aged individuals, we are required to report the concerns to the authorities.
3. Our legal and ethical responsibilities as an Allied Health Service means that under the Australian Counselling Association Code of Conduct and other relevant standards, we are required to report to the authorities reasonable grounds for concern to health and safety that may include risk of self-harm or other-harm.

Consent and Confidentiality Policy

1. Our Consent Form specifies the nature and limits of confidentiality. 
2. The nature and limits of Confidentiality are laid out by the Australian Counselling Association Code of Conduct and Scope of Practice; the NDIS Act 2013 and Code of Conduct and the Behaviour Support Rules and Standards 2018, the Privacy Act 1988, and the Children and Young Persons (Care and Protection) Act 1998. 
3. Confidentiality means we keep your information private within certain contexts and limitations.
4. For example, when you give us Consent we may discuss your details with your GP or Psychiatrist or NDIS Planner. When you give your Consent we may speak with your Occupational Therapist or Physiotherapist. When we have your Consent we may then provide documents or ask for documents from other practitioners or providers.
5. Other circumstances provide limits for Confidentiality. For example, if you or someone you know was at risk of violence and harm, and where a child or under age person is at risk of violence or harm, as mentioned above we are a Mandatory Reporter. This means that we are obligated under the law to inform relevant authorities of any reasonable perception of risk and harm. For example, we may need to contact the Department of Family Services or similar organisation, and/or the Police.
6. Under the Children and Young Persons (Care and Protection) Act 1998, when ‘concerns of risk of significant harm’ arise, an additional Consent conversation is not required for us to communicate to an appropriate authority. In most cases where we feel this is safe to do, we would speak with you about this development.
7. Under the NDIS additional Conditions of Disclosure apply with respect to NDIS Paid Disability services and records kept by the Provider, the Provider is bound by the following clauses,
   1. “With the exception of an imminent threat to life, health or safety, all requests for disclosure must be referred to the National Disability Insurance Scheme Privacy Contact Officer for consideration prior to release.”
   2. “The Provider is required to report serious incidents to the National Disability Insurance Scheme State Manager and to the relevant statutory authority in the local jurisdiction. A serious incident is defined as:
      1. “The death of, or serious injury to, a Participant, 
      2. Allegations of, or actual sexual or physical assault of a Participant, 
      3. Significant damage to property or serious injury to another person by a Participant, 
      4. An event that has the potential to subject a Participant or National Disability Insurance Scheme to high levels of adverse public scrutiny.”

Consent Management Policy

1. Consent is put into writing on our Consent Form and is signed and dated.
2. Consent may be written or verbal. When we communicate with other providers or professionals on your behalf we seek written or verbal consent that is documented. 
3. Consent can also be implied by your participation with our service. 
4. For example, implied Consent is when you participate in therapy on a weekly basis. Every time you engage in our service, you are implying that you Consent.
5. We gain your ongoing Consent by providing you with choices and options, by asking if you are comfortable, by asking how you are feeling, by seeking what you wish to do, and by understanding how you wish to proceed. We often ask  you to rate the service and how you felt on beginning a session and ending a session. We also provide you an opportunity to give us feedback at the end of services.
6. When new information comes to light, like when you forgot to include important details on your Consent Form that we need during assessment or therapy and when you give us permission to contact a new professional not listed on the Consent Form, we will add this to your Consent form by editing the PDF document. To save you time and funding we may with your permission add, change, or delete your new information to the Consent Form and date the change based on your verbal consent. We can easily send you an updated copy of the Consent Form for your records.
7. A ‘third party’ is any service other than ours. Consent to contact third parties will imply the nature of the request and its purpose in the context of service provision. 
8. In contacting third parties on your behalf, we will supply any information requested to, from, or between third parties such as doctors, therapists, agencies, or other relevant parties, in relation to the provision of support within a reasonable time frame or as specified in the request.

Privacy and Dignity Policy

1. The Privacy and Dignity Policy is both represented within this section and includes the full document of Client Booklet – Disclosure Terms and Conditions in as much as the issue of privacy and its limitations, risks, and procedures are integral to client Consent and is subject to and contingent on the Consent of the client to the service context and its associated limitations and risks.
2. This Privacy and Dignity Policy clearly explains to clients, and to people with disability and workers, the nature of Consent to the Client Booklet – Disclosure Terms and Conditions in light of privacy considerations. 
3. Consent is primarily documented in the Client Consent Form, through ongoing consultation and implied by participation, and in various ways by use of the our website(s) and online Consent-implied procedures such as the Email Contact Form and in Registration or Membership in our website programs.
4. Privacy is a human right and as such attaches every human dignity. Dignity is defined as having the right to respectful interactions. These include being treated with positive regard in service provision, and empathy with understanding in regards to personal experiences and perspectives. Rights related to privacy are set out in the Commonwealth Privacy Act 1988 and State and Territory privacy laws. 
5. Consistent with the Australian Counselling Association Code of Conduct and the NDIS Code of Conduct, factors that may be relevant when assessing if conduct complies with this element of the Codes include but are not limited to,
   1. Complying with Commonwealth and State and Territory privacy laws.
   2. Individuals have the right not to have personal information disclosed to others without their informed Consent. 
   3. Personal information is information or an opinion about a person whose identity can be determined from that information or opinion. Examples of personal information include a person’s name, address, date of birth and details about their health or disability.
   4. That employees will respect and protect the privacy of everyone that receives support and services and will ensure that they manage health information about any people we support or about their workers in accordance with privacy laws related to the management of health information.
   5. That we will manage information about people in accordance with privacy laws, and ensure our workers understand these policies and procedures. Client information is for the most part stored in a secure manner by password protected electronic systems and within the limits of Confidentiality and of risks associated with technical and third party information and data systems. The kinds of personal information collected and held, including,
      1. if and how information is recorded i.e. in audio and/or visual material and for how long this will be kept and then destroyed,
      2. If and why this information is held,
      3. Who will have access to this information, within the limits of confidentiality and of risks associated with technical and third party information and data systems,
      4. How we will ensure the information is secure, within the limits of Confidentiality and of risks associated with technical and third party information and data systems,
      5. How this information will be used,
      6. How to access and amend information held about you,
      7. How to make a complaint if you feel that ATS Pty Ltd has breached our privacy obligations.
6. There are certain circumstances where ATS Pty Ltd should disclose information about a person without Consent from the person involved. This might include Mandatory Reporting requirements on child protection matters, and Obligations to Report incidences of violence, exploitation, neglect and abuse, and sexual misconduct. Such reporting may be to the Department of Community, NDIS Commission, and/or the police.
7. The limits of confidentiality apply when by necessity of law as Mandatory Reporters we need to,
   1. By reasonable perception of risk in reducing or preventing a serious or imminent threat to an individual’s life, health or safety, or preventing a serious threat to public health or safety.
   2. By reasonable perception of risk in preventing, detecting, investigating, prosecuting or punishing of criminal offences and other breaches of the law that attract a penalty.
   3. By reasonable perception of risk in preventing, detecting, investigating or remedying of seriously improper conduct or proscribed conduct.
   4. Under the preparation or conduct of proceedings before any court or tribunal.
   5. Under required Clinical Supervision for the Provider’s staff, wherein client details are de-identified unless there is a compelling need for details as required for quality assurance and/or standards of safety and risk. 
   6. While maintaining a professional framework supported by ongoing clinical supervision as a regular requirement of professional practice. The exchange of information within professional supervision maintains Client confidentiality and privacy with the exception of statutory requirements as noted above.

Privacy and Service Context Policy

1. All clients, and particularly people with disability have a right to privacy including in relation to the collection, use and disclosure of information concerning them and the services they receive. 
2. Privacy as a principle necessarily includes the client offering Consent in various ways to use and disclose their personal information including health information for the  purposes of ATS Pty Ltd providing a quality clinical, educational, and/or capacity building and training purpose.
3. All clients, and particularly people with disability who have provided Consent to use their information in specific ways and contexts have the right to service provision that respects their dignity and human rights by the appropriate use of their information within the clinical support, review, and where applicable in the online training and capacity building environment.
4. ATS Pty Ltd have from time to time provided quality capacity building to disability providers on behalf of a client or clients. In such situations, the clients or their parents or guardians have provided documented Consent. 
5. It has become increasingly necessary to inform clients of the risks versus benefits of online Telehealth, information exchange, and participation in online programs, learning, and clinical training services that are associated with the client’s case and personal information. While we provide as much information as we can in good faith, all decisions in this regard as to what and how to use technology remain the responsibility of the client.
6. Where the online and cloud-based services have become increasingly normative across society and within the human services industry, ATS Pty Ltd has invested considerable time and resources into improving our online capacity to offer clinical video conferencing services, an online website, and online programs.
7. Clients who decide to engage in online Telehealth services, as covered throughout the Client Booklet – Disclosure Terms and Conditions particularly in relationship to risks in the use of technology, to use these services the client must necessarily Consent to the risks associated with the use of third party applications, video conferencing services, data and internet servers, data systems, and information retrieval systems; whether in Australia or overseas. 

Privacy and Data Security Policy

1. In regards to providing Consent for online and telehealth services we stress that clients need to understand that there is the chance that your personal and health information may be compromised whether by mistake or by external malicious intention or a breach in the security or operations of any number of third parties involved in the provision of distance technology services.
2. While ATS Pty Ltd would take all precautions within our control in relation to the safe storage and retrieval of client’s personal information, such as carefully guarding passwords and access to online systems, and that we would take whatever actions are reasonable in the event of our being made aware of a breach to the systems and applications being used; we also must acknowledge that ATS Pty Ltd like all service providers does not control the highly technical computer systems that interact with our work. 
3. The client therefore indemnifies ATS Pty Ltd and our employees from all claims and losses and implied harm that may be implied or perceived or in material form due to the breach of technical and online and training systems; and the client accepts whatever relevant personal liability and responsibility as such being both inherent and integral to the exercise of personal choice and control in providing Consent to the service provision that necessarily in this day and age includes these risks.
4. This being said, ATS Pty Ltd seeks to reduce risks and we care about client’s personal and health information, even while we venture into online Telehealth systems at the request and need of clients. As such we provide the following protocols and guidelines to uphold the privacy and security of client information.
5. The Contact Form on our website allows people to enter name and basic information into the fields and the system generates an email to our inbox. 
6. For the most part ATS Pty Ltd uses a PDF Consent Form and Service Agreement and other PDF Forms to document services. As such the information on Forms is stored in the PDF format in client folders and the system is password protected and access is restricted within the organisation environment. When we write reports and assessments, these are normally kept in PDF format to attempt to control document integrity. More often than not documents are shared via email systems and these systems are more than likely not secure or encrypted. 
7. To attempt to increase data security ATS Pty Ltd has a subscription to Medical Objects which is an Australian wide cloud based encrypted system used by medical and allied health practitioners to more securely share clinical, medical, and health information. As a first order of business when communicating with such practitioners on a client’s behalf, we check to see if they are on the Medical Objects platform. Sadly, we report that many medical and allied health practitioners we correspond with are not on Medical Objects.
8. Where the client Consents to Zoom or teleconferencing or any other third party application, ATS Pty Ltd is able to share information on the client’s behalf in good faith and with Consent in an online or other system in real time and/or in asynchronous written materials. 
9. Such information that may be shared may or may not include,

1. Name, age, date of birth, location.
2. Clinical reports, behaviour support plan, other materials.
3. Health information, status, and concerns.
4. Behavioural or therapeutic or learning strategies and methods.
5. More generic information associated with therapy or behaviour support skills and resources, including materials for general purposes (that is, not related directly to the case per se but entirely relevant to the case when applied as such).
6. Other relevant information, and depending on Consent, that may or may not include past clinical reports, medical reports, NDIS reviews, funding information, etc…

Privacy and Online Programs Policy

1. ATS Pty Ltd, and/or via our pilot project, Ability Academy Australia, may from time to time create online Capacity Building Programs.
2. Interested parties in the programs may gain access via the participant’s parents, or their provider’s control of access, or via direct enrollment from one of our websites.
3. Where programs are made available to a staff group individual staff may be assigned or use an email address associated with their account. 
4. Contact and other personal information entered into the system will be stored in the online system.

