Positive Behaviour Support Policy

1. Purpose

The Learning for Life Autism Centre Inc (Learning for Life) recognises that children and vulnerable people have the right to be in a safe environment at all times and be treated with dignity and respect. The purpose of this Policy is to outline the positive behaviour management approach that Learning for Life takes when working with Clients.

Through this Policy Learning for Life contributes to the elimination of the use of Restrictive Practices for persons with a disability and ensures safeguards are in place for occasions where it is necessary to use Restrictive Practices to protect the welfare of Clients and the safety of third parties.

2. Policy Statement

1. Learning for Life supports a “Person-centred Approach” to the delivery of therapy services such that therapy may include inputs from Clients, families, friends and carers to make informed decisions about a Client’s health and wellbeing. Learning for Life also recognises and understands the central role of families in children’s lives and in turn supports a family-centred approach being included in the delivery of therapy services to children. Any reference in this Policy to a Person-centred Approach therefore also includes family-centred approach given Learning for Life’s services are provided to children.

2. Learning for Life understands that therapy services may be provided that assist with Behaviours of Concern exhibited by Clients. Learning for Life is committed to ensuring that Behaviours of Concern exhibited by Clients under Learning for Life’s programs and supervision are dealt with promptly and appropriately, having due regard for the rights of the Client, the rights of any other persons affected by the behaviour and Learning for Life’s duty of care

3. Learning for Life is committed to upholding the dignity and safeguarding the rights of the Client and the right to receive services in a manner which results in the least restriction of their rights and opportunities.

4. Learning for Life shall engage employees and contractors have who the right skills and training to meet the standards prescribed by this Policy.

3. Scope

This Policy applies to all staff of Learning for Life and will be implemented with all Clients of Learning for Life.

4. Definitions

Authorised Program Officer means each Learning for Life staff member who is an NDIS registered behaviour support practitioner and is authorised to develop and implement Behaviour Support Plans with respect to Learning for Life Clients.

Behaviours of Concern may be defined as behaviour of such an intensity, frequency or duration as to threaten the quality of life and/or the physical safety of the individual or others and likely to lead to responses that are restrictive, aversive or result in exclusion. Behaviours of Concern include:

• self-injury and self-mutilation which leads to physical trauma and/or disfigurement requiring medical attention including biting, hitting, pinching, scratching themselves, pulling hair;
• violent or dangerous behaviour which has the potential to cause physical injury or emotional trauma to others including biting, hitting, kicking, pinching, scratching, swearing, screaming, throwing objects;
• persistent refusal to follow necessary treatment procedures for medical conditions e.g. as epilepsy, diabetes or other conditions that, if not treated, will further endanger the person’s health;
• persistent refusal to participate in agreed activities such as recreation, social events and with respect to children, attendance at school;
• extreme manipulative behaviour including mischievous accusations against others, inappropriately engaging emergency support services or persistently overusing medical and other professional services;
• offensive behaviour including extracting, eating or smearing faeces or other body products, engaging in sexual activities in public places, or generally behaving in a manner likely to elicit negative community reactions.

Behaviour Management Plan means a training plan developed under the NDIS specialist behavioural intervention support framework which supports parents, carers and other relevant workers in implementing behaviour management strategies required to support a Client.

Behaviour Support Plan means a comprehensive and specialised support plan developed under the NDIS specialist behavioural intervention support framework to address significantly harmful or persistent behaviours of concern.

Client for the purpose of this policy, means a child who is enrolled in a Learning for Life program. Where Client is referred to in the context of obtaining consents, consultation, decision making or providing information, it also extends to the Client’s parents/guardians.

Dignity of Risk is the idea that self-determination and the right to take reasonable risks are essential for dignity and self-esteem, thus should not be impeded by excessively cautious caregivers concerned about their duty of care.

Head Authorised Program Officer means the Learning for Life Authorised Program Officer appointed to oversee and authorise all Behaviour Support Plans developed and/or  implemented by Learning for Life Authorised Program Officers.

Informed Consent means permission an individual gives to sharing information, either implied or explicit, after they have demonstrated that they understand the purpose of the request and the likely outcomes of that consent.

Interim Behaviour Support Plan means a Behaviour Support Plan that is developed for the temporary use of Restrictive Practices, with the intention to minimise these practices, while a comprehensive Behaviour Support Plan is being prepared.

