Restrictive Practices and Behaviour Support Plans: What Has Changed and What Providers Must Do Now

The requirements for using and reporting restrictive practices under the NDIS have recently tightened. These changes increase accountability, shorten timeframes, and require clearer documentation and evidence of positive behaviour support.

If your organisation works with participants who display behaviours of concern, these changes directly affect your compliance and your audit risk.

What’s Changing: At a Glance

Area	Previous Requirement	New Requirement (Current)	Compliance Impact
Interim Behaviour Support Plan (BSP)	No formal timeframe. Could be delayed until assessments were complete.	Must be completed within 30 days of identifying a need for any restrictive practice.	Delays are no longer acceptable. No interim BSP = immediate non-compliance.
Comprehensive BSP	Often extended beyond recommended timelines; long delays were common and overlooked.	Must be completed within 6 months of interim BSP being lodged.	Providers must track expiry and ensure completion or risk investigation.
State/Territory Authorisation	Some restrictive practices were used before formal approval, as long as “application was in progress.”	Restrictive practices cannot be used unless authorisation is in place (except in immediate risk emergencies, which must be reported).	Unauthorised use = reportable incident every time.
Monthly Reporting	Reporting was required but audits rarely cross-checked frequency vs BSP.	Monthly reporting is actively reviewed, and patterns are monitored by the Commission.	Missing or inconsistent reports now trigger compliance action.
Support Coordinator Responsibilities	Monitoring BSP implementation was considered supportive, not mandatory.	Support Coordinators must ensure plans are implemented, authorisations are current, and fade-out progress is occurring.	SCCs now have accountability, not just oversight.
Fade-Out / Reduction Planning	Plans often included generic strategies with no measurable fade-out timeframe.	BSP must show real, scheduled steps toward reducing restrictive practices, with review intervals.	Auditors assess whether fade-out actions are actually happening.

1. Interim Behaviour Support Plans: Now Mandatory Within 30 Days

Previously:

Interim plans were often delayed until assessments, referrals, or other clinicians were involved.

Now:

If any restrictive practice is used, an Interim BSP must be written and uploaded within 30 days.

This applies even when:

1. The participant has just joined your caseload

2. You are still collecting background information

3. Assessment sessions are still being scheduled

No interim plan = automatic non-compliance.

2. Comprehensive Plans Must Be Completed Within 6 Months

Previously:

Comprehensive BSPs could take many months (or even years) with minimal oversight.

Now:

A Comprehensive BSP must be finalised within 6 months of submitting the interim plan, and it must include:

1. A functional behaviour assessment (FBA)

2. Positive behaviour support strategies

3. Restrictive practice rationale

4. A fade-out schedule with review milestones

Extensions are no longer automatically accepted.

3. Restrictive Practices Require Formal Authorisation Before Use

Previously:

Providers could proceed with restrictive practice use while “waiting for authorisation.”

Now:

Authorisation must be approved first, except in immediate risk emergencies, where the incident must be reported within the critical incident timeframes.

If chemical restraint, physical restraint, environmental restriction, or seclusion is used without authorisation, every instance becomes a reportable incident.

4. Monthly Reporting is Now Monitored, Not Just Submitted

Previously:

Monthly reporting was submitted but often not checked for trends or alignment with BSP goals.

Now:

The Commission actively cross-checks monthly reports with:

1. BSP strategies

2. Frequency of restraint use

3. Training records

4. Progress notes showing positive behaviour strategies

This means the quality of your report matters.

5. Support Coordinators Now Have Defined Monitoring Duties

Previously:

Support Coordinators supported “connection and navigation” but had no formal monitoring obligations.

Now:

Support Coordinators must ensure:

1. BSPs are in place and current

2. Interim plans progress to comprehensive plans

3. Authorisation is obtained and renewed

4. Teams implementing the plan are trained and competent

Failure to monitor can result in non-conformity against Practice Standard: Support Coordination.

Need Help Adjusting to These Changes?

We’ve got you.

📧 info@alliedadminpartners.com.au

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💬 Supporting Allied Health & NDIS providers Australia-wide