Data Risk Mitigation Policy

1. A key principle of privacy in the technological era is risk mitigation. Risk mitigation is seeking to limit risk where possible and within our control. Containing and restricting access to client data and information is first and foremost standard procedure under Australian standards.
2. Seeking data security is also a central principle and relies heavily on governments and corporations who set the standard within the data and technology industries that apply to the systems ATS Pty Ltd uses in good faith and in the hope of good effect. From time to time ATS Pty Ltd reevaluates our use of third party applications when new information comes to light. 
3. Consent in regards to data security and risks as such relies on taking into account a wide range of factors. We encourage you to explore and learn as much as you can about these realities prior to engaging in Telehealth and online services.
4. To limit and contain risks where possible, and to uphold the human rights of our participants and clients what we do and create online exists within the technological limitations of the day and will remain at the discretion of ATS Pty Ltd to engage, curtail, limit, or refuse service depending on our evaluation of the contexts.
5. For the most part and excepting where the law of NSW and Australia determine otherwise, your use of these and our systems is at your own risk and you indemnify ATS Pty Ltd and our staff from liability in the event of adverse actions that compromise data security and that expose your personal information in the technological and online environment. Please make your Consent decisions accordingly.
6. Our website and all information from ATS is provided for information purposes only. While we have made every effort to ensure the information provided is free from error. The Provider does not warrant the accuracy, adequacy or completeness of the material provided. All information is subject to change or deletion without notice. 
7. We recommend that you seek independent advice before acting upon material on our website and elsewhere provided. Where the Client wishes to engage the Provider for any and all services such agreements will be engaged on their own merit irrespective of representations made. 
8. We reserve the right to change, alter, delete or modify any service provided and all information on this site as required at any time. In relation to the course of business and to any decisions therein, our website and information provided does not constitute a definitive representation of the substance or details of business transactions. 
9. All agreements, covenants, contracts or other kinds of arrangements made between parties are represented under direct contracts, agreements, covenants or other schedules entered into in respect to the business undertaken by the parties. 
10. ATS Pty Ltd operates in the context of using information technologies including the world-wide-web, email, text, mobile phone, video conferencing, and relevant applications and systems for data management and security.
11. Consent to use our service includes your agreement to using communication technologies that characterise contemporary service provision and business management. You have the right to refuse the use of communication technologies under certain limitations, i.e. depending on how you wish to proceed, we may not be able to provide a service where certain systems are necessary for our legislative, legal, and standards compliance.
12. We do not guarantee that use of our website or any third party websites or servers or email providers will be safe or without virus or other threats to security. We do not guarantee or imply your safety in the use of any third party technology systems or companies involved in the technology and communications industries.
13. We expressly provide warning hereby giving notice of your risk in using any or all technologies associated with the world-wide-web and/or national and/or global telecommunications industries including email. We do not warrant that your use of any technologies will be free from viruses, or that access to our website or any third party website or email system or server or other communications technology or company involved in this service will be uninterrupted, uncompromised, or that security will be maintained. 
14. We do not guarantee, warrant, or control the quality and security and functioning or confidentiality of the server(s) and/or other systems through which information is routed via telecommunications and the world-wide-web, including through emails and/or audio, video, text, or other types of communications as facilitated via third party technologies.
15. In the fullest extent possible and in respect of the law of New South Wales, Australia, and of any other applicable law as deemed relevant by our legal jurisdiction, we will not be held liable for error, omission, loss, corruption, interruption, security breach, lack of quality or functioning, or any other problem associated with or arising from problems with communications exchanged via third party companies and in the course of business provision. 
16. We do not warrant the security, safety or confidentiality of passwords, messages, video, audio, emails or any other communications used and/or sent and received in the course of business provision and during the course of professional consultation particularly in respect of such communications being of confidential and highly sensitive nature. The Client as the service user accepts full responsibility in regards to your choice and Consent in undertaking these and related risks in disclosing your personal information in these contexts and by these communication methods. 
17. As such you the Client agree to indemnify the Provider of all liability under the fullest extent possible under the law of NSW or all manner of loss, harm, damage, grief, and suffering that may arise whether directly or indirectly now or at any time in the future and in perpetuity in association with failures of communication systems that are reasonably accepted to be outside of our direct control.
18. Subject to any responsibilities implied by law and which cannot be excluded, we are not liable to you for any losses, damages, liabilities, claims and expenses (including but not limited to legal costs and defence or settlement costs) whatsoever arising out of or referable to any material on this website or any third party website whether in contract, tort including negligence, statute or otherwise. 
19. Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on our website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.
20. Your use of any information or materials on our website or with this service is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any products, services or information available will meet your specific requirements. 
21. Our website and information provided to you contains material which are owned by or licensed to the Provider. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these Client Booklet – Disclosure Terms and Conditions.
22. Unauthorised use of our website may give rise to a claim for damages and/or be a criminal offense. From time to time this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).

Therapy with Young People and Early Childhood Policy

1. ATS maintains a Therapy with Young People and Early Childhood Policy that expresses our family and relational-based approach to assessment and treatment that works closely with parents, guardians, children, youth and adults within the family in an ecological approach to ensure choice and control. Partnership governs these relationships with children and families, within a strengths based approach while respecting the family’s sense of priorities and needs.
2. ATS promotes a culture where each young person and child participant accesses supports that promote and respect their legal and human rights, support their development of functional skills, and enable them to participate meaningfully and be included in everyday activities with their peers.
3. “Young people” is a phrase used to describe developmental stages from birth through to the early 20s and sometimes up to age 30. Of particular importance for this policy are the early stages of human development in childhood, adolescence, and young adulthood where legal guardianship is warranted and maintained by adults in the young person’s world. 
4. Legal age in Australia and under the jurisdiction of NSW under which this policy applies is 18 (eighteen) years. The following principles guide our practice with people who are under the legal age and to a great extent our work with chronological adults who are developmentally not capable of functioning as independent adults in society.
5. The ATS policy and values within our ecological model sees the family as the primary informants and experts in their experience of the child. ATS highly regards this expertise and actively engages this through parental empowerment, coaching, and encouraging development of skills and capacities within a strength-based approach that nurtures unconditional positive regard.
6. Cultural responsiveness is central to ATS values as an organisation with expertise in culturally infused methods. Our staff are highly regarded with many years of research and practice in culturally infused methods in therapy, including among Australian, North American, European, Celtic, Aboriginal, First Nation, as well as urban, regional, and remote cultures and traditions and with senior expertise in the fields of personal development, spirituality and culture.
7. ATS uses integrative methods to ensure supports are naturalised within the child’s development and family routines, enabling maximum uptake of plans and outcomes. 
8. ATS focuses on strengths to co-enable parents and families to develop their own skills and capacities, and to organise their informal and formal supports, and where possible to address their child’s needs in ways that may reduce the child’s needs for therapeutic intervention in future. 
9. ATS works closely with parents and family to inform and strengthen their participation in, and contribution to, the child’s learning and development. These goals within therapeutic assessment and treatment planning seek to use our role as therapists within a holistic manner to build parental capacity to manage their child’s unique needs and developmental challenges. 

Upholding Standards

10. ATS supports the NDIS Quality and Safeguarding standards of practice that promotes, “knowledge and understanding of each participant’s legal and human rights, and incorporation of those rights into everyday practice. The implementation of practices and procedures to manage risk with a focus on creating a safe environment for children.” 
11. Regarding the management of risk, the practice standards require that ATS “maintains compliance with all relevant state and territory legislation relating to the reporting of risk of harm to children; and facilitation of the active involvement of the participant’s support network in the participant’s development.” 
12. These factors are applied within our ecological and relational model of therapy with children and young people during clinical assessment, observation, listening to parental concerns, attending to issues that arise in daily support, addressing behaviours of concern, and in treatment planning and recommendations for future care and/or with other therapies and/or within home-based and/or school-based psychoeducational interventions.
13. In application of these standards ATS provides “alternative arrangements for the continuity of supports for each child participant, when changes or interruptions are unavoidable, are: (a) explained and agreed with them (taking into account their capacity to understand and agree to alternative arrangements) and their family; and, (b) delivered in a way that is appropriate to their needs, preferences and goals.” 
14. ATS acknowledges that continuity of therapeutic assessment and treatment is important for the child and that when interruptions happen it is more difficult for the child as managing transitions may not be easy, particularly where disability and other relational sensitivities exist. From our side, during a planned course of therapy ATS seeks to minimize and mitigate interruptions beyond a fortnight by deployment of our staff to step in to help if one of our staff are sick or unavailable. 
15. ATS understands that often families and parents face issues that challenge continuity and that can cause lengthy delays in continuity of therapy. In these cases, where possible and ideally before the period of therapy interruption ATS therapists suggest ways for parents or guardians to continue the work of positive person centred support within the family environment. In other cases, the family’s day to day context driven interruptions are unforeseen and ATS therapists will seek to continue therapy when/if this becomes possible. These factors are addressed during the assessment and therapy delivery cycle and are noted within the client file and monitored by the therapist in due course of their responsibilities under the service agreement.
16. ATS upholds the general principles set out in the NDIS Quality and Safeguards Commission’s 2021 Practice Guide on Regulated Restrictive Practices with Children and Young People with Disability, “All children and young people have rights protected under international, national, state and territory laws. In 1990 and 2008 respectively, Australia ratified the United Nations Convention on the Rights of the Child (UNCRC) and the United Nations Convention on the Rights of Persons with Disability (CRPD). This means Australia is bound to protect and uphold the rights of children and young people with disability (Australian Government, 1986; Australian Government, 2012; Australian Human Rights Commission, 2019; Australia Government, 2013).”
17. ATS upholds the general principles quoted by the NDIS Quality and Safeguards Commission’s 2021 Practice Guide as set out by, “The UN Conventions includes (but are not limited to) the following:

• The right of children with disability to fully enjoy all human rights and fundamental freedoms on an equal basis with other children and considering the best interests of the child (CRPD, Articles 3 and 7)
• The right of children to enjoy a full and decent life, in conditions which ensure dignity, promote self-reliance and facilitate participation in the community (CRC, Article 23)
• The right of children to express their views freely on matters affecting them and for these views to be given due weight and consideration having regard to their evolving capacities (CRPD, Article 7 and CRC, Article 12)
• The right to equal recognition before the law (CRPD, Article 12)
• The right to liberty and security (CRPD, Article 14)
• The right to freedom from torture or cruel, inhuman or degrading treatment or punishment (CRPD, Article 15)
• The right to freedom and protection from exploitation, violence, abuse and neglect (CRPD, Article 16 and UNCRC, Article 19)
• The right to respect for their physical and mental integrity on equal basis with others (CRPD, Article 17)
• The right and responsibility of families to guide children as they develop (UNCRC, Article 5)
• The right to life and development to a child’s full potential (UNCRC, Article 6)
• The right and responsibility of parents in bringing up their children considering what is in the best interests of the child (UNCRC, Article 18)
• The right to receive support so children can live a full and independent life (UNCRC Article 23).”

18. ATS upholds the general principles set out in the NDIS Quality and Safeguards Commission’s 2021 Practice Guide as such, “Under the National Disability Insurance Scheme (Provider Registration and Practice Standards) Rules 2018, registered NDIS providers who provide early intervention supports to children who are participants (or prospective participants) of the National Disability Insurance Scheme must:

• Promote and respect the child’s legal and human rights, support skill development and enable inclusive and meaningful participation in everyday life (Schedule 5, sections 3 and 5)
• Be family-centred, culturally inclusive and strengths based (Schedule 5, sections 3, 4 and5)
• Be collaborative and meet the needs and priorities of the child and their family (Schedule 5, section 6)
• Build capacity and support the child’s learning and development (Schedule 5, section 7)
• Be evidence-informed and outcome based (Schedule 5, sections 8 and 9).”
• In addition to the above, NDIS registered providers must meet all other Practice Standards relevant to their registration and the services they are providing.”

19. ATS is a Child Safe Organisation, and as such, we uphold the general principles set out in the NDIS Quality and Safeguards Commission’s 2021 Practice Guide as such, “In 2018, the Australian Human Rights Commission developed the National Principles for Child Safe Organisations in response to the findings of the Royal Commission into Institutional Responses to Child Sexual Abuse. These principles have been endorsed by all Commonwealth, state and territory governments and provide a nationally consistent approach to embedding child safe cultures within organisations. It is important for providers supporting children both with and without disability to have an understanding of these principles. The National Principles for Child Safe Organisations are as follows:

• Child safety and wellbeing is embedded in organisational leadership, governance and culture.
• Children and young people are informed about their rights, participate in decisions affecting them and are taken seriously.
• Families and communities are informed and involved in promoting child safety and wellbeing.
• Equity is upheld and diverse needs respected in policy and practice.
• People working with children and young people are suitable and supported to reflect child safety and wellbeing values in practice.
• Processes to respond to complaints and concerns are child focused.
• Staff and volunteers are equipped with the knowledge, skills and awareness to keep children and young people safe through ongoing education and training.
• Physical and online environments promote safety and wellbeing while minimising the opportunity for children and young people to be harmed.
• Implementation of the national child safe principles is regularly reviewed and improved.
• Policies and procedures document how the organisation is safe for children and young people.”

Ecological Model of Therapy

20. ATS works within a holistic, ecological, and relational model of therapy where the child or under aged person is addressed as a member of a family and community. ATS works with under aged persons within a family therapy model. Family in this context is defined as close day to day support and living relationships. 
21. We see children or young persons within the presence of adult parental or guardian-based relationships – we do not see under aged persons alone or apart from their adult support relationships. 
22. ATS works with young persons under parental or guardian arrangements only where there is an adult present in the room and nearby i.e. within visual and auditory distance and to provide supervision.
23. ATS services are telehealth and online. We work with children via use of video conferencing systems where their parents or guardians are present in the room or near enough for either visual or auditory participation and to provide supervision.
24. The adult(s) present with the under aged person are part of the therapeutic process and are treated as such, i.e. adults are also clients subject to therapeutic intervention and need to Consent to this holistic family-context approach. 
25. Where private issues arise for under aged persons, for example, with trauma issues or personal identity issues that the child cannot disclose in front of parents or guardian-based relationships, the adults present in therapy are asked to provide additional space via a partition in the room or sitting outside the room but within visual or auditory range whichever seems more appropriate.
26. In some cases another therapist may be present nearby to assist and/or observe. Co-joint therapy using two therapists with the young person and family is also conducted to assist observations and greater insight to the young person’s capacities and issues. At the discretion of the Provider, we may seek parental Consent as to costs for conjoint therapy to include payment for two therapist’s clinical hours where funding permits.
27. Our approach to therapy and provision via telehealth is not for everyone and not all parents want to be engaged during therapy with their child. Likewise, not all children have the capacity to engage well with telehealth.
28. Under aged persons and younger children in particular are never expected to engage per se “with the screen” of the computer or Ipad or other device. Children with Autism have many and varied ways of experiencing visual and auditory stimulation within their overall sensory makeup. Young persons with Intellectual Disability have varying levels of speech recognition and capacity to express communication. These and many other examples show that expectations for telehealth must be realistic and need to be tailored for and around the individual’s needs and capacity. 
29. In many situations our work with children and young people under the NDIS and privately focuses less on direct interaction with the child or young person and more on assessment and treatment planning while building the empowerment and capacity of the parent(s) and/or other providers. This model again builds up maximum outcomes and is more sustainable because the parent can then apply skills over time and make the need for therapy less over time.
30. We acknowledge that many parents like everyone have personal issues that come up during therapy that can be challenging to face and work through. Parents that work with us need to make an informed decision about their level of involvement and sharing. Sometimes a parent will share deeply with their therapist and this helps them to help their child. 
31. We see our role as supporting the parents within their child’s funded program because evidence shows that this is the most effective and sustainable way to ensure optimal capacity building for the child’s future. Once a parent or parents have the skills necessary to address various needs, they can apply these skills over many years, thus preventing more difficult issues and helping their child grow and develop. Where a parent is dealing with difficult personal issues that are outside of the scope of their child’s funded therapy, we may suggest referrals to another therapist for support.