Regulated Restrictive Practices in relation to Learning for Life Clients involve the practices listed below, except where the practice is an age-appropriate child safety or injury prevention measure implemented in line with community standards and its recommendation or use would be relevant to any child of that age and not just because the Client has a disability or behaviour of concern:

• seclusion: sole confinement of a person in a room or physical space (at any hour of the day or night) where voluntary exit is prevented or not facilitated, or it is implied that voluntary exit is not permitted;
• chemical restraint: the use of medication or chemical substance for the primary purpose of influencing a person’s behaviour. Chemical restraint does not include the use of medication as prescribed by a medical practitioner for the treatment of, or to enable treatment of, a diagnosed mental disorder, physical illness or physical condition;
• mechanical restraint: the use of a device to prevent, restrict or subdue a person’s movement for the primary purpose of influencing a person’s behaviour. Mechanical restraint does not include the use of a device for therapeutic or non-behavioural purposes;
• 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. Physical restraint does not include the use of a hand-on technique in a reflexive way to guide or redirect a person away from potential harm or injury, consistent with what could reasonably be considered the exercise of care towards a person;
• environmental restraint: restriction of a person’s free access to all parts of their environment, including items or activities.

Determining whether a practice or intervention is a Regulated Restrictive Practice for the purpose of a Client needs to be made on a case by case basis, taking into account the context in which the practice is used and the age of the Client.

Restrictive Practice means any practice or intervention that has the effect of restricting the rights or freedom of movement of a Client.

The Victorian Senior Practitioner has the power to issue prohibitions and directions under the Victorian Disability Act 2006 and is responsible for, among other things:

• ensuring that the rights of people who are subject to Regulated Restrictive Practices in Victoria are protected and appropriate standards are complied with; and
• the authorisation of chemical and environmental restraint and the approval for the use of seclusion, mechanical and physical restraint in Victoria.

5. Communication

1. This Policy shall be communicated to existing Clients on its commencement and to new Clients on the commencement of their service.

2. This Policy shall be communicated to all staff of Learning for Life on its commencement and to new staff members on the commencement of their employment in compliance with Recruitment and Induction Policy and Training and Registrations Policy.

3. Learning for Life shall provide information and training to all clinical staff about this Policy and its application.

4. Client feedback about the practices of Learning for Life can be communicated according to the Client Complaints, Feedback and Grievances Policy.

6. Human Rights

1. The Universal Declaration of Human Rights sets out a number of articles that are fundamental human rights to be universally protected. Learning for Life acknowledges these human rights and the interrelationship between these rights and the delivery of therapeutic services to Clients. Learning for Life shall ensure Clients’ rights are upheld whilst delivering positive behaviour support in line with the NDIS (Restrictive Practices and Behaviour Support) Rules 2018.

2. Learning for Life acknowledges the following Articles under the United Nations (2006) Convention on the Rights of Persons with Disabilities which underpin the Positive Behaviour Support Capability Framework:

Article 12: Equal recognition as a person before the law. This article recognises the right to protection from abuse through support to work on legal and financial issues; that rights and choices are respected; and that support is given to make decisions without coercion.

Article 13: The right to justice.

Article 14: The right to liberty and security. This article recognises the importance of protection against the removal of liberty illegally and without reason, and to protections under the law if liberty is taken away.

Article 16: Freedom from exploitation, violence and abuse. This article is the most direct link with the Australian Government’s (2014) commitment to the reduction and elimination of restrictive practices, and is supported by a Zero Tolerance Framework.

Article 19: Living independently and being included in the community. This article covers people making choices about where they live, who they live with, and the supports they seek to be part of the community.

Article 21: Freedom of expression and opinion, and access to information. This article is about the right to say what one thinks through the type of communication that a person chooses.

Article 26: Habilitation and rehabilitation. This article covers actions that make it possible for people with disability to enjoy maximum independence, full abilities, and be involved in all aspects of life.

7. Positive Behaviour Support

1. The NDIS Positive Behaviour Support Capability Framework (July 2019) outlines the capabilities required of individuals providing behaviour support under the NDIS and has been produced by the NDIS Commission using best practice positive behaviour support as its guidance.

2. Positive behaviour support is the term used to describe the integration of the contemporary ideology of disability service provision with the clinical framework of applied behaviour analysis. Positive behaviour supports are supported by evidence encompassing strategies and methods that aim to increase the person’s quality of life and reduce behaviours of concern (Source note: Carr, et al., 2002; Singer & Wang, 2009).

