Having the policy is not the same as having the record
Checked against the instrument on
Pick your three most recent starters and find, without asking anybody, the record of what was checked before each of them began. The published indicators ask for documents that describe how your organisation works and, separately, for records showing it happened, and a folder of policies holds only the first kind.
Two indicators in a row ask for two kinds of paper
Here are the first two indicators for human resource management, exactly as the Guidelines set them out.
(1) The skills and knowledge required of each position within a provider are identified and documented together with the responsibilities, scope and limitations of each position. (2) Records of worker pre-employment checks, qualifications and experience are maintained.
Quality Indicators Guidelines, s 17 · open the instrument
The verbs change between them. The first says "documented", and it is about positions: what each role needs and where its limits are. You may well have that already, in a position description or an organisational chart.
The second says "records" and "maintained", and it is about people. It is a trail gathered as each worker was hired, and kept since.
Incident management asks for both in one sentence
The same split sits inside a single indicator a few sections earlier.
(3) Demonstrated continuous improvement in incident management by regular review of incident management policies and procedures, review of the causes, handling and outcomes of incidents, seeking of participant and worker views, and incorporation of feedback throughout the provider’s organisation.
Quality Indicators Guidelines, s 16 · open the instrument
Reviewing the policies and procedures is work on a document. Reviewing the causes, handling and outcomes of incidents is only possible if the incidents were written down when they happened, and if the review left a dated note behind it.
Why the records are the half that goes missing
A policy is written once, by somebody who set aside the time to write it. A record is made in the middle of a busy week, by whoever was doing the hiring or dealing with the incident, into whatever folder was open.
One is an act of authorship and the other is an accumulation. The first survives a change of staff. The second often leaves with the person who kept it.
So a folder can look complete from the outside and still have a gap nobody has walked into yet. The only way to find it is to go looking for a specific record, about a specific person, on a specific day.
Twenty minutes on your own files
Do this before you open a single policy.
- For each of your three most recent starters, find the pre-employment check, the qualification and the note of their experience.
- For your last three incidents, find the record made at the time and the note of what was looked at afterwards.
- Where something is missing, write down what was different about that starter or that incident: who handled it, which week, which folder.
An item you find is one you can point to. A gap you find is a record that cannot be made after the fact, so the useful answer to it is a trail that starts now.
Start it with the next event of each kind. The next starter's checks go into one named place, filed on the day they are done. The next incident review gets a date, a name and a line saying what changed because of it. Three months of that is a record, and it is the half a policy cannot give you.
Check it yourself
Every passage quoted above was read from the copy named below and appears in it word for word. The address is where the instrument is published, so you can read the same document we read.
- National Disability Insurance Scheme (Quality Indicators for NDIS Practice Standards) Guidelines 2018 (heading in the epub body text; made under subsection 181D(2) of the National Disability Insurance Scheme Act 2013; Compilation No. 3, compilation date 1 July 2026)
- Compilation No. 3, compilation date 1 July 2026; includes amendments up to F2026N00443; registered as F2026C00528
- published at: https://www.legislation.gov.au/F2018N00041
- checked against the copy we keep
- first fetched from the publisher on 21 July 2026
- fetched again and matched word for word on 14 September 2026