Inclusive Practices

32. In concert with the NDIS Quality and Safeguarding standards, the ATS Therapy with Young People and Early Childhood Policy and our practice maintains an assessment approach that supports each child’s developmental needs and focuses on the child’s functions in their everyday routines and activities in their natural learning environments. ATS achieves these goals within a Telehealth model that connects with parents and guardians in the everyday context where the child lives and that uses common cultural experiences of handheld devices to assist in ease of access to therapy.
33. ATS promotes a child’s inclusive, meaningful and active participation in their family life, community life and natural environments through a telehealth model that communicates a strength-based and skill-development approach in the family’s everyday contexts. 
34. ATS builds on the existing linkages within each family’s local and regional ecology through their consent to engage community and other support agency stakeholders including teachers and schools through actively building a referral network and tapping into existing or referrals to new family networks. 
35. ATS builds our plans and practices around a child’s natural daily routines and environments, as the primary basis of support and intervention.

Developmental Considerations

36. As children age and become teenagers, the progression toward independence is respected and parental or guardian supervision remains equally important and necessary, even though the supervision may provide a bit more space to the under aged person the parent or guardian must remain involved in the therapeutic engagement. 
37. A solid working relationship between parties in these situations is important and where some conversations are given a little more privacy, the therapist will communicate with the parent or guardian and vice versa to ensure open lines of communication are maintained. 
38. ATS therapists work intentionally with adult’s presence, space, and distance as elements of positive attachment theory that at various life stages provide indications of and methods for addressing therapeutic issues. 
39. Positive behaviour support provides many insights to developmental issues that arise for children and young people. As early childhood intervention specialists, ATS promotes a prevention-education orientation that assists parents to adopt positive behaviour support principles and practices early in the child’s development to help prevent future concerns.

Collaboration and Transition Planning

40. ATS Therapy with Young People and Early Childhood Policy promotes a culture of collaboration with the child, parents, families, extended family, providers, and to some extent teachers and schools where the NDIS support profile requires building synergy and mutual relationships with a consistency in support methods across environments. As such, ATS works with NDIS providers and key workers involved in a child’s life. ATS may assist families to gain necessary skills to self-identify, interview, and retain a suitable key worker. 
41. ATS policy and practice builds on collaboration with other providers wherever possible, towards building links with and for families, particularly vulnerable families with children with disabilities. 
42. ATS shares information under consent in collaborative team-based efforts through written methods or meetings, case reviews, encouraging mutual sharing of information, and where relevant co-joint therapy and/or support work with a child and family. 
43. ATS policy and practice is sensitive to and supports well planned transitions for children, including in the beginning and end of a course of therapy, family life-stage transitions, annual and term school-based transitions, leaving school transitions; and in addressing other major developmental milestones like puberty and young adult transitions. ATS works with other providers and systems to encourage positive transition planning and implementation.

Capacity Building

44. ATS Therapy with Young People and Early Childhood Policy and practice outcomes sees our therapists working regularly with the support network in each child’s life to build their capacity to achieve the functional outcomes identified in the child’s support plan. 
45. ATS works with building the family’s actual skills and capacity and therefore their confidence through encouraging a strength-based attitude that values day to day practices of affirmation, gratitude, patience, and empathy for and with the child and within the parent. These dimensions nurture positive person centred support methods that encourage best practices in behavioral and developmental support. ATS provides these methods to the family directly via Telehealth access in the family home and therefore more readily encourages integration within the family’s daily routines and everyday activities to nurture and apply evidenced based support of their child’s development.
46. ATS policy and practice builds the capacity of the child, family and collaborating providers involved with the child through coaching, capacity building support and collaborative teamwork. 
47. The ATS policy and practice approach with young people and children applies person centred support methods within collaborative discussions and information sharing. These tasks are undertaken to affirm, challenge, and support the child, family and collaborating providers to further develop their skills and to improve practice and relationships. 
48. ATS policy and practice provides therapy assessment, treatment, and treatment planning as well as person centred behavioural support consultation and planning in a dialogical-method that requires careful attention to listening to and responding to parent’s concerns and provider’s feedback and learnings from working with the child and/or the family and/or with other professionals and in different local contexts. This approach applies active and clearly conveyed verbal and written communication in formats that can be understood by the parties and that express the therapist’s feedback and clinical recommendations to parents and stakeholders. This close attention to detail and adjusting our communication methods along with our therapeutic approach and strategies enables best practice in the co-production of treatment planning documents and/or reports while ensuring that ATS provides quality improvements in our delivery of therapeutic support.

Evidence and Outcomes

49. ATS Therapy with Young People and Early Childhood Policy and practice bases our work on evidenced based intervention strategies that include explicit principles, validated practices, best available research and relevant laws and regulations. 
50. ATS applies appropriate information, knowledge, skills and expertise to deliver quality support to families. ATS works within the limits of our expertise, and wherever necessary, refers a family on to other practitioners when needs arise that may be outside of our capacity to help. 
51. ATS Therapy with Young People and Early Childhood Policy and practice ensures that knowledge and skills are maintained with continual relevance by practitioner’s ongoing responsibility to maintain professional development, critical and skill-building self-assessment, peer-supervision, external clinical supervision, and documenting these along with keeping notes on a professional training register that is monitored during internal and external quality audits.
52. ATS Therapy with Young People and Early Childhood Policy and practice works with the functional outcomes for the child and their family that are based on their needs and priorities, and the skills needed to achieve those outcomes are identified through collaboration with the child and their family. We achieve this in part through ongoing case review, clinical supervision, and reflective practice. 
53. ATS works with the child’s documented support plan that describes the interventions and their functional outcomes. ATS develops these plans with the family and child and their stakeholders in a collaborative manner. In other cases, ATS works with existing plans developed by other therapists or teachers within the early intervention or other contexts. 
54. Regardless the origin of plans the family and parents are central and where existing plans do not reflect this ATS practitioners work closely with the parents as the experts and key informants in revising plans that are in best practice co-designed, co-written, endorsed, and fully supported and able to be applied and managed by the parents who can then take on a leadership role with other therapists and providers. ATS is family focused, and they are actively involved in the assessment of the child and the development and review of the support plan. We encourage families to co-author plans that we develop with them to ensure participation and to empower their role within an often complex social and community services context.
55. ATS works with person centred plans, built within the participant’s language and communication modes. Our plans express a co-designed method to ensure parental roles and oversight in their child’s development and to encourage their leadership within the child’s service system or context.
56. ATS policy and practice is based on a functional capacity model within person centred methods of relational support, encouragement, identification of risk, providing duty of care, and seeking to ensure that functional outcomes can be measured and to nurture the child’s meaningful participation in family and community. 
57. ATS works to make assessment, intervention planning and outcomes for the child and the family relevant and timely, practical and measured through mutually co-designed objective observations that make sense to the family, that can be evaluated and reported upon by the family and/or by advocates and/or therapists and/or teachers, and can be actively used by the parents or guardian to build on existing support systems and funding models. 
58. In line with these objectives, ATS often supplies NDIS funding assessments and reviews that assist parents or guardians to advocate the needs of their children. In keeping with our policy and practice objectives, with parent and/or guardian consent ATS supplies high quality assessment observations and treatment recommendations via clinical letters and reports to a wide range of allied health, medical, educational, and specialist practitioners and agencies.

Video Use Policy

1. Our person centred service operates within the modern technological world where many or indeed most of our clients are using handheld devices, IPads, desktop computers, and the wide range of third party applications (Apps) that exist and are in common usage.
2. Your Client Booklet – Disclosure, Terms, and Conditions outlines the use of third party technology systems and the commonly known data security limitations and risks associated with third party applications that you the Client may take on when you decide to use these systems. This section outlines the common ways people make use of video sharing options. 
3. The decision of what and how to use these technologies is entirely yours alone and the risks you take in communicating personal information over these third party systems is also at your own risk. 
4. ATS Pty Ltd must also make our own decisions about what technologies we will use and in some cases how a technology will be used for optimal safety and data security. As new information comes to light, our policy and practice may change.
5. Video Sharing generally happens in two ways:
   1. In real time where video systems also act like a telephone for talking but include video. Their advantage is that they are either free or very inexpensive to use.
   2. In delayed time where Clients share video or audio files that illustrate behaviours of concern or other experiences during a video chat or via a secure messaging application. 
   3. For instance, a family may film during behavioural episodes and share the clips with a specialist. Another example is a service provider working with a client to record video clips of social interactions with staff. These may then be used for training staff to work effectively with the individual. 
6. In all these cases and generally in the social and human services environment, documented Consent is of primary importance. That is, Consent to make, to define use, to allow access, to establish a timeline for use and then to establish a delete date for this information. These agreements are central to protecting privacy and human rights and are to be upheld.
7. ATS Pty Ltd does not keep any video or photographic material for clients. Clients may share video information with us, but ATS therapists will then delete the information or pass it back to the client. All such materials remain the property of the individual and their parent or guardian.
8. ATS Pty Ltd also has not used our client’s photographs in our public materials. All public materials that include images or video of people and individuals or children with disabilities are from established online databases such as Pexels.
9. When a family or client requests, we may use a headshot taken by the family or staff in a personal document like a behaviour support plan. However the use of this document is controlled by the participant, parents and/or guardian.
10. ATS reserves the right to refuse participation in accessing personal materials via certain systems without any need for explanation. 
11. As stated in the Client Booklet -Disclosure Terms Conditions, ATS Pty Ltd will not be held responsible or liable for loss of personal data, information, or compromises to security of data for any reasons including any perceived or plausible errors or mistakes by our employees. Clients who chose to use these systems under our Client Booklet Disclosure, Terms and Conditions do so at your own risk.

Video Sharing Policy

1. ATS Pty Ltd therapists prefer not to view recorded videos on systems where there are potential data security risks. Our therapists generally prefer “real time” live chats, on an encrypted App ideally, where the client uses a smartphone or video camera on a laptop or computer to allow us to see what is happening at the moment. 
2. Where behaviours or issues happen when a client has their phone, but are not talking with us, often clients or parents or a staff member with permission and Consent will take a short video and will want to share this with the therapist or behaviour specialist. 
3. Sometimes people will then show the smartphone video by using a separate device to look at the video being played. This way the information can be shared with the therapist and then deleted.
4. Zoom sessions allow clients to share video files on their desktop with the therapist during a teleconference, in this example the files remain in the sole control of the client.
5. Videos of specific social interactions between a family member and a person with a disability can be helpful for a wide range of reasons. These can help the therapist to understand relationship patterns and behaviours of concern. Discussion with the person with disability can provide more insight about what is happening and how to proceed, and how to help family or carer to change what they are doing to help the individual.
6. Video used in this therapeutic way can help the therapist to observe and point out ways to improve the communication or social interaction. The participant, family member and/or staff may then practice new skills, which they may also record on video to share progress. Use of video for sharing this kind of personal information must happen under very careful guidelines to ensure documented Consent, comfort, respect, dignity, and privacy are maintained to the highest standard.
7. In a disability provider service setting deletion of data must always be carefully considered, scheduled, and verified by people using video or text information of a personal nature.
8. The pace of change with technology makes it difficult to cover the many contingencies involved. The best that anyone can do is to research, and make as informed a decision as possible. Consider the risks, and then work to minimize those that are within your control. For these reasons ATS Pty Ltd is developing and continually reviewing policy and practice guidelines for the use of information and video sharing.

Conflict of Interest Policy

1. ATS is committed to preventing conflict of interest in the first place, and where issues arise to reduce and eliminate conflicts of interest as quickly as possible.
2. The Provider will have no financial or other interests that could directly or indirectly influence or compromise the provision of support to a Client. 
3. The Provider will not accept offers of money, gifts, services or benefits that would cause the Provider to act in a manner contrary to the interests of the Client.
4. The Provider will maintain standard professional service provision to all clients and will not give special gifts to clients apart from Christmas cards or marketing and promotional offerings that are given to all clients and not just to one client.
5. Regarding conflict of interest that may come to light during service provision the Provider will act to resolve the issue as quickly as possible. 
6. When an issue comes to light the Provider will raise the concern with those involved, discuss the issue, and determine a resolution. In retrospect, the provider will work to resolve the potential for conflict of interest in future and will communicate this outcome to the relevant parties where appropriate.
7. Conflicts of interest will be entered into the cloud based client management system as an incident to be reported internally. The issue and how it is resolved will be documented.
8. Where a client is involved in the issue, the client will be supported in discussion toward resolution and will be notified verbally of the resolution, and in writing where appropriate to their capacity and preferences.
9. The Provider will make every effort to demonstrate clear role definitions and to document tasks completed per service agreement hours of service.

Fees and Cancelation Policy

1. Where services are provided to NDIS participants, these are paid for by the Scheme. 
2. Fee structures and categories for service are determined by the NDIS. 
3. NDIS services are GST exempt. 
4. The Provider notes that NDIS payment policies at the time of the client’s Service Agreement are honoured, and while the principles of this section generally apply, these principles cannot in practice contradict the Provider’s obligation to abide by NDIS payment policy and practice.
5. ATS Pty Ltd charges for support delivered in accordance with the National Disability Insurance Scheme pricing arrangements and guidelines. We claim or charge or invoice the NDIS or Plan Management Agency or the Individual Self Manager after the support has been provided. 
6. Our Service Agreement will clearly set out for the Participant the costs to be paid, timing of delivery and the payment method. NDIS-based service agreements are GST exempt. No fee additional to the agreed price for the support will be levied upon a Participant for support directly associated with the Service Agreement.
7. Services that fall outside of the NDIS-focused Service Agreement may be negotiated separately for payment by other means at the sole discretion of ATS Pty Ltd. Services under this category are private and are subject to GST. A quote for services will be provided and an acceptance of quote will be documented by signature. Fees under the quote will be billed periodically and after any relevant hour is performed.
8. Our service is based on a fee for service model.
9. For consultations with private clients we use a fee structure that assists with cost mitigation via a concession fee model for those in need. ATS private and corporate services are GST applicable. 
10. The Client agrees that booking the provider’s time is a binding agreement to purchase/pay for the service when booked or on the day of the consultation. 
11. Clients normally pay for services after they have received them. The one exception is for private clients who pay for a block of sessions at a further reduced rate to save money. These sessions can be booked at any time contingent on the therapist’s availability.
12. 24 Hour Cancel or Pay: If not cancelled outside the 24 hour window, a full charge for the  session is warranted. The 24 hour cancel or pay policy is waived for emergencies to hospital, unexpected sickness, death of a loved one, car or other major accident, and when a doctor’s certificate is provided. The client agrees to please contact the provider ASAP to inform of the crisis.
13. If the client is unable to pay a bill, but wishes to settle the account, they agree to contact the Provider to offer advice that they will pay the amount within three days maximum. If the client chooses to not pay, all further service will be suspended on the day following when payment is due. The client agrees that in the unlikely case of refusal to pay, invoices may be sent to a collection agency.