3. Where the behaviour support needs of a Client are complex, significantly harmful or persistent, a Behaviour Support Plan may be implemented and can be documented as a part of that client’s overall support plan, having regard to the Client being at the centre of every part of positive behaviour support.

4. Behaviour support plans must be proactive, reflect the person’s individual needs, improve their quality of life and support their progress towards positive change.

5. A Behaviour Support Plan for a Client shall be developed in consultation with key stakeholders and in accordance with the Individual Programs Policy. The Behaviour Support Plan should include:

• detailed description and analysis of the behaviour;
• information about staff members responsible for documenting, reviewing and implementing the plan;
• Informed Consent of Client’s advocates or parents;
• recommended and implemented interventions;
• client’s behavioural goals;
• client’s progress against behavioural goals;
• progress notes for each therapy session; and
• amendments made upon review of the plan along with notes on consultation with external professionals and other relevant parties.

6. A behaviour support assessment, including a functional behaviour assessment, must be undertaken before a comprehensive Behaviour Support Plan is developed for a Client and should always identify the strengths of the Client, their will and preference for important elements of their life, and the person’s environmental (physical, interpersonal, internal) context. Informed Consent or consultation as required by the relevant authority must be obtained before the assessment begins.

7. Under the NDIS (Restrictive Practices and Behaviour Support) Rules 2018 any Client with an immediate need for a behaviour support plan should receive an Interim Behaviour Support Plan that minimises the risk to the person and others.

• Where the use of Regulated Restricted Practice is required all reasonable steps must be taken to facilitate the development of an Interim Behaviour Support Plan that covers the use of the Regulated Restrictive Practice within one month of the Regulated Restrictive Practice having occurred or, if Learning for Life has not been engaged until after the use of the Regulated Restrictive Practice by another party, within one month of being engaged to develop the interim support.
• In the case where an Interim Behaviour Support plan being developed contains Regulated Restrictive Practices, all reasonable steps must be taken to facilitate the development of a comprehensive Behaviour Support Plan within six months of the Regulated Restrictive Practice having occurred or, if Learning for Life has not been engaged until after the use of the Regulated Restrictive Practice by another party, within one month of being engaged to develop the interim support.

8. Regular monitoring and evaluation of Behaviour Support Plans shall be undertaken and results can be incorporated, reviewed and updated where changes in requirements or progress towards goals occur.

9. As noted in clause 9 below, Learning for Life may only recommend the use of a Regulated Restrictive Practice as a component of a documented Behaviour Support Plan when informed by an Authorised Program Officer and/or an external registered specialist in behaviour management working as part of a Client support team.

10. As detailed in clause 10 below, Behaviour Support Plans that contain Regulated Restrictive Practices must be lodged with the NDIS Commission in accordance with the NDIS (Restrictive Practices and Behaviour Support) Rules 2018.

8.     Managing Behaviours of Concern

1. Learning for Life supports active decision-making and individual choice of Clients to make informed decisions and understand their rights and responsibilities and shall provide information on how services uphold human rights having regard to:

• Age Discrimination Act (Cth) 2004;
• Australian Human Rights Commission Act (Cth) 1986;
• Disability Discrimination Act (Cth) 1992;
• Equal Opportunity Act (Vic) 2010;
• Racial Discrimination Act (Cth) 1975;
• Sex Discrimination Act (Cth) 1984.

2. When responding to Behaviours of Concern the following principles shall be held in regard:

• supporting positive behaviour;
• using least restrictive alternative;
• promoting freedom of expression;
• supporting Clients to make their own decisions;
• Dignity of Risk;
• eradicating discrimination;
• using person-centred planning;
• respecting the role of parents or advocates in safeguarding Clients’ rights;
• addressing allegations of abuse quickly and appropriately;
• managing risks that may arise when providing support to Clients.

