NDIS Conflict of Interest Policy Template

The National Disability Insurance Scheme (NDIS) aims to empower Australians with disability to exercise choice and control over their supports and services. However, as the sector grows in size and complexity, situations where a provider, employee, or other party could have a "conflict of interest" are increasingly common. That’s why every NDIS provider—including sole traders to large organisations—must have a robust Conflict of Interest Policy in place. [object Object]

This resource walks you through everything you need to know about NDIS Conflict of Interest Policy Templates: what they are, their importance, who they apply to, how to develop one, relevant NDIS rules, latest updates, and practical advice for compliance.

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What is an NDIS Conflict of Interest Policy?

[object Object] A Conflict of Interest Policy is a formal document that outlines how a person or business avoids, manages, and discloses actual, potential, or perceived conflicts where their professional judgment regarding participant’s interests might be influenced by a secondary interest (financial, personal, or otherwise).

NDIS providers are mandated under the NDIS Code of Conduct and the NDIS Practice Standards to manage conflicts of interest, especially in areas such as support coordination, plan management, and service delivery. This ensures that decisions and recommendations are made only in the participant’s best interests. [object Object]

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Why Is an NDIS Conflict of Interest Policy Important?

Having an effective Conflict of Interest Policy:

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• Protects Participants: Ensures participants receive unbiased advice and support, safeguarding their right to choice and control.
• Builds Trust: Demonstrates transparency and ethical practice to participants, families, advocates, and the NDIS Commission.
• Meets NDIS Regulatory Requirements: The NDIS Quality and Safeguards Commission requires all registered providers to manage conflicts according to the NDIS Code of Conduct and Practice Standards. [object Object]
• Reduces Legal and Compliance Risks: Non-compliance can result in penalties, deregistration, or reputational harm.
• Encourages Professional Practice: Promotes objective decision-making among staff and support workers.

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Who Needs a Conflict of Interest Policy?

[object Object] Most NDIS service providers—regardless of size—must have a Conflict of Interest Policy. This includes:

• Sole traders and allied health professionals (occupational therapists, psychologists, physiotherapists, speech pathologists) [object Object]
• Disability support agencies (large and small)
• Support coordinators and plan managers
• Residential care providers and group homes [object Object]
• Transport and community participation service providers
• Registered and unregistered NDIS providers

[object Object] Note: Support coordination and plan management are areas of particular focus due to high risk of conflict.

Real-World Scenarios

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• Support Coordinator also delivers core supports: Support coordinators should not recommend their own organisation’s services unless it’s the only practical option within the region (e.g., small rural communities). In such cases, the conflict must be declared and managed.
• Family members as providers: If a family member both manages and delivers supports, this dual role must be transparently handled.
• Allied health business referring to its own employees for follow-up services: The process must address these circumstances. [object Object]

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What Should an NDIS Conflict of Interest Policy Cover?

A robust policy template should include:

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• Definition of Conflict of Interest: Outlines what constitutes a conflict.
• Purpose: Explains the intent to maintain the integrity of services.
• Scope: Clearly states who the policy applies to (all staff, volunteers, contractors). [object Object]
• Procedure for Identification: Steps for staff to identify actual, potential, or perceived conflicts.
• Disclosure Process: How, when, and to whom staff must report a conflict.
• Management and Resolution: Options for managing conflicts (recusal, reassignment, transparent disclosure to participants). [object Object]
• Record Keeping: Details on documenting conflicts and decisions made.
• Obligations under NDIS Commission Rules: References to the NDIS Practice Standards and Code of Conduct.
• Review and Updating: How often the policy is reviewed (typically every 1-2 years). [object Object]
• Staff Training: Commitment to regular staff education.

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How to Go About Developing a Conflict of Interest Policy

1. Download or Draft a Template

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• The NDIS Commission provides a helpful Conflict of Interest Policy Example (DOCX).
• Customise to reflect your business model, size, risk profile, and service types.

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2. Consult the NDIS Practice Standards

• Specifically: “Provider Governance and Operational Management” and “Support Coordination” modules.

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3. Tailor to Your Context

• Consider family-run, allied health, or large provider settings—adapt accordingly.

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4. Staff Training and Rollout

• Train all staff and contractors on recognising, declaring, and managing conflicts.
• Refresh this training annually or with onboarding. [object Object]

5. Review Regularly

• Policies should be “living documents”—review them at least every 12-24 months. [object Object]
• Update following changes in NDIS guidelines or significant business changes.

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How Does It Work in the Context of Australian Migration?

Some NDIS providers are run by, employ, or cater to migrants and culturally diverse communities. The policy applies universally, but specific scenarios may include: [object Object]

• Bilingual staff working with relatives or community members: Culturally sensitive service provision must still comply with conflict management.
• New migrants as participants or providers: Information must be provided in accessible English (and other languages if possible), clarifying roles and expectations under the NDIS. [object Object]

Providers supporting migrant or CALD communities may also require additional safeguards, including translated materials and cultural liaison officers.

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Key Benefits and Features

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• Transparency: Ensures open communication about potential dual interests.
• Consistency: Staff follow a set process every