Service Agreement Policy

1. Under NDIS policy standards, participants of the NDIS are provided with a written Service Agreement. 
2. Supports delivered are in accordance with the Agreement and are adapted from the National Disability Insurance Scheme “Model Agreement”. 
3. Our Service Agreement is consistent with the National Disability Insurance Scheme’s pricing arrangements and guidelines.
4. This information does not replace the text of your NDIS ATS Pty Ltd Service Agreement. 
5. This section only highlights some of the key points of your agreement. 
6. The Agreement itself is the definitive text.
7. If the Provider intends to withdraw or terminate our services with you, we will provide adequate notice to you or to your nominee. You agree that the timeframe for notice will vary according to the nature and frequency of the support and a termination clause will be included in your Agreement.
8. The Agreement template is updated periodically to reflect changes in the NDIS service context, and we seek to provide you with the most current information that is necessary to document services agreed and their timelines.
9. During 2023, the NDIS is piloting a transition to the PACE portal system in Tasmania that they intend to make national in future. This has implications for participants who become part of the PACE model. Our Agreement template is being updated regularly as new information comes to light on the PACE system to help participants understand what they need to do in the PACE system. This in part ensures that our Company is registered inside the participant’s NDIS Plan monitoring system under the relevant service categories. These steps by participants or their NDIS Nominee must be completed before we can be paid for services provided. In future we may need to verify that our ‘approved provider status’ in the portal is completed for each participant before we can begin providing a service.

Audit and Certification Policy

1. Under NDIS Quality and Safeguards standards governed by the NDIS Commission, ATS is subject to external audit certification review and to behaviour support clinician registration.
2. ATS is extremely grateful to our clients who so often provide Informed Consent to participation in external audit and in supporting our behaviour support registration. Clients often say that they are happy to help as they know this keeps our work available to them and to others who need our assistance.
3. Behaviour support clinician registration happens directly between ATS clinicians and the NDIS Commission Behaviour Support directorate. Even though our standard Consent legally allows us to share Client behaviour support information with the NDIS, to maintain even higher standards of respect for client confidentiality this process involves informing and seeking our participant’s express Consent to share information as such, while in cases where client’s information is not routinely shared with the NDIS Commission per se (see below) we de-identify clinical reports that are requested by the Commission and that need to be shared as examples of our work. Cases where clinical reports and behaviour plans are not routinely lodged with the NDIS Commission are those reports and plans without regulated restricted practices. In cases with regulated restricted practices where information is lodged to the NDIS Commission portal already, we still seek client Informed Consent and  this is very helpful where clients provide Consent given that the NDIS Commission is already in possession of information and given that these cases are usually rated highest in terms of complexity and in demonstration of our skills as senior clinicians.
4. Audit by an external agency means that ATS provides information and transparency to ensure that we comply with the standards and can continue to offer services under the NDIS. ATS will cooperate fully with the National Disability Insurance Agency and/or the NDIS Commission and their officers or auditors who undertake review activities. Where a decision by the National Disability Insurance Agency or the NDIS Commission is the subject of a merits review or complaint, or a request for information is made under the Freedom of Information Act 1982, the Provider is required to cooperate in providing any documents or other information requested in compliance with our obligations as a Registered NDIS Provider.
5. The process of external audit begins when ATS is notified by the NDIS Commission that we must apply for registration renewal to the NDIS Commission online portal. Once this step of application for registration renewal is complete, we are provided a Scope of Audit, and we can elect an external audit agency who is included on a list of agencies approved by the NDIS Commission. 
6. Participants of the NDIS are automatically included under the provisions of audit. This means that Participant’s information may be included in the quality review of the Provider’s services. As our primary aim is to uphold our client’s confidentiality and privacy obligations, ATS Pty Ltd is committed to inform participants of an approaching audit to let them know of their automatic enrolment in the audit process and of their rights to withdraw from participation in the audit. These include clients who are on our active client list within the timeframe of the audit. We let clients know that they can decline participation in the audit in regards to (A) declining to be interviewed and/or to share documentation with the auditor. For example, in the past certain clients chose to share documentation on file but not to be contacted directly by the auditor, and ostensibly clients may choose to be contacted directly but not to share documentation on file.
7. Where clients agree to participate in the audit we provide a de-identified list to the auditor which they then choose a random sample from our cohort of clients. They then contact the clients randomly selected for a brief phone conversation about the participant’s experience of our service. They may ask if we provided a copy of our Client Booklet – Disclosure Terms and Conditions. They may ask if the client felt heard and understood, and if things were explained to your satisfaction? The auditor may ask if the client had any problem or complaint with our service, and if so, how did we address the concern? They may ask for any other kind of feedback on the client’s experience of working with the clinician and our service.
8. Audit participation or electing not to participate does not change or impact on client services or NDIS participation. 
9. ATS upholds the rights of our participants to decline or to participate in the audit as such. When clients withdraw from participation in the audit, depending on the details of their decision, we are bound by the Rules to share this information with the auditor who will decline contacting the participant for an interview and/or they will not be able to view participant’s information.Independence and Informed Choice Policy

1. ATS policy is underpinned by International, National and State-based standards in relation to the human rights of people with disabilities. Article 12 of the United Nations Convention on the Rights of Persons with Disabilities is the critical driver behind supported decision-making. 
2. ATS will provide support with all of our clients and where appropriate their parents, families and carers, staff and other therapists and stakeholders to help the client and/or person responsible to make informed choices, exercise control, and maximise their independence as relating to the support provided.
3. This policy applies the National Standards for Disability Services, in particular Standard 1: Rights, “The service promotes individual rights to freedom of expression, self-determination and decision-making and actively prevents abuse, harm, neglect and violence.”
4. This policy applies the NDIS Code of Conduct, in particular, Statement 1, “In providing supports or services to people with disability, a person covered by the Code must: Act with respect for individuals rights to freedom of expression, self-determination and decision-making in accordance with applicable laws and conventions.”
5. This policy guides staff to support people to exercise their rights and have choice and control over their services. As stated under our Consent Policy, ATS views ongoing Consent and feedback from our clients as a primary means to actively engage both informed Consent and informed decision making throughout the process of assessment, therapy, behaviour support, and/or early childhood intervention.
6. ATS will respect the rights of people with disability in exercising choice and control about matters that affect them. In a relationship built on respect and positive regard our therapists build rapport and collaborate with our clients, parents, carers, and all stakeholders as esteemed experts in their situation. 
7. Our role is to help build upon the support and efforts already being made, and to help improve understanding and support planning where relevant. 
8. Collaborative work in clinical consultation with individuals and with people with disability and their circle of support promotes and ensures active choice and control in relation to our services and how our work informs and influences personal and supportive directions.
9. All people and those with disability along with those with complex diagnoses and needs have unique levels and expressions of personal capacity to make decisions, exercise choice, and provide informed consent regardless of their disability. Our role is in part to assess and understand these unique capacities and work in tandem to support appropriate planning and interventions. 
10. At the same time, all persons potentially have factors that influence and that may reduce their executive functional capacity to understand and make decisions. These factors may include genetic, physical or organic limitations; disability and/or mental health diagnoses; drug use or medications related outcomes; injury and/or cognitive decline over time… Our therapeutic role is in part to assess and understand these unique limitations and to work in tandem to support appropriate planning and interventions. 
11. Our therapists will help and support clients and their stakeholders to develop their capacity, skills, and to make as independent decisions as is possible and appropriate to the individual’s age and objective functional capacity. As such, timely information is provided in appropriate formats to support informed decision making including people’s rights and responsibilities. Choice and control is exercised in many varied ways and so includes smaller everyday decisions about daily activities and lifestyle issues through to more complex consultations that may include the co-design of therapy and service planning and review.
12. ATS therapists support individuals and people with disability in a way that is appropriate to their circumstances and cultural needs so as to maximise people’s opportunities to make choices and have control over decisions that affect their lives.
13. We recognise the roles of family, carers and advocates in representing people’s interests and promoting choice and control in the planning and delivery of therapeutic supports.
14. We uphold client’s dignity of risk in their autonomy and self-determination when making decisions, including the choice to take some risks in life. At the same time, we uphold the client’s need for duty of care that is well matched with their objectively measured functional capacity, needs, and vulnerabilities.
15. As stated in our Consent Policy, we uphold informed Consent as a voluntary agreement and willing acceptance of a proposition and following action where the person making the decision has appropriate information and capacity to make the decision free of fear or influence.
16. Relevant legislation and policy includes,
    1. Carers Recognition Act 2004 (WA)
    2. Disability Discrimination Act 1992 
    3. Disability Services Act 1993 (WA)
    4. Equal Opportunity Act 1984 (WA)
    5. Occupational Health and Safety Act 1984 (WA)
    6. Universal Declaration of Human Rights
    7. United Nations Convention on The Rights of Persons with Disabilities
    8. National Standards for Disability Services
    9. National Disability Insurance Scheme 2013: Principles
    10. National Disability Insurance Scheme Quality and Safeguarding Framework

Feedback and Complaints Management Policy

1. As a therapy agency, ATS practitioners rely on continual feedback, advice, and direction from our clients who we often view as the personal experts in their own situation. For instance, a person with Autism has the best perspective to help their therapist and assessment process and as they grow, develop capacity, and learn new skills their perspective also changes.
2. We value feedback also on the quality and direction of our work for each and every client. We seek participant’s Consent throughout the assessment and treatment processes, we check for comfort and ease, we ask how are you going during sessions, where possible we aim for our clients to feel better when they finish than when they started, and we often check in to evaluate each session.
3. At the end of a block of therapy, or when assessments are completed, we often provide a brief Client Feedback Form. Very often our clients are busy and dealing with complex issues so not everyone completes the feedback form – but we very much value the input during our work together and the form does help us to reflect on how we are going and what we can improve.
4. Another valuable form of feedback is when clients are not OK or happy with what we are doing. We most often prevent this from happening because we check with clients at every step throughout our service tasks. As our service is based on active listening and active Consent, we have a high rating for client satisfaction.
5. This being said, there may be times when a client is not happy and wishes to express their feelings and to express an informal or formal complaint to Dr Kennedy or Dr Bowers. We very much value and welcome this feedback as well because self-expression and empowerment are central to our work in therapy. 
6. Where our clients have built the skill and capacity to express a complaint we celebrate this ability and we listen carefully to see what we can do to understand, help, resolve a situation, or to say sorry for any misunderstanding.
7. ATS takes concerns and complaints seriously, and we act on them. We have guiding principles to help with this process, these are,
   1. Quality service review, 
   2. Accountability, 
   3. Minimal dispute costs, 
   4. Timely resolution,
   5. Increased personal satisfaction, 
   6. A means of ensuring that goals and outcome measures are met.
8. A person with a complaint will be valued for their contribution to service development and will be protected from any repercussions or reprisals as a result of making a complaint.
9. All feedback will be encouraged and the privacy of all documents and parties involved will be safeguarded.

Complaint Procedure

1. The Consent Form informs participants of their right to complain and the process of making a complaint.
2. Dr Dwayne Kennedy and Dr Joseph Bowers are able to act as an initial contact for the purpose of expressing a complaint.
3. The Director, Dr Joseph Bowers, is the person who is, in the normal course, responsible for handling formal complaints.
4. The Client agrees that concerns and complaints are to be expressed verbally to the person directly related to the concerns and complaints, and when necessary may be expressed in writing to the person directly related to the concern and complaint.
5. The Client agrees that records related to complaints will be maintained for at least 5 years or as required by applicable law.
6. Feedback comes in many forms and we welcome all of these.
7. People receiving service and other stakeholders can complain about anything they feel is unreasonable, unfair, or objectionable.
8. Feedback and complaints often need to be discussed directly with the client’s therapist where possible. Sometimes people need to talk to the other therapist in our practice and this is also very much welcome.
9. Most complaints can be addressed through this first conversation. The next section below describes the steps involved.
10. In human relationships providing feedback as critique is a way of expressing concerns less formally. This is often done in the midst of interactions and services where issues can be quickly resolved. People who have this skill find the process helpful and useful. This is a skill that many of our clients actively learn during their time with our service.
11. Clients, people receiving a service, family, staff or other stakeholders can contact either Dr Kennedy or Dr Bowers at any time to express concerns and to critique what they perceive we are doing or could do better.
12. Contact to express all forms of feedback can include deciding to chat at the next appointment or making a new appointment via email, text, or phone message, and setting up a time to chat which can be on phone or video.
13. If the matter is not able to be resolved at this level, or is a serious matter requiring further action then the complaint will move on to formal complaint procedure.

Formal Internal Complaints

14. To express a  formal complaint the person will discuss things with either Dr Dwayne Kennedy or Dr Joseph Bowers who will assist and support them through the process if they wish.
15. While a formal complaint is reported to the Director, as a small agency we work as a team to resolve issues quickly. 
16. If for some reason the complainant does not wish to address the complaint to the Director Dr Bowers, then their concerns should be directed to the Secretary Dr Kennedy. 
17. Complaints against the alleged actions of the Director are made to the Secretary.
18. The participant will be invited to complete the Complaint Form found at the end of this Client Booklet. ATS staff can help to complete this form.
19. The staff member discussing the complaint will explore whether the participant wishes to engage an advocate in the process. The client will be supported by ATS or others if desired in accessing an advocate as required. Where the client does not currently have an advocate or person who they may wish to use as an advocate, and they would like such support, advocacy may be accessed through Ability Incorporated Advocacy Service – 1800 657 961, or Disability Advocacy – 1300 365 085
20. Our staff will ensure that people have access to advocacy services and are supported in contacting advocacy services. We will actively encourage people to access independent advocacy services to promote:

1. Social justice in the areas of rights, access, and participation
2. The prevention of abuse, discriminatory or negligent treatment
3. An increase in wellbeing
4. Acceptance and involvement in community

21. Formal complaints can also be directed in writing, by email, or fax, to either the ‘Director Dr Bowers’ or ‘Secretary Dr Kennedy’. 
22. The staff who is the recipient of a formal complaint will acknowledge receipt of the complaint either in writing or by phone, inviting discussion to clarify issues and to help to resolve the matter. If the issues are not resolved at this stage, the staff member will offer helpful information on the steps below and the timeframe for resolution.
23. When a staff member is the subject of a complaint they are to be informed as soon as possible and asked for their response. The response is shared with the person with the complaint via the staff member they had been in contact with to resolve the issues. If issues are resolved at this stage, no further action is necessary.
24. Where issues are unresolved, ATS via the Director Dr Bowers and Secretary Dr Kennedy will invite to a meeting the person with the complaint and their support person and/or an advocate if they have an advocate where the content of the complaint will be discussed and documented, and possible solutions and courses of action discussed and chosen.
25. A record of the meeting, the resolutions if achieved, and time frame should be completed by the Director or Secretary and signed by all involved parties. The person with the complaint will be given a copy of this record.
26. If parties are unable to agree to a resolution, then the Director should prescribe a time-framed action plan aimed at resolving the complaint, with all parties being informed of the action plan. Such an action plan will include a review date to ensure resolution of the complaint has been achieved.
27. If by the review date, the parties are unable to agree to a resolution then external procedures may be followed.