3. Where a Behaviour of Concern is identified Learning for Life shall undertake the following:

• respond within an appropriate time frame having regard to the threats posed to the Client and others whilst the Behaviour of Concern persists;
• undertake and document a thorough analysis of the relevant behaviour;
• develop and document an individualised Behaviour Support Plan in consultation with the Client and key stakeholders, having regard to the Client’s decision making capacity and rights, and make it available to all relevant parties;
• seek support and resources from appropriate external professionals as required;
• ensure that any Restrictive Practice authorised and consented to is administered appropriately with the least infringement of the rights of the Client;
• monitor progress of Client against behavioural goals described and quantified in the Behaviour Support Plan;
• review the Behaviour Support Plan and include consultation with relevant parties who were involved in the construction of the initial plan;
• understand their duty of care towards Clients and consider risk management to remove the risk of harm arising from Behaviours of Concern;
• assess risk and harm to a child or young person and report any breaches to authorities as outlined in the Duty of Care and Incident Management Policy;
• remove any employees who are not appropriately trained or equipped to deal with the Behaviour of Concern having regard to their safety and wellbeing;
• Provide counselling if required to employees affected by Behaviours of Concern;
• address any grievances in accordance with the Client Complaints, Feedback and Grievances Policy.

4. All activities related to behaviour management shall be supportive and respectful of the Client’s individual needs and goals, as identified through the Behaviour Support Plan, and based on a current and comprehensive behaviour support assessment.

5. In the instance that an Interim Behaviour Support Plan needs to be developed for a client with an immediate need for a behaviour support plan, consideration shall be had to the following:

• risk to the Client and others;
• any required collaboration with mainstream service providers such as Victoria Police; program officer; emergency services; mental health and emergency departments, treating medical practitioners and other allied health clinicians; and
• any other relevant matters.

6. Learning for Life has a responsibility to ensure that people who receive a behaviour support service are protected from exploitation, abuse, neglect, and unlawful and degrading treatment in accordance with the Child Safe & Vulnerable Persons Policy and Code of Conduct Policy.

7. Where Learning for Life recommends a Regulated Restrictive Practice, this shall be done as part of a Behaviour Support Plan and be in line with least restrictive practice principles. This means that Learning for Life shall apply practices and interventions that are no more restrictive or intrusive than is necessary to prevent foreseeable harm to the Client and apply them no longer than is necessary to manage an identified risk.

8. Learning for Life owes a duty of care to Clients and staff as is outlined in the Duty of Care and Incident Management Policy and Occupational Health & Safety Duty of care shall always be balanced with the Dignity of Risk and that principle shall be upheld in relation to a Client’s Behaviour Support Plan as a whole and their Behaviour Management Plan as its integral part.

9. Restrictive Practices

1. Learning for Life gives regard to the National Framework for Reducing and Eliminating the Use of Restrictive Practices in the Disability Service Sector as the primary guideline when considering the policies and work practices related to ensuring Clients’ safety, handling Behaviours of Concern and using Restrictive Practices.

2. Learning for Life shall ensure that where a Behaviour Support Plan recommends the use of a Regulated Restrictive Practice, staff involved are familiar with operational aspects of the proposed practice as a component of the Behaviour Support Plan, are competent to implement it, can demonstrate an understanding of its specific purpose, and have access to relevant supports.

3. The Senior Practitioner Physical Restraint Direction and Guidelines provide information on the approval and use of physical restraint in Victoria including when developing a Behaviour Support Plan. In Victoria, in accordance with the Victorian Senior Practitioner Direction (and without limiting any other approvals required under this policy), all registered NDIS Providers must comply with guidelines and standards for the use of physical restraint and obtain specific approval for using physical restraint.

4. Learning for Life may only recommend the use of a Regulated Restrictive Practice as a component of a documented Behaviour Support Plan when informed by an Authorised Program Officer and/or an external registered specialist in behaviour management working as part of a Client support team.

5. Supported by the Information Sheet 14 in Appendix A, for a Regulated Restrictive Practice to be implemented within a program the Behaviour Support Plan in which it is recommended must be co-approved by a Learning for Life Authorised Program Officer and the Head Authorised Program Officer at Learning for Life, and submitted to the Victorian Senior Practitioner for approval.

6. Restrictive Practices shall not be considered therapeutic interventions and shall only be used as a last resort when other options have failed to maintain safety for the Client in distress, staff or other parties.

7. The primary reason for using Restrictive Practices is to protect the person from causing harm to themselves or others. Reasonable force can be used to maintain safety, however this must be the least restrictive form of intervention possible being used to protect staff and/or others that may be at risk, to ensure the Client does not inflict harm on staff, themselves or others. All other options shall be exhausted before implementing restraint.

10. Process for Authorisation of Regulated Restrictive Practices for NDIS Participants

1. Learning for Life shall ensure an Authorised Program Officer is assigned to any Behaviour Support Plan being developed for a given Client that includes recommendation for the use of a Regulated Restrictive Practice (RRP BSP).

