Confirm the Practice

First, you must confirm if a practice is a “regulated restrictive practice” (RRP). Check if the action falls into one of the five categories defined by the NDIS Commission:

• Seclusion: The sole confinement of a person with a disability in a room or other enclosed space from which they are physically prevented from leaving.
• Chemical Restraint: The use of medication or chemical substance for the primary purpose of influencing a person’s behaviour.
• Mechanical Restraint: The use of a device to prevent, restrict, or subdue a person’s movement for the primary purpose of influencing their behaviour.
• Physical Restraint: The use or action of physical force to prevent, restrict, or subdue movement of a person’s body, or part of their body, for the primary purpose of influencing their behaviour.
• Environmental Restraint: Restricting a person’s free access to all parts of their environment, including items and activities.

Report Unauthorised Use

Any use of an RRP without proper authorisation and a Behaviour Support Plan (BSP) in place is considered a reportable incident.

• Log the incident immediately in your internal system.
• Notify the NDIS Commission within 5 business days.
• If the incident resulted in serious harm to the person, you must notify the commission within 24 hours.

Engage a Specialist Behaviour Support Provider

If not already involved, you must engage a Specialist Behaviour Support (SBS) provider. The NDIS Commission sets clear timeframes starting from the date of engagement (typically the service agreement date):

Develop the Interim Behaviour Support Plan (IBSP)

The IBSP is a short, safety-focused document. It must be developed in consultation with the person, their family/guardians, and the implementing provider. Key components include:

• Clear details of the restrictive practice.
• Strategies to reduce risks and use the least restrictive alternatives.
• Protocols for monitoring and data collection.
• A plan for fading out the restrictive practice.

Resource: Use the NDIS Commission’s Interim BSP Checklist for guidance.

“Send Draft” Plan for Review

Once the IBSP is created in the NDIS Commission Portal, the practitioner shares it with the implementing provider for review before seeking state authorisation. This is not the final lodgement.

Obtain Victorian State Authorisation

Using the draft BSP, the provider must now get specific authorisation from the Victorian Senior Practitioner (VSP).

Upload Authorisation to NDIS Portal

Once the official authorisation letter is received from the VSP, it must be uploaded to the draft BSP record in the NDIS Commission Portal. This links the state approval to the plan.

Final Lodgement of the Plan

Once the state/territory authorisation documentation is uploaded in the NDIS Commission Portal, the plan can be officially lodged (submitted) to the Commission.

Activate the Plan

After the Specialist Behaviour Support (SBS) Practitioner lodges the BSP, the next step before implementation is activation. This confirms that the implementing provider is ready to carry out the supports under the plan.

Implement & Report Monthly

As the implementing provider, you must:

• Implement the BSP exactly as written.
• The provider’s designated Authorised Reporting Officer (ARO) must submit monthly reports on all RRP use through the NDIS Portal.
• Every use of PRN (as-needed) restraint must be reported as a separate event.
• Important: The NDIS Commission states that monthly reporting must be attached to a lodged BSP. Do not use the “RRP Record (no BSP)” option for ongoing practices.

Review and Progress to Comprehensive BSP

The ultimate goal is to reduce and eliminate the need for restrictive practices. This involves:

• Working towards the Comprehensive BSP within 6 months.
• Formally reviewing the plan at least every 12 months, or sooner if the person’s circumstances change.
• Continuously focusing on strategies that support the person and fade out the RRP.