External Complaint Procedure

28. Should a complaint continue to be unresolved the Director will offer external options for resolution. These may include, but are not limited to,
    1. An independent review, e.g. A review panel composed of people outside ATS with knowledge of the NDIS Code of Conduct, the Disability Services Act and Standards,
    2. The NSW Ombudsman,
    3. A mediation session arranged with a service such as the Community Justice Centre,
    4. Below are contact details of various services that may be available to assist,

NSW Ombudsman

Level 24, 580 George St SYDNEY NSW 2000
Phone: 02 9286 1000
1800 451 524 Toll free (outside Sydney metro)
TTY: 02 9264 8050
TIS: 131 450
Fax: 02 9283 2911

Web: https://Director.ombo.nsw.gov.au/ 

Email: nswombo@ombo.nsw.gov.au

NSW Anti-Discrimination Board

Stockland House
Level 4, 175-183 Castlereagh St
PO Box A2122 SYDNEY SOUTH NSW 1235
Phone: (02) 9268 5555
Freecall: 1800 670 812 (within NSW)
TTY: (02) 9268 5522
Fax: (02) 9268 5500

Email: complaintsadb@agd.nsw.gov.au 

Web: Director.lawlink.nsw.gov.au/adb

People with Disability Australia Incorporated

For people with a disability who wish to make a complaint about their rights being infringed.

52 Pitt St REDFERN NSW 2016
Phone: (02) 93703100
Freecall: 1800 422 015
TTY: (02) 9318 2138
TTY: 1800 422 016 freecall
Fax: (02) 9318 1372
Web: Director.pwd.org.au 

Email: pwd@pwd.org.au

Human Rights and Equal Opportunity Commission

GPO Box 5218, SYDNEY NSW 2001
Phone: (02) 9284 9600
Complaints Infoline: 1300 656 419
General enquiries and publications: 1300 369 711
TTY: 1800 620 241
Fax: (02) 9284 9611
Web: Director.hreoc.gov.au 

Intellectual Disability Rights Service (IDRS)

A community legal centre specialising in legal and rights issues for people with a disability.

2C/199 Regent St REDFERN NSW 2016
Phone: (02) 9318 0144
Freecall: 1800 666 611
Fax: (02) 9318 2887

Email: info@idr.org.au 

Web: Director.idrs.org.au 

Culture and Diversity Policy

1. We uphold the UN Convention on the Rights of Persons with Disabilities (CRPD), Article 30 – Participation in cultural life, recreation, leisure and sport, to “recognize the right of persons with disabilities to take part on an equal basis with others in cultural life… [and to] Enjoy access to cultural materials in accessible formats; Enjoy access to television programmes, films, theatre and other cultural activities, in accessible formats; Enjoy access to places for cultural performances or services, such as theatres, museums, cinemas, libraries and tourism services, and, as far as possible, enjoy access to monuments and sites of national cultural importance.”
2. In concert with the UN Convention, we support all of our clients right “to develop and utilize their creative, artistic and intellectual potential, not only for their own benefit, but also for the enrichment of society.; on an equal basis with others, to recognition and support of their specific cultural and linguistic identity, including sign languages and deaf culture; to participate on an equal basis with others in recreational, leisure and sporting activities…”
3. As specialists in cultural methods in psychotherapy we respect diversity in identity, culture, and language as well as in gender expression or non-binary identities. We uphold personal choice and self-expression in sexuality and identity among straight, gay, lesbian, bisexual, transgender, intersex, and in the Indigenous expressions of Sister Girl, and Two Spirit communities.
4. Further, as specialists in human developmental progress and sexuality and gendered or non-binary identities we acknowledge that all people with disabilities have an equal right to self-expression and to equal participation in their unique personal experiences and expressions of intimacy and sexuality.
5. Wherever possible we uphold and seek to support individual’s personal freedoms to self-expression within their private domain, and to the free exercise of their human rights to intimacy as such within consensual adult relationships. 
6. At the same time, we acknowledge that intellectual and cognitive capacity as well as executive functional capacity varies from person to person, and that where capacity is limited due to profound disabilities that the individual’s expression of sexuality and intimacy may be limited, but nonetheless, is due the empathy, respect, and personal space warranted under the definition of privacy and dignity and under the law and conventions of Australia.
7. We uphold and respect the right of gay and lesbian people to marry in Australia. This right extends to gay and lesbian people who have disabilities and/or mental health diagnoses.
8. Likewise, we uphold the individual’s rights and freedoms to live within their cultural and familial environments which in Australia extends to religious freedom under the Constitution that states, “The Commonwealth shall not make any law for establishing any religion, or for imposing any religious observance, or for prohibiting the free exercise of any religion, and no religious test shall be required as a qualification for any office or public trust under the Commonwealth.”
9. We define “spirituality” as how a person makes their sense of meaning. As such, our therapists seek to provide an open space for self-exploration and discovery. Human growth and development in spirituality, in this light, is an important component of human identity and well being. Our sense of purpose and identity informs mental health and human relationships. In everyday practice our practitioners seek to respect and uphold every individual client’s rights and self-expression in their unique exercise of their innate capacity to make meaning from their everyday lives.

Advocacy and Empowerment Policy

1. Advocacy comes in many forms. Informal advocacy exists where one person seeks to support another person. Family relationships have inherent within them an advocacy role, in as much as we seek to support each other in our lives. 
2. Our therapists take on an advocacy role to understand in-depth the needs and capacities of our client. This role is formal as it is defined by our therapist qualifications and provision of services toward helping the participant.
3. Formal advocacy has grown and changed over the past couple of decades to now include agencies whose role is to promote advocate roles for people with disabilities. People in contact with the mental health and justice systems may have similar kinds of advocates available from time to time. 
4. Empowerment is the process of helping people to find their voice and to speak for themselves where possible, and to address their own needs in various contexts. We see advocacy and empowerment as linked processes that build an individual’s capacity to manage from day to day and to advocate for their own personal and social needs. Here again, where a person’s disability limits their capacity to advocate for their own needs, an advocacy service can be quite valuable and important.
5. As a therapy provider our clients have not traditionally brought along nor sought independent advocacy while working with us, however this may change given that the NDIS now funds advocacy providers.
6. The role of advocates is varied and can conceivably enhance working with our service when the advocate on behalf of the individual can convey or share knowledge and detailed understanding of contexts and needs with the therapist or specialist. 
7. At the same time, our approach and method of working is to align closely with the participant’s interests and needs. In effect, we often provide advocacy in our therapist and behavioural support roles in as much as we express the best intentions of the participant to other providers while building the case to support their needs and goals.
8. We encourage participants to work with advocacy services in regards to their needs with NDIS providers and where there are any conflicts or debates about their needs and goals. We also encourage advocacy wherever clients need support in dealing with a potential conflict or misunderstanding with our service. Please see the Feedback and Complaints Policy for more details.
9. In certain cases we have recommended to family or carers to enlist an independent advocate to help with an external perspective, in case review, and to ensure human rights are upheld.
10. Under the NDIS advocacy has become a funded service. Participants can find a list of providers at the Department of Social Services website, https://www.dss.gov.au/disability-and-carers-programs-services-for-people-with-disability-national-disability-advocacy-program-ndap-operational-guidelines/list-of-agencies-funded-under-the-national-disability-advocacy-program.

Violence, Abuse, Neglect, Exploitation and Discrimination Policy 

1. ATS recognises the right of all participants to feel safe and to live in an environment that provides protection from assault, neglect, exploitation, discrimination or any other form of abuse. People with disabilities, children and young people are some of the most vulnerable groups in our society. It is essential that ATS identify, consult and respond to instances where persons with disabilities, children or young persons are at risk of significant harm.
2. Common reasons for people with disabilities, children and young people to be at risk of significant harm include: Domestic and family violence; Physical, sexual, psychological and emotional abuse; Neglect and/or seclusion. The impact of violence, abuse and neglect can impact all domains of a person’s development. People who experience violence, abuse and neglect are more likely to have problems with learning and development, physical and mental health, behaviour, and social skills.
3. Terms:
   1. Violence is the threat or use of physical force that results in injury, psychological harm or death.
   2. Abuse is the violation of a person’s human rights, through an action of another person. Abuse can be physical, sexual, psychological, financial, chemical, or via withhold essential support by denial of access or legal remedy.
   3. Neglect is the failure to provide the necessary care, aid or guidance to someone who needs it. Neglect can be physical, passive, wilful deprivation, emotional, or failure to act with the appropriate duty of care.
   4. Exploitation is the action or fact of treating someone unfairly in order to benefit from their work and includes labour exploitation, sexual exploitation, or domestic servitude.
   5. Discrimination is the unjust or prejudicial treatment of different categories of people, especially on the grounds of race, age, sex, sexual or gender identity, religion or belief, or ability.
   6. In this context, we note that Restrictive Practices are defined as any intervention that is used to restrict the rights or freedom of movement of a person with a disability. Restrictive practices include, but are not limited to chemical restraint, mechanical restraint, environmental restraint, physical restraint, and seclusion.
4. ATS is committed to safeguarding all participants, promoting and maintaining a safe environment for all people that is free from violence, abuse, neglect, exploitation and discrimination; and to the elimination of restrictive practices; and where necessary under a specialist written behaviour support plan to the reduction of the use of restrictive practices.
5. ATS has zero tolerance to any behaviours or practices that present as violence, abuse, neglect, exploitation and discrimination. All staff are responsible for implementing all procedures and work practices in a manner that upholds each participant’s human and legal rights. Any incidences of violence, abuse, neglect, exploitation and discrimination are not acceptable and will be dealt with appropriately. Where it is suspected that a criminal offence has occurred, the matter will be immediately reported to the police. ATS will continue to review the services and supports provided looking for opportunities to improve them and to strengthen our safeguarding process.
6. To prevent incidents of violence, abuse, neglect, exploitation and discrimination of participants ATS will,
   1. Provide participants, and their support networks, with information about their rights, the use of advocates, and referral to advocacy service; 
   2. Provide participants, and their support networks, with information on what constitutes violence, abuse, neglect, exploitation and discrimination as per this policy;
   3. Undertake security screening and checks of staff and contractors prior to commencing work;
   4. Provide staff and contractors induction and training on what constitutes violence, abuse, neglect, exploitation and discrimination as per this policy, and their role in the prevention, identification and reporting of incidents;
   5. Provide staff with training regarding behaviour support, restrictive practices and that the use of any unauthorised restrictive practices is an abuse of a person’s rights.
7. To identify and report allegations and incidents of violence, abuse, neglect, exploitation and discrimination of participants ATS will,
   1. Act on all allegations and incidents of violence, abuse, neglect, exploitation and discrimination by supporting and assisting the affected participant;
   2. Identify, respond to, and report all allegations of violence, abuse, neglect, exploitation and discrimination;
   3. Provide participants, and their support network, with information about how they may raise issues related to violence, abuse, neglect, exploitation and discrimination, report allegations of incidents and the way they will be supported during the reporting process and in the future;
   4. Promote a culture where participants, and their support network know that it is “ok to complain” and any issues will be received respectfully and investigated appropriately;
   5. Ensure that the person who has experienced violence, abuse, neglect, exploitation and discrimination have the opportunity to be safe, receive medical treatment as required and that any immediate source of harm is removed;
   6. Support participants in accordance with their preferences and to refer them to appropriate therapeutic and/or other services for help and assistance.
8. To investigate allegations and incidents of violence, abuse, neglect, exploitation and discrimination of participants ATS will,
   1. Follow all directives of police and statutory bodies in relation to internal investigations and timing of those investigations  
   2. Where appropriate provide information on the progress of the investigation to participants and their support network;
   3. Where appropriate provide information regarding the outcome of the investigation, individual and systemic recommendations made as a result of the investigation, actions that will be undertaken and timeframes for their completion.

Incident Management Policy

1. As a Telehealth therapy consultation agency, ATS does not see clients in person. This reduces the need for incident management procedures. 
2. Where incidents occur these are documented in the Risk Register under the appropriate category.
3. The Director will ensure that ATS staff have access to debriefing and counselling and support opportunities and services.
4. ATS therapists during consultations with clients may become aware of incidents happening in real time, or at other times, and will provide appropriate advice and suggestions for the care and safety of those involved. These suggestions may include,
   1. To implement and manage any significant incidents with the primary aim to maintain the safety of all people involved and to protect property.
   2. To review the individual’s behaviour support plan and any programs relating to the person they support.
   3. To seek further training in critical incident response and protective behaviours, where possible and applicable.