2. Any authorisation by an Authorised Program Officer of the use of a Regulated Restrictive Practice must be in line with the requirements of the Disability Act and the proposed use must be:

• clearly identified in the Client’s Behaviour Support Plan;
• as a last resort only in response to risk of harm to the Client or another person, and only after having explored and applied evidence-based, person centered, proactive strategies;
• necessary to prevent a person from causing physical harm to themselves or another person;
• the option which is the least restrictive of the person as is possible in the circumstances;
• proportionate to the potential negative consequences or risk of harm;
• used for the shortest time possible to ensure the Client’s safety and the safety of others;
• linked to a clear plan for reducing and eliminating the restrictive practice over time; and
• in accordance with the NDIS Commission’s requirements (under the NDIS (Restrictive Practices and Behaviour Support) Rules 2018 (Cth)).

3. An Authorised Program Officer may only authorise the use of seclusion as a Regulated Restrictive Practice if:

• the above requirements in clause 10.2 are met;
• the person is supplied with appropriate bedding and clothing as relevant;
• the person has access to adequate heating and cooling (as is appropriate for the circumstances);
• the person is provided with food and drink at the appropriate times, and
• the person is provided with adequate toilet arrangements.

4. The Authorised Program Officer for a given Client is to ensure that an adult who is independent from Learning for Life is available to be present when the RRP BSP is explained to the Client. For this purpose, the Client’s parent or guardian constitutes an independent adult even if the explanation is being directed at the parent or guardian rather than the child given the context or age of the child.

5. Each RRP BSP must be co-approved by the assigned Authorised Program Officer and the Head Authorised Program Officer.

6. Following co-approval of a RRP BSP as detailed in clause 10.3 above, the assigned Authorised Program Officer must lodge the RRP BSP for approval by the Victorian Senior Practitioner in the Restrictive Interventions Data System.

• The Victorian Senior Practitioner will provide evidence that Restrictive Practices meet Victorian authorisation requirements to the relevant Authorised Program Officer.
• Additional approval by the Victorian Senior Practitioner is required for physical restraint, mechanical restraint, seclusion and other practices as directed by the Victorian Senior Practitioner.

7. Upon implementation or modification, each RRP BSP in respect of a Client who is an NDIS participant must also be lodged by the assigned Authorised Program Officer with the NDIS Commission upon implementation or modification, along with evidence of Victorian Senior Practitioner authorisations). Behaviour Support Plans that do not include Regulated Restrictive Practices, or RRP BSP’s for a Client that is not an NDIS participant, are not required to be lodged with the NDIS Commission.

8. RRP BSP’s must be reviewed every 12 months, or earlier if the Client’s circumstances change.

11. Use of Restrictive Practices

1. The use of a Restrictive Practice shall be closely monitored to safeguard against abuse and replaced with less restrictive strategies as soon as possible.

2. Where the use of a Restrictive Practice involves the Client being physically restrained, Learning for Life shall:

• immediately refer the Client for assessment by a medical practitioner; and
• provide the Client with support and counselling.

3. Each use of a Restrictive Practice shall be documented in the Restrictive Practice Use Form and submitted to the Practice Manager as soon as reasonably possible following the use. Completed Restrictive Practice Use Forms, each of which must be included on the relevant Client’s file, shall include:

• date, time and location of each episode of implementation;
• brief description of environment and events prior to implementation of strategy;
• description of presenting behaviour;
• detail of other less restrictive strategies attempted (if any);
• consequences and outcomes of less restrictive strategies attempted;
• reason for use of strategy;
• duration of use;
• periodic observational notes of the presentation of Client (if applicable);
• name and position of staff involved in implementation of the strategy;
• name and position of staff directing use of strategy;
• name and position of staff responsible for conducting and recording periodic observations (if applicable);
• consequences and outcomes of the use of strategy.

Upon receipt of the completed Restrictive Practice Use Form, the Practice Manager will enter the incident into the Restrictive Practice Register and inform the Clinical Director and/or the Head Authorised Program Officer.

4. A team debrief shall occur following any event involving the use of any Restrictive Practice (whether authorised or not) and staff shall be provided support and counselling as necessary. The debrief shall identify areas for improvement and shall be documented.

