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Audit & Compliance · 7 min read ·

How to Close NDIS Audit Non-Conformities (Within the 90-Day Window)

After your audit, you'll receive a report with non-conformities (major and minor) and observations. You have 90 days to close them. Most providers close in 6-8 weeks if they're organised. Here's how.

ST
the Provider Scale team
Founder, Provider Scale · Director, the NDIS company we operated (live NDIS provider)

Understanding Non-Conformity Types

Your auditor categorises findings as: major non-conformities (serious breaches - e.g. missing worker police checks, no incident log, unsafe premises). These must be closed to get registered. Minor non-conformities (fixable gaps - e.g. a policy hasn't been reviewed in 18 months, one participant file is missing a signature). These also must be closed within 90 days. Observations (suggestions for improvement - not mandatory to close but show good practice). Most providers have 2-5 major non-conformities and 5-15 minor non-conformities. This is normal.

Your 90-Day Closure Timeline

Day 1-7 after receiving the audit report: understand each non-conformity, clarify anything with your auditor, determine root cause. Day 8-21: take corrective action (fix the gap, update policies, create missing evidence). Day 22-35: gather evidence of closure and document it. Day 36-50: submit your closure evidence to the auditor. Day 51-65: auditor reviews your evidence. They may ask for clarification. Day 66-80: you respond to auditor's questions. Day 81-90: auditor provides final sign-off. Some closures happen faster (Week 2-3). Complex ones take all 90 days. Plan conservatively.

Closing Major Non-Conformities: Examples

Non-conformity: Worker police checks are missing for three staff. Closure: obtain police checks for all three workers, create a screening register showing all workers' current checks, provide certificates to auditor. Non-conformity: No incident log exists. Closure: create an incident log template, log all historical incidents you can recall, document your incident response process, show the log to your auditor. Non-conformity: Participant agreements are absent for two participants. Closure: create written agreements with both participants, have them signed and dated, submit copies to auditor. These closures require actual work - don't try to bluff your way through.

Closing Minor Non-Conformities: Examples

Non-conformity: Policy review dates are out of date. Closure: review each policy, update the date and version number, document the review, sign off on the policy. Non-conformity: One participant file lacks progress notes for two months. Closure: add retrospective progress notes (document what support was provided, what progress was made, what the participant said), ensure future notes are regular and detailed. Non-conformity: Staff training records aren't centralised. Closure: create a staff training register, list every staff member and their training completion dates, attach certificates as evidence.

Your Closure Evidence Must Be Credible

Don't make up evidence. Auditors know when evidence is fabricated or backdated. If you didn't have an incident log before the audit, don't retroactively create detailed logs from 12 months ago. Instead, document an honest response: We didn't have a formal incident log. As of [date]

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