Work Health and Safety Policy

1. Ability Therapy Specialists Pty Ltd (ATS)
   1. Accepts that the workplace health and safety of all people in the workplace is of the utmost importance. 
   2. In order to promote and maintain WHS the service will comply with all requirements contained within the WHS Regulation 2011, and ensure that the workplace is safe and risks are managed. 
2. This policy,
   1.  Shows the commitment of management and workers to health and safety.
   2. Aims to remove or reduce the risks to the health, safety and welfare of all workers, contractors and visitors, and anyone else who may be affected by our business operations.
   3. Aims to ensure all work activities are done safely.
3. ATS aims to:
   1. Protect and promote the health, safety and welfare of all people in the workplace including staff, committee members, people receiving support, visitors, students, and volunteers.
   2. Provide a fulfilling work environment for staff and committee members.
   3. Provide a secure home environment for people receiving support.
   4. Ensure stakeholders have an opportunity to raise and address WHS issues with the Service.
   5. Uphold the principles of occupational rehabilitation. 
4. ATS expects that others will,
   1. Take reasonable care of health and safety of themselves and others in the workplace.
   2. Cooperate with all stakeholders in efforts to comply with WHS and Workcover Authority requirements.
   3. Advise the Director immediately of any incident, injury, or unsafe workplace condition, practice or behaviour.
   4. Not interfere with or misuse equipment or materials provided in the workplace.
   5. Not obstruct attempts to prevent risk to the health and safety of people in the workplace, or efforts to give first aid by those qualified to do so.
   6. Not refuse a reasonable request to assist in giving aid or preventing risk to health and safety.
   7. Work with management to ensure a positive outcome from rehabilitation.
5. The Director of ATS is responsible for providing and maintaining,
   1. A safe working environment.
   2. Safe systems of work.
   3. Facilities for the welfare of all workers.
   4. Any information, instruction, training and supervision needed to make sure that all workers are safe from injury and risks to their health.
   5. Safe client visitation policies and practice guidelines.
6. Senior Colleagues and Workers of ATS are responsible for,
   1. Ensuring their own personal health and safety, and that of others in the workplace.
   2. Complying with any reasonable directions (such as safe work procedures, wearing personal protective equipment) given by management for health and safety.
   3. Following any policies or practice guidelines that management provide from time to time for safe work practices.
   4. Maintaining a WHS Journal that records relevant procedures, including,
      1. Staff induction and ongoing training,
      2. Checks on fire equipment, 
      3. Fire safety procedural updates, 
      4. Safe client visiting practices,
      5. Periodic staff and management WHS discussions at monthly or bi-monthly meetings.
7. We expect visitors and contractors to,
   1. Act in a manner that is conducive to service delivery and safety.
   2. Comply with safety procedures and instructions of staff, including fire safety as and when necessary.
   3. Leave the premises if and when necessary for reasons of safety.
8. ATS will ensure that systems are established and maintained to promote safety in all workplaces serviced by the organization.
9. ATS will comply with all obligations under relevant legislation and acceptable industry standards.
10. For Infectious Disease Control, the Director will ensure that all staff are aware of and put into practice Infectious Disease Management as follows.
    1. ATS will provide equipment as required and appropriate within service resources to support the practice of Infection Control Procedures.
    2. ATS will reimburse support staff for Hepatitis B, Fluvax and Boostrix immunisation.
    3. All service cleaning equipment will be colour coded to promote safe cleaning practices and avoid contamination.
    4. All cleaning products and chemicals i.e. ‘Hazardous Substances’ will be secured in a locked area with the contents of the locked area clearly displayed on the access point to that area. A copy of this document to be maintained in the WHS Folder.
    5. See the Covid-19 and Pandemic Policy.
11. For Hazardous Substances Control,
    1. The site WHS officer will ensure that a Minimum Safety Data Sheet on each hazardous substance is available for staff to read in the area where the hazardous substance is stored. 
    2. A copy of all MSDS to be maintained in the WHS Folder.
    3. Risk Assessments will be completed for each hazardous substance held and will be displayed in the area where hazardous substances are held.
    4. All staff will ensure that they are aware of and comply with safety precautions for each hazardous substance.
    5. Equipment will be provided by the service to ensure that staff are able to comply with safety precautions.
    6. No hazardous substances are to be decanted into other containers without specific purpose from the Director. 
12. For WHS Staff Shared Duties,
    1. WHS Officer duties will be delegated by the Director.
    2. Each service staff meeting will address the issue of WHS, with WHS issues included as an agenda item for the meeting.
    3. The service will conduct 6 monthly WHS inspections using the WHS checklist as attached.
    4. Completed WHS checklists and enclosed recommendations will be forwarded to the Company Meeting for discussion and resolution within suitable time frames.
13. For Notification of Risks,
    1. All staff must take reasonable steps to prevent risk to health and safety at work to themselves and/or others by notifying management or the WHS officer of any risks.
    2. Notification of risks identified from time to time to be done in writing by the employee in the Risk Register.
    3. Management will consider the matter and respond in a timely fashion in accordance with WHS Regulation 2011.
    4. All Work Cover notices will be prominently displayed in the workplace.
    5. Any injuries received at work will be documented on Incident Report forms as soon as is practical, noted in the Risk Register, and forwarded to the Director.
    6. All completed Staff Incident Reports will be filed by the Director in the WHS Incident Register.
    7. When workplace injury results in a claim for Worker’s Compensation, ATS will process the claim as quickly as possible.
14. For Injury and Liability at Work,
    1. ATS will support staff in returning to work as soon as is possible dependent on medical recommendation. Where service liability is established, ATS will support staff in accessing a range of medically recommended interventions.
    2. The Director will consult with the injured staff member and GIO (the insurer) in accessing and developing a program of rehabilitation where reasonable and practical. Referral to a rehabilitation planner can be made only with approval of involved parties.
    3. A rehabilitation planner must be accredited by Work Cover, and should be agreed upon by ATS, the staff member, and GIO (the insurer)
    4. The rehabilitation plan should include the objectives of the plan, the services to be provided, the duration of the provision of services, and the cost of the services.
    5. The rehabilitation plan should identify the current medical status and prognosis for the staff member, their functional ability and the details of their employment and duties.
    6. ATS is limited in its opportunity to offer alternative duties for staff.
    7. Where service liability is established, the cost of the rehabilitation plan will be met by ATS. In the case where service liability is not established, rehabilitation planning can continue at the staff member’s cost. 
15. For Lifting/Manual Handling,
    1. ATS staff are not required to perform any heavy lifting.
    2. In the case where people receiving support have fallen, staff will provide support for the person receiving support on the ground until the person receiving support is able to get up themselves or is otherwise moved. e.g. ambulance.

Risk Management Policy

1. As a clinical consultative agency, ATS associates risk management with client’s vulnerability assessments that comprise a layer of our overall assessment process. 
2. Our standardised functional behavioural assessment provides a context for client risk assessment. Counselling Psychotherapy and behaviour support services generally have a strong framework for building clinical skills in risk assessment and mitigation planning.
3. Dignity of risk recognises that people with a disability have a right to make their own decisions and are entitled to take reasonable risks in their everyday life. At the same time, services are required, as far as practicable, to ensure that staff working with clients are safe, and not exposed to health and safety risks (Occupational Health and Safety Act NSW 2000).
4. The Client Risk Policy operates within a risk management framework that provides staff with a better understanding of the need to manage risks and a structured approach to prevent, minimise, or eliminate injuries or incidents to clients, themselves and others before they occur.
5. Client risk assessment and management are fundamental components of the individual planning process and the allied health care planning process.
6. All clients receiving support from ATS clinicians are assessed for risks to their lifestyle, health, safety and wellbeing and this is part of the core business of clinical assessment and treatment planning. 
7. Client risks are further identified within a standardised Client Risk Assessment that is, where appropriate and possible under funding restrictions, incorporated into clinical reports and planning documents and with recommendations arising from consultation processes.
8. The Client Risk Assessment is conducted internally by ATS staff for each client during our consultative process when enough information is available to answer the range of questions. These risk assessments are documented in our client management system, and can be shared with participants upon request or used by carers, family, or providers to assist with documented evidence of risks and needs.
9. Information and documentation about risk assessment in relation to individual clients is subject to Consent and Confidentiality and where possible is made available to those persons who need to know about risk assessments because they are involved in supporting the client, and provided in a language or format that suits their communication needs.
10. Personal client information is protected in compliance with the Privacy and Personal Information Protection Act, 1998, and Health Records and Information Privacy Act, 2002.
11. Normal clinical procedural processes in client assessment includes
    1. Identifying risks and issues for and with the client.
    2. Assessing the extent and expression of risk.
    3. Identifying the types of risk i.e. whether physical, health, mental, emotional, social, and in relation to self-harm, other-harm, property damage, and risk to public safety.
    4. Providing a risk management report in the context of a formal risk assessment, brief clinical summary, clinical report, behaviour support plan, or mental health report as the circumstances and case requires and directed to the appropriate people as the client requests.
    5. Where clinical consultative services continue from this point, we would normally continue in therapy, or provide training or capacity building. All identified risks are managed day to day by the client’s family or providers. Our role is limited to providing clinical assessments, and we do not provide supervision or ongoing oversight of risk management.
12. Risks to the health and safety of clients and ATS staff are managed under day to day operational procedures associated with our work health and safety policy, fire safety, and first aid policy. Under pandemic circumstances the Covid-19 and Pandemic Policy provides guidance. 
13. ATS uses various Risk tools including a WHS Checklist, Hazard Reporting form, Fire Drill form, and a standardised Risk Register.
14. The ATS Risk Register incorporates the relevant data for a wide range of risk areas including Incidents, Feedback, Evaluation, Complaints, WHS, Hazard, First Aid, Fire Safety, Quality Review, Conflict of Interest, and Home Visits.

Fire Safety Policy

Staff will conduct fire drills periodically and no less than six monthly.

1. Fire drills will be designed to create a range of scenarios ensuring that staff and people receiving support on site (if applicable) are experienced in evacuating through various and appropriate building exits.
2. Details of fire drill procedures and person receiving support actions are recorded on the Fire Drill Report as attached.
3. All staff are trained in fire equipment use.
4. Emergency contact numbers are displayed prominently in the building entry area.
5. Emergency procedures as follows are prominently displayed in the building entry area.
6. Fire drills and inspections are summarized and recorded on the Fire Training/Inspection/Drill Record as attached.

Life Threatening Emergency FIRE POLICE AMBULANCE CALL 000 (24 HOURS) ASK THE OPERATOR FOR THE SERVICE YOU NEED WAIT TO BE CONNECTED THIS IS A FREE CALL  WHAT TO DO EVACUATE GET EVERYONE OUT PICK UP YOUR MOBILE PHONE AND TAKE WITH YOU ASSEMBLE GO TO ASSEMBLY PLACE AT GATE CHECK THAT EVERYONE IS ACCOUNTED FOR RAISE ALARM PHONE 000 AND SAY “WE HAVE A FIRE AT 39 NORTHCOTT STREET, ARMIDALE” REMAIN TOGETHER AND ENSURE THAT EVERYONE STAYS TOGETHER  IN CASE OF SMALL FIRES TRY TO EXTINGUISH FIRE WITHOUT RISK TO YOURSELF

First Aid Policy

1. ATS Pty Ltd Staff are informed of First Aid Policy and Protocol during WHS reviews.
2. Staff are responsible to keep their Provide First Aid Certificate up to date and ATS Pty Ltd will provide the cost of training.
3. ATS Pty Ltd is a smoke-free workplace. Smoking is not permitted on the premises.
4. ATS  Pty Ltd is a No Perfume and No Nuts Environment due to the fact that our clientele and staff may have allergies that can be life-threatening.
5. ATS  Pty Ltd provides First Aid Kits in our office. The Large First Aid Kit is in the Main Office. A secondary First Aid Kit is provided in the other building.
6. First Aid Kits will contain minimum equipment as required under the WHS regulation, and the Large First Aid Kit includes an Inventory List.
7. A First Aid Review will be conducted by our WHS Officer during WHS reviews.
8. In a First Aid Incident the Person Responsible for Administering the First Aid is the Staff Person attending the staff member, client or participant. If more than one staff member is present, the Primary Therapist is responsible.
9. A First Aid Incident Report Form will be completed by the Staff Person Responsible in the situation, and entered into the Risk Register. First Aid Incidents reporting will include completing the Form and a Debrief with another member of staff. Debrief will be noted and signed by both staff members.
10. In all cases the Emergency Response Number is 000.
11. Having emergency phone access is the responsibility of Staff. Staff must keep their mobile phone with them during consultations and while at work.
12. ATS Pty Ltd keeps a landline active in the main office, used as a fax machine but ready to use for any outgoing and emergency calls.

Covid-19 and Pandemic Safety Policy

This safety policy provides a NSW Health guided safety plan that is based on the NSW Government Covid-19 Safety Plan for General Purposes, and applied within the NDIS and Disability Services context. ATS Pty Ltd and employees and clients must follow the current NSW Health and/or Public Health Orders and manage risks to staff and other people in accordance with WHS laws.

Business Details

Name: Ability Therapy Specialists Pty Ltd

Plan Completed by: Dr Joseph R Bowers, Director

Approved by: Dr Dwayne A Kennedy, Secretary

Wellbeing of Staff and Clients

Physical Distancing and Cleaning

1. Staff and clients who are unwell, or deemed to be unwell, as in showing any signs of cough or cold or other symptoms, will self-isolate or be advised to self-isolate from in-person meetings.
2. From 16 March 2020, ATS elected to self-isolate in quarantine and from that date 100% of our work remained via telehealth online.
3. From 1 December 2021, ATS elects to remain a telehealth provider and will not normally elect to see people in person. During 2023, ATS reaffirmed the decision to remain a telehealth provider.
4. During 2020, ATS published a book on Telehealth clinical services, and began to routinely distribute this to all clients and to all new and prospective clients. 
5. ATS further published articles on our website to assist clients on issues associated with Covid-19 issues and telehealth services which at the time was a new area for disability behaviour support and therapy provision.
6. Where local clients need to visit our site to sign paperwork or exchange information, and where receipt of paperwork or packages, staff protocol is to:
   1. Arrange to meet at the gate of the property. 
   2. Clarify with the client before meeting the procedure and protocol for masks.
   3. Our procedure and protocol is to wear masks as mandated by NSW Health.
   4. Where the visitor to the gate is not wearing a mask, we can offer them a mask. 
   5. During 2023, as mask wearing is no longer mandatory ATS staff may elect to wear masks but we cannot ask or expect others to comply.
   6. People will generally maintain at least 1.5 metres apart.
   7. Staff will wear protective gloves if deemed necessary.
   8. Staff will wear a protective mask if deemed necessary.
   9. Have paperwork ready, with a clipboard to make it easier to sign.
   10. Where possible, set up a folding table for clients to sign documents and to provide a further physical barrier for distancing.
   11. Provide the person with a sanitised pen they can keep to help further reduce risk of transmission.
   12. Sanitize all materials and equipment and return them to their holding place if relevant prior to removal of masks and gloves.