5. As outlined in clause 10 of the Duty of Care and Incident Management Policy, the use of a ‘Reportable Restrictive Practice’ with respect to a Client that is an NDIS participant, must be notified to the NDIS Commissioner via the NDIS Commission Portal within 5 business days of staff being made aware of it. If the Reportable Restrictive Practice harmed the Client, NDIS Commissioner notification must be made within 24 hours, with a more detailed report about the incident and actions taken to be provided within 5 business days.

• A Reportable Restrictive Practice means an unauthorised use of a Regulated Restrictive Practice due to it not being in accordance with a Victorian Senior Practitioner approved Behaviour Support Plan.
• After submission of a 5-business day Restrictive Practice Report, the NDIS Commissioner may require the submission of a final report within 60 days.
• The Head Authorised Program Officer is responsible for ensuring required NDIS notifications are made within the timeframe required.
• The use of a Regulated Restrictive Practice with respect to a Client that is an NDIS Participant that is in accordance with a Behaviour Support Plan that has been approved by the Victorian Senior Practitioner need not be reported to the NDIS Commissioner as a reportable incident on the NDIS Portal, but must be included in the relevant Authorised Program Officer’s monthly reporting obligations to the NDIS Commission.
• The use of a Regulated Restrictive Practice with respect to a Client that is not an NDIS participant need not be reported to the NDIS Commissioner.
• For the avoidance of doubt, the use of a Restrictive Practice that Learning for Life determines is not a Regulated Restrictive Practice (having regard to the context and age of the Client and the practice being a genuine child safety/injury prevention measure in line with community standards where its use would have been relevant to any child of that age and not just because the Client has a disability or behaviour of concern) need not be reported and does not require development of a Behaviour Support Plan, but its use still must be recorded in the Restrictive Practice Use Form and submitted to the Practice Manager as per Clause 11.3 above.

6. With respect to a Client that is not an NDIS participant, each use of a Regulated Restrictive Practice that is inconsistent with Behaviour Support Plan approved by the Victorian Senior Practitioner (or where the Client does not have in place a Behaviour Support Plan that is approved by the Victorian Senior Practitioner) must be reported to the Victorian Senior Practitioner by the Authorised Program Officer within 7 days after the end of the calendar month during which the incident occurred.

7. In addition to documenting and reporting the use of a Regulated Restrictive Practice that is not in accordance with a Victorian Senior Practitioner approved Behaviour Support Plan, the relevant Authorised Program Officer must give consideration as to whether:

• the Client requires an Interim Behaviour Support Plan (in accordance with clause 7.6 above); or
• the Client’s existing Behaviour Support Plan requires amendment and (re)submission for approval by the Victorian Senior Practioner, and ensure relevant plan development or amendment and approval if so required.

8. The staff at Learning for Life are not permitted to administer medication to Clients (other than in specific emergency response in line with a Client’s health risk management plan circumstances and where the individual has been trained to do so, such as administration of EpiPens or insulin in relevant circumstances). Learning for Life staff will therefore not administer any chemical restraint or psychotropic medication. Where psychotropic medication has been prescribed by a clinical psychiatrist or pediatrician and is consented to for administration on an “as needs” basis, the Client’s parent or legal guardian is responsible for administering the medication.

12. Application of Restrictive Practices in an Emergency

1. In emergency situations, the primary consideration for Learning for Life staff must be the immediate safety and wellbeing of the Client and other parties.

2. As far as possible, the application of Regulated Restrictive Practice in an emergency shall be consistent with the Behaviour Support Plan.

3. Once the safety of all parties is ensured, staff shall brief the Head Authorised Program Officer and/or Clinical Director and document both the emergency and the Restrictive Practice as soon as practicable using the Restrictive Practice Use Form referred to in clause 11.3 above.

4. Learning for Life shall debrief both the Client subject to Restrictive Practices and the staff as soon as practicable.

5. Where the application of an emergency Restrictive Practice on a Client that is an NDIS Participant constitutes a Reportable Restrictive Practice, relevant notifications must be made by the Authorised Program Officer via the NDIS Portal must be made in accordance with clause 11 above and the Duty of Care and Incident Management Policy.

6. Where the application of an emergency Restrictive Practice is a Regulated Restrictive Practice used on a Client that is not an NDIS participant due to believed imminent risk of the Client causing serious physical harm to them themselves or others and use of the Regulated Restrictive Practice was necessary to prevent that risk (whether authorised or not), the Authorised Program Officer must report the use of the Restricted Practice to the Victorian Senior Practitioner within 7 days after the end of that calendar month.