Conditions of Entry

7. Clients will not enter the premises and will remain at the gate.
8. Calls to our mobiles suffice to inform us of visitors or otherwise.
9. Where entry is permitted, a staff member meets people at the gate, and will address the protocols from there.

Information Updates

10. Information on Covid-19 that comes through via email alerts from NDIS, NSW Health, is shared between ATS staff.
11. ATS staff work to keep up to date on developments nationally and regionally via media sources.

Staff and Covid-19 Testing

12. When/if staff are showing any signs of cold, flu, body aches, headaches, etc., they will submit to Covid-19 testing.
13. All staff will be vaccinated against Covid-19, and following the guidelines from NDIS Commission from 1 November 2021 vaccination is mandatory as an employee of ATS Pty Ltd.
14. Staff must lodge a vaccination certificate to the Director who will keep certificates in the staff member’s employee folder.
15. During 2023, mandatory vaccination is no longer required but as we move into winter flu season, flu and Covid-19 vaccination is highly recommended.

Staff Flexi-work and Leave

16. ATS encourages working from home, flexible hours, and provides generous leave entitlements to staff if/when they are feeling sick or are required to self-isolate.

Hygiene and Cleaning

Staff Work Spaces and Cleaning

17. Staff workstations are maintained separately in separate rooms.
18. When showing signs of symptoms or risk of infection or when self-isolating after Covid-19 testing, where necessary movement will be restricted to respective rooms/work stations.
19. Following item 15 above, staff who work in the sunroom office space will use the Studio kitchenette only and/or set up practical provisions in the office itself.
20. Between uses of the workstation cleaning with disinfectant/detergent will be maintained.
21. ATS Pty Ltd will remain at current staffing levels and will not engage other persons in the workspaces.
22. Where necessary, trades people may visit the premises by agreed protocols and with ‘contactless’ procedures.

Cleaning Equipment Provisions

23. ATS provides gloves, masks, sanitizers, and cleaning materials including disinfectant and wipes for daily staff use.
24. Hand washing with soap and water for 20 sections is to be encouraged and maintained.

Record Keeping

Storage of Contact Information

25. During 2023, contact tracing is no longer engaged by public authorities. 
26. ATS routinely keeps contact information for anyone who visits the premises as we receive people by prearrangement or appointment only. 

Spirit of Cooperation

27. Keeping people as safe as possible requires cooperation and consideration of different needs, as well as sharing information when possible.
28. Employees will cooperate with NSW Health if/when contacted in relation to a positive case of Covid-19 at the workplace, and staff will notify Safework NSW on 13 10 50.

Emergency and Disaster Management Policy

1. ATS is a small telehealth specialist clinical consultative service, and as such, our emergency and disaster management policy reflects the limited size and focus of our operation. 
2. ATS emergency and disaster management includes planning to ensure that possible risks to the health, safety and wellbeing of participants that may arise in an emergency or disaster are considered and mitigated.
3. ATS emergency and disaster management ensures that we are transparent regarding risks to the continuity of our services, and that we will provide referral advice to participants in the event of service failure or closure. Please refer to the Continuity of Service Policy.
4. As ATS does not provide direct in-person support in day-to-day living, the emergency and disaster management implications for our service are limited in terms of the critical impacts to the health, safety and wellbeing of participants in an emergency or disaster.
5. ATS addresses the following quality measures to enable continuity of supports that are critical to the safety, health and wellbeing of each participant before, during and after an emergency or disaster.
   1. Preparing for, and responding to, the emergency or disaster;
   2. Making changes to participant supports or to delay the provision of supports within reasonable timeframes, and where possible;
   3. Adapting, and rapidly responding to changes to participant supports and to other interruptions;
   4. Communicating changes to participant support to families, to workers and to participants and their support networks as relevant to the case.
6. ATS has developed this emergency and disaster management plan during consultations with participants over the Covid-19 period, and in the context of floods and bushfires, as part of the standard practice of consultation to help us understand the nature of participant experiences to emergencies and disasters and the ways that support systems have managed these concerns.
7. ATS has maintained that our service, emphasis, and capacity is NOT suited to emergency or disaster intervention. 
8. ATS has placed our emphasis on focused clinical consultation as our primary way to respond to emergency or disaster situations, usually by assisting people after events to process the social and emotional impacts and to help with behavioural support methods and planning. In our experience, these contexts include providing therapeutic assessment and treatment, including with sensitivity to Post Traumatic Recovery and Healing while advising parties on ways to stabilise and maintain therapeutic environments.
9. The consultative and therapeutic mechanisms that ATS has employed apply to the full range of particular kinds of emergency or disaster as these methods rely on well established therapeutic principles and evidenced based practices.
10. As part of our standard service provision in clinical consultation, ATS engages in periodic review of this policy and consults with participants and their support networks to enable us to respond to the changing nature of emergency or disaster, and this includes the range of other policies in this booklet including the Covid-19 and Pandemic Response Policy. 
11. Our client cohort feels that ATS needs to keep our approach simple and entirely focused on high quality clinical support, as the value of this service far outweighs the risks of taking on wider emergency and disaster response services which are outside of our capacity.
12. ATS communicates our focus in clinical consultative work only and our limited scope to address emergency and disaster management to participants and their support networks.
13. ATS therapists are trained in the implementation of our therapeutic range of services and are familiar with our emphasis in addressing emergency and disaster management as a telehealth clinical agency.

Continuity of Service Policy

1. To keep our focus on high quality participant services and support, ATS Pty Ltd has chosen to remain a small operation with two full time staff who each take on the delegations of company management and providing clinical services.
2. The Director and Secretary roles are taken by Dr Bowers and Dr Kennedy, and each staff member is also a highly experienced and qualified senior clinician. 
3. Our staff answer the phones personally, and we provide direct service and problem solving to each participant. 
4. In practice, our staff limit the number of clients that we take on so that our capacity to provide this high quality service is maintained. 
5. For ATS, continuity of service is more than addressing the risks of emergency and disaster management. Continuity is about maintaining quality services. This model that we have based on sustainability principles has worked quite well and effectively over time, reflected by extremely high and consistent client satisfaction ratings.
6. In the event of an emergency or disaster happening to our service directly to our staff and/or to our service offices, for example, where a staff role is compromised due to ill health or accident, all business and clinical authority passes to the other relevant staff person.
7. Where both roles are compromised due to disaster, emergency, critical ill health or accident, this emergency clause activates to allow a third party to assist our operations, for example, per financial and regulatory requirements our accountancy firm steps in to assist. 
8. Where both roles are compromised due to disaster, emergency, critical ill health or accident, this emergency clause activates to allow our External Clinical Supervisor or our Accountancy Firm to send notifications to active clients to let them know about the interruption to services and to advise regarding remediation plans and return to work as these come to light.
9. In the event of staff retirement and/or where ATS Pty Ltd elects to close, merge with another provider, or sell the company, sufficient notice will be given to existing participants. This issue is not taken lightly, given that many of our clients rely on our service over extended time frames. 
10. In our discussions with clients about the possibilities regarding service changes that can be mitigated, the majority inform us that they would want to continue with us after an emergency situation has passed. Others who seek a brief intervention or report are in some cases willing to find another practitioner to assist, and they are happy with a referral, although in our experience the choice of another practitioner is highly personal and unlikely to be greatly influenced by a referral suggestion.
11. In regard to continuity requirements under the NDIS, as a senior specialist therapy agency our work is in-depth and personal tailored to each client and is not able to be replicated per se. Nor would our clients seek or want anyone else per se to step into the clinical role, which in most cases would not be appropriate. There is a certain level of natural limitations and uniqueness involved in a highly personalised therapeutic relationship. 
12. This being said, the therapy and behaviour support space as well as the number of telehealth providers has greatly expanded in the past during the Covid-19 pandemic and afterwards, so there are now more choices for telehealth provision. 
13. Regardless, we understand that it is not easy nor simple for people to find a new therapy provider as they need to inquire, often wait for months under waiting lists, and then begin with a new therapist to see if they can work together. In light of these eventualities, we take the situation very seriously and seek to provide as much notice and support as possible to address major changes to our service or our company when these circumstances come to light. Our clients appear to understand that certain changes cannot be avoided and that eventually our company may face major changes or closure to our operations.

Quality Management Policy

1. ATS is committed to the provision of high quality services which are strengthened by a continuous improvement approach. 
2. ATS is committed to meeting legislative and regulatory requirements as well as our own quality objectives through implementation of our Quality Management Policy.
3. Our Quality and Safeguarding Framework that is comprised of our entire policy and procedural guidelines is aligned to:
   1. The National Disability Insurance Scheme Provider Registration and Practice Standards Rules.
   2. The National Disability Insurance Scheme Quality Indicators.
   3. Local, state based and national health regulations.
   4. Human rights principles.
   5. Our Quality Management Policy. 
4. ATS is a Registered Provider with the NDIS Quality and Safeguards Commission and is certified as a NDIS provider on the basis of our compliance with the practice standards and rules. 
5. ATS has robust systems in place to meet quality and safeguarding requirements. These include,
   1. Meeting ongoing internal quality audit schedules throughout the cycle.
   2. Maintaining a Continuous Improvement Register.
   3. Regular external quality audits conducted by an independent auditor against the NDIS Practice Standards. See our NDIS Audit and Review Policy. 
   4. Ongoing review of our policies and practices.
   5. Listening to our clients who we work with quite closely and who often provide us with high quality feedback and suggestions on how we can improve, change, or redirect our approach.
6. Our policies and procedures reflect our commitment to delivering high quality support services and ensuring the safety and wellbeing of clients and staff.
7. Standard measures of quality indicators include,
   1. Client feedback and suggestions.
   2. Stakeholder feedback and suggestions.
   3. Evaluation forms completed.
   4. Practitioner self-review of written reports and plans using our quality management evaluation tool.
   5. Practitioner peer-review of written reports and plans using our quality management evaluation tool.
   6. External clinical supervision feedback of our work.
   7. NDIS Commission behaviour support practitioner registration and review measures.
   8. Ongoing professional development and learning opportunities being reflected in our interests and engagement in therapy.
8. Quality drives innovation and ATS is committed to continual improvements in our work and outlook. As such, the Quality Management Policy sits alongside the Continuous Improvement Policy.

Continuous Improvement Policy

1. This policy supports ATS to apply the principles and practices of the NDIS Act 2013 along with the NDIS Quality and Safeguarding Framework; and the NDIS Commission Behaviour Support Rules 2018; and the National Standards for Disability Services, in particular Standard 6: Service Management.
2. ATS is committed to continuous service improvement. Continuous improvement requires a deliberate and sustained effort and a learning culture. It is results-driven with a focus not only on strengthening service delivery but also on individual outcomes. This policy guides the design and delivery of services and ensures ATS maintains high standards, improves systems and processes, adapts to changing needs and demonstrates organisational improvement.
3. Principles that guide our work include,
   1. All services provided to people with disability and all processes and procedures undertaken by staff are the best they can be. 
   2. Services are regularly reviewed and measured for quality and effectiveness.
   3. Staff and people with disability are encouraged to provide feedback on how to improve service delivery.
   4. People with disability should be involved in all decision-making processes that affect them.
   5. People with disability, family and carers can provide valuable insights about the effectiveness of services, highlight any gaps/or issues that arise and provide ideas for improvements and innovation.
   6. A learning culture of quality of the organisation ensures all staff, regardless of their role, contribute to service quality and quality management.
   7. Planning, resource allocation, risk management and reporting are critical for continuous improvement and part of an integrated approach that supports the ATS mission and vision.
   8. ATS is committed to innovation, high quality, continuous improvement, evidenced based practice, high standards for clinical assessment and treatment planning, contemporary best practice and effectiveness in the provision of clinical support consultation with people who are with disability and/or mental health and other concerns and needs.
4. ATS keeps an internal Continuous Improvement Register that documents efforts throughout the cycle of review and audit to ensure both compliance to review as well as to help motivate and direct efforts to improve and goals within the improvement cycle.
5. The Continuous Improvement Register is cited by the external NDIS auditor during the audit process as a means to ensure compliance with standards but also to provide our staff with a touch point for accountability and discussion that provides insights to new perspectives and ways to improve. 
6. ATS staff use a Quality Management Evaluation Tool that is adapted to use with our common types of clinical reports written during a range of assessments and treatment planning. The tool provides a quality reflection and indicator score of how we are going as reflected by the areas covered in each clinical report. While this is just one measure, the outcomes are used during staff peer and external clinical supervision to assist with raising awareness of how to improve person centred care and support with our clients.

Forms

How To Lodge a Complaint

1. We value all feedback, positive and negative. Both help us to grow and change.
2. Person Centred Support means that we appreciate your complaint as feedback, and we will learn from what you have to share and work to improve our service.
3. If you have an issue or complaint with our service please contact us directly first and we will resolve your complaint as soon as possible. 
4. The Forms below you can use, or talk to us directly.
5. Please read our Feedback and Complaints Policy for more information.
6. Complaints are of two types, Internal and External.
7. Internal Complaints are the first step in most cases. This is when you let us know directly about the issue. We will then work to resolve the problem in a timely way.
8. External Complaints are when you decide to lodge a complaint to the NDIS Commission or another external body.
9. Under the NDIS it is simple and straightforward to lodge a complaint about a provider.
10. Go to the NDIS Commission home page and click on Make A Complaint in the upper right hand corner, or go directly to: https://www.ndiscommission.gov.au/about/complaints
11. Follow the instructions.
12. Fill in the form.
13. Click send.

Complaint Report Form

Date: ________________ Name of complainant: ___________________________________

Address: _________________________________________________Phone: _________________________ 

Staff member handling complaint ___________________________________

Complaint description ____________________________________________________________________

____________________________________________________________________________________________________

Solutions discussed: ____________________________________________________________________

____________________________________________________________________________________________________

Solution/s chosen: ____________________________________________________________________

____________________________________________________________________________________________________

Action Required	By Whom	Time Frame

Signatures

___________________ ___________________ __________________      

Staff member Complainant   Other 

Complaint Review Form

Name of Complainant: ____________________________

Date of Complaint Form: _________________________

Staff Handling Complaint: _________________________

Review to be held: ________________ (date)

Details of ongoing conciliation

Outcome/Resolution at review date:  

Further referral required (please circle) Yes   No                

If yes, to whom: ___________________________________________

Signatures

____________________ ____________________ _________________      

Staff member Complainant   Other 

Complaint Resolution Evaluation Form

(To be completed by the complainant)

The information contained on this form is non-identifying and will be retained for review purposes. This information will assist us in ensuring that our complaints handling procedures are efficient, and helpful for those making complaints.

What did you complain about? ___________________________________________________________________________________________________

Who did you complain to?

______________________________________________________________

Was your complaint carefully listened to? (please circle appropriate response) Yes No

Was your complaint written down? Yes No

Were you given a copy of the complaint report? Yes No

What was done about your complaint?

_____________________________________________________________________________________________________

Was it helpful in the circumstances? Yes No

Was it what you wanted? Yes No

If not, what do you still think needs to be done?

_____________________________________________________________________________________________________

Are you satisfied about the way your complaint was handled? Yes No

If not, what was unsatisfactory? 

_____________________________________________________________________________________________________

Thank you for your feedback

From management and staff of ATS

Significant Incident Form

Person’s Name: __________________________________________

Behaviour of Concern:   

Client Notes Completed:

Medical: Client Notes Completed:

Financial: Client Notes Completed:

Staffing Issue: Staff Report Completed:

Damage to Car/House/Property:

Appointment/s to be made: Staff requests debriefing:

Date	Time	COMMENTS/ACTIVITY REPORT	Signature(Print Surname)

Action Taken:  

Action Required:

Date:

Client Evaluation Form

This will take you 5 or 10 minutes. There are two questions with a few parts in each. All you need to do is circle some answers. Then you are done!

You can write a bit if you want to, but no worries! 

We need your opinions about your experience of therapy that was provided with you and/or your family member or client.

Your opinion is valuable and helps us and future clients because we take your advice to heart and make actual improvements in our service wherever possible. 

We urge you to please complete this form if you want to keep this service going for yourself or other people in future because we need to support our work with evidence of successful outcomes. 

Our work is based on funding good outcomes not our time. If the outcomes are not good for you, we really need to know so we can grow and improve. 

For Family or Staff or Carers: 

If you are filling this in for or with or on behalf of another person, please rate your perceptions of the service as to how you see it being useful for that person. 

If you can ask the person their feelings and get their general feedback please do. 

But we really do need all the questions answered. 

If you need to make extra notes please feel free. If you want to make verbal feedback give us a call or email so we can make time to chat.

If you have any questions about this form, please contact your therapist.

Kind regards,

Dr Joseph Randolph Bowers and Dr Dwayne Andrew Kennedy

Please circle the number that best describes your opinion

     1       2       3     4       5

Strongly Disagree   Neutral Agree Strongly agree

Disagree

Overall Service:

I am satisfied with the quality of the service 1 2 3 4 5

The therapist was pleasant and welcoming   1 2 3 4 5

Relevant needs were met in therapy   1 2 3 4 5

We will recommend your service to friends   1 2 3 4 5

We will recommend your service to family 1 2 3 4 5

We will return to your service again if need be 1 2 3 4 5

We can now deal more effectively with the

issues or problems that brought us to therapy 1 2 3 4 5

Therapy:

We were able to focus on our main concerns  1 2 3 4 5

The therapist understood our issues/problems 1 2 3 4 5

The therapist helped us understand things more 1 2 3 4 5

The therapist was friendly and approachable   1 2 3 4 5

We felt free to express and share openly 1          2 3 4 5

The therapist seemed to understand our issues

including our feelings and thinking               1 2 3 4 5

We felt treated with respect by the therapist   1 2 3 4 5

Please circle the answer that best represents your opinion

How much progress do you feel was made in dealing with the issues/problems that brought you to this therapy service? 

1. Have become worse

2. No progress made

3. A little progress

4. Considerable progress

5. Progress has solved these issues/problems

How effective do you feel this therapy was? 

1. It made things worse

2. It had no effect

3. A little effective

4. Moderately effective

5. Extremely effective

When you think about the initial goals for therapy…

Did you achieve…..         

1. No goals of therapy

2. Some Goals of therapy

3. Most Goals of Therapy

4. All Goals of therapy

Anonymous Endorsement

Do you want to tell other people something good about this service? If you do, please write your statement here. We might publish your comments on our website or Facebook page. We will not use real names. Please pick a made up name and put it below.

Made Up Name Chosen: 

Other Comments: Feel free to write or call us or email. Thanks heaps!

Hazard Reporting and Action Form

 Identified Hazard or Safety Issue

 _____________________________________________________________________________________________________

Location of Hazard (exact location) _____________________________________________________________________________________________________

 Description of Hazard _____________________________________________________________________________________________________

 Possible remedies _____________________________________________________________________________________________________

Name ________________ Signed __________________ Date_____________

Investigation Report and Action Plan (to be conducted by WHS Officer or Director)

 Is hazard as described above? Yes / No

 Investigation conclusion i.e. possible risks and consequences _____________________________________________________________________________________________________

Action to be taken and by Whom _____________________________________________________________________________________________________

 Target Date for completion, or action plan (attach details if necessary) _____________

Have employees been informed of the actions and their process  Yes / No

Name ________________ Sign. ________________ Date _______________

Action Plan Review (to be completed by Director)

Has the action been completed Yes / No

Has the hazard been eliminated   Yes / No  If not, what further action is required

_____________________________________________________________________________________________________

Signed (Director) __________________ Date_____________

Home Visit Risk Assessment Form

ATS does not do home visits. If an exception is made, this form assists to ensure WHS.

1. Client location _________________________________________________________
2. Date of visit ____________________________
3. Informed Work Mate of visit____________________________________
4. Check for Dog or other hazards before you go_________________________
5. Domestic situation – any concerns? _______________________________________
6. Check upon arrival:
   1. Paths, Obstacles, Gates, Rubbish, Pets______________________________
7. Upon entry to home check safety and sanitation:
   1. Air quality, smoke, seating options__________________________________
8. Determine risks, and decide how long you can stay_______________________
9. Exit plan_______________________________________________________________________
10. Follow up – make client notes, and debrief with work mate_______________

Check List:

Attached to Client Notes Entry Y N

Reviewed by Colleague for Safety Prior to Visit Y N

Reviewed by Supervisor Y N

Date Completed: _______________________________________________

WHS Incident Report

STAFF MEMBER’S NAME________________________________________

DETAILS OF INCIDENT

DATE OF INCIDENT: ___________________  TIME: __________________

PLACE: _______________________________________________________

PEOPLE PRESENT: _____________________________________________________ 

DESCRIPTION OF INCIDENT (Actual event eg. Slipped over, bumped chair etc)

 _________________________________________________________________________________________________

_________________________________________________________________________________________________

ANY RELEVANT INFORMATION ON EVENTS PRECEDING INCIDENT: (eg. floor recently mopped)

_________________________________________________________________________________________________

________________________________________________________________________________________________

ANY INJURIES NOTED IMMEDIATELY FOLLOWING THE INCIDENT: (eg. worker complaining of soreness)

_________________________________________________________________________________________________

_________________________________________________________________________________________________

PERSON MAKING THE REPORT AND INVOLVEMENT: (eg. person affected by incident, witness, supervisor)

_________________________________________________________________________________________________

 ACTION TAKEN:

_________________________________________________________________________________________________

_________________________________________________________________________________________________

SIGNED: ______________________             Name: 

SIGNED: ______________________             Director Date:

Date to be reviewed: ………………………………………………………….

WHS Checklist

To be completed by WHS Officer or delegated person

DATE:
DESCRIPTION	OK: TickIssue: X	COMMENTS
External Environments
Nature Strip
Gate
Concrete at nature strip/gate
Driveway/walkway to office/studio
After daylight hours lighting
Is the property number clearly displayed?
Any issues with external surfaces of walkways or buildings?
Are pets contained?
Any sign of pest infestation?
Any other issues?
Internal Environments: Offices x 2
External doors
Internal doors
Blinds on windows
Furniture
Floors
Steps
Tripping hazards
Wood heater
Grate for wood heater
Containment of wood heater tools / equipment

Do any power points appear overloaded/faulty?
Are light switches faulty?
Any faulty electrical leads?
Is there an electrical overload switch?
Is there adequate ventilation in all areas?
Is the lighting quality adequate?

Desks ergonomic assessment for desk #1
Desks ergonomic assessment for desk #2
Office Fire Extinguisher Tag/Date:
Internal Environments: Therapy StudioWhere the studio is accepting visitors only by authority of the Director,Confirmed by Director:                                        Date:
External doors
Windows and Mechanisms
Kitchenette clean and safe?
Is jug in safe working order?
Toilet door
Toilet condition
Sink condition
Studio Reverse Cycle
Power points overloaded?
Electrical cords
Equipment
Furniture
Tripping hazards?

Give details of any identified risk and action required

IDENTIFIED RISK SOURCE	ACTION REQUIRED	DATE ACTION COMPLETED	MANAGER’S SIGNATURE

Fire Drill / Activity Report

Date: ____________________          Time:  __________________ 

Staff Member(s): ________________________________

Location: __________________________

Activity: _________________________________________________________________________________________

Procedure followed by:

Staff: _________________________________________________________________________________________ 

Person receiving support (if applicable) ____________________________________________________ 

_____________________________________________________________________________________________________ 

Any comments or suggestions arising from fire drill or activity:

_____________________________________________________________________________________________________ 

Signed: Date:

WHS & Fire Safety Officer

First Aid Incident Report Form

Date of Incident: _______________________________________________ 

Time of Incident: _______________________________________________ 

Location of Incident: _______________________________________________

Who Was Involved

Person Needing First Aid: _______________________________________________________________________

First Aid Responder: ___________________________________________________________________________ 

Incident Description

What happened:  _______________________________________________________________________________

 ___________________________________________________________________________________________________

What First Aid Steps Were Taken: _____________________________________________________________

 ___________________________________________________________________________________________________

Was Emergency Services Called: Y N

If so, what time called: _______________________________________________ 

If so, what time did Emergency Services arrive: _______________________________________________ 

How was the incident resolved? _____________________________________________________________

 ___________________________________________________________________________________________________

Debrief Date and Time: _______________________________________________ 

Debrief Completed by: _______________________________________________

Signed: _________________________________________ Signed: _________________________________________

First Aid Incident Review Form

Date Reviewed: ___________________

Person Reviewing: ________________________

Staff Certificates & Preparedness

Dates of First Aid Certificates of Staff Reviewed: 

Dr Kennedy, Date:  ____________________________

Dr Bowers, Date:  ____________________________ 

Other if Applicable, Date:  ____________________________

Are the current staff adequately trained to support this requirement? If not, identify training needs. _____________________________________________________________________________________________________

First Aid Equipment

Primary First Aid Kit:

What the Kit Used between this and the last review date? Y N

If the Kit was Used, was the used items replaced/replenished? Y N

Is the Kit Complete? Y N

If not, what is required? __________________________________________________________________________

Secondary First Aid Kit:

What the Kit Used between this and the last review date? Y N

If the Kit was Used, was the used items replaced/replenished? Y N

Is the Kit Complete? Y N

If not, what is required?_________________________________________________________________________________________

Minor First Aid Kit in Car #1 ATS Vehicle:

What the Kit Used between this and the last review date? Y N

If the Kit was Used, was the used items replaced/replenished? Y N

Is the Kit Complete? Y N

If not, what is required?_________________________________________________________________________________________

Minor First Aid Kit in Car #2 Kennedy:

What the Kit Used between this and the last review date? Y N

If the Kit was Used, was the used items replaced/replenished? Y N

Is the Kit Complete? Y N

If not, what is required?_________________________________________________________________________________________

Prior First Aid Incident Review for WHS

Were there any First Aid Incidents reported between now and the last WHS Review?

Y N

If so, was there an adequate First Aid Incident Report and Debrief conducted? Y N

If so, is there any follow up necessary? Y N

If so, are there any Quality Improvements noted for policy or practice? Y N

Notes Here Please: _______________________________________________________________________________

Actions Required From This WHS Review

Detail any action required_________________________________________________________________________________________

Sig. WHS/First Aid Officer                Sig. Director

DATE: _________________________ 

Follow Up Actions

Are required actions completed?   _____________________________________________________________________________________________________

_____________________________________________________________________________________________________

ONLY SIGN THIS WHEN EVERYTHING ABOVE IS COMPLETE

Sig. First Aid Officer              Sig. Director (signature)

Date ___________________

Resources

Australian Counselling Association Code of Ethics, http://www.theaca.net.au/documents/ACA%20Code%20of%20Ethics%20and%20Practice%20Ver%2012.pdf (15-6-17)

Federal Register of Legislation, National Disability Insurance Scheme Act 2013, https://www.legislation.gov.au/Details/C2016C00934, and from the NDIS website https://www.ndis.gov.au/about-us/governance/legislation (15-5-17)

Freedom of Information Act 1982, https://www.legislation.gov.au/Series/C2004A02562. 

NSW Government, NSW Consolidated Acts, Children and Young Persons (Care and Protection) Act 1998, http://www.austlii.edu.au/au/legis/nsw/consol_act/caypapa1998442/ (15-5-17)

NSW Community Services, Keep them Safe and Interagency Guidelines, http://www.community.nsw.gov.au/kts/collaboration (15-5-17)

Privacy Act 1988, https://www.legislation.gov.au/Details/C2019C00025. 

Privacy Law, Office of the Australian Information Commissioner, https://www.oaic.gov.au/privacy-law/. 

United Nations Universal Declaration on Human Rights 1948, http://www.un.org/en/universal-declaration-human-rights/ (13-2-19)

United Nations, Declaration on the Rights of the Child, https://www.unicef.org/malaysia/1959-Declaration-of-the-Rights-of-the-Child.pdf (15-5-17)

Supported Decision Making Policy NDIS, https://www.ndis.gov.au/about-us/policies/supported-decision-making-policy (12-5-23)